BVY 03-112, Emergency Plan Implementing Procedure Changes

Emergency Plan Implementing Procedure Changes

ML033580687
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	12/17/2003
From:	Tkaczyk L Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Security and Incident Response
References
-RFPFR, BVY 03-112
Download: ML033580687 (60)

Text

{{#Wiki_filter:Entergy Nuclear Northeast Alk Vermont Yankee RO. Box 0500

                                                                                   ~~~~~~~~~~~~~~~~~185 E n teigy       * ' r^ rye {{2X'{Xl o

Old Ferry Road Brattleboro, Vr 05302-0500

                                                                                   ~~~~~~~~~~~~~~~~~~Tel 802 257 5271 December 17, 2003 BVY 03-112 U.S. Nuclear Regulatory Commission ATN: Document Control Desk Washington, DC 20555

Subject:

Vcrmont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271) Vermont Yankee Emergency Plan Implementing Procedure Changes In accordance with 10 CFR 50.54(q), enclosed is the latest changes to the Vermont Yankee Emergency Plan Implementing Procedures including the change memos and the 10 CFR 50.54(q) Evaluation Checklists: OP 3507, Rev. 30, LPC#I OP 3508, Rev. 24, LPC# I OP 3511, Rev. 13, LPC#1 OP 3532, Rev. 11, LPC#I OP 3712, Rev. 17, LPC#I These changes were determined to not need prior NRC review and approval. If you have any questions, please contact Audra Williams, Emergency Planning Coordinator, in our Brattleboro office at (802) 258-4177. Sincerely, Lori Tkaczyk Emergency Planning Manager Attachments cc: USNRC Region I Administrator USNRC Resident Inspector - VYNPS USNRC Project Manager - VYNPS (no attachments) David M. Silk, Senior Emergency Preparedness Specialist, USNRC Region I Vermont Department of Public Service

6 S S To: E-Plan Implementing Procedure Controlled Set Holders

  'From: Technical Support- DCC - Marie E. Sherer Date:   12/17/03 Re:    Entergy Vermont Yankee Emergency Plan Implementing Procedure Change 223, Instruction Sheet A new Table of Contents is included.

LPCs: The following LPC should be incorporated into the appropriate procedures: Proc/Rev # LPC# Procedure Title OP 3507/30 1 Emergency Radiation Exposure Control OP 3508/24 1 On-Site Medical Emergency Procedure OP 3511/13 1 Off-Site Protective Action Recommendations . K -' AP 3532/11 1. Emergency Preparedness Organization OP 3712/17 1 Emergency Plan Training

I Vermont Yankee Emergency Plan Implementing Procedures Table of Contents

                                                                  .9.         I nflPemhger 17 'Anna Title                                  Number    Revision LPC #      Use Classification Emergency Plan Classification and Action Level Scheme                  AP 3125   Rev. 19         "Reference" Emergency Communications                                               OP 3504   Rev. 36    2    "Reference" Emergency Preparedness Exercises and Drills                           OP 3505   Rev. 25        "Information" Emergency Equipment Readiness Check                                   OP 3506   Rev. 43    1    "Reference" Emergency Radiation Exposure Control                                  OP 3507   Rev. 30    1    "Reference" On-Site Medical Emergency Procedure                                   OP 3508   Rev. 24    1    "Reference" Environmental Sample Collection During an Emergency                   OP 3509   Rev. 18         "Reference" Off-Site and Site Boundary Monitoring                                 OP 3510   Rev. 27    1    "Reference" Off-Site Protective Action Recommendations                            OP 3511   Rev. 13    1    "Reference" Evaluation of Off-Site Radiological Conditions                        OP 3513   Rev. 22         "Reference" Emergency Actions to Ensure Initial Accountability and Security       OP 3524   Rev. 20         "Reference" Response                                                                        _

Radiological Coordination OP 3525 Rev. 11 "Reference" Emergency Call-In Method OP 3531 Rev. 17 "Reference" Emergency Preparedness Organization AP 3532 Rev. 11 1 "Information" Post Accident Sampling of Reactor Coolant OP 3533 Rev. 6 2 "Continuous" Post Accident Sampling of Plant Stack Gaseous Releases OP 3534 Rev. 4 "Continuous" Post Accident Sampling and Analysis of Primary Containment OP 3535 Rev.4 "Continuous" In Plant Air Sample Analysis with Abnormal Condition OP 3536 Rev. 2 "Continuous" Control Room Actions During an Emergency OP 3540 Rev. 3 1 "Reference" Activation of the Technical Support Center (TSC) OP 3541 Rev. 2 "Reference" Operation of the Technical Support Center (TSC) OP 3542 Rev. 2 "Reference" Activation of the Operations Support Center (OSC) OP 3543 Rev. 0 "Reference" Operation of the Operations Support Center (OSC) OP 3544 Rev. 3 1 "Reference" Activation of the Emergency Operations Facility/Recovery Center OP 3545 Rev. 2 1 "Reference" (EOF/RC) Operation of the Emergency Operations Facility/Recovery Center OP 3546 Rev.4 "Reference" (EOFIRC) Security Actions During an Emergency OP 3547 Rev. 2 "Reference". Emergency Plan Training OP 3712 Rev. 17 1 "Information" Page I of 1

PREAPPROVED LPC FORM t - a PART 1 - Initiation Fl Converted to Admin. Revision LPC No: A. Procedure No.: OP 3507 Current Revision#: 30 l

Title:

£,n ernt 6C%? 4Ae4i B. Description of Change:

• CR-VTYLO-2003-0391 CA 00012 - Cross-referenced OP 3544 for emergency exposure control.
• Added reference to AP 0506.
• Title change and corrected reference to a step.

C. Reason for Change: El Result of Design Change, Minor Mod, EDCR_ M Related ER No._ Other O CR-VTYLO-2003-0391 El Editorial D. Duration: 0 Permanent One Time Only I. Originator (Print/Sign/Date) E. Surveillance Database Change? E Yes, change submitted 0 No (Use AP 0096, App. A as a reference) F. Procedure Type: , Technical E1 Admin. (AP,PP) unless editorial) G. AP 0091, Risk Assessment E Yes 0 No Audra Williams 11/14/03 H. Page(s) affected: pages 4. 5 & 8 of 9: cow VYOPF 3507.02 pages I and 2 of 2 _ _ _ _ _ _ _ _ PART 22- Review/Approval (Refer to LPC Criteria of A pendix A) A. Technical Verification Review (Print/Sign/Date) (Use B. Cross-Discipline Review(s) (Print/Sign/Date) AP 0096, Appendix B as a refer nce) E] N/A D N/A Audra Williams 11/14/03 (May perform Qualified Review) (N/A if editorial change) C. Qualified Review (Print/Sign/Date) (Use AP 0096, D. 50.59 review completed type: Appendix D, as a reference El N/A El AD/Screen El Evaluation 0 N/A (N/A if editorial change) Audra-Williams  %-A 1/14/03 (N/A if editorial change) E. RPO Approval (Printfljgn/Date) Briqy,#1,An1 i fSiv') <%/ 3 J 0 50.54(q) PORC Mtg. (EPIP only) F. IF 50.59 Evaluation:

                                                                                                   -
                                                                                                            -N/A Date:

G. Plant Manager (Print/Sign/Date) (SPs only) N/A I H. Training: (Required for Admin Procedures, unless editorial) ON/A 1.Effective Date: 12/17/03 CDS InitialsG VYAPF 0097.02 AP 0097 Rev. 3 Page I of I

APPENDIX C CROSS-DISCIPLINE REVIEW CHECKLIST Required to be completed for new procedures, procedure revisions, and LPCs unless they are designated as Editorial. Procedure Number/Revision OP 3507, Rev 30 L-Pc Reviewer/Date (Print) Audra Williams 11/14/03 GENERAL REVIEW GUIDELINES/SPECIAL REVIEW REOUIREMENTS

• The Cross-Discipline Review Guidelines below constitute minimum review requirements; other reviews may apply.
• Determination of reviews should focus on changes made to a procedure and the potential impact of those changes on the affected group. Changes that are minimally or nonimpacting do not need review by the potentially affected group.

If change impact is unclear, the procedure should be routed to the potentially affected group for review.

• New or revised Administrative or Program Procedures that significantly impact other departments, shall be reviewed by the appropriate Superintendent or Senior Manager. The PAA maintains a list of these Administrative and Program Procedures.
• ALL noneditorial changes to Special Process procedures (WP, NE, heat treating, etc.), including Vendor Procedures that address Special Processes, shall be reviewed by a Welding Engineer (welding procedures) or a NDE Level III certified in the method addressed by the procedure (nondestructive examination procedures), AND the Quality Assurance Manager, AND submitted to the Authorized Nuclear Inservice Inspector (ANII) prior to use.
• A "YES" indicates that a Cross Discipline Review shall be done by the indicated Department. Document the review on VYAPF 0096.01, VYAPF 0097.01, or VYAPF 0097.02, as applicable.

APPLICABLE YES I NO Chemistry:

• Potentially affects condensate, feedwater, or reactor water chemistry, or chemistry instruments.
• Procedures that implement the requirements of the VY Environmental Program.

(see PP 7603, Appendix A)

• Produces/affects effluents or effluent monitoring (VY/QA 01-015).
• Affects NPDES limits or method of compliance. X Maintenance (Mech, Elec, I&C):
• Requires Maintenance personnel to perform activities, such as performance of maintenance procedures, installation of M&TE, lifting and landing of leads and connectors. X Operations:.

Changed requirements for entry iritoa Limiting Condition for Operation (LCO) or significantly changes duration of LCO.

• Requires Operations alignment/restoration of systems or components.
• Specifies surveillance or post maintenance testing by Operations. X EOP/SAG Coordinator:
• Procedures that have the potential to affect the EOPs/SAGs. X Appendix C AP 0096 Rev. 3 Page l of 3

Quality Assurance:

• Compliance with QA Program requirements cannot be readily determined by the Qualified Reviewer. X Radiation Protection:
• Involves work in contaminated areas and high radiation areas.
• Involves work that breaches contaminated systems or components.
• Changes in radwaste or hazardous waste generation. X Emergency Plan Coordinator:
• Emergency Plan Implementing Procedures.
• Obtain and attach a 10CFR50.54(q) Evaluation.
• Affects Emergency Plan personnel, facilities or equipment. X Software Quality Assurance Administrator
• Procedures that define how software is developed. X Reactor Engineering:
• Could affect core reactivity, thermal power, reactor heat balance, or fuel integrity.
• Involves refueling operations. X Systems/ProjectlDesign Engineering:
• Maintenance Rule in-scope systems unavailability time.
• Involves infrequently performed test or evolution.
• Changed requirements for entry into a Limiting Condition for Operation (LCO) or significantly changes duration of LCO.
• Significant changes in system test or operation methodology. X Appendix J Coordinator:
• Changes that affect App. J leakrates or containment boundaries, or boundary valve manipulation. X Appendix R Coordinator:
• Appendix R implementing procedures. X Environmental Qualification (EQ) Coordinator:
• Change in EQ test methodology or component lifetime.
• Potentially affects area EQ component environment. X Fire Protection Coordinator (FPC):
• Fire Protection procedures.
• Affects fire loading
• Affects fire barrier integrity.
• Affects fire protection'systems or component functionality. X IST Program Coordinator:
• Inservice Testing Program implementing procedures.
• All surveillance procedures. X ISI Program Coordinator:
• Inservice Inspection Program implementing procedures. X Appendix C AP 0096 Rev. 3 Page 2 of 3

Setpoint Coordinator:

• Changes that impact setpoints, as-found/as-left tolerances, M&TE or testing methodology. X Nuclear & PRA
• Potentially affects IPEEE or ORAM Sentinel Risk Models.
• Potentially affects plant SSCs reliability.
• Potentially affects Nuclear or Radiological Safety Analysis. XI Security:
• Proceures that implement the requirements of the VY Physical Security and Training and Qualification Plans.
• Changes that have a potential for reduction of the VY Physical Security and Training and Qualification Plan commitments.
• Obtain and attach a 10CFR50.54(P) Evaluation. X MOV Program Coordinator:
• Potentially affects system parameters for which MOV operation has been evaluated. X AOV Program Coordinator:
• Potentially affects system parameters for which AOV operation has been evaluated. X Appendix C AP 0096 Rev. 3 Page 3 of 3

10 CFR 50.54(q) Evaluation Checklist List of Emergency Plan Section(s)/Eniergency Plan Implementing Procedure(s) or any other document to be evaluated. (Include Title and Revision No.): OP 3507, Rev 30, LPC#1, Emergency Radiation Exposure Control A. Screening Evaluation Based on a review of the following questions, determine if the change has the potential to affect our ability to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50. A "YES" answer to any part of the questions requires that a written evaluation be done to determine whether the effectiveness of the Emergency Plan was decreased as specified in Section B of this checklist. A "NO" answer to all questions requires no written evaluation as specified in Section B of this checklist. YES NO I. Could the proposed change affect our ability to meet the following standards of IOCFR50.47(b): (1) Assignment of Emergency Response Organization responsibilities l X (2) Assignment of on-shift Emergency Response Organization personnel X (3) Arrangements for Emergency Response Support and Resources X (4) Emergency Classification and Action levels, including facility system X and effluent parameters (5) Notification Methods and Procedures X (6) Emergency Communications among principal response organizations X and the public (7) Public Education and Information X (8) Adequacy of Emergency Facilities and Equipment X (9) Adequacy of Accident Assessment methods, systems and equipment X (10) Plume exposure pathway EPZ protective actions X (I1) Emergency Worker Radiological Exposure Control X (12) Medical Services for contaminated injured individuals X (13) Recovery and Reentry Plans X (14) Emergency response periodic drills and exercises X (15) Radiological Emergency Response Training X (16) Plan development, review and distribution X VYAPF 3532.01 AP 3532 Rev. 11 Page 1 of3

10 CFR 50.54(q) Evaluation Checklist (Continued) l 'YES I NO I

2. Could the change affect our ability to meet the following requirements of Appendix E to IOCFR50 (1) Section IV. A - Organization (2) Section V. B - Assessment Actions IX (3)

(4) Section IV. C - Activation of Emergency Organizations Section IV. D - Notification Procedures

                                                                                           .<~~X        x (5)    Section IV. E - Emergency Facilities and Equipment xX      1 (6)    Section IV. F - Training (7)    Section IV. G - Maintaining Emergency Preparedness                                       X      1 (8)    Section IV. H - Recovery B.      Effectiveness DeteLmination For each applicable (i.e., a "yes" answer specified) standard to IOCFR50.47(b) and Appendix E to IOCFR50 identified from Section A above, complete the evaluation form below to determine whether the change decreases the effectiveness of the Emergency Plan and whether it continues to meet the stated applicable standard or requirement.

A facsimile of the evaluation form may be used as needed and attached to this checklist. For applicable item OCFR50. N/A of Section A above, this change I DOES 3 DOES NOT decrease the effectiveness of the Emergency Plan and Z DOES LO DOES NOT continue to meet the stated applicable standard or requirement. BASIS FOR ANSWER: This change adds a reference to AP 0506 which is the procedure for exposure control and is followed during an emergency event. A reference to OP 3544 was added to ensure that individuals listed on this form are also listed on 3507.02 for exposure control. VYAPF 3532.01 AP 3532 Rev. 11 Page 2 of 3

10 CFR 50.54(q) Evaluation Checklist (Continued) C. Conclusion (Fill out appropriate information)

      >3      The changes made do not decrease the effectiveness of the Emergency Plan and continue to meet the standards of 10CFR50.47(b) and the requirements of Appendix E to 10CFR50.

El The changes made do decrease the effectiveness of the Emergency Plan and decrease our ability to meet the standards of 10CFR50.47(b) and the requirements of Appendix E to 10CFR50. The following course of action is recommended: El Revise proposed changes to meet applicable standards and requirements. El Cancel the proposed changes. El Process proposed changes for NRC approval prior to implementation in accordance with OCFR50.54(q). D. Impact on Other Documents (TRM, Tech Specs) Keywords used in search:_ Ell This change does not affect any other documents. K>~ This change does affect other documents. Document(s) affected:_ Section(s) affected: E. Impact on the Updated FSAR Use AP 6036 to determine if the proposed E-Plan change modifies existing UFSAR information or requires the addition of new UFSAR information and initiate UFSAR change(s) as required. Keywords used in UFSAR search: there is no impact Additional Comments: Prepared By: Audra Williams Hi Date: 11/14/03 (Print/Sign~ Reviewed By: A.1zL Date: Ilt (Emergency Plan Coordinator) $rint/Sigll) VYAPF 3532.01 AP 3532 Rev. 11 Page 3 of 3

VERMONT YANKEE NUCLEAR POWER STATION OP 3507 REVISION 30 EMERGENCY RADIATION EXPOSURE CONTROL USE CLASSIFICATION: REFERENCE LPC Effective No. Date Affected Pages 1 12/17/03 4, 5 & 8 of 9, VYOPF 3507.02 Pgs 1 & 2 of 2 Implementation Statement: N/A Issue Date: 04/02/03 OP 3507 Rev. 30 Page 1 of 9

ATTACHMENTS

1. Appendix A Emergency Dose Limits

2. Appendix B Emergency Center Habitability and Protective Action Criteria

3. VYOPF 3507.01 Personnel Exposure Log

4. VYOPF 3507.02 Emergency Radiation Exposure Briefing/Debriefing

5. VYOPF 3507.03 Potassium Iodide Administration Record 6.. ..Figure 1 Line Diagram of EOF HEPA Ventilation REFERENCES AND COMMITMENTS

1. Technical Specifications and Site Documents

a. None

2. Codes, Standards and Regulations

a. None

3. Commitmients

a. 10 CFR 20

b. NCRP Report #116

c. 10CFR5OApp.E

d. Information Notice No. 84-40

4. Supplemental References

a. EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actia ins for Nuclear Incidents, Revised 1991 I~ LC b. AP 0506, Personnel Monitoring

c. DP 0530, Radiation Protection Data and Information Logging, VYDPF 0530, Report #0028

d. OP 3544, Operation of the Operations Support Center (OSC)

e. OP 3508, On-Site Medical Emergency Procedure

f. AP 6807, Collection, Temporary Storage and Retrieval of QA Records PRECAUTIONS/LIMITATIONS ..

1. During any emergency involving radiological hazards, personnel radiation exposure should be minimized consistent with the nature of the emergency response required.

OP 3507 Rev. 30 Page 4 of 9 LPC#1

PROCEDURE A. Emergency Radiation Exposure Control

1. Normal Plant Radiological Conditions NOTE This section applies for tasks being conducted within areas that show no significant increase in general area (TEDE) dose rates from normal plant radiological conditions and each individual's dose commitment requirement is less than 1 rem.

a. An RP Representative or designated individual shall plan and control radiation exposure of personnel in accordance with the normal work process to ensure exposures are maintained within administrative limits.

I26 (AP 0506)

2. Off-Normal Plant Radiological Conditions NOTES

• This section applies for tasks being conducted within areas that show a significant increase in general area dose rates from normal plant radiological conditions which may result in any individual dose commitment of 1 rem or greater.

Upon indication of off-normal Plant radiological conditions, Plant Emergency Personnel will immediately be authorized an Emergency Dose Limit of 4.5 Rem TEDE. Authorization to the 10 Rem limit (Protecting Valuable Property) 25 or 75 REM limit (Lifesaving or Protection of a Large Population) may only be made with the joint concurrence of the Shift Supervisor/Plant Emergency Coordinator or TSC Coordinator and the senior Radiation Protection representative.

a. An RP Representative or designated individual shall:

1) As requested by the OSC Work Coordinator and VYOPF 3544.02, OSC Teamwork Status Form, plan and control radiation exposure of personnel using VYOPF 3507.02, Emergency Radiation Exposure Briefing and Debriefing form. Ensure approval for Emergency Dose Commitment is obtained prior to teams being briefed and dispatched and that personnel listed on VYOPF 3544.02 are also listed on VYOPF 3507.02.

2) Limit radiation exposure of personnel in accordance with the guidance contained in Appendix A.

OP 3507 Rev. 30 Page 5 of 9 LPC #1

NOTE Dosimetry may be obtained from a qualified and approved TLD vendor/processor or relayed to the EOF from the plant, if warranted.

c. The Radiological Assistant will ensure an individual is assigned for maintaining a cumulative exposure record for each individual present in the plant, also at the EOF if warranted on a current shift basis.

d. When appropriate, TLD badges will be exchanged at the direction of the Radiological Assistant and used badges will be sent to the designated TLD lab for processing.

e. As TLD results become available, they will be logged on HIS or VYOPF 3507.01 as applicable.

C. Administration of Potassium Iodide (KI)

1. Conditions of Indicating Use of KI

a. When emergency responders have been or may be exposed to elevated radioiodine air concentrations in excess of 500 mRem/hr (4.0 e6 pCi/cc),

evaluate the need for administration of KI. (VYDPF 0530, Report #0028).

                                                               .

2. Method of Administering KI NOTE The RP Manager shall be advised of all KI administration either in advance or as soon as possible after the actual administration.

a. When the respective center Coordinator (TSC Coordinator, Shift It. Manager/Plant Emergency Director, OSC Coordinator, EOF Coordinator) is made aware'of conditions as specified in C.1.a, then each Coordinator will be responsible for ensuring that KI has been offered for administration.

to affected emergency responders.

b. Once it has been determined that KI should be administered, it should be made available as quickly as possible to all individuals, including those non-Vermont Yankee employees present at the respective centers.

c. The center Coordinator shall provide KI for radioiodine blocking as directed on the outer package label of KI tablets located in the respective emergency center kit.

OP 3507 Rev. 30 Page 8 of 9 LPC #1

I EMERGENCY RADIATION EXPOSURE BRIEFING/DEBRIEFING OB NO. (From VYOPF 3544.02) EMERGENCY DOSE COMMITMENT AUTHORIZED TEDE DOSE COMMITMENT AUTHORIZED: APPROVED BY: APPROVAL TIME:__ I Note: SM/PED or TSC Coordinator approval required [ RADIOLOGICAL BRIEFING Known or Anticipated Radiation/ContaminationlAirbome Levels: Maximum Stay Time/Allowable Dose:_ Required Dosimetry: Self-Reading MultibadgeE Portable Dose Ion Chamber MlTeletector l Rate-Meter:. Neutron Meter [Other (Specify).. Respiratory Protection: SCBA El Respirator El Protective Clothing: Full El Other (Specify) KI Needed? YES E NO E Special Instructions: (Specify) BRIEFER INITIALS: DATE/TIME: NAME (PRINT)

                           .    .   .LIST OF INDIVIDUALS AITENDING BRIEFING SSN              j            ::

SIGNATURE I

• 4 VYOPF 3507.02 OP 3507 Rev. 30 Page 1 of 2 LPC #1

A-EMERGENCY RADIATION EXPOSURE BRIEFING/DEBRIEFING (Continued) RADIOLOGICAL DEBRIEFING INFORMATION Time of Return: Job Completed: YES El NOES Comments/Status.(If applicable): Actual Radiation/Contamination/Airborne Levels Found: Observed Personal Hazards: Problems Encountered/General Comments: Post-Entry Exposure TLD and Dosimetry L Body Count El Follow-up: Other Bio-assay (Specify) DEBRIEFER INITIALS. _DATME:____ OSC COORDINATOR IN1TIALS: DATE rIME:_ ___ TSC COORDINATOR INFORMED BY. (INIIALS):.j . DATErEi .__ j OR SMIPED _ Utc_ VYOPF 3507.02 OP 3507 Rev. 30 Page 2 of 2 LPC#1

PREAPPROVED LPC FORM K-' PART 1 - Initiation .1 Converted to Admin. Revision # LPC No: A. Procedure No.: OP 3508 Current Revision #: 24

Title:

On-Site Medical Emergency Procedure B. Description of Change: p K cOCCdrec qc. renmrcdcr z1 7 0

• Include procedure for RCA access control and electronic Dosimetry issue requirements during a medical emergency.

Provide provisions for accessing RCA during non-life threatening and life threatening situation.

• Include RP Tech actions to record dose received by medical team members during medical emergency.

C. Reason for Change: a Result of Design Change, Minor Mod, EDCR ERelated ER No. - 3 Other: CR-VTY-2003-0619 #2 E Editorial D. Duration: 0 Permanent a One Time Only I. Originator (Print/Sign/Date) E. Surveillance Database Change? El Yes, change submitted Z No (Use AP 0096, App. A as a reference)

                                    .i                                                       (Complete & attach AP 0096 App. C, F. Procedure Type:               3          Technical El Admin. (AP,PP)                unless editorial)

G. AP 0091, Risk Assessment El Yes E No Audra Williams 12/3/03 H. Page(s) affected: 5. 7. 9 and 14 of 20 PART 2 - Reviewv/Approval (Refer to LPC Criteria of Appendix A) A. Technical Verification Review (Print/Sigri/Date) (Use B. Cross-Discipline Review(s) (Print/Sign/Date) I AP 0096, Appendix B as a reference) E N/A El N/A t _/v  : PRy-2 lo3lo3 Audra Williams 12/3/03 (May perform Qualified Review) (N/A if editorial change) C. Qualified Review (Print/Sign/Date) (Use AP 0096, D. 50.59 review completed type: I Appendix D, as a reference) El N/A E AD/Screen El Evaluation E N/A Audra 12/3/03 (N/A if editorial change) (N/A if editorial change) A 50.54(q) (EPIP only) E. RPO Approval (Print/Sign/Date) - F. IF 50.59 Evaluation: S N/A iig fz I_ PORC Mtg. Date: G. Plant Manager (Print/Sign/Date) (SPs only) N/A l H. Training: (Required for Admin Procedures, unless editorial) E N/A E-mail changes I. Effective Date: 12/17/03 CDS Initials VYAPF 0097.02 AP 0097 Rev. 3 Page l of I

io CFR 50.54(q) Evaluation Checklist List of Emergency Plan Section(s)/EMergency Plan Implementing Procedure(s) or any other document to be evaluated. (Include Title and Revision No.): OP 3508. Rev. 24. LPC#1. On-Site Medical Emergencv Procedure A. Screening Evaluation Based on a review of the following questions, determine if the change has the potential to affect our ability to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50. A "YES" answer to any part of the questions requires that a written evaluation be done to determine whether the effectiveness of the Emergency Plan was decreased as specified in Section B of this checklist. A "NO" answer to all questions requires no written evaluation as specified in Section B of this checklist. YES NO Could the proposed change affect our ability to meet the following standards of 10CFR50.47(b): (I) Assignment of Emergency Response Organization responsibilities x (2) Assignment of on-shift Emergency Response Organization personnel X (3) Arrangements for Emergency Response Support and Resources X (4) Emergency Classification and Action levels, including facility system X and effluent parameters (5) Notification Methods and Procedures X (6) Emergency Communications among principal response organizations and the public (7) Public Education and Information (8) Adequacy of Emergency Facilities and Equipment (9) Adequacy of Accident Assessment methods, systems and equipment x~~ (10) Plume exposure pathway EPZ protective actions XL~ X. I x~~ (I1) Emergency Worker Radiological Exposure Control (12) Medical Services for contaminated injured individuals

                                                                                              ~-      X          I (13)    Recovery and Reentry Plans                                                                  x-X               Ix (14)    Emergency response periodic drills and exercises x

(15) Radiological Emergency Response Training (16) Plan development, review and distribution VYAPF 3532.01 AP 3532 Rev. 11 Page I of 3

10 CFR 50.54(q) Evaluation Checklist (Continued) I YES NO I

2. Could the change affect our ability to meet the following requirements of Appendix E to I CFR50 (1) Section IV. A - Organization .IX I (2) Section IV. B - Assessment Actions X.

(3) Section IV. C - Activation of Emergency Organizations X (4) Section IV. D - Notification Procedures X (5) Section IV. E - Emergency Facilities and Equipment . X (6) Section IV. F - Training X (7) Section IV. G - Maintaining Emergency Preparedness XI (8) Section IV. H - Recovery XI B. Effectiveness Deterrnination For each applicable (i.e., a "yes" answer specified) standard to OCFR50.47(b) and Appendix E to IOCFR50 identified from Section A above, complete the evaluation form below to determine whether the change decreases the effectiveness of the Emergency Plan and whether it continues to meet the stated applicable standard or requirement. A facsimile of the evaluation form may be used as needed and attached to this checklist. For applicable item IOCFR50.47(b)(l 1) & (12) of Section A above, this change al DOES 3 DOES NOT decrease the effectiveness of the Emergency Plan and N DOES EDOES NOT continue to meet the stated applicable standard or requirement. BASIS FOR ANSWER: The changes define the RCA access control and electronic Dosimetry issue requirements during a medical emergency and provide provisions for access to RCA during non-life threatening and life threatening situations. RP actions were added to record dose received by medical team members during medical emergencies. This does not decrease the effectiveness of the Plan and continues to meet all requirements. VYAPF 3532.01 AP 3532 Rev. 11 Page 2 of 3

10 CFR 50.54(q) Evaluation Checklist (Continued) C. Conclusion (Fill out appropriate information) S The changes made do not decrease the effectiveness of the Emergency Plan and continue to meet the standards of 10CFR50.47(b) and the requirements of Appendix E to 10CFR50. I] The changes made do decrease the effectiveness of the Emergency Plan and decrease our ability to meet the standards of 10CFR50.47(b) and the requirements of Appendix E to 10CFR50. The following course of action is recommended: l Revise proposed changes to meet applicable standards and requirements. C] Cancel the proposed changes. DI Process proposed changes for NRC approval prior to implementation in accordance with OCFR50.54(q). D. Impact on Other Documents (TRM, Tech Specs) Keywords used in search:_

             *This change does not affect any other documents.

al This change does affect other documents. Document(s) affected:_ Section(s) affected: E. Impact on the Updated FSAR Use AP 6036 to determine if the proposed E-Plan change modifies existing UFSAR information or requires the addition of new UFSAR information and initiate UFSAR change(s) as required. Keywords used in UFSAR search: - - Additional Comments: Prepared Byga5,1q (Ask  ; G oI Date: /2-S-6

                                / (Print/Sign)

Reviewed By: Audra Williams , L L LU Date: 12/2/03 (Emergency Plan Coordinator) (Print/Sign) VYAPF 3532.01 AP 3532 Rev. 1 Page 3 of 3

APPENDIX C CROSS-DISCIPLINE REVIEW CHECKLIST Required to be completed for new procedures, procedure revisions, and LPCs unless they are designated as Editorial. Procedure Number/Revision OP 3508, Rev. 24. LPC#1 Reviewer/Date (Print) Audra Williams 12/3/03

                                          ,

GENERAL REVIEW GUIDELINES/SPECIAL REVIEW REQUIREMENTS

• The Cross-Discipline Review Guidelines below constitute minimum review requirements; other reviews may apply.
• Determination of reviews should focus on changes made to a procedure and the potential impact of those changes on the affected group. Changes that are minimally or nonimpacting do not need review by the potentially affected group.

If change impact is unclear, the procedure should be routed to the potentially affected group for review.

• New or revised Administrative or Program Procedures that significantly impact other departments, shall be reviewed by the appropriate Superintendent or Senior Manager. The PAA maintains a list of these Administrative and Program Procedures.
• ALL noneditorial changes to Special Process procedures (WP, NE, heat treating, etc.), including Vendor Procedures that address Special Processes, shall be reviewed by: a Welding Engineer (welding procedures) or a NDE Level III certified in the method addressed by the procedure (nondestructive examination procedures), AND the Quality Assurance Manager, AND submitted to the Authorized Nuclear Inservice Inspector (ANiI) prior to use.
• A "YES" indicates that a Cross Discipline Review shall be done by the indicated Department. Document the review on VYAPF 0096.01, VYAPF 0097.01, or VYAPF 0097.02, as applicable.

APPLICABLE YES 1- NO. Chemistry:

• Potentially affects condensate, feedwater, or reactor water chemistry, or chemistry instruments.
• Procedures that implement the requirements of the VY Environmental Program.

(see PP 7603, Appendix A)

• Produces/affects effluents or effluent monitoring (VY/QA 01-015).
• Affects NPDES limits or method of compliance. x Maintenance (Mech, Elec, I&C):
• Requires Maintenance personnel to perform activities, such as performance of maintenance procedures, installation of M&TE, lifting and landing of leads and connectors. x Operations:
• Changed requirements for entry into a Limiting Condition for Operation (LCO) or:

significantly changes duration of LCO.

• Requires Operations alignment/restoration of systems or components.
• Specifies surveillance or post maintenance testing by Operations. x EOP/SAG Coordinator:
• Procedures that have the potential to affect the EOPs/SAGs. x Appendix C AP 0096 Rev. 3 Page 1 of3

Quality Assurance:

• Compliance with QA Program requirements cannot be readily determined by the Qualified Reviewer. x Radiation Protection:
• Involves work in contaminated areas and high radiation areas.
• Involves work that breaches contaminated systems or components.
• Changes in radwaste or hazardous waste generation. x Emergency Plan Coordinator:
• Emergency Plan Implementing Procedures.
• Obtain and attach a IOCFR5O.54(q) Evaluation.
• Affects Emergency Plan personnel, facilities or equipment. X Software Quality Assurance Administrator
• Procedures that define how software is developed. x Reactor Engineering:
• Could affect core reactivity, thermal power, reactor heat balance, or fuel integrity.
• Involves refueling operations. x SystemsfProjectlDesign Engineering:
• Maintenance Rule in-scope systems unavailability time.
• Involves infrequently performed test or evolution.
• Changed requirements for entry into a Limiting Condition for Operation (LCO) or significantly changes duration of LCO.
• Significant changes in system test or operation methodology. x Appendix J Coordinator:
• Changes that affect App. J leakrates or containment boundaries, or boundary valve manipulation. x Appendix R Coordinator:
• Appendix R implementing procedures. x Environmental Qualification (EQ) Coordinator:
• Change in EQ test methodology or component lifetime.
• Potentially affects area EQ component environment. x Fire Protection Coordinator (FPC):
• Fire Protection procedures.
• Affects fire loading
• Affects fire barrier integrity.
• Affects fire protection systemsor component functionality. x IST Program Coordinator:
• Inservice Testing Program implementing procedures.
• All surveillance procedures. x ISI Program Coordinator:
• Inservice Inspection Program implementing procedures. x Appendix C AP 0096 Rev. 3 Page 2 of 3

Setpoint Coordinator: Changes that impact setpoints, as-found/as-left tolerances, M&TE or testing methodology. x Nuclear & PRA

  - Potentially affects IPEEE or ORAM Sentinel Risk Models.

Potentially affects plant SSCs reliability.' Potentially affects Nuclear or Radiological Safety Analysis. x Security:

• Proceures that implement the requirements of the VY Physical Security and Training and Qualification Plans.
• Changes that have a potential for reduction of the VY Physical Security and Training and Qualification Plan commitments.
• Obtain and attach a IOCFR50.54(P) Evaluation. x MOv Program Coordinator:
• Potentially affects system parameters for which MOV operation has been evaluated. x AOV Program Coordinator:
• Potentially affects system parameters for which AOV operation has been evaluated. x Appendix C AP 0096 Rev. 3 Page 3 of 3

VERMONT YANKEE NUCLEAR POWER STATION OP 3508 REVISION 24 ON-SITE MEDICAL EMERGENCY PROCEDURE USE CLASSIFICATION: REFERENCE LPC Effective No. Date - Affected Pages 1 12/17/03 5,7,9 & 14 of 20 Implementation Statement: N/A Issue Date: _ 10/29/03 OP 3508 Rev. 24 Page I of 20

PRECAUTIONS/LIMITATIONS

1. During a Code Red'Security Event, Medical Response Team announcement and deployment may be delayed until it is determined that the threat has been terminated and movement of personnel around the plant can be accomplished safely.

PREREQUISITES

     . In a non-fire situation (Fire Brigade not activated), Medical Response Team members or Security personnel shall notify the Control Room, or the Technical Support Center (TSC),

when responding and upon returning from an emergency.

2. In a fire related response, the Medical Team will contact the Fire Brigade Leader for directions on where to respond. Upon arriving at the location they will report to the Fire Brigade Leader, who will have overall scene command.

3. In a non-life threatening medical emergency in the RCA, ensure TLDs are worn and normal access control procedures are used to log into the RCA.

In a life threatening medical emergency in the RCA, ensure TLDs are worn and an emergency electronic dosimeter should be obtained and activated from RP Checkpoint or Maintenance Shop entrance. DEFINITIONS

1. Minor Injury or Illness - Any situation where the patient(s) does not need urgent treatment or attention and is not physically or mentally impaired. Examples include small abrasions, lacerations, punctures, minor headaches due to tension, and slivers. Initiation of this procedure is not warranted for minor injuries or illnesses, See Safety Standard No.

105, Section 5.0.

2. Major Injury or Illness - Any situation where the patient(s) needs immediate attention by medically trained individuals. Examples include any bleeding, breathing difficulties, chest pain, possible fractures, confusion, disorientation, or other major injuries. This procedure shall be initiated immediately.

NOTE A medical emergency shall be initiated if bleeding cannot be controlled. When any amount of blood is present, it needs to be properly cleaned up. Safety, Medical Team members or Hazmat-qualified individuals have been trained in the proper clean-up steps. If in doubt as to whether an injury or illness is minor or major, do not hesitate to treat as major injury. OP 3508 Rev. 24 Page 5 of 20 LPC #1

B. Subsequent Actions in Response to a Medical Emergency

1. The Medical Response Team:

NOTE '11 In a fire situation, the Medical Team will be dispatched in accordance with OP 3020 and report to the Fire Brigade Leader for assignment.

a. The highest qualified member of the Medical Response Team to reach the injured person shall establish "Medical Command" and will lead the medical response effort unless or until relieved by a member of the medical team with equal or higher medical training, NOTE The Safety Coordinator will maintain a list of Designated Lead Medical Team Members and keep them aware of their status.

1) Upon establishment of "Medical Command", the Medical Team Response Leader will notify the Control Room (or TSC, if activated) as follows: "This is (NAME). I am assuming command of the Medical Team." (except in a fire situation where they will report to the Fire Brigade Leader.)

                                                     - NOTES

• Treatment of the injured person is the first priority of the Medical Response Team.
• Steps for assuming command should be repeated if command is transferred.

a) Request radiological conditions of the area if known, or request that an RP Tech be dispatched to assist, NOTE The determination if the medical emergency is life threatening is made by the individual medical team member. (1) If the medical emergency is in the RCA and is not life threatening, 1~c - (a) ensure you are wearing your TLD, and (b) log into the RCA using the normal access control procedure. (2) If the medical emergency is in the RCA and is life threatening, (a) ensure you are wearing your TLD, and (b) obtain and activate an emergency electronic dosimeter located at the RP Checkpoint or Maintenance Shop entrance to the RCA. OP 3508 Rev. 24 Page 7 of 20 LPCft1

h) The Medical Team may update the responding ambulance or hospital on the patient's condition by radio or telephone, as needed using the following Emergency Room phone numbers:

• Brattleboro Memorial Hospital

                         .0      Franklin Medical Center

• Cheshire Medical Center

b. All available members of the medical team should proceed to the location of the injured person, unless an announcement of "Sufficient medical team members are available" or "Medical Emergency is under control or terminated" is heard.

c. En route to the specified location, team members shall take or bring emergency medical equipment from first aid stations around the plant and report to the announced Medical Team Leader.

d. The Medical Response Team Leader shall transfer care of the patient to ambulance personnel when deemed medically appropriate.

e. Under limited conditions, ambulance personnel may request Medical "Team members to assist them with medical treatment en route to the hospital.

-

f. If the medical emergency was in the RCA, log out using the normal access Wpc control procedure or return emergency electronic dosimetry to Radiation Protection for dose recording in accordance with AP 0525.

OP 3508 Rev. 24 Page 9 of 20 LPC #1

NOTE Dose measurements may be accomplished in one of several ways (i.e., dosimetry on Radiation Protection Technician, new dosimetry on patient, calculation, dosimetry on ambulance personnel).

• l U

h. if the patient is contaminated to the extent that general area dose rates of greater than 50 mR/hr would occur, then provisions should be madeA6 measure dose to ambulance attendants,

i. keep the Control Room informed of progress, j.- ensure the Radiation Protection Superintendent is informed if a contaminated patient is being transported to the hospital.

k. If used, collect the emergency electronic dosimeters from medical team members who did not use the normal access control system to enter the RCA.

L1C 1) Record the dose information on VYAPF 0525.11 and forvard to dosimetry for database entry.

2) Re-zero and shutoff the electronic dosimeter using Easy EPD, and.

return them to their storage rack.

5. Radiation Protection Management Personnel:

For cases of high radiation exposures (i.e., greater than 50 R Total Effective Dose Equivalent), the Radiation Protection Superintendent or Plant Health Supervisor Radiation Control will be contacted as soon as possible and must contact the following: OP 3508 Rev. 24 Page 14 of 20 LPC#1

PREAPPROVED LPC FORM TV I PART 1 -Initiation M Converted to Admin. Revision # LPC No: / I A. Procedure No.: OP 3511 Current Revision#: 13

Title:

Off-Site Protective Action Recommendations B. Description of Change: Changed Step Ll.A.2.b.1) from... "IfAppendix B.1.a., Nomogram method..." to "If Appendix B method..." C. Reason for Change: El Result of Design Change, Minor Mod, EDCR_ El Related ER No._

                                *Z Other:_

El Editorial D. Duration: 3 Permanent El One Time Only I. Originator (Print/Sign/Date) E. Surveillance Database Change? El Yes, change submitted Z No (Use AP 0096, App. A as a reference) Technical: El Admin. (APPP) F.Procedure (Complete & attach AP 0096 App. C, F. Procedure Type: s editorial)[1 Admin. (APPP~unless 123 Technical

5. AP 0091, Risk Assessment El Yes 3 No Audra William 12/9/03 H. Page(s) affected: Page 9 of 1 F PART 2 - Review/Approval (Refer to LPC Criteria of Appendix A)

A. Technical Verification Review (Print/Sign/Date) (Use B. Cross-Discipline Review(s) (Print/Sign/Date) AP 0096, Appendix B as a reference) E N/A E N/A LDRe >A. 7Z2^r-- Audra Williams 12/9/03 I<r_ (May perform Qualified Review) (N/A if editorial change) C. Qualified Review (Print/Sign/Date) (Use AP 0096, D. 50.59 review completed type: Appendix D, as a reference) El N/A El AD/Screen E Evaluation N N/A Audra Williams 12/9/03 (N/A if editorial change) (N/A editorial change) J 50.54(q) (EPIP only) E. RPO Approval (Print/Sign/Date) ,,/<5;,F. IF 50.59 Evaluation: E N/A PORC Mtg. Date: G. Plant Manager (Print/Sign/Datel (SPs only) N/A H. Training: (Required for Admin Procedures, unless editorial) N N/A I. Effective Date: 12/17/03 CDS nitialth VYAPF 0097.02 AP 0097 Rev. 3 Page of

10 CFR 50.54(q) Evaluation Checklist List of Emergency Plan Section(s)/Einergency Plan Implementing Procedure(s) or any other document to be evaluated. (Include Title and Revision No.): OP 3511, Rev. 13, LPC# 1, Off-Site Protective Actions Recommendations A. Screening Evaluation Based on a review of the following questions, determine if the change has the potential to affect our ability to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50. A "YES" answer to any part of the questions requires that a written evaluation be done to determine whether the effectiveness of the Emergency Plan was decreased as specified in Section B of this checklist. A "NO" answer to all questions requires no written evaluation as specified in Section B of this checklist. I YES NO Could the proposed change affect our ability to meet the following standards of IOCFR50.47(b): (I) Assignment of Emergency Response Organization responsibilities X (2) Assignment of on-shift Emergency Response Organization personnel

                                                                                                 . .        X1K.

(3) Arrangements for Emergency Response Support and Resources (4) Emergency Classification and Action levels, including facility system X and effluent parameters (5) Notification Methods and Procedures X (6) Emergency Communications among principal response organizations x and the public (7) Public Education and Information X (8) Adequacy of Emergency Facilities and Equipment X (9) Adequacy of Accident Assessment methods, systems and equipment X (10) Plume exposure pathway EPZ protective actions (1H) Emergency Worker Radiological Exposure Control x~~ X (12) Medical Services for contaminated injured individuals x (13) Recovery and Reentry Plans x (14) Emergency response periodic drills and exercises I~~ ~ (15) Radiological Emergency Response Training I I ~X I (16) Plan development, review and distribution VYAPF 3532.01 AP 3532 Rev. 11 Page 1 of3

10 CFR 50.54(q) Evaluation Checklist (Continued) I YES I NO I

2. Could the change affect our ability to meet the following requirements of Appendix E to IOCFR50 (I) Section IV. A - Organization 1x I (2) Section IV. B - Assessment Actions X (3) Section IV. C - Activation of Emergency Organizations X (4) Section IV. D - Notification Procedures X (5) Section IV. E - Emergency Facilities and Equipment I I X X

(6) Section IV. F - Training X (7) Section IV. G - Maintaining Emergency Preparedness X (8) Section IV. H - Recovery B. Effectiveness Determination For each applicable (i.e., a "yes" answer specified) standard to IOCFR50.47(b) and Appendix E to IOCFR50 identified from Section A above, complete the evaluation form below to determine whether the change decreases the effectiveness of the Emergency Plan and whether it continues to meet the stated applicable standard or requirement. A facsimile of the evaluation form may be used as needed and attached to this checklist. For applicable item I0CFR50.47(b)(9), (10) and Appendix E, Section IV. B of Section A above, this change a1 DOES 3 DOES NOT decrease the effectiveness of the Emergency Plan and N DOES DOES NOT continue to meet the stated applicable standard or requirement. BASIS FOR ANSWER: The reference to the specific procedure step was incorrect. By removing it, the step can be performed accurately. VYAPF 3532.01 AP 3532 Rev. 11 Page 2 of 3

10 CFR 50.54(q) Evaluation Checklist (Continued) K</ C. Conclusion (Fill out appropriate information) S The changes made do not decrease the effectiveness of the Emergency Plan and continue to meet the standards of 10CFR50.47(b) and the requirements of Appendix E to 10CFR50. El The changes made do decrease the effectiveness of the Emergency Plan and decrease our ability to meet the standards of 10CFR50.47(b) and the requirements of Appendix E to 10CFR50. The following course of action is recommended: El Revise proposed changes to meet applicable standards and requirements. al Cancel the proposed changes. El Process proposed changes for NRC approval prior to implementation in accordance with 10CFR50.54(q). D. Impact on Other Documents (TRM, Tech Specs) Keywords used in search:_ El This change does not affect any other documents. I] This change does affect other documents. Document(s) affected:_ Section(s) affected:_ E. Impact on the Updated FSAR Use AP 6036 to determine if the proposed E-Plan change modifies existing UFSAR information or requires the addition of new UFSAR information and initiate UFSAR change(s) as required. Keywords used in UFSAR search:- Additional Comments: Prepared By: Audra Williams Date: 12/9/03 (Print/Sgn Reviewed By: Lor4 A- *Rc (A7Q A Date: 1 q,,W (Emergency Plan Coordinator) (Print/Sig VYAPF 3532.01 AP 3532 Rev. 11 Page 3 of 3

APPENDIX C CROSS-DISCIPLINE REVIEW CHECKLIST Required to be completed for new procedures, procedure revisions, and LPCs unless they are designated as Editorial. Procedure Number/Revision OP 3511. Rev. 13. LPC# I Reviewer/Date (Print) Audra Williams 12/9/03 GENERAL REVIEW GUIDELINES/SPECIAL REVIEW REQUIREMENTS

• The Cross-Discipline Review Guidelines below constitute minimum review requirements; other reviews may apply.
• Determination of reviews should focus on changesmade to a procedure and the potential impact of those changes on the affected group. Changes that are minimally or nonimpacting do not need review by the potentially affected group.

If change impact is unclear, the procedure should be routed to the potentially affected group for review.

• New or revised Administrative or Program Procedures that significantly impact other departments, shall be reviewed by the appropriate Superintendent or Senior Manager. The PAA maintains a list of these Administrative and Program Procedures.
• ALL noneditorial changes to Special Process procedures (WP, NE, heat treating, etc.), including Vendor Procedures that address Special Processes, shall be reviewed by- a Welding Engineer (welding procedures) or a NDE Level III certified in the method addressed by the procedure (nondestructive examination procedures), AND the Quality Assurance Manager, AND submitted to the Authorized Nuclear Inservice Inspector (ANII) prior to use.
• A "YES" indicates that a Cross Discipline Review shall be done by the indicated Department. Document the review on VYAPF 0096.01, VYAPF 0097.01, or VYAPF 0097.02, as applicable.

APPLICABLE . YE S NO - Chemistry:

• Potentially affects condensate, feedwater, or reactor water chemistry, or chemistry instruments.
• Procedures that implement the requirements of the VY Environmental Program.

(see PP 7603, Appendix A)

• Produces/affects effluents or effluent monitoring (VY/QA 0 1-015).
• Affects NPDES limits or method of compliance. X Maintenance (Mech, Elec, I&C):
• Requires Maintenance personnel to perform activities, such as performance of maintenance procedures, installation of M&TE, lifting and landing of leads and connectors. X Operations:.
• Changed requirements for entry-into a Limiting Condition for Operation (LCO) or.

significantly changes duration of LCO.

• Requires Operations alignment/restoration of systems or components.
• Specifies surveillance or post maintenance testing by Operations. X EOP/SAG Coordinator:
• Procedures that have the potential to affect the EOPs/SAGs. X Appendix C AP 0096 Rev. 3 Page 1 of 3

Quality Assurance:

• Compliance with QA Prograi requirements cannot be readily determined by the Qualified Reviewer. X Radiation Protection:
• Involves work in contaminated areas and high radiation areas.
• Involves work that breaches contaminated systems or components.
• Changes in radwaste or hazardous waste generation. X Emergency Plan Coordinator:
• Emergency Plan Implementing Procedures.

I

• Obtain and attach a I OCFR50.54(q) Evaluation.
• Affects Emergency Plan personnel, facilities or equipment. X Software Quality Assurance Administrator ,
• Procedures that define how software is developed. X Reactor Engineering:
• Could affect core reactivity, thermal power, reactor heat balance, or fuel integrity.
• Involves refueling operations. X Systems/Project/Design Engineering:
• Maintenance Rule in-scope systems unavailability time.
• Involves infrequently performed test or evolution.
• Changed requirements for entry into a Limiting Condition for Operation (LCO) or significantly changes duration of LCO.
• Significant changes in system test or operation methodology. X Appendix J Coordinator:
• Changes that affect App. J leakrates or containment boundaries, or boundary valve manipulation. X Appendix R Coordinator:

     .*  Appendix R implementing procedures.                                                                X Environmental Qualification (EQ) Coordinator:

• Change in EQ test methodology or component lifetime.
• Potentially affects area EQ component environment. X Fire Protection Coordinator (FPC):
• Fire Protection procedures.
• Affects fire loading
• Affects fire barrier integrity.
• Affects fire protection systems or component functionality. X IST Program Coordinator:
• Inservice Testing Program implementing procedures.
• All surveillance procedures. X ISI Program Coordinator:
• Inservice Inspection Program implementing procedures. X Appendix C AP 0096 Rev. 3 Page 2 of 3

Setpoint Coordinator:

• Changes that impact setpoints, as-found/as-left tolerances, M&TE or testing methodology. X l Nuclear & PRA
• Potentially affects IPEEE or ORAM Sentinel Risk Models.
• Potentially affects plant SSCs reliability.
• Potentially affects Nuclear or Radiological Safety Analysis. X Security:
• Proceures that implement the requirements of the VY Physical Security and Training and Qualification Plans.
• Changes that have a potential for reduction of the VY Physical Security and Training and Qualification Plan commitments.
• Obtain and attach a 10CFR50.54(P) Evaluation. X MOV Program Coordinator:
• Potentially affects system parameters for which MOV operation has been evaluated. X AOV Program Coordinator:
• Potentially affects system parameters for which AOV operation has been evaluated. X Appendix C AP 0096 Rev. 3 Page 3 of 3

VERMONT YANKEE NUCLEAR POWER STATION OP 3511 REVISION 13 OFF-SITE PROTECTIVE ACTION RECOMMENDATIONS USE CLASSIFICATION: REFERENCE LPC Effective Affected Pages No. Date 1 12/17/03 9of 11 Implementation Statement: N/A Issue Date:

         ._

10/29/03 OP 3511 Rev. 13 Page 1 of 11

NOTES Table 4 and Table 5 are conservatively based on METPAC plume trajectories, the river valley effect for stability classes E, F and G, and plume wvidth.

• The town of Marlboro, VT is not a VY EPZ town.
• In the EOF, in the initial stages of the event, determine the plume trajectory by calculating a "what i" METPAC 10-mile plume projection with a default source term and actual meteorology.

Use the METPAC Batch Mode with 8 time steps. See OP 3513, Appendix K.

• For Stability Classes E, F and G and variable wind direction from the NE or the SW sectors, it would be prudent to consider evacuating all the towns as listed in these sections of Tables 4 and 5.
• In all cases, use the field team data to verify the actual downwind direction of the plume. Adjust the PAR as appropriate.

b. Choose the towns affected by the PAR as follows:

1) If Appendix B method of OP 3513 shows that the PAR

_-1I (evacuation) is exceeded, then use TABLE 5 and appropriate meteorological data (wind direction and stability class A) to obtain affected towns out to five miles downwind.

2) If ODPS shows that the PAR (evacuation) is exceeded between five and ten miles, then use TABLE 4 and appropriate meteorological data (wind direction and stability class) to obtain affected towns out to ten miles downwind.

3) If ODPS shows that the PAR (evacuation) is exceeded between the site boundarv and five miles, then use TABLE 5 and appropriate meteorological data (wind direction and stability class) to obtain affected towns out to five miles downwind.

OP 3511 Rev. 13 Page 9 of 11 LPC#1

PREAPPROVED LPC FORM I .I PART _ 1 - Initiation r71 Converted to Admin. Revision # LPC No: I A. Procedure No.: AP 3532 Current Revision #: 11

Title:

Emergency Preparedness Organization B. Description of Change: CR-VTYLO-2002-0281 00017-Added NUREG-0654 review to VYAPF 3532.01 TidckLc( K T+o flAP (o in Ae c I nj,ads sduS>I/(nct C. Reason for Change: Result of Design Change, Minor Mod, EDCR ERelated ER No. 0 Other: CR-VTYLO-2002-0281_ E Editorial D. Duration: 0 Permanent E]One Time Only I. Originator (Print/Sign/Date) E. Surveillance Database Change? al Yes, change submitted E No (Use AP 0096, App. A as a reference) (Complete & attach AP 0096 App. C, F. Procedure Type: qa^? l' Technical Admin. (AP,PP) unless editorial) G. AP 0091, Risk Assessment El Yes 0 No Audra Williams 11/20/03 H. Page(s) affected: panes 8. 12 of 12. VYAPF 3532.01 page 3 of 3 PART 2 - Review/Approval (Refer to LPC Criteria of Appendix A) A. Technical Verification Review (Print/Sign/Date) (Use B. Cross-Discipline Review(s) (Print/Sign/Date) I AP 0096, Appendix B as a reference) El N/A N/A Lori~-~ gAudra iezak 3,2Aw~tJlZll3 Williams 1120/03 (May perform Qualified Review) (N/A if editorial change) C. Qualified Review (Print/Sign/Date) (Use AP 0096, D. 50.59 review completed type: I Appendix D, as a reference) I] N/A El AD/Screen El Evaluation 0N/A Audra Willi 11/20/03 (N/A if editorial change) (N/A if editorial change) A 50.54(q) (EPIP only). E. RPO Approval (Print/Sign/Date) //Z//b3 F. IF 50.59 Evaluation: 0 N/A __________________________J d PORCMtg. D ate: G. Plant Manager (Print/Sign/Date) (SPs only) N/A I H. Training: (Required for Admin Procedures, unless editorial) A 3 1.Effective Date: 12/17/03 CDS Initials VYAPF 0097.02 AP 0097 Rev. 3 Page 1 of I

I'. 10 CFR 50.54(q) Evaluation Checklist List of Emergency Plan Section(s)/Emnergency Plan Implementing Procedure(s) or any other document to be evaluated. (Include Title and Revision No.): OP 3532, Rev. 1l, LPC# 1, Emergency Preparedness Organization A. Screening Evaluation Based on a review of the following questions, determine if the change has the potential to affect our ability to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50. A "YES" answer to any part of the questions requires that a written evaluation be done to determine whether the effectiveness of the Emergency Plan was decreased as specified in Section B of this checklist. A "NO" answer to all questions requires no written evaluation as specified in Section B of this checklist. I YES NO I

1. Could the proposed change affect our ability to meet the following standards of IOCFR50.47(b):

(I) Assignment of Emergency Response Organization responsibilities X (2) Assignment of on-shift Emergency Response Organization personnel X (3) Arrangements for Emergency Response Support and Resources (4) Emergency Classification and Action levels, including facility system and effluent parameters X (5) Notification Methods and Procedures X (6) Emergency Communications among principal response organizations

• X X and the public *x -

(7) Public Education and Information xX (8) Adequacy of Emergency Facilities and Equipment (9) Adequacy of Accident Assessment methods, systems and equipment xX (10) Plume exposure pathway EPZ protective actions xX (11) Emergency Worker Radiological Exposure Conitrol x X (12) Medical Services for contaminated injured individuals I I ~x (13) Recovery and Reentry Plans (14) Emergency response periodic drills and exercises (15) Radiological Emergency Response Training (16) Plan development, review and distribution VYAPF 3532.01 AP 3532 Rev. 1 Page 1 of3

I; . . 10 CFR 50.54(q) Evaluation Checklist (Continued) I YES l NO l

2. Could the change affect our ability to meet the following requirements of Appendix E to I OCFR50 (1) Section IV. A -Organization X' (2) Section IV. B - Assessment Actions X.

(3) Section IV. C - Activation of Emergency Organizations X (4) Section IV. D - Notification Procedures X (5) Section IV. E - Emergency Facilities and Equipment X (6) Section IV. F - Training X (7) Section IV. G - Maintaining Emergency Preparedness X (8) Section IV. H - Recovery X B. Effectiveness Determination For each applicable (i.e., a "yes" answer specified) standard to IOCFR50.47(b) and Appendix E to 10CFR50 identified from Section A above, complete the evaluation form below to determine whether the change decreases the effectiveness of the Emergency Plan and whether it continues to meet the stated applicable standard or requirement. A facsimile of the evaluation form may be used as needed and attached to this checklist. For applicable item IOCFR50. N/A of Section A above, this change 2 DOES DOES NOT decrease the effectiveness of the Emergency Plan and N DOES El DOES NOT continue to meet the stated applicable standard or requirement. BASIS FOR ANSWER: The addition of a reference to NUREG-0654 Cross Reference helps to ensure that this document is being looked at for all procedure and E-Plan changes. The list of specific surveillances was removed and reference to AP 4000, Surveillance Testing Procedure was added. Everytime the surveillances changed, this procedure had to change as well. By removing the list and adding the reference to the procedure that governs surveillances, it removes the chance of the list not being up to date. VYAPF 3532.01 AP 3532 Rev. II Page 2 of 3

10 CFR 50.54(q) Evaluation Checklist (Continued) X C. Conclusion (Fill out appropriate information) 53 The changes made do not decrease the effectiveness of the Emergency Plan and continue to meet the standards of IOCFR50.47(b) and the requirements of Appendix E to 10CFR50. [] The changes made do decrease the effectiveness of the Emergency Plan and decrease our ability to meet the standards of IOCFR50.47(b) and the requirements of Appendix E to IOCFR50. The following course of action is recommended: [] Revise proposed changes to meet applicable standards and requirements. [] Cancel the proposed changes. 2 Process proposed changes for NRC approval prior to implementation in accordance with OCFR50.54(q). D. Impact on Other Documents (TRM, Tech Specs) Keywords used in search:_ U-

        %3      This change does not affect any other documents.

E] This change does affect other documents. Document(s) affected: Section(s) affected:_ E. Impact on the Updated FSAR Use AP 6036 to determine if the proposed E-Plan change modifies existing UFSAR information or requires the addition of new UFSAR information and initiate UFSAR change(s) as required. Keywords used in UFSAR search: No impact on USFSAR Additional Comments: Prepared By: Audra Williams, Date: 11/20/03 (Print/Sign) / ,: Reviewed By: LAZ -d/ a0X ic Date:_ _______ (EmergencyPlanCoordinator) (Print/Sign) ' VYAPF 3532.01 AP 3532 Rev. 11 Page 3 of 3

APPENDIX C CROSS-DISCIPLINE REVIEW CHECKLIST Required to be completed for new procedures, procedure revisions, and LPCs unless they are designated as Editorial. Procedure Number/Revision. OP 3532. Rev. 11.LPC#1 Reviewer/Date (Print) Audra Williams 11/20/03 = GENERAL REVIEW GUIDELINES/SPECIAL REVIEW REOUIREMENTS

• The Cross-Discipline Review Guidelines below constitute minimum review requirements; other reviews may apply.
• Determination of reviews should focus on changes made to a procedure and the potential impact of those changes on the affected group. Changes that are minimally or nonimpacting do not need review by the potentially affected group.

If change impact isunclear, the procedure should be routed to the potentially affected group for review.

• New or revised Administrative or Program Procedures that significantly impact other departments, shall be reviewed by the appropriate Superintendent or Senior Manager. The PAA maintains a list of these Administrative and Program Procedures.
• ALL noneditorial changes to Special Process procedures (WP, NE, heat treating, etc.), including Vendor Procedures that address Special Processes, shall be reviewed by: a Welding Engineer (welding procedures) or a NDE Level III certified in the method addressed by the procedure (nondestructive examination procedures), AND the Quality Assurance Manager, AND submitted to the Authorized Nuclear Inservice Inspector (ANII) prior to use.
• A "YES" indicates that a Cross Discipline Review shall be done by the indicated Department. Document the review on VYAPF 0096.01, VYAPF 0097.01, or VYAPF 0097.02, as applicable.

APPLICABLE YES NO Chemistry:

• Potentially affects condensate, feedwater, or reactor water chemistry, or chemistry instruments.
• Procedures that implement the requirements of the VY Environmental Program.

(see PP 7603, Appendix A)

• Produceslaffects effluents or effluent monitoring (VY/QA 01-015).
• Affects NPDES limits or method of compliance. X Maintenance (Mech, Elec, I&C):
• Requires Maintenance personnel to perform activities, such as performance of maintenance procedures, installation of M&TE, lifting and landing of leads and connectors. X Operations:
• Changed requirements for entry into a Limiting Condition for Operation LCO) or significantly changes duration of LCO.
• Requires Operations alignment/restoration of systems or components.
• Specifies surveillance or post maintenance testing by Operations. X EOP/SAG Coordinator:
• Procedures that have the potential to affect the EOPs/SAGs. X Appendix C AP 0096 Rev. 3 Page 1 of3

Quality Assurance:

• Compliance with QA Program requirements cannot be readily determined by the Qualified Reviewer. X Radiation Protection:
• Involves work in contaminated areas and high radiation areas.

Involves work that breaches contaminated systems or components.

• Changes in radwaste or hazardous waste generation. X Emergency Plan Coordinator:

     - Emergency Plan Implementing Procedures.

• Obtain and attach a IOCFR50.54(q) Evaluation.
• Affects Emergency Plan personnel, facilities or equipment. X Software Quality Assurance Administrator
• Procedures that define how software is developed. X Reactor Engineering:
• Could affect core reactivity, thermal power, reactor heat balance, or fuel integrity.
• Involves refueling operations. X Systems/Project/Design Engineering:
• Maintenance Rule in-scope systems unavailability time.
• Involves infrequently performed test or evolution.
• Changed requirements for entry into a Limiting Condition for Operation (LCO) or significantly changes duration of LCO.

       -Significant changes in system test or operation methodology..                                     X Appendix J Coordinator:

• Changes that affect App. J leakrates or containment boundaries, or boundary valve manipulation. X Appendix R Coordinator:
• Appendix R implementing procedures. X Environmental Qualification (EQ) Coordinator:
• Change in EQ test methodology or component lifetime.
• Potentially affects area EQ component environment. X Fire Protection Coordinator (FPC):
• Fire Protection procedures.
• Affects fire loading
• Affects fire barrier integrity.
• Affects fire protection systems or component functionality. X IST Program Coordinator:
• Inservice Testing Program implementing procedures.
• All surveillance procedures. X ISI Program Coordinator:
• Inservice Inspection Program implementing procedures. X Appendix C AP 0096 Rev. 3 Page 2 of 3

Setpoint Coordinator:

• Changes that impact setpoints, as-found/as-left tolerances, M&TE or testing methodology. X Nuclear & PRA
• Potentially affects IPEEE or ORAM Sentinel Risk Models.
• Potentially affects plant SSCs reliability.
• Potentially affects Nuclear or Radiological SafetyAnalysis. X Security:
• Proceures that implement the requirements of the VY Physical Security and Training and Qualification Plans.
• Changes that have a potential for reduction of the VY Physical Security and

      .Training and Qualification Plan commitments.

• Obtain and attach a IOCFR50.54(P) Evaluation. X MOV Program Coordinator:
• Potentially affects system parameters for which MOV operation has been evaluated. X AOV Program Coordinator:
• Potentially affects system parameters for which AOV operation has been evaluated. X Appendix C AP 0096 Rev. 3 Page 3 of 3

VERMONT YANKEE NUCLEAR PONVER STATION AP 3532 REVISION 11 EMERGENCY PREPAREDNESS ORGANIZATION USE CLASSIFICATION: INFORMATION LPC Effective No. DateNo. Date ~~~~~~~~~Affected P'ages 1 12/17/03 8 & 12 of 12 & VYAPF 3532.01 Pg 3 of 3 I Implementation Statement: N/A 1.. . Issue Date: 04/02/03 AP 3532 Rev. 11 Page I of 12

4.4.5. Surveillance Tests: The EPM is responsible for the conduct per AP 4000, Surveillance Testing Program, of Emergency Planning Surveillances. I I AP 3532 Rev. 11 Page 8 of 12 LPC #1

l 5.4. Supplemental References 5.4.1. Public Affairs Department Guideline No.4, "Joint News Center Implementation I / Guideline" 5.4.2. AP 0028, Commitment Tracking 5.4.3. AP 0058, NRC Correspondence Control 5.4.4. AP 0095, Plant Procedures 5.4.5. AP 3125, Emergency Plan Classification and Action Level Scheme 5.4.6. OP 3504, Emergency Communications 5.4.7. OP 3505, Emergency Preparedness Exercises and Drills 5.4.8. OP 3506, Emergency Equipment Readiness Check 5.4.9. OP 3507, Emergency Radiation Exposure Control 5.4.10. OP 3508, On-Site Medical Emergency Procedure 5.4.11. OP 3509, Environmental Sample Collection During an Emergency 5.4.12. OP 3510, Off-Site and Site Boundary Monitoring 5.4.13. OP 3511, Off-Site Protective Action Recommendations 5.4.14. OP 3513, Evaluation of Off-Site Radiological Conditions 5.4.15. OP 3524, Emergency Actions to Ensure Initial Accountability and Security Response 5.4.16. OP 3525, Radiological Coordination 5.4.17. OP 353 1, Emergency Call-In Method 5.4.18. OP 3533, Post Accident Sampling of Reactor Coolant 5.4.19. OP 3534, Post Accident Sampling of Plant Stack Gaseous Releases 5.4.20. OP 3535, Post Accident Sampling and Analysis of Primary Containment 5.4.2.1. OP 3536, In-Plant Air Sample Analysis with Abnormal Conditions 5.4.22.. OP 3540, Control Room Actions During an Emergency 5.4.23. OP 3541, Activation of the Technical Support Center 5.4.24. OP 3542, Operation of the Technical Support Center 5.4.25. OP 3544, Operation of the Operations Support Center 5.4.26. OP 3545, Activation of the Emergency Operations Facility/Recovery Center 5.4.27. OP 3546, Operation of the Emergency Operations Facility/Recovery Center 5.4.28. OP 3547, Security Actions During an Emergency 5.4.29. OP 3712, Emergency Plan Training 5.4.30. AP 4000, Surveillance Testing Program 5.4.3 1. AP 6805, Document Control 5.4.32. AP 6807, Collection, Temporary Storage and Retrieval of QA Records 6.0 RECORDS RETENTION . 6.1. Retain VYAPF 3532.01 in accordance with AP 6807. 7.0 ATTACHMENTS 7.1. VYAPF 3532.01 10CFR50.54(q) Evaluation Checklist AP 3532 Rev. 11 Page 12 of 12 LPC#1

10 CFR 50.54(q) Evaluation Checklist (Continued) C. Conclusion (Fill out appropriate information) El The changes made do not decrease the effectiveness of the Emergency Plan and continue to meet the standards of 10CFR50.47(b) and the requirements of Appendix E to 10CFR50. El The changes made do decrease the effectiveness of the Emergency Plan and decrease our ability to meet the standards of 10CFR50.47(b) and the requirements of Appendix E to* 10CFR50. The following course of action is recommended: Ea Revise proposed changes to meet applicable standards and requirements. El Cancel the proposed changes. El Process proposed changes for NRC approval prior to implementation in accordance with 10CFR50.54(q). Lc I rD. Impact on Other Documents (TRM, Tech Specs, NUREG-0654 Cross Reference) Keywords used in search:_ El This change does not affect any other documents. K2 El This change does affect other documents. Document(s) affected:_ Section(s) affected:_ E. Impact on the Updated FSAR Use AP 6036 to determine if the proposed E-Plan change modifies existing UFSAR information or requires the addition of new UFSAR information and initiate UFSAR change(s) as required. Keywords used in UFSAR search: - Additional Comments: Prepared By: Date:_ (Print/Sign) Reviewed By: Date:_ (Emergency Plan Coordinator) (Print/Sign) VYAPF 3532.01 AP 3532 Rev. 11 Page 3 of 3 LPC #1

V PREAPPROVED LPC FORM I PART 1 - Initiation F] Converted to Admin. Revision # LPC No: I A. Procedure No.: OP 3712 Current Revision #: 17

Title:

Emergency Plan Training B. Description of Change: CR-VTYLO-2003-0680 00013 - Added LLEA training to procedure. C. Reason for Change: a Result of Design Change, Minor Mod, EDCR_ El Related ER No._ 3 Other: CR-VTYLO-2003-0680 El Editorial D. Duration: I Permanent El One Time Only I. Originator (Print/Sign/Date) E. Surveillance Database Change? Yes, change submitted [D No (Use AP 0096, App. A as a reference) F. Procedure Type:Technical F. Procedure Type:  ; El Admin. (APPP) (Complete & attach AP 0096 App. C, El Technical editorial)DAdmin. (APPP~unless G. AP 0091, Risk Assessment E Yes [D No Audra Williams . 11/20/03 H. Page(s) affected: panes 2,4. 6 of 6 acheZ UOA og$ae PART 2 - Review/Approval (Refer to LPC Criteria of Appendix A) A.Technical Verification Review (Print/Sign/Date) (Use B. Cross-Discipline Review(s) (Print/Sign/Date) I AP 0096, Appendix B as a reference) EN/A EN/A e~ eK-  ; Audra Williams 11/20/03 (May perform Qualified Review) (N/A if editorial change) C. Qualified Review (Print/Sign/Date) (Use AP 0096, D. 50.59 review completed type: Appendix D, as a reference) E] N/A El AD/Screen El Evaluation ED N/A Audra Williams 11/20/03 (N/A if editorial change) (N/A if editorial change) u 50.54(q) (EPIP only) E. RPO Approval (Print/Sign/Date) F. IF 50.59 Evaluation: l N/A PORC Mtg. Date: G. Plant Manager (Print/Sign/Date) (SPs only) N/A H. Training: (Required for Admin Procedures, unless editorial) -N/A 1.Effective Date: 12/17/03 CDS Initials 'MA8 VYAPF 0097.02 AP 0097 Rev. 3 Page 1 of 1

i4 10 CFR 50.54(q) Evaluation Checklist List of Emergency Plan Section(s)/Eimergency Plan Implementing Procedure(s) or any other document to be evaluated. (Include Title and Revision No.): OP 3712, Rev. 17, LPC#I, EPlan Training A. Screening Evaluation Based on a review of the following questions, determine if the change has the potential to affect our ability to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50. A "YES" answer to any part of the questions requires that a written evaluation be done to determine whether the effectiveness of the Emergency Plan was decreased as specified in Section B of this checklist. A NO" answer to all questions requires no written evaluation as specified in Section B of this checklist. YE S NO~ Could the proposed change affect our ability to meet the following standards of 10CFR5O.47(b): (1) Assignment of Emergency Response Organization responsibilities x (2) Assignment of on-shift Emergency Response Organization personnel x (3) Arrangements for Emergency Response Support and Resources .. ~x (4) Emergency Classification and Action levels, including facility system x and effluent parameters (5) Notification Methods and Procedures x (6) Emergency Communications among principal response organizations x and the public (7) Public Education and Information x . (8) Adequacy of Emergency Facilities and Equipment x (9) Adequacy of Accident Assessment methods, systems and equipment x (10) Plume exposure pathway EPZ protective actions .x (11) Emergency Worker Radiological Exposure Control x (12) Medical Services for contaminated injured individuals x (13) Recovery and Reentry Plans x (14) Emergency response periodic drills and exercises x (15) Radiological Emergency Response Training x (16) Plan development, review and distribution T x__ VYAPF 3532.01 AP 3532 Rev. 11 Page l of3

10 CFR 50.54(q) Evaluation Checklist (Continued) I YES l NO l

2. Could the change affect our ability to meet the following requirements of Appendix E to 10CFR50 (1): Section IV. A - Organization (2) Section IV. B - Assessment Actions

                                                                                              .~~            X (3)    Section IV. C - Activation of Emergency Organizations                                        X (4)    Section IV. D - Notification Procedures                                                      X I , ~.          x X      I (5)    Section IV.E - Emergency Facilities and Equipment (6)    Section IV. F - Training                                                      X (7)    Section IV. G - Maintaining Emergency Preparedness                           =                 ~X (8)    Section IV. H - Recovery B.      Effectiveness Determination For each applicable (i.e., a "yes" answer specified) standard to IOCFR50.47(b) and Appendix E to IOCFR50 identified from Section A above, complete the evaluation form below to determine whether the change decreases the effectiveness of the Emergency Plan and whether it continues to meet the stated applicable standard or requirement.

A facsimile of the evaluation form may be used as'needed and attached to this checklist. For applicable item 10CFR50.47(b)(15) and Appendix E. Section IV. F of Section A above, this change [1 DOES DOES NOT decrease the effectiveness of the Emergency Plan and 3 DOES Li DOES NOT continue to meet the stated applicable standard or requirement. BASIS FOR ANSWER: The inclusion of the LLEA training is to formalize and integrate the Security portion of training that is currently being done, but was not identified in the procedure. VYAPF 3532.01 AP 3532 Rev. II Page 2 of 3

10 CFR 50.54(q) Evaluation Checlist (Continued) C. Conclusion (Fill out appropriate information) 3 The changes made do not decrease the effectiveness of the Emergency Plan and continue to meet the standards of IOCFR50.47(b) and the requirements of Appendix E to 10CFR50.. [1 The changes made do decrease the effectiveness of the Emergency Plan and decrease our ability to meet the standards of 10CFR50.47(b) and the requirements of Appendix E to 10CFR50. The following course of action is recommended: C1 Revise proposed changes to meet applicable standards and requirements. [1 Cancel the proposed changes. l Process proposed changes for NRC approval prior to implementation in accordance with 10CFR50.54(q). D. Impact on Other Documents (TRM, Tech Specs) Keywords used in search:_ This change does not affect any other documents. Ei This change does affect other documents. Document(s) affected: Section(s) affected:_ E. Impact on the Updated FSAR Use AP 6036 to determine if the proposed E-Plan change modifies existing UFSAR information or requires the addition of new UFSAR information and initiate UFSAR change(s) as required. Keywords used in UFSAR search:.No impact on USFSAR Additional Comments: Prepared By: Audra Williams SAUDIr fD

                                                 )    J4r           Date: 11/20/03 (Print/Sigp          ,

Reviewed By: Le /. zn)ePf (Emergency Plan Coordinator)

                                              -        a (Print/Si6)

Date: ///2Ob VYAPF 3532.01 AP 3532 Rev. 11 Page 3 of 3

APPENDIX C CROSS-DISCIPLINE REVIEW CHECKLIST Required to be completed for new procedures, procedure revisions, and LPCs unless they are designated as Editorial. ProcedureNumber/Revision OP 3712. Rev. 17. LPC#I Reviewer/Date (Print) Audra Williams 11/20/03 GENERAL REVIEW GUIDELINES/SPECIAL REVIEW REOUIREMENTS

• The Cross-Discipline Review Guidelines below constitute minimum review requirements; other reviews may apply.
• Determination of reviews should focus on changes made to a procedure and the potential impact of those changes on the affected group. Changes that are minimally or nonimpacting do not need review by the potentially affected group.

If change impact is unclear, the procedure should be routed to the potentially affected group for review.

• New or revised Administrative or Program Procedures that significantly impact other departments, shall be'reviewed by the appropriate Superintendent or Senior Manager. The PAA maintains a list of these Administrative and Program Procedures.
• ALL noneditorial changes to Special Process procedures (WP, NE, heat treating, etc.), including Vendor Procedures that address Special Processes, shall be reviewed by- a Welding Engineer (welding procedures) or a NDE Level III certified in the method addressed by the procedure (nondestructive examination procedures), AND the Quality Assurance Manager, AND submitted to the Authorized Nuclear Inservice Inspector (ANII) prior to use.
• A "YES" indicates that a Cross Discipline Review shall be done by the indicated Department. Document the review on VYAPF 0096.01, VYAPF 0097.01, or VYAPF 0097.02, as applicable.

APPLICABLE K. - YES NO. Chemistry:

• Potentially affects condensate, feedwater, or reactor water chemistry, or chemistry instruments.
• Procedures that implement the requirements of the VY Environmental Program.

(see PP 7603, Appendix A)

• Produces/affects effluents or effluent monitoring (VY/QA 01-015).
• Affects NPDES limits or method of compliance. X Maintenance (Mech, Elec, I&C):
• Requires Maintenance personnel to perform activities, such as performance of maintenance procedures, installation of M&TE, lifting and landing of leads and connectors. X Operations::
• Changed requirements for entry into a Limiting Condition for Operation (LCO) or significantly changes duration of LCO.
• Requires Operations alignment/restoration of systems or components.
• Specifies surveillance or post maintenance testing by Operations. X EOP/SAG Coordinator:
• Procedures that have the potential to affect the EOPs/SAGs. X Appendix C AP 0096 Rev. 3 Page 1 of3

Quality Assurance:

• Compliance with QA Program requirements cannot be readily determined by the Qualified Reviewer. X Radiation Protection:
• Involves work in contaminated areas and high radiation areas.
• Involves work that breaches contaminated systems or components.
• Changes in radwaste or hazardous waste generation. X Emergency Plan Coordinator:
• Emergency Plan Implementing Procedures.
• Obtain and attach a I OCFR50.54(q) Evaluation.
• Affects Emergency Plan personnel, facilities or equipment. X Software Quality Assurance Administrator
• Procedures that define how software is developed. X Reactor Engineering:
• Could affect core reactivity, thermal power, reactor heat balance, or fuel integrity.
• Involves refueling operations. X Systems/ProjectlDesign Engineering:
• Maintenance Rule in-scope systems unavailability time.
• Involves infrequently performed test or evolution.
• Changed requirements for entry into a Limiting Condition for Operation (LCO) or significantly changes duration of LCO.
• Significant changes in system test or operation methodology. X Appendix J Coordinator:
• Changes that affect App. J leakrates or containment boundaries, or boundary valve manipulation. X Appendix R Coordinator:
• Appendix R implementing procedures. X Environmental Qualification (EQ) Coordinator:
• Change in EQ test methodology or component lifetime.
• Potentially affects area EQ component environment. X Fire Protection Coordinator (FPC):
• Fire Protection procedures.
• Affects fire loading
• Affects fire barrier integrity.

Affects fire protection systems or component functionality. X IST Program Coordinator:

• Inservice Testing Program implementing procedures.
• All surveillance procedures. X ISI Program Coordinator:
• Inservice Inspection Program implementing procedures. . X Appendix C AP 0096 Rev. 3 Page 2 of 3

Setpoint Coordinator: .

• Changes that impact setpoints, as-found/as-left tolerances, M&TE or testing methodology. X Nuclear & PRA
• Potentially affects IPEEE or ORAM Sentinel Risk Models..

   - Potentially affects plant SSCs reliability.

• Potentially affects Nuclear or Radiological Safety Analysis. X Security:
• Proceures that implement the requirements of the VY Physical Security and Training and Qualification Plans.
• Changes that have a potential for reduction of the VY Physical Security and Training and Qualification Plan commitments.
• Obtain and attach a IOCFR50.54(P) Evaluation. X MOV Program Coordinator:
• Potentially affects system parameters for which MOV operation has been evaluated. X AOV Program Coordinator:
• Potentially affects system parameters for which AOV operation has been evaluated. X Appendix C AP 0096 Rev. 3 Page 3 of 3

VERMONT YANKEE NUCLEAR POWER STATION OP 3712 REVISION 17 EMERGENCY PLAN TRAINING USE CLASSIFICATION: INFORMATION LPC Effective' No. Date Affected Pages 1 12/17/03 2,4,6 & ADDED 6A of 6 Implementation Statement: N/A Issue Date: 04/30/2003 OP 3712 Rev. 17 Page 1 of 6

TABLE OF CONTENTS PURPOSE............ ............................................................................................................................................. ;.................... DISCUSSION....... ..............................................................................................................................................- ATITACHMENTS .4 REFERENCES AND COMMITMENTS....................................................................................................4 RESPONSIBILiTIES .............................. 4 PR OC ED U R E .................................................................................................................................................... 5 I. EMERGENCY RESPONSE TRAINING .. 5 A. Medical Response Team .5 B. Fire Brigade .5 II. SPECIAL EMERGENCY RESPONSE TRAINING GROUPS.............................................5 A. Local Medical Support Personnel .5 B. State and Local Governments .6 C. Local Fire Department .....................  ; 6 KU I D. Local Law Enforcement Agency ...................... . . . . 7 FIN AL CONDITION S ...................................................................................................................................... 7 OP 3712 Rev. 17 Page 2 of 6 LPC#1

ATTACHMENTS

1. None REFERENCES AND COMMITMENTS

1. Technical Specifications and Site Documents

a. - Vermont Yankee Emergency Plan

2. Codes, Standards, and Regulations

a. Appendix E, 10CFR50

3. Commitments

a. None

4. Supplemental References

a. Vermont Yankee Implementing Procedures to the Emergency Plan

b. Training Department Directives

c. Emergency Plan Training Program Description

d. AP 0700, Vermont Yankee Staff Training

e. AP 0840, Medical Response Team Training

f. AP 6807, Collection, Temporary Storage and Retrieval of QA Records RESPONSIBILITIES

1. The Emergency Plan Manager has the overall responsibility to ensure all training is completed in accordance with Emergency Plan Training Program Description.

(SSCA0983, IF1932401)

2. The Emergency Plan Drill/Exercise Coordinator is responsible for coordinating the training of the local medical support personnel, local law enforcement personnel, state and local government personnel, and personnel from the Vernon fire department and other Southwestern Fire Mutual Aid District fire departments within the VY 10 mile EPZ. The'Training Department will, upon request, assist in this effort (Section ll.A, B, C of this procedure) (SSCA 0539 and SSCA 0618).

3. The Director, Public Affairs is responsible for providing subject matter experts to assist in the annual training of the news media and Joint News Center Staff.

4. The Training Department is responsible for completion of training in accordance with the EPTPD under the direction of the Supt. Nuclear Training.

OP 3712 Rev. 17 Page 4 of 6 LPC#1

4. establishing radiation and contamination control areas,

5. biological sampling, and

6. plant access and reporting requirements.

B. State and Local Governments Annually (defined as per calendar year), selected state and local emergency response personnel will be offered training in the following areas as specified in the EPTPD:

1. emergency classification system and EALs,

2. off-site dose projection methodology,

3. plant protective action recommendation criteria and its relationship to plant conditions, and

4. plant access and reporting requirements.

These officials will also be provided instructions concerning the operation of the EOF/RC. These state and local officials will be requested to participate in the biennial emergency exercise (SSCA 0539 and SSCA 0618). C. Local Fire'Department

1. The Vernon fire department shall annually be trained in the following areas:

a. plant layout and fire hazards,

b. basic radiation protection needed for fire fighting,

c. fire protection system orientation, and

d. plant access and reporting requirements.

2. Other Southwestern Fire Mutual Aid District fire departments within the VY 10 mile EPZ are annually'offered training in the above mentioned areas.

OP 3712 Rev. 17 Page 6 of 6 LPC #1

D. Local Law Enforcement Agency

1. Selected local law enforcement personnel are offered annual training in the following areas:

 \3C~C                     a. emergency classification system and EALs,

b. basic radiation protection,

c. plant access and reporting requirements, and I d. plant layout.

FINAL CONDITIONS

1. All training attendance will be documented in accordance with AP 0700.

2. All documentation will be retained in accordance with AP 6807.

OP 3712 Rev. 17 Page 6A of 6 LPC #1}}