ML15062A122

Vermont Yankee, Response to Request for Additional Information Regarding Amendment Request for Permanently Defueled Emergency Plan and Emergency Action Level Scheme - Supplement 2 (TAC MF4279)

ML15062A122
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	02/05/2015
From:	Wamser C J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 15-009, TAC MF4279
Download: ML15062A122 (153)

Text

ItSm.PEntergy Entergy Nuclear Operations, Inc.Vermont Yankee320 Governor Hunt Rd.Vernon, VT802-257-7711 Christopher J. WamserSite Vice President BVY 15-00910 CFR 50.9010 CFR 50.54(q)(4)

February 5, 2015U.S. Nuclear Regulatory Commission Attn: Document Control DeskWashington, DC 20555-0001

REFERENCES:

Vermont Yankee Permanently Defueled Emergency Plan and Emergency Action Level Scheme -Supplement 2 (TAC No. MF4279)Vermont Yankee Nuclear Power StationDocket No. 50-271License No. DPR-281. Letter, Entergy Nuclear Operations, Inc. to USNRC, "VermontYankee Permanently Defueled Emergency Plan and Emergency Action Level Scheme,"

BVY 14-033, dated June 12, 2014(ML14168A302)

(TAC No. MF4279)2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel,"

BVY 15-001, datedJanuary 12, 2015 (ML15013A426)

3. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Request forExemptions from Portions of 10 CFR 50.47 and 10 CFR 50,Appendix E," BVY 14-009, dated March 14, 2014 (ML14080A141)

(TAC No. MF3614)4. Letter, USNRC to Entergy Nuclear Operations, Inc., "VermontYankee Nuclear Power Station -Request for Additional Information Regarding License Amendment Request forPermanently Defueled Emergency Plan Change (TAC No.MF4279),"

NVY 14-075, dated October 20, 2014 (ML14281A233)

Dear Sir or Madam:

By letter dated June 12, 2014 (Reference 1), Entergy Nuclear Operations, Inc. (ENO) requested an amendment to Renewed Facility Operating License Number DPR-28 for Vermont YankeeNuclear Power Station (VY). The proposed amendment would revise the Site Emergency Plan(SEP) and Emergency Action Level (EAL) Scheme to reflect the permanently defueled condition of VY (Reference 2), and implements the emergency planning exemptions, if granted by theNRC, as requested in a letter dated March 14, 2014 (Reference 3).LI!57 BVY 15-009 / Page 2 of 3By letter dated October 20, 2014 (Reference 4), the NRC provided VY with specific questions ina Request for Additional Information (RAI) regarding the proposed changes to the SEP and EALscheme. Attachment 1 of this letter provides the response to the RAI. Attachments 2 and 3 ofthis letter provide the revised Permanently Defueled Emergency Plan and Permanently Defueled EAL Technical Bases with the proposed changes shown in strikethrough andunderline format to reflect the RAI response, respectively.

The conclusions of the no significant hazards consideration and the environmental considerations contained in Reference 1 are not affected by, and remain applicable to, thissupplement.

Attachment 4 of this letter contains new regulatory commitments.

Should you have any questions concerning this letter or require additional information, pleasecontact Mr. Philip Couture at 802-451-3193.

I declare under penalty of perjury that the foregoing is true and correct.Executed on February 5, 2015.Sincerely, CJW/plcAttachments:

1. Response to Request for Additional Information

2. Permanently Defueled Emergency Plan, Revision

03. Permanently Defueled Emergency Action Level Technical Bases,Revision

04. List of Regulatory Commitments cc list next page BVY 15-009 / Page 3 of 3cc: Mr. Daniel H. Dorman, Regional Administrator, Region 1U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100King of Prussia, PA 19406-2713 Mr. James S. Kim, Project ManagerDivision of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O8D15Washington, DC 20555USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC320 Governor Hunt RoadVernon, Vermont 05354Mr. Christopher

Recchia, Commissioner Vermont Department of Public Service112 State Street -Drawer 20Montpelier, Vermont 05620-2601 BVY 15-009Docket 50-271Attachment 1Vermont Yankee Nuclear Power StationResponse to Request for Additional Information BVY 15-009 / Attachment 1/ Page 1 of 24REQUEST FOR ADDITIONAL INFORMATION REGARDING AMENDMENT REQUEST FORPERMANENTLY DEFUELED EMERGENCY PLAN CHANGEENTERGY NUCLEAR OPERATIONS, INC.VERMONT YANKEE NUCLEAR POWER STATIONDOCKET NO. 50-271The following request for additional information (RAI) applies to Attachment 2,"Permanently Defueled Emergency Plan [PDEP],"

of Entergy's submittal dated June 12,2014, (Agencywide Documents Access and Management System (ADAMS) Accession Number No. ML 14168A302).

VY-RAI-01 Please provide a section cross-reference between the Vermont Yankee Nuclear PowerStation (VY) PDEP and NUREG-0654/FEMA-REP-1 to assist the U.S. Nuclear Regulatory Commission (NRC) staff in verifying that applicable evaluation criteria are consistent with proposed exemptions.

ResponseThe following table provides a cross-reference of NUREG-0654/FEMA-REP-1, as well as the 10CFR 50.47(b)

Planning Standards, Appendix E.IV Planning Requirements to the applicable VYPDEP sections.

NUREG-0654,Section II Planning Standard Planning Requirement VY PDEPEvaluation Criteria (10 CFR 50.47)**

(Appendix E.IV)** Section7.08.0A (b)(1) A.1,2, 4,7 8.8.1.1Figure 8.18.08.18.1.18.2B (b)(2) A.1, 2,4,9; C.1 8.8.3Table 8.110.4Appendix D3.78.1.1C (b)(3) A.6, 7 8.2.3Appendix CAppendix D

BVY 15-009 / Attachment 1/ Page 2 of 24NUREG-0654,Section II Planning Standard Planning Requirement VY PDEPEvaluation Criteria (10 CFR 50.47)**

(Appendix E.IV)** Section5.0D (b)(4) B.1,2; C.1,2 5.0____ ___ ___ ___ _ _ ___ ___ ___ ___ ___ ___ ___ Appendix A8.39.09.2E (b)(5) A.6, 7; C.1,2; D.1, 3; E Table 9.111.1Appendix DAppendix E7.0Table 7.1F (b)(6) C.1; D.1, 3; E 9.2Figure 9.112.1.2G (b)(7) A.7; D.2 11.26.16.28.2H (b)(8) E; G 9.212.4Appendix B6.2.51 (b)(9) A.4; B.1; C.2; E 10.0Appendix AJ (b)(10) C.1; E; 1 10.310.2K (b)(11) E 10.310.4Table 8.1L (b)(12) A.6, 7; E 10.210.4M (b)(13) H 8.2.4N (b)(14) E9; F 12.1Table 8.10 (b)(15) F 10.412.0 BVY 15-009 / Attachment 1/ Page 3 of 24NUREG-0654,Section II Planning Standard Planning Requirement VY PDEPEvaluation Criteria (10 CFR 50.47)**

(Appendix E.IV)** SectionTable ofContentsP (b)(16) G 12.0Appendix Eas exemptedThe above table has been added to the Permanently Defueled Emergency Plan (PDEP) asAppendix F. Attachment 2 of this response provides the revised PDEP with the proposedchanges shown in strikethrough and underline format resulting from the addition of the abovetable as Appendix F.VY-RAI-02 Section 1.0, "Introduction" of the PDEP inaccurately states, "The analysis of the potential radiological impact of an accident in a permanently defueled condition Indicates that any[italics added] releases beyond the Site Boundary are below the Environmental Protection Agency's (EPA's) Protective Action Guide (PAG) exposure levels...."

Pleaseclarify that this statement applies to site-specific analyses provided for applicable "design-basis-accidents" not exceeding EPA PAGs at the site boundary, or providetechnical justification that a spent fuel fire, if it were to occur, would not exceed EPAPAGs at the site boundary.

While unlikely, consideration is still given as an exemption for the possibility of a spent fuel fire that offsite government officials may determine warrants implementation of a protective action for the public in the vicinity of the VYfacility.

In addition, Section 1.2, "Scope" inaccurately states, "Because there are no postulated accidents that would result in dose consequences that are large enough to require offsiteemergency planning..."

Please clarify that site-specific analyses are provided forapplicable "design-basis-accidents" not exceeding EPA PAGs at the site boundary andwhether comprehensive (all hazards) emergency management planning may be used byoffsite government officials to implement protective measures for the public as deemedwarranted.

ResponseThe statement concerning the analysis of the potential radiological impact of an "accident" inSection 1.0 is meant to apply to "design basis" accidents only. Similarly, the statement includedin Section 1.2 of the PDEP is intended to apply to postulated "design basis" accidents.

Inaddition, the analyses show that after the spent fuel has decayed for 15.4 months, for beyond-design-basis events related to the spent fuel pool, the analyzed event is either not credible; sufficient time is available to take mitigative actions or, if needed, offsite protective actions usingan all-hazards approach; or the radiological consequences of the event will not exceed the limitsof the EPA PAGs at the exclusion area boundary.

To ensure clarity, the statements in Sections 1.0 and 1.2 of the PDEP have been revised toinclude the phrase "design basis accidents."

Section 1.2 is also revised to state that an all BVY 15-009 / Attachment 1 / Page 4 of 24hazards approach to emergency planning may be used by government officials to implement protective measures for the public as deemed appropriate.

Attachment 2 of this letter provides the revised PDEP with the proposed changes shown instrikethrough and underline format resulting from the revisions to Sections 1.0 and 1.2,described above.VY-RAI-03 VY's current Emergency Plan provides the following information in Section 3.5, "StateGovernment Notification and Response":

Vermont Yankee is responsible for conveying specific accident information, radiological assessment information, and protective action recommendations to the State ofVermont, State of New Hampshire, and Commonwealth of Massachusetts.

VY exemption

request, dated March 14, 2014 (ADAMS Accession No. ML14080A141) requested the following:

E.9.a. Provision for communications with contiguous

[italics added]Stateflocal governments w-ithin than plume oxposuro pathway EPZ. Suchcommunications shall be tested monthly.Sections 3.1, "Overview of Permanently Defueled Emergency Plan" and 3.6, "State andLocal Government Notification and Response" of the PDEP provide no reference tointerfaces with the State of New Hampshire and the Commonwealth of Massachusetts.

Please provide documentation that the State of New Hampshire and the Commonwealth of Massachusetts have agreed that they no longer require notification from the VY in theevent of a declared emergency or revise to address these notifications.

Notification ofother contiguous States also needs to be addressed in Section 3.3(5) and Figure 9.1,"Notification Plan" of the PDEP.ResponseAs states that are contiguous to the VY site, VY will maintain the capability to communicate with,and notify the state emergency management agencies of Vermont and New Hampshire of anemergency declaration.

Additionally, as a noncontiguous state, VY will maintain the capability tocommunicate with, and notify, the Commonwealth of Massachusetts of an emergency declaration because of its proximity to the VY site. As described in Sections 3.6 and 7.1 of thePDEP, VY maintains the capability to communicate with the state emergency management agencies on a 24-hour basis and convey specific accident information using the InFormNotification System (InForm).

As a backup to InForm, the commercial telephone can be used tonotify the State Police of Vermont, New Hampshire and Massachusetts of any emergency.

Sections 7.1, 7.2 and 12.1.2 of the PDEP describe the monthly tests of the communications channels between VY and the states.Sections 3.1, 3.3 (Item #5). 3.6, 5.2, 5.3, 7.1, 7.2, 8.1.1 (Item #1), 8.3, 9.2.1 (Item #3), 11.1,12.1.2, Table 7.1, Figure 9.1 and Appendix D (Letters of Agreement) of the PDEP have beenrevised to address the capability to communicate with and notify New Hampshire andMassachusetts of an emergency declaration.

BVY 15-009 / Attachment 1/ Page 5 of 24Attachment 2 of this letter provides the revised PDEP with the proposed changes shown instrikethrough and underline format resulting from the revisions to the sections described above.VY-RAI-04 Section 3.1 (3rd paragraph) inaccurately states, "Because there are not postulated accidents that would result in off-site dose consequences large enough to require off-site emergency planning..."

The NRC's evaluation of requested exemptions canconsider credit for comprehensive (all hazards) emergency management

planning, ifneeded, for an unlikely spent fuel fire or at the judgment of offsite government officials.

Elimination of the Site Area and General Emergency classifications is based on analysesof applicable design-basis-accidents.

Please revise accordingly to reflect that thecapability exists to implement offsite protective action for the public, if needed, based onthe judgment of offsite government officials using comprehensive (all hazards)emergency management planning.

Additionally, in the unlikely event that there is a catastrophic loss of spent fuel pool(SFP) water inventory, there is a potential for an offsite release of radioactive

material, although they may be a small fraction of the EPA PAG. Please provide furtherdiscussion on how the interfaces with State and local government agencies would beperformed to support an offsite protective action decision, if deemed appropriate byrespective government authority.

ResponseThe statement included in Section 3.1 of the PDEP is intended to apply to postulated "designbasis" accidents.

In addition, the analyses show that after the spent fuel has decayed for 15.4months, for beyond-design-basis events related to the spent fuel pool, the analyzed event iseither not credible; sufficient time is available to take mitigative actions or, if needed, offsiteprotective actions using an all-hazards approach; or the radiological consequences of the eventwill not exceed the limits of the EPA PAGs at the exclusion area boundary.

To ensure clarity, the statement in Section 3.1 of the PDEP has been revised to include thephrase "design basis accidents."

Section 3.1 is also revised to state that an all hazardsapproach to emergency planning may be used by government officials to implement protective measures for the public as deemed appropriate.

Attachment 2 of this letter provides the revised PDEP with the proposed changes shown instrikethrough and underline format resulting from the revisions to Section 3.1, described above.In the unlikely event that there is a catastrophic loss of SFP water inventory VY maintains thecapability to communicate with the state emergency management agencies on a 24-hour basisand convey specific accident information using the InForm Notification System (InForm).

As abackup to InForm, the commercial telephone can be used to notify offsite authorities of anyemergency.

As described in Section 11.1 of the PDEP, notification is made within 60 minutes ofemergency declaration or change in classification.

Due to the slow rate of the postulated eventscenarios and the absence of immediate actions necessary to protect the public health andsafety, the notification time of 60 minutes is appropriate.

In the permanently defueled condition, notification to offsite authorities will continue to include the classification of an emergency, theimpact of a potential release of radioactive materials and sufficient information to support an BVY 15-009 / Attachment 1/ Page 6 of 24offsite protective action decision utilizing an all hazards approach to emergency

planning, ifdeemed appropriate by respective government authorities.

VY-RAI-05 Section 3.8, "Technical Support" of the PDEP states (in part), "augmentation..

.can berequested from various contractors."

Please specify what functions are relied on in thePDEP for contractor support and identify whether contracts or letters of agreement arein-place with these contract organizations for response during an emergency at the VYfacility.

ResponseVY does not rely upon contractor support to implement the PDEP. Thus, there are no contracts or letters of agreement in place with any contract organizations to provide personnel to respondto an event requiring implementation of the VY Emergency Plan. However, if an emergency exceeds the capabilities of the VY emergency organization, additional resources are available within the Entergy fleet. Additional expertise could also be requested through a variety ofcontractors and private sector support organizations.

However, the necessary expertise wouldbe dependent on the specific nature of the emergency and cannot be determined in advance.VY-RAI-06 Please provide an estimate of the time frame required to implement the SFP mitigation strategies outlined in Section 3.9 "Mitigation of Consequences of Beyond Design BasisEvents" using designated on-shift personnel trained and available to perform theseactions.ResponseSee response to RAI-16.VY-RAI-07 NRC evaluation of exemption request in SECY-14-0066 considered that in the unlikelyevent of a beyond design-basis-accident, resulting in a radiological release due to apostulated zirconium fire, early offsite protective measures could be implemented.

Section IV.B.1 to Appendix E of Part 50 still requires that the licensee have the means todetermine the magnitude of, and for continually assessing the impact of, a release ofradioactive materials.

However, no reference to any type of dose assessment is providedin Section 6.0, "Emergency Response Facilities and Equipment" of the PDEP. Pleasedescribe in Section 6.0 of the PDEP on how VY addresses the capabilities to performdose assessment to assess the magnitude of a potential radiological release.ResponseVY maintains and operates on-site monitoring systems needed to provide data that is essential for initiating emergency measures and performing accident assessment.

This includesmonitoring systems for plant processes, radiological conditions, meteorological conditions, andfire hazards.

The essential monitoring systems are incorporated in the EALs referenced in BVY 15-009 / Attachment 1/ Page 7 of 24Appendix A of the PDEP. In addition to installed monitoring

systems, VY has augmented onsiteradiological assessment capability, including portable radiation and contamination monitoring instruments and sampling equipment.

Section 6.1 of the PDEP states that the Control Room is where plant systems and equipment parameters are monitored.

Control Room personnel assess plant conditions, evaluate themagnitude and potential consequences of abnormal conditions, initiate preventative, mitigating and corrective actions and perform notifications.

Sections 6.2 and 6.2.2 of the PDEP have been revised to address the capability to perform doseassessment and to assess the magnitude of a potential radiological release.

Attachment 2 ofthis letter provides the revised PDEP with the proposed changes shown in strikethrough andunderline format resulting from the revisions to Sections 6.2 and 6.2.2.VY-RAI-08 Section 6.2.1, "Process Monitors" of the PDEP states, "Annunciator and computeralarms are provided for a variety of parameters including SFP cooling to indicate SFPlevel, temperature and pump status."

Please clarify what specific parameters reflecting SFP cooling and level status will continue to be available in the Control Room in supportof prompt classification and implementation of mitigation

measures, if needed.ResponseThe SFP pumps are monitored in the Control Room and locally near the equipment.

ControlRoom indication includes direct SFP temperature, fuel pool water temperature out of the heatexchangers (taken downstream of the pumps), pump run lights, pump discharge pressures, service water flow, Station Service Water System (SWS) to the Standby Fuel Pool CoolingSubsystem (SFPCS) heat exchanger discharge pressure and valve position lights. Localindication includes SFP water temperature into the heat exchangers, pump suction anddischarge pressures, and heat exchanger discharge pressure.

There are two narrow range channels of continuous remote indication of spent fuel pool waterlevel in the control room. Each of these channels provides high and low annunciation on theFuel Pool Filter Demineralizer Panel with a system trouble alarm and high and low levelindicator lights in the Control Room. In addition, each of these channels provides input to theplant computer and there is local water level indication on the side of the SFP.There are two channels of continuous remote indication of the spent fuel pool water temperature in the Control Room. There are two channels of SFP water temperature to a common recorderthat provides high temperature annunciation in the Control Room. In addition, there are twochannels of SFP water temperature that provide input to the plant computer.

There are two channels of continuous remote indication of Refueling Floor area radiation in theControl Room. Each of these channels provide high area radiation annunciation in the ControlRoom. A local alarm to notify personnel of high area radiation levels is also in place. In addition, each of these channels provides input to the plant computer.

The manner in which process monitors are used for accident recognition and classification isprovided in EALs referenced in Appendix A of the PDEP.

BVY 15-009 / Attachment 1/ Page 8 of 24VY-RAI-9Clarify whether meteorological parameters, discussed in Section 6.2.1 "Meteorological Capability" of the PDEP, are available in the Control Room and are adequate to supportdose assessment activities.

ResponseMeteorological data is displayed in the Control Room and is adequate to determine theprojected radiological conditions in the event of an accidental release of radioactivity to theenvironment.

Section 6.2.3, "Meteorological Capability" of the PDEP has been revised to indicate that themeteorological data is available in the Control Room and is used to determine the projected radiological conditions in the event of an accidental release of radioactivity to the environment.

VY has no plans to modify or alter data currently provided to the Control Room to support doseassessment activities.

Attachment 2 of this letter provides the revised PDEP with the proposed changes shown instrikethrough and underline format resulting from the revisions to Section 6.2.3.VY-RAI-10 Section 7.3, "Emergency Response Organization

[ERO] Notification System" of the PDEPidentifies the ERO Notification System as the primary means of activating the ERO upondeclaration of an emergency, but provides no description of system capabilities.

Pleasedescribe the capabilities and communications methods used by the ERO Notification Systems to provide for the timely notification and augmentation of ERO personnel.

ResponseOn-site staff are informed of an emergency condition through the use of the plant public addresssystem and/or office telephone and/or wireless devices capable of receiving telephone callsand/or text messages.

In the event that personnel required to staff emergency positions are noton-site at the time an emergency is declared, they may be contacted by commercial telephone including land lines and/or wireless devices capable of receiving telephone calls and textmessages.

Mobilization of the ERO will be conducted under the direction of the Emergency

Director, according to personnel assignments and telephone numbers maintained in varioustelephone directories.

The system is tested as described in Section 12.1.2 of the PDEP.Sections 3.5 and 7.3 of the PDEP have been revised to address the capabilities andcommunications methods used to perform timely notification and augmentation of EROpersonnel.

Attachment 2 of this letter provides the revised PDEP with the proposed changesshown in strikethrough and underline format resulting from the revisions to Sections 3.5 and 7.3.

BVY 15-009 / Attachment 1/ Page 9 of 24VY-RAI-1 1Table 7.1, "Vermont Yankee Emergency Communication Matrix" of the PDEP providesreference to the Southwest Fire Radio. Is this radio tested on a set frequency similar toall of the other communications

devices, as listed in Section 12.1.2, "Communications Tests"? In addition, please clarify why the Southwest Fire Radio is not described inSection 7.0, "Communications",

but is listed on Table 7.1 as a backup means ofcommunication with the State Emergency Operations Centers.ResponseVY maintains a multi-channel radio, referred to as the Mutual Aid Radio, in the Control Roomthat can be utilized to contact the Southwest Mutual Aid; Rescue, Inc.; Brattleboro MemorialHospital and the State EOCs in the event that all other offsite channels of communication fail.The Southwest Fire Radio is not a stand-alone system, but is a single channel on the Mutual AidRadio. The Southwest Fire Radio is tested on a monthly basis.Section 7.8 has been added to the PDEP to address the Mutual Aid Radio. Table 7.1 has beenrevised to indicate that the Mutual Aid Radio serves as a means to communicate with the StateEOCs. Section 12.1.2 of the PDEP has not been revised to address periodic testing of theMutual Aid Radio because the system is a communication channel with the state government ofNew Hampshire and is addressed in Item 1 of Section 12.1.2. Attachment 2 of this letterprovides the revised PDEP with the proposed changes shown in strikethrough and underline format resulting from the addition of Section 7.8 and change to Table 7.1.VY-RAI-12 Please describe the alternate external telephone line arrangement, described in Section7.7, "Commercial Telephone System" of the PDEP, to address telephone equipment blockage in the local area. Is this referring to "microwave" communications listed InSection 7.8, "Emergency Power Supply for Communications"?

ResponseThe alternate external telephone line arrangement consists of two distinct paths from the plantto the telephone company Central Office (CO) with no single failure point that would result in aloss of capability of the system. Additionally, Internet Protocol (IP) telephones are installed toprovide additional diversity when added to the CO and Private Branch Exchange (PBX)telephones.

The alternate telephone line arrangement described in Section 7.7 of the PDEP does not referto the "microwave" communication system. VY currently utilizes the microwave system to notifysystem load dispatchers of emergency conditions at the plant. In a permanently shutdown anddefueled condition, VY will no longer supply electricity to the grid and there is no need to contactsystem load dispatchers to notify them of potential disruptions to the electricity supply. Thiscommunication system is not included in the PDEP and reference to "microwave" in Section 7.9(as revised) of the PDEP has been replaced with "IP" to indicate that the IP telephones areprovided with a redundant power supply.

BVY 15-009 / Attachment 1/ Page 10 of 24Section 7.9 has been revised to replace "microwave" with 113" in accordance with this response.

Attachment 2 of this letter provides the revised PDEP with the proposed changes shown instrikethrough and underline format resulting from the change to Section 7.9.VY-RAI-13 Section 7.8 of the PDEP states, "All emergency communications (including all phones)located within the plant are connected to an emergency or redundant supply. Pleasedescribe the power source and duration for these emergency or redundant supplies.

ResponseAs a backup to the normal offsite power supply, a feed from the Vernon Hydroelectric Stationcan also be used as an additional source of backup power. Power can be provided to thestation, including communication

systems, using the Station Blackout (SBO) Diesel Generator (DG). The SBO DG has a dedicated fuel oil storage tank with a capacity sufficient for operation of the SBO DG at 100% rated load for at least 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.VY-RAI-14 Plan objective

1. 5, listed In Section 3.2, "Objectives" of the PDEP, is to "establish anengineering support organization to aid the plant personnel in limiting the consequences of and recovery from an event." However, this is not addressed in Section 8.2,"Emergency Response Organization",

or specifically Section 8.2.4, "Recovery Organization" of the PDEP. Please describe how this plan objective is under the PDEP.ResponseDuring an emergency, engineering personnel would focus on plant assessment and providetechnical support to the ERO as requested by the Technical Coordinator.

To clarify how planobjective

1. 5 is met, Section 8.2.1 of the PDEP has been revised to address engineering supportto the Technical Coordinator for plant assessment and technical support.Sections 8.2 and 8.2.1 of the PDEP have been revised to address plan objective

1. 5. Attachment 2 of this letter provides the revised PDEP with the proposed changes shown in strikethrough and underline format resulting from the revisions to Sections 8.2 and 8.2.1.With respect to engineering support provided to the Recovery Organization, as described inSection 8.2.4 of the PDEP, planning for the recovery mode of operations involves thedevelopment of an organizational capability that can be adapted to any emergency situation.

The Emergency Director utilizes the normal plant and emergency organizations described inSections 8.1 and 8.2 of the PDEP to staff the recovery organization and provide the radiological and technical expertise required to restore the plant to normal conditions.

VY-RAI-15 Section 8.2.4 of the PDEP provides a general overview of recovery expectations.

Pleasedescribe the position/title, authority and responsibilities of individuals who will fill keypositions in the facility recovery organization, including technical personnel withresponsibilities to develop, evaluate and direct recovery and reentry operations, consistent with NUREG-0654/FEMA-REP-1 Evaluation Criterion M.2.

BVY 15-009 / Attachment 1/ Page 11 of 24ResponseAs described in Section 8.2.4 of the PDEP, planning for the recovery mode of operations involves the development of an organizational capability that can be adapted to any emergency situation.

In a permanently shutdown and defueled condition, the only key position identified inthe recovery organization is the Emergency Director.

Upon termination of an emergency andtransition into the recovery phase, the Emergency Director assembles the recovery organization to address the specific emergency circumstances of the terminated event. The Emergency Director is responsible for:" Ensuring VY is maintained in a safe condition;

• Managing onsite recovery activities during the initial recovery phase;* Keeping corporate support apprised of VY activities and requirements.

The Emergency Director utilizes the normal plant and emergency organizations described inSections 8.1 and 8.2 of the PDEP to staff the recovery organization and provide the radiological and technical expertise required to restore the plant to normal conditions.

VY-RAI-16 In reference to Table 8.1, "Minimum On-Shift and Staffing Requirements" of the PDEP,please response to the following:

a. Has VY performed an on-shift analysis for ERO functions to ensure sufficient personnel will be able to respond to the limiting event, which is a catastrophic loss of SFP water inventory, using the minimum shift staffing as indicated in theTable 8.1, to verify that a SFP mitigation strategy can be promptly implemented using available on-shift personnel?

The response should include:* SFP mitigation strategies as described in Section 3.9 of the PDEP, and* All functional areas of the Table B-1 to address any potential collateral duties.Additionally, provide an update to Table 8.1 reflecting the on-shift personnel required toperform mitigation strategies for a catastrophic loss of SFP inventory.

ResponseAn analysis of the time frame required to implement the SFP mitigation strategies outlined inSection 3.9 of the PDEP has been performed and indicates that the strategies can beimplemented using the on-shift staffing complement (Shift Manager/Emergency

Director, Non-certified Operator (NCO) and Radiation Protection Technician (RPT)) within two hours andwithout impacting the ability to meet all of the major functional areas of Table B-1 in NUREG-0654/FEMA-REP-1.

The two hour time frame is based on Performance Attribute 11 in Section2.3.1, SFP Makeup Capability, of NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline (Reference 2):The system should be capable of being deployed within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> from the time plantpersonnel diagnose that external SFP makeup is required.

BVY 15-009 / Attachment 1/ Page 12 of 24The specific event scenario utilized for this analysis involves a catastrophic loss of SFP level.The analysis of the time to initiate SFP mitigation strategies is based on the expected systemconfigurations at the time the PDEP will be implemented (April 2016) and assumes that anengineering change has been completed to permanently relocate the B.5.b pump closer to itswater source at the cooling tower deep basin and permanently makeup the associated suctionand discharge hoses to reduce the time to implement.

This engineering change is scheduled tobe completed prior to the end of 2015. It is further assumed that the intake structure and the fireprotection system in the Turbine Building (TB) and/or Reactor Building (RB) is damaged whichrequires those structures to be isolated to support pressurizing the fire header successfully.

The Shift Manager retains the responsibility to make emergency classifications, notify the Stateand NRC, and activate the ERO in a timely manner, and is not distracted from emergency eventoversight, including ERO leadership responsibilities.

The Shift Manager is capable of assessing, classifying and declaring an emergency condition within 30 minutes, notifying the states ofVermont, New Hampshire and Massachusetts within 60 minutes of emergency declaration andmaking notifications to the ERO of the need to augment.It is reasonable to expect that mitigating actions required to address a catastrophic loss of SFPcan be performed using an on-shift RPT because credit is taken for existing area radiation monitors and associated alarms and NCOs are trained to self-monitor using radiation dose ratemeters. In extreme conditions, the Radiation Protection Director would be responding within therequired ERO two hour response time to assist in final implementation of the mitigating actions.The demonstration was performed on November 8, 2014. Calibrated stop watches were utilizedto time the actions.

Operators were stationed in the Auxiliary Operator break room. This locationyields the longest time to reach the B.5.b storage shed to assemble/obtain the requiredequipment.

The external SFP strategy was used (PP 7019, Appendix G, Attachments 1, 2, 2Aand 16) for the demonstration because it is considered the longest to implement.

The following results (times are identified in minutes) were obtained:

T=0: Start. The NCO and RPT start from the Administration Building.

If they were to start fromthe Plant Support Building (PSB), then the time to obtain the required hoses, fittings and toolswould be reduced accordingly.

It is assumed the NCO and RPT would discuss the requiredactions to coordinate their response.

T=1 2: Time for the NCO/RPT to reach the B.5.b shed, obtain the required gear and return toSecurity Gatehouse

2. It is assumed that the Shift Manager would contact the Lead SecurityShift Supervisor and request their support getting the gear through the gate house to reduce thedelay. Security would work out the quickest means to support to minimize the delay.Upon entering the protected area, the NCO and RPT would separate to perform the following tasks concurrently:

RPT:T=24: Time after entering the Protected Area (PA) to make the required connections from thefire hydrant on the west side of the Containment Access Building (FH-2) to the RB penetration (SB-1 00-5 or 6). It is assumed that this task takes 12 minutes to account for handling of thehoses, tools and fittings by a person who will be new to handling fire equipment at the start ofSAFSTOR.

The time to accomplish is based on operator experience for operating the valves.

BVY 15-009 / Attachment 1/ Page 13 ot 24T=39: Time to rotate the inside RB penetration (SB-100-5(6))

out of the way (assume 15minutes per flange) (includes travel from outside to inside RB).T=59: Time to isolate the intake structure and TB/RB from the outer Fire Protection loop. Aconservative estimate of 5 minutes per valve is utilized.

For this scenario, it is assumed that four(4) valves would need to be isolated.

T=74: Time to rotate the outside RB penetration and make the final connection of the hoses. Itis expected that the NCO and RPT would coordinate their actions to aid in making theconnections.

Straps are available inside and out to hold the hose to the penetration.

T=84: Time after making the final connections of the inside and outside fire hoses, the valves onFH-2 would start being throttled open to commence making up water to the fuel pool.NCO:T=42: Time to complete routing the hose from the RB 345 foot elevation to the 252 footelevation including attaching the SFP diffuser to the fuel pool railing and installing straps to holdthe fire hoses in place. It is assumed to take 30 minutes to be conservative based on the actualrecorded time of 26 minutes 58 seconds for the single operator to complete.

T=57: Time for the NCO to walk from the RB to the pump at the West Cooling Tower. Timingwas performed utilizing the several paths possible to the location the B.5.b pump will be located.The time to walk through the West Security Owner Controlled Area access building and aroundthe West Cooling Tower was 10 minutes 44 seconds.

To be conservative, it is assumed to take15 minutes to account for uncertainties based on weather/plant conditions.

T=69: Time for the NCO to start the pump once any leaks in the fire header have been isolated.

Per the guideline, the pump would not be started until the header is isolated so that will coincidewith the RPT isolating the header at T=59 minutes.SummarySuccessful implementation of the mitigating strategy was achieved within 84 minutes utilizing only the on-shift staffing (Shift Manager, NCO and RPT) required by the proposed PDEPcurrently undergoing NRC review. Specifically, the PDEP minimum on-shift staff is tasked withimplementation of the mitigating strategy.

The Shift Manager retains the responsibility toimplement the emergency plan. The NCO and RPT are capable of performing the actionsnecessary to implement the mitigation strategy without the need to mobilize off-site resources orthe utilization of other on-shift personnel.

Table 8.1 of the PDEP has been revised to reflect the positions performing the mitigating strategy.

Section 3.9 of the PDEP has been revised to correct the reference to the mitigation strategies order, EA-02-026.

BVY 15-009 / Attachment 1/ Page 14 of 24VY-RAI-17 Sections 5.0, "Emergency Classification System" and 9.1, "Emergency Condition Recognition and Classification" of the PDEP state (in part), "VY maintains the capability to assess, classify, and declare an emergency condition in accordance with siteprocedures

....." Please identify a specific time frame, and supporting technical justification, where VY will maintain the capability required for the prompt classification of an emergency condition, based on the permanent shutdown and defueled condition ofthe facility, or provide a copy of the site procedure that provides this information?

ResponseThe emergency classification levels that will be applicable at VY, in order of increasing

severity, are a Notification of Unusual Event and Alert. Each of these emergency classes requiresnotification to offsite agencies, as designated in the PDEP, as well as to the NRC. Theclassification of emergencies up to an Alert is consistent with the regulations for an ISFSI in 10CFR 72.32(a)(3) and the exemptions proposed in Reference 1.VY will maintain the capability to assess, classify, and' declare an emergency condition within 30minutes after the availability of indications to plant operators that an emergency action levelthreshold has been reached.

In the permanently defueled condition, the rapidly developing scenarios associated with events initiated during reactor power operation are no longer credible.

The consequences resulting from the only remaining events (e.g., fuel handling accident) develop over a significantly longer period. The 30 minute classification time frame is consistent with that approved for Kewaunee Power Station (Reference 3). Section 9.1 of the PDEP hasbeen revised to include the 30 minute time frame.VY-RAI-18 Section 10.1.1, "Initial Radiological Dose Projection" of the PDEP provides that VY hasdeveloped a method to quickly determine the projected radiological conditions at the siteboundary.

Please provide further information on how this dose projection is performed using on-shift staffing identified in Table 8.1, and include a copy of the applicable implementing procedure.

ResponseDuring the initial stages of an emergency, the Shift Manager, or an individual designated by theShift Manager, is responsible to perform the initial evaluation of radiological conditions.

Thisactivity is identified as a responsibility of the Shift Manager in Section 8.1.1 of the PDEP.Additionally, the on-shift staffing includes a Radiation Protection Technician.

With VY permanently

shutdown, the only design basis accident scenario will be a fuel handlingaccident (FHA) in the SFP and the predominant isotope that will be released from a FHA is Kr-85. It is no longer necessary to maintain a sophisticated dose assessment capability withassociated

hardware, software and training appropriate for an operating nuclear power plantand a simplified manual method can provide an effective replacement dose assessment capability.

Conceptually, the method used to predict a Site Boundary dose from a FHA in theSFP area is to multiply a radiation monitor reading by a dose conversion factor based on windspeed and stability class. VY currently maintains a manual method to evaluate off-siteradiological conditions.

Specific procedures supporting the PDEP, including the procedure BVY 15-009 / Attachment 1/ Page 15 of 24associated with Initial Radiological Dose Projection, have not yet been developed.

Theprocedure will be developed considering that after permanent shutdown and removal of fuelfrom the reactor, the only viable accident scenario is a FHA in the SFP and will be provided tothe NRC in a supplemental response by June 30, 2015.VY-RAI-19 Section 10.3.1, "Site Personnel Accountability" of the PDEP provides that the goal of thepersonnel accountability process is to account for personnel at an Alert declaration.

Please clarify in the PDEP how the following NUREG-0654/FEMA-REP-1 evaluation criterion is addressed or provide justification for why criteria are no longer considered applicable:

[J.5] Each licensee shall provide for a capability to account for allindividuals onsite at the time of the emergency and ascertain the names ofmissing individuals within 60 minutes of the start of an emergency andaccount for all onsite individuals continuously thereafter, In addition, describe the communication means intended to notify site personnel ofaccountability, since Section 7.5 of the PDEP only identifies that the Plant IntercomSystem is located in "many areas" throughout the plant.ResponseUpon declaration of an emergency, Control Room personnel announce the emergency classification over the plant page system. As described in Section 7.5 of the PDEP, duringemergency situations, the system is used as the primary means for notifying plant personnel ofthe emergency and calling for any missing or unaccounted for personnel that may be in theplant. In a permanently shutdown and defueled condition, the inability to communicate with plantpersonnel because of noise is no longer a significant issue. The use of the plant page system,supplemented by Security sweeps as described below, is appropriate to notify plant personnel of an emergency declaration.

In accordance with site procedures, following announcement of an emergency classification, plant personnel are responsible for reporting to designated areas and aiding Security in theaccountability process.

The emergency classification announcement prompts Security to print areport detailing the locations of on-site personnel.

If personnel are not accounted for, the ControlRoom is notified and announcements are made using the plant page system. If personnel arestill unaccounted for following announcements, Security will initiate sweeps to locate the missingindividuals.

Section 10.3.1 has been revised to indicate that the goal of the personnel accountability processis to account for personnel within 60 minutes of an Alert declaration.

Section 10.3.1 has alsobeen revised to indicate that plant personnel are responsible for reporting to designated areasfollowing announcement of an emergency classification; the Control Room will initiateannouncements using the plant page system if personnel are unaccounted for; and if personnel are still unaccounted for following Control Room announcements, then Security will initiatesweeps to locate the missing individuals.

Attachment 2 of this letter provides the revised PDEPwith the proposed changes shown in strikethrough and underline format resulting from theaddition of Section 10.3.1.

BVY 15-009 / Attachment 1/ Page 16 of 24VY-RAI-20 Section 10.3.3, "Decontamination Capability" of the PDEP is limited to a generaldiscussion of personnel monitoring and decontamination.

Please describe how, orwhere, NUREG-0654/FEMA-REP-1 Evaluation Criteria K.5.a and K.6 are addressed fordecontamination and on-site contamination control.ResponseEvaluation Criteria K.5.a requires the emergency plan to address action levels for determining the need for decontamination.

During emergency conditions, VY maintains normal plantdecontamination and contamination control measures as closely as possible.

However, thesemeasures may be modified by the Emergency Director should conditions warrant.Evaluation Criteria K.6 requires licensees to provide contamination control measures withrespect to area access control, drinking water and food supplies and the return of areas anditems to normal use. VY isolates and restricts the use of contaminated areas; monitorspersonnel leaving contaminated areas; controls access to potentially contaminated drinkingwater and food supplies; makes arrangements for transport of non-contaminated off-sitesupplies if the potential exists for contamination of on-site food or drinking water supplies thatrenders these supplies non-consumable; and restricts areas and contaminated items fromreturning to normal use until conduct of appropriate surveys and verification that thecontamination levels are acceptable.

Section 10.3.3 of the PDEP has been revised to reflect standard station protocol described above. Additionally, the title of Section 10.3.3 has been revised to Contamination Control andDecontamination Capability to reflect the changes.

Attachment 2 of this letter provides therevised PDEP with the proposed changes shown in strikethrough and underline format resulting from the revisions to Section 10.3.3.VY-RAI-21 Section 10.4.1, "Medical Treatment" of the PDEP provides that initial on-site medicaltreatment is provided by on-site personnel.

Please provide further information on whothese personnel are (e.g., on-shift, duty performed as a collateral function),

and whatlevel and frequency of training are they giving.ResponseUpon implementation of the PDEP, rescue and first aid treatment will be provided by twoqualified, on-shift personnel (Control Room staff or other qualified personnel).

The membersassigned rescue/first aid treatment duties will attend to normal plant duties until notified of anincident requiring a first-aid response.

Individual responsibilities then immediately change to thehigher priority role. The health and safety of personnel take precedence over other normallyassigned responsibilities.

Rescue/first aid duties of on-shift staff do not create a conflict betweentheir normal and emergency duties.NUREG-0654/FEMA-REP-1, Revision 1, Evaluation Criterion 11.0.3 establishes guidance foruse of Red Cross Multi-Media Training for individuals assigned to licensee first aid teams. Thisguidance was published in 1980. In the interim, Red Cross Multi-Media Training has beensuperseded by other courses.

Because the suggested Red Cross Multi-Media course no longer BVY 15-009 / Attachment 1/ Page 17 of 24exists, VY is unable to provide a direct correlation between its own training program and theRed Cross Multi-Media training course. However, VY notes that the Red Cross Multi-Media training program was intended to train a layperson to recognize simple first aid situations andprovide minimal first aid care until the arrival of a professional medical response team. The RedCross Multi-Media training course was an 8 to 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> program.

VY personnel who will bequalified to provide initial on-site medical treatment will, at a minimum, complete an 8-hourprogram based on the American Heart Association First Aid/CPR/AED course to meet theeducational and examination requirements of its Basic First Aid and CPRIAED courses.

Thecourse provides critical skills needed to respond to and manage a first aid, choking or suddencardiac arrest emergency in the first few minutes until emergency medical services (EMS)arrives.

Students learn skills such as how to treat bleeding,

sprains, broken bones, shock andother first aid emergencies.

This course also teaches adult CPR and AED use. Therefore, thecontent of the training course meets or exceeds the requirements of the superseded Red CrossMulti-Media training course identified in NUREG-0654-FEMA-REP-1.

Recertification of the members assigned rescue/first aid treatment duties will be conducted asrequired by the level of certification held by the individual.

Section 12.1.5 of the PDEP, specifies the frequency of medical drills that evaluate the training of the medical response provided by on-site personnel.

VY-RAI-22 Section 10.5, "Protective Actions for Onsite Personnel" of the PDEP states, "A range ofprotective actions to protect onsite personnel and how they will ensure continued abilityto perform the functions of the emergency plan." Please describe this intended range ofprotective actions to protect onsite personnel and how they will ensure continued abilityto perform the functions of the emergency plan, or provide reference to and a copy ofapplicable implementing procedure.

ResponseProtective actions for onsite personnel are addressed in Sections 10.2 through 10.4 of thePDEP consistent with the applicable guidance providing the Planning Standard J of NUREG-0654-FEMA-REP-1.

Section 10.2 of the PDEP describes measures to be taken to controlradiation exposure for the VY ERO and augmented personnel.

These measures includeemergency kits with self-reading dosimeters and maintenance of dose records.

Section 10.3.4of the PDEP addresses the use of plant supplied radiation protection equipment and gear tosupport the emergency response effort, including respiratory protection and protective clothingassigned to ERO members.Additionally, Section 10.3.1 of the PDEP describes the means and timely notification of plantpersonnel following an emergency declaration and provisions for completing accountability within 60 minutes of an Alert declaration.

Section 10.3.2 of the PDEP describes the provisions for evacuating all visitors and unnecessary contractors upon an Alert declaration andradiological monitoring of personnel evacuated from the site.Section 10.5 of the PDEP has been revised to reflect that a range of protective actions for onsitepersonnel are addressed in Sections 10.2 through 10.4 of the PDEP. Attachment 2 of this letterprovides the revised PDEP with the proposed changes shown in strikethrough and underline format resulting from the revisions to Section 10.5.

BVY 15-009 / Attachment 1/ Page 18 of 24VY-RAI-23 Section 11.1, "Emergency Notification" of the PDEP states, "The format and contents ofthe initial message between the plant and State authorities are specified in notification procedures and have been established with the review and agreement of responsible state authorities."

Please provide documentation that this commitment has beenreviewed with responsible state authorities to address the permanent shut down anddefueled condition of facility.

In addition, has the frequency and format/content offollow-up reports been discussed with responsible state authorities based on therequested change in notification time requirements and the permanently shut down anddefueled condition of the facility?

ResponseAs described in Section 7.1 of the PDEP, VY maintains the capability to communicate with thestate emergency management agencies on a 24-hour basis and to convey specific accidentinformation using the InForm Notification System (InForm).

This system is currently in use atVY. Within InForm, an Emergency Message is composed using a structured emergency datainput that provides a format for the user. The data entered is used by InForm to compose theEmergency Message that is sent electronically to offsite authorities.

Preparation of theEmergency Message using the emergency data input will be evaluated following permanent cessation of operations to determine the necessary data inputs to the Emergency Message withconsideration given to VY's permanently defueled condition.

Specific procedures supporting the PDEP, including the procedure associated with initialnotification and follow-up messages to offsite authorities, have not yet been developed.

However, in accordance with 10 CFR 50.47(b)(5),

VY will develop a procedure establishing theformat and content of initial and follow-up messages and the frequency at which the messagesare provided.

The procedure will address the permanently shutdown and defueled condition andthe format and content of the initial and follow-up messages will be mutually agreed upon withresponsible offsite authorities in accordance with the guidance contained in Planning StandardE, Evaluation Criterion 1 of NUREG-0654/FEMA-REP-1, "Criteria for Preparation andEvaluation of Radiological Emergency Response Plans and Preparedness in Support of NuclearPower Plants" (November 1980).With respect to the frequency of follow-up

messages, Section 9.2.2 of the current revision of theVY Emergency Plan, at an Alert, follow-up information is provided to offsite emergency organizations as needed. Additionally, Section 11.2 of the current revision of the VY Emergency Plan states that follow-up reports are provided on an as-needed basis until such time that theemergency condition has been terminated.

State agreement with the as-needed basis of follow-up messages is acceptable as evidenced by the existing Letters of Agreement.

VY has notproposed any changes to the frequency of follow-up reports in Sections 9.2.2 and 11.1 of theproposed PDEP.VY will develop the format and content of the initial and follow-up messages and provide theproposed messages to responsible offsite authorities for review prior to May 31, 2015. Asindicated in the response to RAI-32, Letters of Agreement in support of the PDEP will bedeveloped with consideration given to NRC-approved Regulatory Exemptions and thePermanently Defueled Emergency Action Levels (PD EALs) still under NRC review. VY willprovide the Letters of Agreement to the NRC in a supplemental response to this RAI by June BVY 15-009 / Attachment 1/ Page 19 of 2430, 2015. The Letters of Agreement will address the format and content of initial and follow-up messages and the frequency of follow-up messages.

VY-RAI-24 Section 11.2, "Public Information" of the PDEP refers to the dissemination of information during an event at VY. Please explain how the following NUREG-0654/FEMA-REP-1 evaluation criteria are addressed under the Entergy Corporate Communication protocols:

• [G.4.a] Designated spokesperson, which should have access to all necessary information;

• [G.4.b] Arrangements for the timely exchange of information among designated company/agency spokespersons; and* [G.4.c] Coordinated arrangements for dealing with rumors.Additionally, please clarify how Entergy corporate communications protocols willcontinue to support the capability of Federal, State and local emergency responseorganizations to disseminate appropriate information regarding an emergency at VY.ResponseBecause the VY Joint Information Center (JIC) is planned to be vacated following implementation of the PDEP and the current dedicated JIC company spokesperson position isplanned for elimination, Entergy Nuclear Operations, Inc. (ENO) has not determined at this timeexactly which, if any, revisions are needed to the current Entergy Corporate Communications protocols to ensure that the NUREG-0654/FEMA-REP-1 evaluation criteria will be addressed.

For the same reasons, it has yet to be determined if the protocols will require revision to ensurethat they will support the capability of Federal, State and local emergency responseorganizations to disseminate appropriate information regarding an emergency at VY.A comprehensive response to this RAI, including any identified revisions to the PDEP, will beprovided in a supplemental response by June 30, 2015.VY-RAI-25 Please clarify why the following offsite support organizations listed in Appendix D,"Letters of Agreement" of the PDEP are not provided the opportunity to participate inbiennial exercises or periodic drills, as described in Section 12.1.1, "Radiation Emergency Exercises and Drills" of the PDEP:* Vernon Fire Department, and* Town of Vernon.ResponseThe Vernon Fire Department and the Town of Vernon are currently, and will continue to be,provided the opportunity to participate in biennial exercises and periodic drills.Section 12.1.1 of the PDEP has been revised to include the Vernon Fire Department and theTown of Vernon. Attachment 2 of this letter provides the revised PDEP with the proposed BVY 15-009 / Attachment 1/ Page 20 of 24changes shown in strikethrough and underline format resulting from the revisions to Section12.1.1.VY-RAI-26 Please clarify why Section 12.1.4, "Fire Drills" of the PDEP only lists the Vernon FireDepartment for demonstration of coordination with the plant's fire brigade, but does notaddress participation by the Brattleboro Fire Department, which is listed as an off-sitesupport organization in Appendix D, "Letters of Agreement" of the PDEP.ResponseThe Brattleboro Fire Department is currently, and will continue to be, provided the opportunity toparticipate in annual fire drills.Section 12.1.4 of the PDEP has been revised to include the Brattleboro Fire Department.

Attachment 2 of this letter provides the revised PDEP with the proposed changes shown instrikethrough and underline format resulting from the revisions to Section 12.1.4.VY-RAI-27 Please clarify whether the Medical Drills, as discussed in Section 12.1.5 of the PDEP, willinvolve the actual participation of the Brattleboro Memorial Hospital and Rescue Inc.Ambulance

Service, as off-site support organizations listed in Appendix D of the PDEP.ResponseAnnual medical drills with a simulated contaminated injured individual currently, and willcontinue to, involve the actual participation of the Brattleboro Memorial Hospital and RescueInc. Ambulance Service as off-site support organizations.

Section 12.1.5 of the PDEP has beenrevised to incorporate this clarification.

Attachment 2 of this letter provides the revised PDEPwith the proposed changes shown in strikethrough and underline format resulting from therevisions to Section 12.1.5.VY-RAI-28 Under Section 12.2, "Training" of the PDEP, please describe site-specific emergency response training for those offsite emergency organizations who may be called upon toprovide assistance in the event of an emergency, as outlined in NUREG-0654/FEMA-REP-1 Evaluation Criteria O.1.a.ResponseVY offers training annually to offsite response organizations which may be requested to provideassistance in the event of an emergency at VY (e.g., law enforcement, fire-fighting, rescue,medical services, transport of injured, etc.). The training is structured to meet the needs of thespecific organization being trained to align with the nature of the support to be provided by theorganization.

Topics such as event notification, site access procedures, basic radiation BVY 15-009 / Attachment 1/ Page 21 of 24protection and interface activities between the offsite organization and VY are included in thetraining.

Section 12.2 of the PDEP has been revised to include a discussion of the training offered tooffsite organizations.

Attachment 2 of this letter provides the revised PDEP with the proposedchanges shown in strikethrough and underline format resulting from the revisions to Section12.2.VY-RAI-29 Please provide copies of Emergency Plan Training Procedure AP 3712 and theEmergency Plan Training Program Description, as referenced In Section 12.2 of thePDEP, which describes specific details of the training given on an annual basis.ResponseThe current versions of Emergency Plan Training Procedure AP 3712 and the Emergency PlanTraining Program Description support the current VY Emergency Plan and are not fullyapplicable to the PDEP. Revisions to AP 3712 and the Emergency Plan Training ProgramDescription will be developed to support the PDEP and will be provided to the NRC in asupplemental response by June 30, 2015.VY-RAI-30 Under Section 12.5, "Responsibility for Planning Effort" of the PDEP, describe howtraining is provided to individuals responsible for the planning effort, per NUREG-0654/FEMA-REP-1 Evaluation Criteria P.1.ResponseThe Emergency Planning Manager is responsible for maintaining an adequate knowledge ofregulations, planning techniques and the latest applications of emergency equipment andsupplies.

Training for this position

includes, but is not limited to:1. Training courses specific or related to emergency preparedness;

2. Observation of, or participation in, drills and/or exercises at other decommissioned nuclear power plants;3. Participation in industry review and evaluation programs;

4. Participation in regional or national emergency preparedness

seminars, conferences, committees, workshops or forums.Section 12.5 of the PDEP has been revised to include a discussion of the training provided toindividuals responsible for the planning effort. Attachment 2 of this letter provides the revisedPDEP with the proposed changes shown in strikethrough and underline format resulting fromthe revisions to Section 12.5.

BVY 15-009 / Attachment 1/ Page 22 of 24VY-RAI-31 Appendix B, "Emergency Equipment Inventory" lists specific radiological monitoring instruments/equipment, but merely indicates that it be provided by other non-affected Entergy nuclear sites, as needed. Please list what procedures are in place to coordinate obtaining/transporting or remotely utilizing this equipment, and describe an estimated time frame when equipment would become available for use in support of an emergency at the VY facility.

ResponseVY does not maintain specific Emergency Plan Implementing Procedures for obtaining ortransporting equipment from other non-affected Entergy nuclear sites. However, VY doesmaintain contact information with other Entergy facilities.

In the event that equipment isrequired, it can be obtained through established lines of communications within the Entergyfleet. In the event that equipment is obtained from other non-affected Entergy nuclear sites, thesupplying facility will provide VY with the applicable operating procedures for the specificequipment being provided.

Based on the proximity of other Entergy nuclear sites in the region(Pilgrim, Indian Point, Fitzpatrick),

it is estimated that any equipment that is requested could beprovided within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the request being made.VY-RAI-32 Appendix D of the PDEP discusses various active and in-force letters of agreement withvarious offsite support organizations.

Please provide copies for staff review of letters ofagreement applicable to this proposed PDEP, which will be in-force upon VY'spermanent cessation of operations.

ResponseVY's existing Letters of Agreement with the offsite support organizations support the current VYEmergency Plan and are not fully applicable to the PDEP, which will be implemented approximately 15.4 months after permanent cessation of operations.

Development of the Lettersof Agreement in support of the PDEP will be developed with consideration given to NRC-approved Regulatory Exemptions and the Permanently Defueled Emergency Action Levels (PDEALs) still under NRC review.VY will develop the Letters of Agreement and provide them to the NRC in a supplemental response by June 30, 2015.The following RAIs are for Attachment 3, "Permanently Defueled Emergency Action LevelTechnical Bases," of Entergy's June 12, 2014 submittal:

VY-RAI-33 Please annotate in Section 1, "Purpose" whether this document will be maintained inaccordance with 10 CFR 50.54(q).

ResponseThe document will be maintained in accordance with 10 CFR 50.54(q).

The first paragraph of BVY 15-009 / Attachment 1 / Page 23 of 24Section 1.0 of the Permanently Defueled Emergency Action Level Technical Bases concludes with the following statement:

"All recommendations for changes to this document or associated implementing procedures are reviewed in accordance with 10 CFR 50.54(q)."

VY-RAI-34

[Page 32 of 51] EAL PD, "[Permanently Defueled" AU-2.2, basis discusses that if the arearadiation monitors cannot detect or display values at or above 25 mR/hr over normal,then survey instruments can be used.* Verify whether the ranges of ARM-14 "Rx Bldg West RefueG" and ARM-15 "SpentFuel Pool" are capable of detecting and displaying radiation levels at or above 25mR/hr over normal.* Which area radiation monitors are known to not be capable of detecting ordisplaying values at or above 25 mR/hr over normal?* What would be the timeliness of performing local radiation surveys?ResponseThe area radiation monitors (ARMs) that would indicate that an EAL threshold has beenexceeded are ARM-14 (Rx Bldg West Refuel) and ARM-15 (Spent Fuel Pool). Both ARM-14and ARM-1 5 indicate in the Control Room and are capable of detecting and displaying radiation levels at or above 25 mR/hr over normal background levels.Because the ARMs that would indicate whether an EAL threshold has been exceeded arecapable of detecting and displaying radiation levels at or above 25 mR/hr over normalbackground levels, the statements included in the Vermont Yankee Basis for EALs PD-AU2.2and PD-AU2.1 related to plant area radiation monitors that are unable to detect or display areading that is 25 mR/hr over normal levels have been removed consistent with this response.

However, if performance of local radiation surveys is required, this action would be performed ina timely manner, primarily because VY maintains a Radiation Protection (RP) Technician on-shift as indicated in Section 8.1.3 and Table 8.1 of the PDEP. Furthermore, additional stationpersonnel, including additional RP Technicians, would be onsite to support fuel movement.

Attachment 2 of this response provides the revised Permanently Defueled Emergency ActionLevel Technical Bases with the proposed changes shown in strikethrough and underline formatresulting from the revisions to PD-AU2.1 and PD-AU2.2.

VY-RAI-35

[Page 51 of 51] EAL E, "Independent Spent Fuel Storage Installation" HU-1.1 basisprovides the actual EAL values. Please explain why these values are not provided in theEAL itself to allow for timely event classification.

ResponseWhen making an emergency classification, the VY Emergency Director is trained to consider allinformation having a bearing on the proper assessment of an Initiating Condition prior to makingthe declaration.

This information includes the EAL and the associated basis information.

In thecase of the subject EAL, this review would also include the ISFSI Technical Specifications.

BVY 15-009 / Attachment 1/ Page 24 of 24Providing the ISFSI Technical Specification allowable levels in the Basis, rather than the EALwould not impact the timeliness of an event classification.

However, to facilitate timely eventclassification, the threshold values will be placed in the EAL.Attachment 3 of this response provides the revised Permanently Defueled Emergency ActionLevel Technical Bases with the proposed changes shown in strikethrough and underline formatresulting from the revision to E- HU1.1.REFERENCES

1. Letter, Entergy Nuclear Operations, Inc., to NRC, "Request for Exemptions from Portionsof 10 CFR 50.47 and 10 CFR 50, Appendix E," BVY 14-009, dated March 14, 2014(ML14080A141)

2. NEI 06-12, B.5.b Phase 2&3 Submittal

Guidance, Revision 3, September 2009(ML092890400)

3. Letter, NRC to Dominion Energy Kewaunee, Inc., "Kewaunee Power Station -Issuanceof Amendment for Changes to the Emergency Plan and Emergency Action Levels (TACNo. MF341 1)," dated October 31, 2014 (ML14279A482)

BVY 15-009Docket 50-271Attachment 2Vermont Yankee Nuclear Power StationPermanently Defueled Emergency PlanRevision 0

PERMANENTLY DEFUELED EMERGENCY PLANENTERGY VERMONT YANKEEVERNON, VERMONTREVISION 0I PREPARER:

(ler)REVIEWED:

APPROVED:

APPROVED:

Emergency Planning Manager (Print/Sign)

On-Site Safety Review Committee (Print/Sign)

General Manager (Print/Sign)

Site Vice President (Print/Sign)

DateDateDateDateEffective Date ENTERGY VERMONT YANKEE PERMANENTLY DEFUELED EMERGENCY PLANREVISION SUMMARYDATETBDREVISIONDESCRIPTION 0 The analyses of the potential radiological impact of accidents while theplant is in a permanently defueled condition indicate that no designbasis accident or reasonably conceivable beyond design basisaccident will be expected to result in radioactive releases that exceedEnvironmental Protection Agency (EPA) Protective Action Guides(PAGs) beyond the site boundary.

The slow progression rate ofpostulated event scenarios indicate sufficient time is available toinitiate appropriate mitigating actions to protect the health and safetyof the public. Therefore, the Permanently Defueled Emergency Planadequately addresses the risk associated with VY's permanently defueled condition and continues to provide adequate protection forplant personnel and the public. Exemptions from the applicable portions of 10 CFR 50.47(b),

Appendix E to 10 CFR Part 50 and 10CFR 50.47(c)(2) were previously approved by the Nuclear Regulatory Commission (NRC).Permanently DefueledEmergency PlanRevision 0Revision SummaryPage-i-ef-4Paqe i of viiIEntergy Vermont Yankee TABLE OF CONTENTS

1.0 INTRODUCTION

...................................................................................................

11.1. Purpose .......................................................................................................

11.2. Scope ..........................................................................................................

12.0 DEFINITIONS

.....................................................................................................

33.0 SUM MARY OF EM ERGENCY PLAN ...................................................................

53.1. Overview of Permanently Defueled Emergency Plan ..................................

53.2. Objectives

..................................................................................................

53.3. Actions in an Emergency

...........................................................................

63.4. Emergency Response Facilities

.................................................................

73.5. Mobilization

................................................................................................

73.6. State and Local Government Notification and Response

............................

73.7. Federal Government Notification and Response

.........................................

83.8. Technical Support .......................................................................................

83.9. Mitigation of Consequences of Beyond Design Basis Events ....................

84.0 SITE DESCRIPTION

.............................................................................................

94.1. Facility Description

....................................................................................

94.2. Area Characteristics and Land Use .............................................................

95.0 EMERGENCY CLASSIFICATION SYSTEM .......................................................

115.1. Unusual Event ............................................................................................

115.2. Alert ..........................................................................................................

115.3. Emergency Classification System Review by State Authorities

................

126.0 EMERGENCY RESPONSE FACILITIES AND EQUIPMENT

...............................

136.1. Control Room ............................................................................................

136.2. Assessment Capability

..............................................................................

136.2.1. Process Monitors

......................................................................

146.2.2. Radiological Monitors

...............................................................

146.2.3. Meteorological Capability

..........................................................

146.2.4. Fire Detection and Suppression Equipment

..............................

156.2.5. Assessment Facilities and Equipment

.......................................

157.0 COM MUNICATIONS

...........................................................................................

167.1. InForm Notification System ......................................................................

167.2. Nuclear Alert System ................................................................................

167.3. ERO Notification System ...........................................................................

167.4. Mobile UHF Radio System .........................................................................

177.5. Plant Intercom System .............................................................................

177.6. NRC Telephone System ...........................................................................

17Permanently DefueledEmergency PlanRevision 0Table of ContentsPa-e-ii-Gf-v4Pqae_ii ofViiEntergy Vermont Yankee 7.7. Commercial Telephone System ...............................................................

177.8. Mutual Aid Radio .......................................................................................

187.9. Emergency Power Supply for Communications

.......................................

188.0 ORGANIZATION

................................................................................................

208.1. Normal Plant Organization

........................................................................

208.1.1. Shift Manager/Emergency Director

..........................................

208.1.2. Non-Certified Operator

.............................................................

218.1.3. Radiation Protection Technician

...............................................

218.1.4. Security

....................................................................................

218.2. Emergency Response Organization

........................................................

228.2.1. Technical Coordinator

...............................................................

228.2.2. Radiation Protection Coordinator

..............................................

238.2.3. Extensions of the Vermont Yankee Emergency ResponseOrganization

..............................................................................

238.2.4. Recovery Organization

.............................................................

248.3. Coordination with State Government Authorities

.......................................

259.0 EMERGENCY RESPONSE

................................................................................

289.1. Emergency Condition Recognition and Classification

...............................

289.2. Activation of the Emergency Response Organization

...............................

289.2.1. Unusual Event Response

........................................................

289.2.2. Alert Response

.................................................

.........

299.3. Emergency Termination Criteria

................................................................

3010.0 RADIOLOGICAL ASSESSMENT AND PROTECTIVE MEASURES

..................

3310.1. Radiological Assessment

.........................................................................

3310.1.1. Initial Radiological Dose Projection

..........................................

3310.2. Radiological Exposure Control ..................................................................

3310.3. Protective Measures

................................................................................

3310.3.1. Site Personnel Accountability

....................................................

3310.3.2. Site Egress Control Methods ....................................................

3410.3.3. Contamination Control and Decontamination Capability

...........

3410.3.4. Use of Onsite Protective Equipment and Supplies

...................

3510.3.5. Fire Fighting

.............................................................................

3510.4. Aid to Affected Personnel

.........................................................................

3510.4.1. Medical Treatment

....................................................................

3510.4.2. Medical Transportation

.............................................................

3510.5. Protective Actions for Onsite Personnel

...................................................

3611.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION

.........................

3811.1. Emergency Notification

.............................................................................

3811.2. Public Information

.....................................................................................

38Permanently DefueledEmergency PlanRevision 0Revision SummaryPage iii of viiiEntergy Vermont Yankee 12.0 MAINTAINING EMERGENCY PREPAREDNESS

..............................................

3912.1. Drills and Exercises

..................................................................................

3912.1.1. Radiation Emergency Exercises and Drills ...............................

3912.1.2. Communication Tests ..............................................................

4012.1.3. Augmentation Capability Drills ..................................................

4012 .1.4 .Fire D rills ...................................................................................

404412.1.5. Medical Drills .............................................................................

4041-12.1.6. Radiological Monitoring Drills ...................................................

4112.1.7. Health Physics Drills .................................................................

4112.1.8. Security Drills ...........................................................................

4112.1.9. Scenarios

..................................................................................

4112.1.10.

Evaluation of Exercises

.............................................................

4212.1.11.

Emergency Plan Audit ...............................................................

424312.2. T raining ...................................................................................................

..4312.3. Review and Updating of Plan and Procedures

..........................................

434412.4. Maintenance and Inventory of Emergency Equipment and Supplies

........

4412.5. Responsibility for the Planning Effort .........................................................

44Permanently DefueledEmergency PlanRevision 0Revision SummaryPage iv of viiiEntergy Vermont Yankee APPENDICES APPENDIX A Emergency Classification System and Emergency Action LevelsAPPENDIX B Emergency Equipment APPENDIX C Environmental Laboratory Analytical and Dosimetry ServicesAPPENDIX D Letters of Agreement APPENDIX E Index of Emergency Plan Implementing Procedures andSupport PlansAPPENDIX F Cross-Reference between the PDEP, NUREG-0654/FEMA-REP-1, the 10 CFR 50.47(b)

Planning Standards, and Appendix E.IVPlannina Reauirements Paue424346485154Permanently DefueledEmergency PlanRevision 0Revision SummaryPage v of viiiIEntergy Vermont Yankee LIST OF TABLESTable 7.1Table 8.1Table 10.1Vermont Yankee Emergency Communications MatrixMinimum On-Shift and ERO Staffing Requirements Emergency Dose LimitsPermanently DefueledEmergency PlanRevision 0Revision SummaryPage vi of viiiEntergy Vermont Yankee LIST OF FIGURESFigure 4.1Figure 8.1Figure 9.1Vermont Yankee SiteNormal On-Shift Emergency Organization Notification PlanPermanently DefueledEmergency PlanRevision 0Revision SummaryPage vii of viiiEntergy Vermont Yankee

1.0 INTRODUCTION

The Permanently Defueled Emergency Plan (PDEP) describes the station's plan forresponding to emergencies that may arise at the Vermont Yankee Nuclear Power Station(VY) while in a permanently shutdown and defueled configuration.

VY has providedcertification to the Nuclear Regulatory Commission (NRC) required by 10 CFR50.82(a)(1)(i) and (ii) that the station has permanently ceased operations and that all fuelhas been permanently removed from the reactor vessel. In this configuration, all irradiated fuel is stored in the Independent Spent Fuel Storage Installation (ISFSI) and in the SpentFuel Pool (SFP). In this condition, no reactor operations can take place and the station isprohibited from emplacement or retention of fuel in the reactor vessel. An analysis of thepossible design basis events and consequences is presented in the evaluation of theUpdated Final Safety Analysis Report (UFSAR) accident assessment.

This PDEPadequately addresses the risks associated with VY's current conditions.

The analysis of the potential radiological impact of a-n-desiqn basis accidents in apermanently defueled condition indicates that any releases beyond the Site boundary arebelow the Environmental Protection Agency (EPA) Protective Action Guide (PAG) exposurelevels, as detailed in the EPA's "Protective Action Guide and Planning Guidance forRadiological Incidents,"

Draft for Interim Use and Public Comment dated March 2013 (PAGManual).

Exposure levels, which warrant pre-planned response

measures, are limited toonsite areas. For this reason, radiological emergency planning is focused onsite.1.1. PurposeThe purpose of the PDEP is to assure an adequate level of preparedness by which to copewith a spectrum of emergencies that could be postulated to occur, including the means tominimize radiation exposure to plant personnel.

This plan integrates the necessary elements to provide effective emergency response considering cooperation andcoordination of organizations expected to respond to potential emergencies.

1.2. ScopeThe PDEP has been developed to respond to potential radiological emergencies at VYconsidering the permanently shutdown and defueled status. Because there are nopostulated design basis accidents that would result in dose consequences that are largeenough to require off site emergency

planning, the overall scope of this plan delineates theactions necessary to safeguard onsite personnel and minimize damage to property.

Ifdetermined appropriate by government officials, protective actions may be implemented toprotect the public using an all -hazards approach to emergency planning.

The concepts presented in this plan address the applicable regulations stipulated in 10CFR 50.47, "Emergency Plans" and 10 CFR Part 50, Appendix E, "Emergency Planningand Preparedness for Production and Utilization Facilities."

Permanently DefueledEmergency PlanRevision 0Page 1 of 5360Entergy Vermont Yankee Exemptions to selected portions of 10 CFR 50.47(b),

10 CFR 50.47(c)(2) and 10 CFR Part50, Appendix E were previously approved by the NRC.Permanently DefueledEmergency PlanRevision 0Page 2 of 5,60Entergy Vermont Yankee

2.0 DEFINITIONS

Alert -Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involvesprobable life threatening risk to site personnel or damage to site equipment because ofHOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPAProtective Action Guideline exposure levels.Assessment Actions -Those actions which are taken to effectively define the emergency situation necessary for decisions on specific emergency measures.

Code Red -A Security related contingency requiring the activation of the SecurityResponse Team. This contingency shall, as a minimum cause an Unusual Event to beannounced.

Committed Dose Equivalent (CDE) -The dose equivalent to organs or tissues ofreference (e.g., thyroid) that will be received from an intake of radioactive material by anindividual during the 50 year period following the intake.Confinement Boundary

-The barrier(s) between areas containing radioactive substances and the environment.

Corrective Actions -Those emergency measures taken to ameliorate or terminate anemergency situation.

Emergency Action Levels -A pre-determined, site-specific, observable threshold for anInitiating Condition that, when met or exceeded, places the plant in a given emergency classification level.Emergency Classification

-One of a set of names or titles established by the US NuclearRegulatory Commission for grouping off-normal events or conditions according to (1)potential effects or consequences, and 2) resulting onsite and offsite response actions.

Theemergency classification levels, in ascending order of severity, are: UNUSUAL EVENT andALERT.Emergency Implementing Procedure

-Specific action taken by the plant staff to activateand implement this Emergency Plan.Emergency Operating Procedures

-The outline of specific corrective actions to be takenby plant operators in response to abnormal operating conditions.

Emergency Response Organization

-Organization comprised of assigned VermontYankee personnel who would respond and assist in a classified emergency situation.

Gai-Tronics

-An intra-site station operation and public address system which consists ofspeakers and microphones located in areas vital to the operation of the station.

ThePermanently DefueledEmergency PlanRevision 0Page 3 of 5360Entergy Vermont Yankee system has four channels which provide separate and independent page andintercommunication capabilities.

Hostile Action -An act toward an NPP or its personnel that includes the use of violentforce to destroy equipment, takes hostages, and/or intimidates the licensee to achieve anend. This includes attack by air, land, or water using guns, explosives, projectiles,

vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intentmay be included.

HOSTILE ACTION should not be construed to include acts of civildisobedience or felonious acts that are not part of a concerted attack on the NPP.Non-terrorism-based EALs should be used to address such activities, (e.g., violent actsbetween individuals in the owner controlled area).Independent Spent Fuel Storage Installation (ISFSIJ -A complex that is designed andconstructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.Initiating Condition

-An event or condition that aligns with the definition of one of the twoemergency classification levels by virtue of the potential or actual effects or consequences.

Notification of Unusual Event- Events are in progress or have occurred which indicate apotential degradation of the level of safety of the plant or indicate a security threat to facilityprotection has been initiated.

No releases of radioactive material requiring offsite responseor monitoring are expected unless further degradation of safety systems occurs. Alsoreferred to as an Unusual Event.Projected Dose -The amount of radiation dose estimated at the onset of any accidental radiological release.

It includes all the radiation dose the individual would receive for theduration of the release assuming that no protective measures were undertaken.

Protective Action -Those emergency measures taken to effectively mitigate theconsequences of an accident by minimizing the radiological exposure that would likelyoccur if such actions were not undertaken.

Recovery Actions -Those actions taken after the emergency has been controlled in orderto restore safe plant conditions.

Site -That property within the fenced boundary of Vermont Yankee which is owned by theCompany.Total Effective Dose Equivalent (TEDE) -The sum of the deep dose equivalent fromexternal sources and the committed effective dose equivalent from internal exposures.

Permanently DefueledEmergency PlanRevision 0Page 4 of 5360Entergy Vermont Yankee 3.0 SUMMARY OF EMERGENCY PLAN3.1. Overview of Permanently Defueled Emergency PlanIn the event of an emergency at the plant, actions are required to identify and assess thenature of the emergency and to bring it under control in a manner that protects the healthand safety of plant personnel.

This plan describes the organization and responsibilities for implementing emergency measures.

It describes interfaces with Federal, States of Vermont and New Hampshire, theCommonwealth of Massachusetts and local organizations which may be notified in theevent of an emergency, and may provide assistance.

Emergency services are provided bylocal public and private entities.

Fire support services are provided by the Vernon andBrattleboro Fire Departments and Tri-State and Southwestern Fire Mutual Aid Networks.

Law enforcement support services are provided by local, county, state, and federal lawenforcement authorities, as appropriate.

Ambulance service is provided by Rescue, Inc.Medical services are provided by Brattleboro Memorial Hospital.

I Because there are no postulated design basis accidents that would result in off-site doseconsequences that are large enough to require off-site emergency

planning, emergencies I are divided into two classifications:

1) Notification of Unusual Event (Unusual Event); and 2)Alert. This classification scheme has been discussed and agreed upon with responsible offsite organizations and is compatible with their respective emergency plans. According tothe EPA PAG Manual, "Emergency Planning Zones (EPZs) are not necessary at thosefacilities where it is not possible for PAGs to be exceeded off-site."

If determined appropriate by government officials, protective actions may be implemented to Protect thepublic using an all -hazards approach to emergency planning.

VY is responsible for planning and implementing emergency measures within the Site.This plan is provided to meet that responsibility.

To carry out specific emergency measuresdiscussed in this Plan, detailed emergency plan implementing procedures are established and maintained.

In addition to the description of activities and steps that can be implemented during anemergency, this Plan also provides a general description of the steps taken to recover froman emergency situation.

It also describes the training, drills, planning, and coordination appropriate to maintain an adequate level of emergency preparedness.

3.2. Obiectives

The basic objectives of this plan are:1) To establish a system for identification and classification of the emergency condition and initiation of response actions;Permanently DefueledEmergency PlanRevision 0Page 5 of -5360Entergy Vermont Yankee

2) To establish an organization for the direction of activity within the plant to limit theconsequences of the incident;

3) To establish an organization for control of surveillance activities to assess the extentand significance of any uncontrolled release of radioactive material;

4) To identify facilities, equipment and supplies available for emergency use;5) To establish an engineering support organization to aid the plant personnel inlimiting the consequences of and recovery from an event;6) To establish the basic elements of an emergency recovery program;7) To specify a system for coordination with federal, state/commonwealth, and localauthorities and agencies for offsite support organizations;

8) To develop a communications network between the plant and offsite authorities toprovide notification of emergency situations;

9) To develop a training and Emergency Plan exercise program to assure constanteffectiveness of the plan.3.3. Actions in an Emergencv This Plan is activated by the Shift Manager upon identification of an emergency situation based upon Emergency Action Level (EAL) criteria.

The emergency measures described inthe subsequent sections and emergency plan implementing procedures are implemented inaccordance with the classification and nature of the emergency at the direction of the ShiftManager.

Regulatory authorities and offsite support organizations are notified inaccordance with this Plan. The Shift Manager has authority and responsibility for controland mitigation of the emergency, including emergency response resources, coordination ofradiological assessment activities, and recovery implementation.

If an emergency condition

develops, the Shift Manager assumes the role of Emergency

Director, including responsibilities for initiating emergency actions to limit the consequences of the incident and to bring the plant into a stable condition.

The individual must:1) Recognize the emergency condition by observation of EALs;2) Classify the accident in accordance with the emergency classification system;3) Initiate emergency procedure(s) applicable to the event;4) Activate the plant emergency alarm system;Permanently DefueledEmergency PlanRevision 0Page 6 of -5,60Entergy Vermont Yankee

5) Notify state-authorities in Vermont, New Hampshire and Massachusetts using theInForm Notification System;6) Notify the NRC using the Emergency Notification System (ENS);7) Use the notification plan to notify appropriate personnel as set forth in Figure 9.1;and8) Direct and coordinate all emergency response efforts until overall responsibility isassumed by the Emergency Director.

3.4. Emergency Response Facilities The emergency response facilities, which are utilized by the Emergency ResponseOrganization (ERO), are described in Section 6.0. Key site personnel are dispatched toperform accident assessments, implement corrective

actions, and analyze accident data.3.5. Mobilization The mobilization scheme is based on the emergency notification system shown inFigure 9.1. The notification system utilizes the plant public address system (Gai-Tronics),

dedicated telephone lines, and the ERO notification system to notify and mobilize plantpersonnel.

The mobilization scheme ensures that specific technical disciplines can beaugmented within appropriate time frames. On-site staff are informed of an emergency condition through the use of the plant public address system, office telephone and/orwireless devices capable of receiving telephone calls and text messages.

In the event thatpersonnel required to staff emergency positions are not on-site at the time an emergency isdeclared, they may be contacted by commercial telephone including land lines and/orwireless devices capable of receiving telephone calls and text messages.

Mobilization ofthe ERO will be conducted under the direction of the Emergency

Director, according topersonnel assignments and telephone numbers maintained in various telephone directories.

Section 8.2, Figure 8.1 and Table 8.1 outline the minimum staffing requirements for the ERO at VY.3.6. State and Local Government Notification and ResponseVY's Emergency Plan interfaces with the state-emergency response plans of Vermont, NewHampshire and the Commonwealth of Massachusetts.

Vernon, Vermont, in coordination with the emergency management agencies of Vermont, maintains the capability tocommunicate on a 24-hour per day basis.VY conveys specific accident information to the States of Vermont and New Hampshire andthe Commonwealth of Massachusetts using the InForm Notification System.A cooperative arrangement exists among the Vermont and New Hampshire and theCommonwealth of Massachusetts State-authorities and VY concerning radiological Permanently DefueledEmergency PlanRevision 0Page 7 of 5360Entergy Vermont Yankee emergency preparedness.

VY's emergency classification system and notification I messages are reviewed with these States-/Commonwealth Of-VeFmOn-on an annual basis.3.7. Federal Government Notification and ResponseNotification to the NRC is made using the ENS as soon as possible afterState/Commonwealth notifications and within 60 minutes of event classification or changein classification.

Once notified of an emergency, the NRC evaluates the situation anddetermines the appropriate NRC response.

Depending on the severity of the accident andthe emergency classification

declared, the NRC activates their incident responseoperations in accordance with the NRC Incident Response Plan. If the emergency

warrants, the NRC notifies the Federal Emergency Management Agency (FEMA) and otherappropriate federal agencies to activate the federal emergency response organization inaccordance with the National Response Framework (NRF). The NRF makes available theresources and capabilities of federal agencies to support plant, state and localgovernments, as necessary to respond to the specific nature of the emergency.

Principal participants are the NRC, FEMA, Department of Energy (DOE), and Environmental Protection Agency (EPA).3.8. Technical SupportIn the event of an emergency that requires personnel and other support resources beyondthose available within the VY organization, augmentation is available from other Entergyfacilities and can be requested from various contractors.

Additional technical andmanpower support are provided to VY through support plans listed in Appendix E.3.9. Mitigation of Consequences of Beyond Design Basis EventsStrategies to mitigate a loss of SFP inventory and prevent a zirconium fire are contained within Appendix G, "Loss of Large Areas of the Plant Due to Fire or Explosion,"

of PP 7019,"Severe Accident Management Program."

Appendix G of PP 7019 describes theequipment, resources (such as water supplies),

procedures and strategies in place formovement of any necessary portable equipment that will be relied upon for prevention of azirconium fire in the SFP. These mitigative strategies were developed as a result of NRCOrder on Mitigative Strategies (EA-1-2-04902-026) and implement the requirements ofLicense Condition 3.N, "Mitigation Strategy License Condition."

Permanently DefueledEmergency PlanRevision 0Page 8 of -51,60Entergy Vermont Yankee 4.0 SITE DESCRIPTION 4.1. Facility Description VY is located on the west bank of the Connecticut River immediately upstream of theVernon Hydrostation, in the town of Vernon, Vermont.

VY consists of a permanently shutdown boiling water reactor having a thermal rated power of 1912 MWt. An ISFSI islocated on the plant site. The station, shown in Figure 4.1, is located on about 125 acres inWindham County, and is owned by Entergy, with the exception of a narrow strip of landbetween the Connecticut River and the VY property for which it has perpetual rights andeasements from the owner, New England Power Company.The 10 CFR Part 50 license for VY no longer authorizes operation of the reactor;-

oremplacement or retention of fuel into the reactor vessel, as specified in 10 CFR50.82(a)(2).

4.2. Area Characteristics and Land UseThe site is bounded by the Connecticut River (Vernon Pond) on the east, by farm andpasture land mixed with wooded areas on the north and south, and by the town of Vernonon the west. Most of the land around the site is undeveloped.

The developed land is usedfor agriculture,

dairying, and for residential areas within small villages.

The nearestresidence is 1,300 feet from the Reactor Building and is one of several west of the site.The Vernon Elementary School (approximate enrollment of 250 pupils) is about 1,500 feetfrom the Reactor Building.

The nearest hospital, Brattleboro

Memorial, is approximately five (5) miles north-northwest from the site.Permanently DefueledEmergency PlanRevision 0Page 9 of &360Entergy Vermont Yankee raidiusVermont YVankeeNuclear PowerStationVernonfacinnaimy SchoolCJUV'anor

--'Hunt Hoi-usS5NVemonHydromation

-- I_O 200METERSinnFigure 4.1Vermont Yankee SitePermanently DefueledEmergency PlanRevision 0Page 10 of 5360Entergy Vermont Yankee 5.0 EMERGENCY CLASSIFICATION SYSTEMThe emergency classification system covers an entire spectrum of possible radiological andnon-radiological emergencies at the VY. The emergency classification system categorizes accidents and emergency situations, according to severity, into two emergency classification levels: Unusual Event and Alert.The incidents leading to each of the emergency classifications are further identified bycertain measurable and observable indicators of plant conditions (EALs). EALs addressed in Appendix A aid the operator in recognizing the potential of an incident immediately andassure that the first step in the emergency response is carried out. The classification of theevent may change as the conditions change. VY maintains the capability to assess, classifyand declare an emergency condition in accordance with site procedures.

EALs and EAL bases were derived from NEI 99-01, "Development of Emergency ActionLevels for Non-Passive Reactors" Rev. 6, for classifying emergencies.

Specifically, Appendix C of NEI 99-01, Rev. 6 contains a set of Initiating Conditions/

EALs forpermanently defueled nuclear power plants that had previously operated under a 10 CFRPart 50 license and have permanently ceased operations.

The classification systemreferenced in NEI 99-01, Rev. 6 has been endorsed by the NRC and provides a standardmethod for classifying emergencies.

5.1. Unusual EventEVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INDICATE APOTENTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE PLANTOR INDICATE A SECURITY THREAT TO FACILITY PROTECTION HASBEEN INITIATED.

NO RELEASES OF RADIOACTIVE MATERIALREQUIRING OFFSITE RESPONSE OR MONITORING ARE EXPECTEDUNLESS FURTHER DEGRADATION OF SAFETY SYSTEMS OCCURS.Unusual Event conditions do not cause serious damage to the plant. The purpose of theUnusual Event declaration is to: 1) provide for an increased awareness of abnormalconditions;

2) ensure that the first step in any response later found to be necessary hasI been carried out; 3) bring the ERO to a state of readiness;

4) te-provide for systematic handling of information and decision-making, and 5) augment on-shift personnel, if deemednecessary by the Emergency Director.

See Appendix A for a complete list of EALs corresponding to an Unusual Event.5.2. AlertEVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INVOLVEAN ACTUAL OR POTENTIAL SUBSTANTIAL DEGRADATION OF THELEVEL OF SAFETY OF THE PLANT OR A SECURITY EVENT THATINVOLVES PROBABLE LIFE THREATENING RISK TO SITE PERSONNEL Permanently DefueledEmergency PlanRevision 0Page 11 of .5360Entergy Vermont Yankee OR DAMAGE TO SITE EQUIPMENT BECAUSE OF HOSTILE ACTION.ANY RELEASES ARE EXPECTED TO BE LIMITED TO SMALLFRACTIONS OF THE EPA PAG EXPOSURE LEVELS.The purpose of the Alert declaration is to: 1) activate the Emergency ResponseOrganization to perform event mitigation and radiation monitoring, if required,

2) provide theState of Vermontoffsite authorities and the NRC with current information on plant status,and 3) ensure that all necessary resources are being applied to accident mitigation.

Plant responses associated with this event classification assure that sufficient emergency response personnel are mobilized and respond to event conditions.

Actual releases ofradioactivity which exceed Technical Specification limits may be involved, thus radiation monitoring and dose projection may be required.

See Appendix A for a complete list of EALs corresponding to an Alert.5.3. Emergency Classification System Review by State Authorities The emergency classification system specified above and the EALs presented in AppendixA, are reviewed with the state-authorities of Vermont, New Hampshire and Massachusetts annually.

Permanently DefueledEmergency PlanRevision 0Page 12 of 5360Entergy Vermont Yankee 6.0 EMERGENCY RESPONSE FACILITIES AND EQUIPMENT Following the declaration of an emergency, the activities of the emergency responseorganization are coordinated in the Control Room. Descriptions of VY facilities andassessment capabilities are presented below.6.1. Control RoomThe Control Room is where plant systems and equipment parameters are monitored.

Control Room personnel assess plant conditions, evaluate the magnitude and potential consequences of abnormal conditions, initiate preventative, mitigating and corrective actions and perform notifications.

The Control Room is the onsite center for emergency command and control.The Control Room crew coordinates all phases of emergency response and corrective action required to restore the plant to a safe condition.

Classification and subsequent declaration of the appropriate emergency condition by the Shift Manager results inactivation of the ERO. The Control Room staff's attention focuses on mitigating theemergency as the ERO reports and is delegated emergency functions.

When activated, the ERO reports to the Emergency Director to assist the on-shift staff inthe assessment, mitigation and response to an emergency and to support the dispatch ofemergency teams. The composition of the ERO is addressed in Section 8.2.ERO activation may be modified or suspended if the safety of personnel may bejeopardized by a security event or other event hazardous to personnel.

The Control Room contains communications equipment, emergency radiation monitoring equipment, emergency respiratory

devices, and an emergency kit containing protective clothing and other supplies.

The ERO has access to up-to-date technical documentation, including

drawings, system information and procedures to enable mitigation planning andsupport of Control Room staff.A general assembly area for emergency mitigation and radiation protection personnel ismaintained.

6.2. Assessment Capability The activation of the Emergency Plan and the continued assessment of accident conditions require monitoring and assessment capabilities.

VY maintains and operates on-sitemonitoring systems needed to provide data that is essential for initiating emer-gency measures and performinq accident assessment, including dose assessment and assessing the magnitude of a release.

This includes monitorinq systems for plant processes, radiological conditions, meteorological conditions, and fire hazards.

The essential monitoring systems needed are incorporated in the EALs specified in Appendix A. Thissection briefly describes monitoring systems as well as other assessment capabilities.

Permanently DefueledEmergency PlanRevision 0Page 13 of -5360Entergy Vermont Yankee 6.2.1. Process MonitorsAnnunciator and computer alarms are provided for a variety of parameters including theSFP cooling system to indicate SFP level, temperature and pump status.The manner in which process monitors are used for accident recognition and classification is given in the detailed EAL listings in Appendix A.6.2.2. Radiological MonitorsA number of radiation monitors and monitoring systems are provided on process andeffluent liquid and gaseous lines that serve directly or indirectly as discharge route forradioactive materials.

These monitors, which include Control Room readout and alarmfunctions, exist in order that appropriate action can be initiated to limit fuel damage and/orcontain radioactive material.

The equipment

1) provides radiological surveillance capabilities;

2) warns personnel of a radiological release;

3) provides warning of certainplant malfunctions which might lead to a radiological release; and 4) prevents, orminimizes, the effects of an accidental release of radioactivity to the environment.

Plant instrumentation provide personnel in the Control Room with the following parameters necessary to perform dose assessment and determine the magnitude of a potential release:* Gaseous and liquid effluent monitor readings* Radiation levels* SFP area radiation levelsSpecific details on these monitoring systems such as location, type, etc., are contained inthe UFSAR.In addition to installed monitoring

systems, VY has augmented onsite radiological assessment capability, including portable radiation and contamination monitoring instruments and sampling equipment.

6.2.3. Meteorological Capability The meteorological equipment at the site consists of wind-speed and direction transmitters, signal translators, and recorders.

In addition, the temperature measurement consists ofrecorders and resistance temperature detectors (RTDs). RTDs are used to monitorambient temperature and calculate differential temperature.

Meteorological data is displayed in the Control Room. These meteorological data is used todetermine the proiected radiological conditions in the event of an accidental release ofradioactivity to the environment.

Permanently DefueledEmergency PlanRevision 0Page 14 of -5360Entergy Vermont Yankee In addition, VY has the capability to access additional meteorological information throughoffsite support services.

This information can be forwarded to VY upon request.6.2.4. Fire Detection and Suppression Equipment The fire protection system has been designed to detect and extinguish potential fires. Thesystem is designed in accordance with the standards of the National Fire Protection Association (NFPA) and recommendations of the Nuclear Electric Insurance Limited(NEIL). Fire detectors are located throughout the plant with alarms and indicators in theControl Room. The fire protection system is described in the Vermont Yankee FireProtection Program.6.2.5. Assessment Facilities and Equipment Vermont Emergency Management provides reports concerning natural occurrences orsevere weather conditions that may affect the plant area. Offsite fire departments ofVernon and Brattleboro notify the plant of any fire which might have an impact on the plant.Local Law Enforcement Agencies notify Plant Security of any situation in the area whichmight have an impact on the plant.VY maintains an offsite environmental monitoring program.

Radiological environmental monitoring stations for the site and surrounding area monitor the environment under normaland accident conditions.

Radiological environmental monitoring stations have beenestablished in accordance with Technical Specification R.,ui,,m,,t, Manual),requirements.

VY has access to outside analytical assistance and laboratory facilities from other non-affected Entergy nuclear sites, State and Federal agencies and other utilities.

Environmental laboratory analytical and dosimetry services are described in Appendix C.The above facilities have the capability to perform laboratory analyses of variousenvironmental samples (e.g., terrestrial, marine and air). It is also estimated that theanalytical assistance and laboratory support will be able to respond within four (4) to eight(8) hours from initial notification.

Permanently DefueledEmergency PlanRevision 0Page 15 of 5360Entergy Vermont Yankee

7.0 COMMUNICATIONS

Various modes of communication are available to plant staff to transmit information withinVY and to various locations offsite during normal and emergency conditions.

A summary of the communication systems is defined in the communication matrix providedin Table 7.1 and outlined below.7.1. InForm Notification SystemThe InForm Notification System is located in the Control Room. InForm consists of sourceand destination computers that take advantage of the internet to send Emergency Notification Forms to the States of Vermont, New Hampshire and the Commonwealth ofMassachusetts.

This system is staffed on a 24-hour basis on both ends -the Control Room and the StatePolice dispatching points. InForm performs self-checks at frequent intervals and has theability to notify personnel of any problems identified during the self-check.

InForm is testedmonthly between the Control Room and the State/Commonwealth Police dispatching points.Backup to the InForm Notification System is the Nuclear Alert System (NAS).7.2. Nuclear Alert SystemThe NAS can be used to notify the State/Commonwealth Police of Vermont, NewHampshire and Massachusetts of any emergency.

This system is a secure (dedicated) communications arrangement.

This system is staffed on a 24-hour basis in the Control Room and by theI State/Commonwealth Of VermontPol4ca Dispatchinq Points. The NAS is tested monthlybetween the plant and the State/Commonwealth agencies.

The NAS links the Control Room and the Vermont Emergency Operations Center.Backup to the NAS phone system is the commercial phone system.7.3. ERO Notification SystemThe ERO notification system is the primary means to activate the ERO upon declaration ofan emergency, as directed by the Emergency Director.

In the event that personnel requiredto staff emergency positions are not on-site at the time an emerqency is declared, they maybe contacted by commercial telephone including land lines and/or wireless devices capableof receiving telephone calls and text messages.

Telephone numbers are maintained invarious telephone directories.

This system is tested as described in Section 12.1.2.Permanently DefueledEmergency PlanRevision 0Page 16 of 5360Entergy Vermont Yankee 7.4. Mobile UHF Radio SystemThe Mobile UHF Radio System is utilized as a primary means of communications forsecurity personnel; it is the alternate means of communications between the Control Roomand onsite response teams. The System consists of UHF repeaters with high gainantennas.

These repeaters are activated by base radio stations.

Also, the portable unitsactivate the repeater.

In the event the repeater fails, a "talk around" feature allowscontinued communications between portable units. This system is tested daily throughoperational use of the system.Security also has the capability to contact the primary local law enforcement agency patrol'vehicle(s),

as defined in the VY Physical Security Plan, that are located in close proximity tothe plant via radio.7.5. Plant Intercom SystemThe Intercom System (Gai-Tronics) is located in many areas throughout the plant, including the Control Room and Security Gates. This system consists of five channels and is utilizedas a paging system and for communications with the refuel bridge. During emergency situations, the system is used as the primary means for: (1) notifying plant personnel of theemergency, (2) coordinating the activities of onsite response teams with the Control Room;and (3) calling for any missing or unaccounted for personnel that may be in the plant. Thissystem is in continuous daily use.7.6. NRC Telephone SystemThe NRC has utilized the Federal Telecommunications System (FTS) telephone networkfor its emergency telecommunications system. The FTS system provides a separate(public cannot access) government telephone network which avoids potential publictelephone blockage which may occur in the event of a major emergency.

The ENS utilizes an FTS line which exists between the NRC Operations Office in Rockville, Maryland and the Control Room. Emergency notification, plant status information andradiological information are communicated via the ENS. The ENS is tested daily by theNRC and has a 24-hour manning capability at both organizations.

7.7. Commercial Telephone SystemThe commercial telephone system is used as a primary and alternate means ofcommunications for notification and coordination.

For conditions involving telephone company equipment blockage in the local area, alternate external telephone linearrangements have been made available to the plant. This system is tested daily throughoperational use of the system.Permanently DefueledEmergency PlanRevision 0Page 17 of 5360Entergy Vermont Yankee 7.8. Mutual Aid RadioThe Mutual Aid Radio is a multi-channel radio that can be utilized to contact Southwest Mutual Aid; Rescue, Inc.; Brattleboro Memorial Hospital and the State EOCs in the eventthat all other offsite channels of communication fail. Periodic testing of this system isdescribed in Section 12.1.2.7-&.7.9.Communications Emergency Power Supply forCurrently there are several telephone and other emergency communication channelsI (Gai-Tronics, radio network, and Mi..ewaveInternet Protocol (IP) telephones) located withinthe plant that are connected to an emergency or redundant power supply. All emergency I communications (including all emergency phones) located within the plant are connected toan emergency or redundant supply.There are power fail phones located in the Control Room, which will automatically activateif power is lost to the internal telephone system.Permanently DefueledEmergency PlanRevision 0Page 18 of -5,60Entergy Vermont Yankee TABLE 7.1VERMONT YANKEE EMERGENCY COMMUNICATIONS MATRIXCROffsite and Site Boundary MonitorsNuclear Regulatory Commission State/Commonwealth Police (VT, NH,MA)State/Commonwealth EOCs (VT NHMA)Vermont Yankee Plant SecurityVermont Yankee Emergency Response Personnel 1,31,41,2,81,2,7,81,3,51,6KEY1.2.3.4.5.6.7.8.Commercial Telephone SystemNASMobile UHF Radio SystemENS (FTS)Gai-Tronics ERO notification systemSouthwcet FircMutual Aid RadioInFormPermanently DefueledEmergency PlanRevision 0Page 19 of -5,60Entergy Vermont Yankee

8.0 ORGANIZATION

This section describes how the normal plant and engineering support organization transform into an emergency response organization to effectively deal with any incident atVY.8.1. Normal Plant Organization The personnel and resources of VY's normal plant and management organization consist ofthe onsite facility organization supported by the engineering and management organizations located offsite.

The relationship and content of these onsite and offsiteorganizations are specified in the plant Technical Specifications, T...hni.al Manual-or and the En.ter.gy Vermont Yankee Nuclear Power Station Quality Assurance Program Manual.The minimum staff required to conduct routine and immediate emergency mitigation ismaintained at the station.

During normal conditions, the minimum staff on duty at the plantduring all shifts consists of one (1) Shift Manager, one (1) Non-Certified

Operator, one (1)Radiation Protection Technician and security personnel as indicated in Figure 8.1 andTable 8.1. The responsibility for monitoring the status of the plant and approving all onsiteactivities is assigned to the Shift Manager.

When an abnormal situation becomes apparent, the Shift Manager shall assume the position of Emergency Director once the emergency classification has been made. Additional personnel are available on an on-call basis torespond to plant emergencies.

8.1.1. Shift Manager/Emergency DirectorThe Shift Manager is at the station 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and is the senior management positionat the station during off-hours.

The Shift Manager shall assume the position of Emergency Director once the emergency classification has been made.This position is responsible for monitoring conditions and approving all onsite activities andhas the requisite authority, management

ability, technical knowledge, and staff to managethe site emergency and recovery organization.

The Emergency Director is responsible forthe direction of the total emergency response and has the company authority to accomplish this responsibility.

The Emergency Director cannot delegate the following responsibilities:

1. Classification of event2. Approval of emergency notification (although the task of making notifications may be delegated)

3. Authorization of radiation exposures in excess of 10 CFR Part 20 limitsPermanently DefueledEmergency PlanRevision 0Page 20 of -5360Entergy Vermont Yankee Other responsibilities assumed by the Emergency Director include:1. Notification of the emergency classification to the NRC and States ofVermont, New Hampshire and the Commonwealth of Massachusetts

2. Management of available station resources

3. Initiation of mitigating actions4. Initiation of corrective actions5. Initiation of onsite protective actions6. Decision to call for offsite police, fire or ambulance assistance

7. Augment the ERO staff as deemed necessary

8. Coordinate Security activities

9. Terminate the emergency condition when appropriate

10. Performance of initial Dose Assessment

11. Maintain a record of event activities 8.1.2. Non-Certified OperatorThe Non-Certified Operator performs system and component manipulations.

Theorganizational relationship to the Shift Manager/Emergency Director is the same duringnormal and abnormal situations.

8.1.3. Radiation Protection Technician The Radiation Protection Technician is available to monitor personnel

exposure, determine if radiological conditions preclude access to areas necessary to maintain SFP cooling, andto provide timely field survey results, if necessary.

8.1.4. SecuritySecurity staffing is maintained in accordance with the Security Plan. The Security Forcewill report to the Emergency Director when implementing the PDEP.During non-security events, Security will activate the station ERO callout system andperform accountability at the direction of the Emergency Director.

Permanently DefueledEmergency PlanRevision 0Page 21 of 6_360Entergy Vermont Yankee 8.2. Emergency Response Organization The VY ERO is activated at an Alert classification.

However, it can be activated in part or inwhole at the discretion of the Emergency Director for an Unusual Event.Plans and procedures are in place to ensure the timely activation of the ERO. The goal ofthe ERO is to augment the on-shift staff within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of an Alert classification.

Due to theslow rate of the postulated event scenarios in the accident analysis and the ability of theon-shift staff to implement the Emergency Plan, the ERO augmentation goal of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> isappropriate.

The minimum augmented staff consists of a Technical Coordinator and a Radiation Protection Coordinator.

Augmented staff provides the technical expertise required to assistthe Emergency Director.

The on-shift staff is augmented by additional personnel that reportas directed after receiving notification of an emergency requiring augmented staff.Designated members of the on-shift staff fulfill roles within the ERO appropriate with theirtraining and experience.

For example, Radiation Protection personnel would be expected toundertake radiation protection activities, Security personnel would undertake securityactivities,

-engineering personnel would focus on plant assessment,-a-Pd provide technical support and assist in recovery operations as designated by the Technical Coordinator, andOperations personnel would focus on plant operations.

The VY ERO is illustrated in Figure 8.1.8.2.1. Technical Coordinator The Technical Coordinator reports to the Emergency Director.

During an emergency, theresponsibilities of the Technical Coordinator include:1. Evaluate technical data pertinent to plant conditions

2. Augment the emergency staff as deemed necessary 2-.3. Designate engineering

support, as necessary, to evaluate plant conditions and provide technical support3-A. Recommend mitigating and corrective actions4ý5. Direct search and rescue operationsCoordinate maintenance and equipment restoration 6-7. Establish and maintain communications as desired by the Emergency Director7-8. Maintain a record of event activities Permanently DefueledEmergency PlanRevision 0Page 22 of -5360Entergy Vermont Yankee 8.2.2. Radiation Protection Coordinator The Radiation Protection Coordinator reports to the Emergency Director.

During anemergency, the responsibilities of the Radiation Protection Coordinator include:1. Monitor personnel accumulated dose2. Advise the Emergency Director concerning Radiological EALs3. Augment the emergency staff as deemed necessary

4. Direct radiological monitoring and analysis5. Dose Assessment

6. Establish and maintain communications as desired by the Emergency Director7. Maintain a record of event activities 8.2.3. Extensions of the Vermont Yankee Emergency Response Organization 8.2.3.1.

Local ServicesArrangements have been made for the extension of the ERO's capability to addressemergencies.

The following arrangements are in place through letters of agreement forambulance

services, treatment of contaminated and injured patients, fire support services, and law enforcement response as requested by the station:1. Transportation of injured personnel using an ambulance service;2. Treatment of radioactively contaminated and injured personnel at a localsupport hospital (Brattleboro Memorial) as specified in the local supporthospital plans; and3. Fire support services by the Vernon and Brattleboro Fire Departments andthe Tri-State and Southwestern Fire Mutual Aid Networks.

4. Law enforcement support services provided by local, county, state, andfederal law enforcement authorities as appropriate and response capabilities are documented in the letters of agreement maintained by Security.

Evidence of agreements with participating local services is addressed in Appendix E; theVermont Yankee Fire Protection Program; and the Annual Law Enforcement Letters ofAgreement (Safeguards Information) maintained by Security.

Permanently DefueledEmergency PlanRevision 0Page 23 of 5360Entergy Vermont Yankee 8.2.3.2.Federal Government SupportResources of federal agencies appropriate to an emergency condition are made available in accordance with the National Response Framework.

This plan and the resources behindit are activated through the plant notification of the NRC.8.2.3.3.

Additional SupportDependent upon the emergency condition and response needs, the VY ERO can beaugmented by manpower and equipment support from the remainder of the EntergyNuclear organization.

This support capability is outlined in the Corporate Supportprocedure referenced in Appendix E.8.2.4. Recovery Organization The emergency measures presented in this plan are actions designated to mitigate theconsequences of the accident in a manner that affords the maximum protection to plantpersonnel.

Planning for the recovery mode of operations involves the development ofgeneral principles and an organizational capability that can be adapted to any emergency situation.

Upon termination of an emergency and transition into the recovery phase, theEmergency Director assembles the recovery organization to address the specificemergency circumstances of the terminated event. The organizations dcscribed inSection 8.1 and 8.2 provides the foundation for such a recovc,'

organization.

The Emergency Director directs the recovery organization-and is responsible for:1. Ensuring VY is maintained in a safe condition;

2. Managing onsite recovery activities during the initial recovery phase;3. Keeping corporate support apprised of VY activities and requirements.

The remainder of the recovery organization consists of the normal plant and emergency organizations described in Sections 8.1 and 8.2, as necessary, to provide the radiological and technical expertise required to assist the Emergency Director restore the plant tonormal conditions.

The organization relics oR plant staff and/or reGources to rcsterc the plant tW normalGonditiOnS.

The expcrtisc providcd through the support plans is available to aid with thnecessary corrective actions required to centre! and/or restore nrmF~al plant status.-The following is a brief summary of the recovery organization's responsibilities:

1. Maintain comprehensive radiological surveillance of the plant to assurecontinuous control and recognition of problems; Permanently DefueledEmergency PlanRevision 0Page 24 of -5360Entergy Vermont Yankee

2. Control access to the area and exposure to workers;3. Decontaminate affected areas and/or equipment;

4. Conduct clean-up and restoration activities;

5. Isolate and repair damaged systems;6. Document all proceedings of the accident and review the effectiveness of theemergency organization in reducing public hazard and/or plant damage.The organization relies on plant staff and/or resources to restore the plant to normalconditions.

The expertise provided through the support plans is available to aid with thenecessary corrective actions required to control and/or restore normal plant status.When plant conditions allow a transition from the emergency phase to the recovery phase,the Emergency Director conducts a plant emergency management meeting to discuss therecovery organization.

The actions taken by this organization concerning termination of theemergency proceeds in accordance with a recovery plan developed specifically for theaccident conditions.

8.3. Coordination with State Government Authorities Section 7.0 describes the communications network between VY and the States of Vermont.New Hampshire and the Commonwealth of Massachusetts as a means of promptlynotifying appropriate authorities under accident conditions.

I The Shift Manager initiates notification of Vermont, New Hampshire and Massachusetts authorities, providing them with applicable information utilizing an established messageformat that describes the accident status and response actions underway.

The Emergency

Director, or designee, issues periodic reports to Statc of VcrmontState/Commonwealth authorities.

Permanently DefueledEmergency PlanRevision 0Page 25 of &360Entergy Vermont Yankee ShiftManager /Emergency DirectorISecurity NCO Fire RPForce Brigade Technician Emergency Response Organization Technical Radiation Coordinator Protection Coordinator r-----------------------------

r ------- II I* I* IFederal State/Local LocalAgencies Agencies ServicesFigure 8.1Normal On-Shift and Emergency Response Organization Permanently DefueledEmergency PlanRevision 0Page 26 of -5360Entergy Vermont YankeeI Table 8.1Minimum On-Shift and ERO Staffing Requirements MAJOR FUNCTIONAL AREA MAJOR TASKS LOCATION VY EMERGENCY ON-SHIFT VY AUGMENTED STAFF-POSITION, TITLE, OR CAPABILITY FOREXPERTISE RESPONSE IN 2 HOURSPlant Operations and Plant Equipment Control Room Non-Certified Operator*

1assessment of Operational Aspects /_Fire BrigadeEmergency Direction and Emergency Director Control Room Shift Manager*"

ControlNotification/Communication Notify Licensee, State. local and Control RoomFederal personnel and maintaincommunications Radiological Accident Onsite Dose Assessment and As Directed by the Radiation Protection 1 (may augment the EROAssessment and Support of Monitoring Emergency Director Coordinator with Radiation Monitoring Operational Accident Personnel as deemedAssessment necessary)

In-Plant Surveys On-Scene Radiation Protection 1Radiation Protection Technician' Protective Actions (In-Plant)

a. Access Controlb. HP Coverage for Repair,Corrective

Actions, Search andRescue, First Aid, andFirefighting

c. Personnel Monitoring

d. Dosimetry Plant Condition Evaluation, Technical Support As Directed by the Technical Coordinator 1 (may augment the ERORepair, and Corrective Action Repair, Mitigation, and Corrective Emergency Director with technical support andAction emergency repairDevelop strategies for search and personnel as deemedrescue and firefighting necessary)

Firefighting Firefighting On-Scene Fire Brigade Per the FireProtection PlanFire Team Leader Fire Fighting On- Scene Fire Brigade Per the FireRescue Operations/

First Aid Rescue and First Aid Protection PlanSite Access Control and Security, Firefighting, Per the Physical Security Personnel Per the PhysicalAccountability Communications, and Personnel Security Plan Security PlanAccountability I II-I On-Shift personnel required to direct or perform site-specifics mitiqation strategies required for a catastrophic loss of SFP inventory Entergy Vermont YankeePermanently DefueledEmergency PlanRevision 0Page 27 of 5360 9.0 EMERGENCY RESPONSE9.1. Emercency Condition Recognition and Classification VY maintains the capability to assess, classify, and declare an emergency condition.

inaccordance with plant procedures, within 30 minutes after the availability of indications toplant operators that an emergency action level threshold has been reached.

foll,;inq ide-R4iciatiGn of thcII aprite emergcncy Glasszific~ati(on lcvc!.Section 5.0 presents the emergency classification system used for categorizing the widespectrum of possible emergency conditions into one of two emergency classes.

Theprocess of condition recognition, immediate response to correct the condition, eventclassification, and initiation of the appropriate emergency implementing procedures arecritical responsibilities of the Shift Manager and the on-shift crew.Site procedures contain the listing of conditions that represents each of the two emergency categories and the detailed EALs that allow the Shift Manager to determine the emergency classification.

Once the emergency is classified, the applicable emergency implementing procedure is initiated, the ERO is activated and the notification of offsite authorities isinitiated.

The activation of the ERO brings to the assistance of the on-shift personnel thevarious support elements described in this plan. Specific support elements areimplemented as detailed in the emergency implementing procedures.

See Appendix E fora listing of these procedures.

9.2. Activation of the Emergency Response Organization Classification of an accident condition requires that the plant staff recognize thatpre-established EALs associated with an emergency condition, as defined in Appendix A,have been reached or exceeded.

Depending upon the specific action levels attained, theShift Manager declares one of the following:

Unusual Event or Alert. The Shift Manageractivates the ERO if plant conditions reach predetermined EALs.9.2.1. Unusual Event ResponseAppendix A defines the conditions that require the declaration of an Unusual Event. AnUnusual Event does not activate the ERO, but may require augmentation of on-shiftresources to address the event. Offsite emergency organizations are notified forinformational

purposes, and aid from offsite fire, medical, and security organizations maybe required depending on the nature of the event.The response required as a result of this declaration of a Unusual Event varies according tothe specified event, but a general summary of actions taken is described below:1. The emergency condition is recognized and classified by the Shift Managerwho instructs Control Room personnel to announce the emergency classification over the plant page system;Permanently DefueledEmergency PlanRevision 0Page 28 of 5,360Entergy Vermont Yankee

2. The on-duty and selected plant personnel respond as directed by the ShiftManager and assume assigned functions;

3. Control Room personnel notify the Vermont, New Hampshire andMassachusetts State-authorities;

4. The NRC is notified;

5. Other support is requested as necessary;

6. The Emergency Call-in Method is implemented as shown in the notification plan (Figure 9.1);7. Additional personnel report to the plant as requested by the Shift Manager;8. The Shift Manager/Emergency Director directs the activities of emergency response personnel;

9. If necessary, appropriate emergency

medical, fire department, or lawenforcement agencies are notified and requested to respond;10. The public information representative is notified and handles publicinformation associated with the event; and11. The Shift Manager/Emergency Director terminates the Unusual Event statusand closes out the event with a verbal summary to offsite authorities orescalates to higher level emergency classification.

The Unusual Event status will be maintained until an escalation in emergency class occursor the event is terminated.

Offsite authorities will be informed of the change in theemergency status and the necessary documentation will be completed as specified in siteprocedures.

9.2.2. Alert ResponseAn Alert requires actions to assure that sufficient emergency response personnel aremobilized to respond to the accident conditions at the site. Notification is made toState/Commonwealth officials and follow-up information is provided as needed to offsiteemergency organizations.

In an Alert, the steps listed in the Unusual Event Responsesection (except for the termination process) and the following are performed:

1. ERO report to the Emergency Director;

2. The Emergency Director/Shift Manager directs the evacuation of all visitorsand unnecessary contractors from the plant;Permanently DefueledEmergency PlanRevision 0Page 29 of .5360Entergy Vermont Yankee

3. If sufficient personnel are not available onsite, off-duty personnel are called inas specified in the emergency implementing procedures;

4. The Emergency Director assumes total responsibility for overall emergency response actions and recovery;

5. The Emergency Director reaches agreement with offsite authorities concerning de-escalation or termination of the event, and closes out the eventby verbal summary to off site authorities.

If an event is a reportable occurrence, a written summary is issued to these authorities in an appropriate time frame through distribution by the Emergency Director.

The Alert status shall be maintained until termination of the event or de-escalation inemergency class occurs. The plant may enter recovery operation without de-escalating from a declared Alert. Off-site authorities will be informed of the change in the emergency status and the necessary documentation shall be completed as specified in siteprocedures.

9.3. Emergency Termination CriteriaAn extensive review of plant parameters including SFP parameters and process andradiation monitoring

systems, in conjunction with the pre-established EALs is required toterminate an emergency.

When plant conditions allow de-escalation in the emergency class, the Emergency Directordirects the emergency response organization to perform certain response actions prior toimplementing any change. These actions include:1. Notification of all plant emergency management personnel of the pendingchange;2. Notification of offsite authorities of the pending change;3. Notification of corporate support services of the pending change;4. Coordination of media releases concerning the transition; and5. Announcement of the transition over the plant page system.Termination of an emergency status is the responsibility of the Emergency Director.

Thedecision will be based on the following considerations:

1. Conditions no longer meet an EAL and it appears unlikely that conditions willdeteriorate; Permanently DefueledEmergency PlanRevision 0Page 30 of 5360Entergy Vermont Yankee

2. Plant releases of radioactive materials to the environment are under control(within Technical Specifications);

3. In-Plant radiation levels are stable or decreasing, and are acceptable givenplant conditions;

4. Operability and integrity of power supplies, electrical equipment and plantinstrumentation including radiation monitoring equipment is acceptable;

5. All required notifications have been made;6. Radiological and plant conditions permit resumption of normal occupational exposure limits to continue mitigation/repair activities.

Permanently DefueledEmergency PlanRevision 0Page 31 of 6360Entergy Vermont YankeeI (SHIFT MANAGERClassify incident and notify:* ,.. .* .,1VERMONT, NEW HAMPSHIRE, MASSACHUSETTS Notify State/Commonwealth Authorities JIIPATSNRCPLANT SECURITYEnotif icationHsytmjnPLANT EMERGENCY RESPONSE ORGANIZATION Respond as assignedIFigure 9.1Notification PlanPermanently DefueledEmergency PlanRevision 0Page 32 of &360IEntergy Vermont Yankee 10.0 RADIOLOGICAL ASSESSMENT AND PROTECTIVE MEASURES10.1. Radiological Assessment 10.1.1. Initial Radiological Dose Projection VY has developed a method to quickly determine the projected radiological conditions atthe Site boundary.

During the initial stages of an emergency, the Shift Manager ordesignated individual is responsible to perform the initial evaluation of radiological conditions.

The initial evaluation is accomplished in accordance with site procedures.

10.2. Radiological Exposure ControlDuring a plant emergency, abnormally high levels of radiation and/or radioactivity may beencountered by plant personnel.

All reasonable measures shall be taken to control theradiation exposure to emergency response personnel providing rescue, first aid,decontamination, emergency transportation, medical treatment

services, or corrective orassessment actions within applicable limits specified in 10 CFR Part 20.Table 10.1 specifies the guidelines on emergency dose limits for personnel providing emergency response duties consistent with Table 2-2, "Response Worker Guidelines,"

provided in the EPA PAG Manual. The Shift Manager/Emergency Director has theresponsibility to authorize emergency dose commitments in excess of 10 CFR Part 20limits. This authorization is coordinated with the assistance of the Radiation Protection Coordinator.

Exposure to individuals providing emergency functions will be consistent withthe limits specified in Table 10.1 with every attempt made to keep exposures As Low AsReasonably Achievable (ALARA).The Radiation Protection Coordinator is responsible for developing emergency radiological protection programs for ERO and augmented personnel.

Emergency kits are provided withself-reading dosimeters.

Each member reporting to the site will be provided a Dosimeter ofLegal Record (DLR). Dose records will be maintained based upon the results of theself-reading dosimeters.

This information is cross-referenced with the DLR data. Thecapability exists for the emergency processing of DLRs on a 24-hour per day basis.Emergency workers are instructed to read self-reading dosimeters frequently, and DLRsmay be processed with increased periodicity.

10.3. Protective Measures10.3.1. Site Personnel Accountability The goal of the personnel accountability process is to account for personnel at-within 60minutes of an Alert declaration.

Accountability for an Unusual Event is at the discretion ofthe Emergency Director.

Plant procedures require Security personnel to maintain a list ofpersonnel entering or leaving the site during a site evacuation.

In accordance with siteprocedures, following announcement of an emergency classification, plant personnel arePermanently DefueledEmergency PlanRevision 0Page 33 of -5360Entergy Vermont Yankee responsible for reporting to designated areas and aiding Security in the accountability process.The Emergency

Director, Technical Coordinator and Radiation Protection Coordinator areresponsible for accounting for their staff. An organizational sign-in method which enhancesthis reporting process is maintained.

All reports are provided to the Emergency

Director, who initiates search and rescue actions for any missing personnel.

Plant security providesassistance for this accountability effort and aids in the control of personnel during extendedemergency operations.

If personnel are not accounted for, the Control Room is notified andannouncements are made using the plant page system. If personnel are still unaccounted for following Control Room announcements, Security will initiate sweeps to locate themissing individuals.

Accountability may be modified or suspended if the safety of personnel may be jeopardized by a Security event or other event hazardous to personnel.

10.3.2. Site Egress Control MethodsAll visitors and unnecessary contractors are evacuated from the plant upon an Alertdeclaration.

All personnel are monitored for radioactive contamination prior to leaving thesite. Portable radiation survey meters are available to frisk personnel for suspected contamination.

If a Code Red Security event has been declared, evacuation andaccountability may put personnel at risk. In these security situations, evacuation andaccountability may be suspended until directed by Security.

Plant evacuees are advised of evacuation procedures prior to being released.

10.3.3. Contamination Control and Decontamination Capability During emergency conditions, VY maintains normal plant decontamination andcontamination control measures as closely as possible.

However, these measures may bemodified by the Emergency Director should conditions warrant.VY maintains contamination control measures to address area access control, drinkingwater and food supplies, and the return of areas and items to normal use.a. Contaminated areas are isolated as restricted areas with appropriate radiological protection and access control.

Personnel leaving contaminated areas are monitored toensure both themselves and their clothing are not contaminated.

Supplies, instruments, and equipment that are in contaminated areas or have been brought into contaminated areas will be monitored prior to removal.

Items found to be contaminated, will bedecontaminated using normal plant decontamination technigues and facilities or may bedisposed of as radioactive waste.Permanently DefueledEmergency PlanRevision 0Page 34 of -5360Entergy Vermont Yankee

b. Should the potential exist for contarnination of on-site food or drinking water suppliesthat renders these supplies non-consumable, VY will make arrangements for transport of non-contaminated off-site supplies.

c. VY permits areas and items to be returned to normal use following conduct ofappropriate surveys and verification that contamination levels have returned toacceptable levels.VY maintains an in-plant decontamination facility.

Waste generated through the use of thissystem is collected and processed by the plant liquid radwaste system. Surveyinstrumentation for personnel "frisking" and sensitive body burden monitoring equipment are available in various plant locations.

Decontamination is performed under the direction ofthe Radiation Protection Coordinator.

10.3.4. Use of Onsite Protective Equipment and SuppliesThe plant supplies of personnel radiation protection equipment and gear are utilized tosupport the emergency response effort. Equipment such as respiratory protection gear andprotective clothing is assigned to emergency response organization members and plantresponse personnel in accordance with established plant radiation protection criteria.

10.3.5. Fire FightingStrategies have been developed for firefighting and fire protection in specific critical areasof the plant. The Fire Protection Program describes the fire protection organization andindividual responsibilities.

10.4. Aid to Affected Personnel 10.4.1. Medical Treatment In-plant medical supplies are provided on-site.

Initial on-site medical treatment is providedby on-site personnel.

Arrangements exist with Brattleboro Memorial Hospital as indicated in Section 8.2.3.1.

Theagreement includes a commitment by the hospital to accept and treat plant personnel withroutine industrial injuries as well as injuries complicated by radioactive contamination orradiation exposure.

The hospital maintains the capability and facilities to providedecontamination.

The hospital participates in medical emergency drills.10.4.2. Medical Transportation Arrangements exist with Rescue, Inc., to provide 24-hour ambulance service for emergency transportation of plant personnel for offsite treatment.

The ambulance service is capable ofradio communications with the hospital while en route with a patient.

Normaltelecommunication channels are used in notifying the ambulance service dispatch center.Permanently DefueledEmergency PlanRevision 0Page 35 of -360Entergy Vermont Yankee Rescue, Inc. personnel are provided with specific training by VY on the health physicsconsiderations associated with radioactively contaminated personnel and site accesscontrol measures.

10.5. Protective Actions for Onsite Personnel A range of protective actions to protect onsite personnel is-are provided in Sections 10.2through 10.4 of this plan to ensure the continued ability to perform the functions of theemergency plan.Permanently DefueledEmergency PlanRevision 0Page 36 of --560Entergy Vermont Yankee TABLE 10.1EMERGENCY DOSE LIMITS(refer to Note 1)Guideline Activity Condition All reasonably achievable 5 rem All occupational exposures actions have been taken tominimize dose.Exceeding 5 rem unavoidable 10 rem(a) Protecting Valuable Property tand allappropriateduce dose.10 rem ~~~~~necessary for public welfare taetordcds.

Monitoring available to projector measure dose.Exceeding 5 rem unavoidable (b) Lifesaving or Protection of and all appropriate actions25 rem Lreboulto taken to reduce dose.Large Population Monitoring available to projector measure dose.NOTES:1. Reference for this table is Table 2-2 of the EPA PAG Manual.(a) For potential doses > 5 rem, medical monitoring programs should be considered.

(b) In the case of a very large incident, consider the need to raise the property and lifesaving Response Worker Guideline to prevent further loss.Permanently DefueledEmergency PlanRevision 0Page 37 of -5360Entergy Vermont YankeeI 11.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION 11.1. Emergency Notification The Shift Manager is responsible for the notification of an emergency declaration to theI States of Vermont and New Hampshire and the Commonwealth of Massachusetts.

Notification is made within 60 minutes of emergency declaration or change in classification.

Due to the slow rate of the postulated event scenarios in the accident analysis and theabsence of immediate actions necessary to protect the public health and safety, thenotification time of 60 minutes is appropriate.

The format and contents of the initial message between the plant and State/Commonwealth authorities are specified in notification procedures and have been established with thereview and agreement of responsible state authorities.

I The Department of Public Health of Vermont, New Hampshire and Massachusetts mayrequest the following information from VY:1. Date and time of the incident;

2. Emergency classification;

3. Status of the facility;

.4. Whether a release has occurred, is occurring, or is anticipated to occur;5. Actual or projected dose rates at the Site boundary; Follow-up reports are provided as additional information describing the emergency situation becomes available and on an as-needed basis until such time that the emergency condition has been terminated.

11.2. Public Information Any emergency generates a continuous and intensive demand for up-to-date information.

As part of its normal corporate structure, Entergy maintains a corporate public affairs office.Upon declaration of an Unusual Event or Alert, information is disseminated to the publicand briefings will be held with pertinent media organizations in accordance with Entergycorporate communication protocols.

Additionally,

Federal, State and local emergency response organizations maintain the capability to disseminate appropriate information regarding an emergency at VY.VY maintains a public inquiry phone for media and public use. During an emergency, apre-recorded message will provide up-to-date status reports regarding the situation.

Permanently DefueledEmergency PlanRevision 0Page 38 of -5360Entergy Vermont Yankee 12.0 MAINTAINING EMERGENCY PREPAREDNESS 12.1. Drills and Exercises An exercise tests the execution of the overall plant emergency preparedness and theintegration of this preparedness.

A drill is a supervised instruction period aimed at testing,developing and maintaining skills in a particular response function.

Emergency exercises and drills are conducted to test and evaluate the adequacy ofemergency facilities, equipment, procedures, communication

channels, actions ofemergency response personnel, and coordination between offsite organizations and thefacility.

A summary of exercises and drills and associated elements is outlined below.12.1.1. Radiation Emergency Exercises and DrillsBiennial exercises shall be conducted to test the timing and content of implementing procedures and methods; to test emergency equipment and communication networks; andto ensure that emergency personnel are familiar with their duties. VY offers the following organizations the opportunity to participate to the extent assistance would be expectedduring an emergency declaration;

however, participation is not required:

1. State of Vermont2. Brattleboro Memorial Hospital3. Brattleboro Fire Department

4. Law Enforcement

5. Rescue, Inc. Ambulance Service6. Town of Vernon5-.7. Vernon Fire Department At least one drill involving a combination of some of the principal functional areas ofemergency response shall be conducted in the interval between biennial exercises.

Communication checks with offsite agencies, fire drills, medical drills, radiological monitoring drills and health physics drills are performed as indicated in the following sections.

Permanently DefueledEmergency PlanRevision 0Page 39 of 5360Entergy Vermont Yankee 12.1.2. Communication TestsTo ensure that emergency communications systems described in Section 7.0 of this planare operable, communications tests are conducted as outlined below.1. Communication channels with the state governments of Vermont.

NewHampshire and the Commonwealth of Massachusetts, is tested monthly.These communications tests will include the aspect of understanding thecontent of messages.

2. The ENS is tested as described in subsection 7.6 of this plan.3. The following communication

systems, as detailed in Section 7.0 of this plan,are used on a frequent basis, therefore periodic testing of these systems isnot necessary:

• Mobile UHF Radio System* Plant Intercom System (Gai-Tronics)

• Commercial Telephone SystemTo ensure the reliability of the plant's call-in procedure, a semi-annual functional test of theERO notification system is performed to test system performance.

This can be performed separately or during the Augmentation Capability Drill described in Section 12.1.3.12.1.3. Augmentation Capability DrillsSemi-annual, off hours, unannounced, communications drill, utilizing both the EROnotification system and commercial telephone, to estimate emergency personnel responsetimes. No actual travel is required.

Participants provide an estimation of the time it wouldtake to report to their designated ERO position.

This drill shall serve to demonstrate thecapability to augment the on shift staff after declaration of an emergency.

12.1.4. Fire DrillsTo test and evaluate the response and training of the plant's fire brigade, fire drills areconducted in accordance with the Vermont Yankee Fire Protection Program.I To demonstrate the coordination between the plant's fire brigade and the Brattleboro andVernon Fire Departments, the fire departments is-are annually offered the opportunity toparticipate in an onsite fire drill.12.1.5. Medical DrillsTo evaluate the training of the facility's medical response and offsite medical responseI (Rescue, Inc. Ambulance ServiceambulaMne and Brattleboro Memorial Hospitalhospital),

aPermanently DefueledEmergency PlanRevision 0Page 40 of 5360Entergy Vermont Yankee medical drill is conducted annually with a simulated contaminated injured individual.

Thisdrill can be performed as part of an Emergency Plan drill or exercise.

12.1.6. Radiological Monitoring DrillsPlant environs and radiological monitoring drills are conducted annually.

These drillsinclude monitoring of accessible areas within the plant and include collection and analysisof airborne sample media, communications, and record keeping performed by members ofthe emergency team. This drill can be performed as part of an Emergency Plan drill orexercise.

12.1.7. Health Physics DrillsHealth Physics drills are conducted semi-annually involving response to, and analysis of,simulated elevated in-plant airborne and liquid samples and direct radiation measurements in the environment.

A drill can be performed as part of an Emergency Plan drill or exercise.

12.1.8. Security DrillsThe purpose of the security drill is to maintain key skills, specifically the site-specific teamskills necessary to mitigate security-based events. Security drills are conducted inaccordance with the Vermont Yankee Physical Security Plan.12.1.9. Scenarios An Exercise/Drill Coordinator is responsible for an Emergency Plan drill or exercise.

TheExercise/Drill Coordinator's responsibilities include developing the exercise/drill

scenario, the accident time sequence, and the selection and training of the Controllers required toevaluate the effectiveness of the VY Emergency Preparedness Program.A scenario is prepared by the Scenario Development Group for each exercise/drill to beconducted.

The scenario varies year to year and is approved by Vermont YankeeManagement.

Within an eight-year period, the scenario content is varied to test all themajor elements of the Emergency Preparedness Program.The contents of the scenario

include, but are not limited to, the following:

1. Basic objective(s);

2. Date, time period, place and participating organizations;

3. Simulation lists;4. Time schedule of real and simulated initiating events;Permanently DefueledEmergency PlanRevision 0Page 41 of -5360Entergy Vermont Yankee

5. A narrative summary describing the conduct of the drill or exercise to includesuch items as simulated casualties, search and rescue of personnel, deployment of radiological monitoring teams, and public information affairs;and6. List of Controllers.

The scenarios are designed to allow free play in exercising the decision-making processassociated with such emergency response actions as exposure

control, emergency classification and de-escalation, and the ERO and additional staff augmentation process.Security based scenarios to test and evaluate security response capabilities will beconducted in accordance with security drills and exercise procedures and may beconducted during Emergency Plan drills or exercises.

Starting times and pre-notification for exercises are coordinated with and agreed upon byall participating organizations.

12.1.10.

Evaluation of Exercises To evaluate the performance of participating facility personnel and the adequacy ofemergency facilities, equipment and procedures during an exercise, the ExerciseCoordinator obtains qualified controllers which includes resources outside the facility toevaluate and critique the exercise.

When feasible, personnel designated as controllers are assigned to an Emergency Planarea germane to their area of expertise.

Controllers are provided general instruction concerning their specific observation function.

Each controller is requested to observe theimplementation of the emergency plan element assigned to him or her, and then to recordand report observed inadequacies.

A critique is conducted at the conclusion of the exercise with facility personnel.

After thecritique, the controllers submit a written evaluation to the Exercise Coordinator in which theexercise performance is evaluated against the objectives.

All comments and/orrecommendations are documented.

Weaknesses and/or deficiencies identified in an exercise critique are processed inaccordance with the site corrective actions program.12.1.11.

Emergency Plan AuditThe VY Emergency Plan is independently audited as part of the Vermont Yankee In-plantAudit Program.

The audit is conducted as part of the Eitergy.-.Vermont Yankee NuclearPower Station Quality Assurance Program Manual in accordance with 10 CFR 50.54(t).

Allaspects of emergency preparedness, including exercise documentation, capabilities, procedures, and interfaces with state and local governments are audited.Permanently DefueledEmergency PlanRevision 0Page 42 of -5360Entergy Vermont Yankee 12.2. TraininaAll non-essential plant personnel receive annual instruction, in accordance with"Emergency Plan Training,"

concerning their expected response action during anemergency.

Those members of the plant staff who have been assigned to the ERO receiveannual training which includes, but is not limited to, the following:

1. Familiarize individuals with Emergency Plan and implementing procedures, especially where emergency response tasks are not part of their normalduties;2. Define an individual's responsibilities associated with their designated function;

3. Familiarize individuals in emergency exposure control measures andguidelines, particularly those associated with an individual's designated emergency functions; and4. Provide sufficient technical insight to maintain emergency functions.

A portion of this training is provided by personnel's participation in drills or exercises.

During these drills and exercises, controllers check the performance of the personnel

assigned, and provide critiques which could be incorporated in future training.

Specificdetails of the training given on an annual basis are described in "Emergency Plan Training,"

and in the Emergency Plan Training Program Description.

Training is offered annually to offsite response organizations that may be requested toprovide assistance in the event of an emergency at VY (e.g., law enforcement, fire-fighting, rescue, medical services, transport of iniured, etc.). The training shall be structured to meetthe needs of that organization with respect to the nature of their support.

Topics such asevent notification, site access procedures, basic radiation protection and interface activities between the offsite organization and VY are included in the traininq.

12.3. Review and Updating of Plan and Procedures The Emergency Plan is reviewed at least annually and the associated implementing procedures are reviewed at least biennially.

All recommendations for changes to theEmergency Plan or associated implementing procedures are reviewed in accordance with10 CFR 50.54(q).

The Emergency Plan is submitted to VY's On-Site Safety ReviewCommittee for approval.

Written agreements with outside support organizations and government agencies areevaluated annually to determine if these agreements are still valid. If agreements are notvalid, then they are renewed and updated.

This agreement review is documented.

Permanently DefueledEmergency PlanRevision 0Page 43 of -5,60Entergy Vermont Yankee Revisions to the Emergency Plan are made in accordance with current regulations andguidelines.

Changes to the Emergency Plan are forwarded to organizations and individuals with a responsibility for implementation of the Plan.Telephone number listings associated with the emergency notification process are verifiedquarterly.

12.4. Maintenance and Inventory of Emergency Equipment and SuppliesThe emergency equipment maintained in the Control Room is contained in a checklist inEmergency Equipment Readiness Check.Designated personnel conduct a weekly test of certain emergency communications equipment.

At least quarterly in accordance with the emergency equipment inventory procedure, and subsequent to each usage, designated VY personnel are assigned toinventory and maintain the emergency kits and/or equipment.

Rotation of surveyinstruments normally used in the plant with instruments in the Emergency Kits assures thatemergency equipment is calibrated and fully operable.

There are sufficient reserveinstruments and equipment to replace those that are removed from emergency kits forcalibration purposes.

Appendix B contains a list of emergency equipment by location.

12.5. Responsibility for the Planning EffortThe Senior Site Executive has overall responsibility for implementation of the Emergency Plan at VY. The Emergency Planning Manager is responsible for emergency planning andthe interface with offsite authorities and organizations.

The duties of the Emergency Planning Manager include, but are not limited to, the following:

1. Revise and update the Emergency Plan;2. Maintain the Emergency Plan implementing procedures so that they areupdated and current with the Emergency Plan;3. Schedule and ensure the conduct of emergency equipment inventories andcalibration;

4. Represent the plant in offsite Emergency Plan interfaces;

5. Represent the plant in NRC emergency planning appraisals and audits;6. Interface with the Exercise Coordinator in preparing and coordinating Emergency Plan drills and exercises; and7. Maintain drill and exercise documentation and coordinate implementation ofcorrective actions deemed necessary following drills and exercises.

Permanently DefueledEmergency PlanRevision 0Page 44 of 5360Entergy Vermont Yankee The Emergency Planning Manager is responsible for maintaining an adequate knowledge of regulations, planning techniques and the latest applications of emergency equipment and supplies.

Training for this position

includes, but is not limited to:1. Trainina courses soecific or related to emeraencv oreoaredness:

2. Observation of, or participation in, drills and/or exercises at otherdecommissioned nuclear power plants;3. Participation in industry review and evaluation Droarams:

4. Participation in regional or national emergency preparedness

seminars, conferences, committees, workshops or forums.Permanently DefueledEmergency PlanRevision 0Page 45 of -5360IEntergy Vermont Yankee APPENDIX AEMERGENCY CLASSIFICATION SYSTEMANDEMERGENCY ACTION LEVELS[NOTE: Reference AP 3125, Emergency Plan Classification and Action Level Scheme forthe most current revision of the EAL Charts.]Permanently DefueledEmergency PlanRevision 0Page 46 of -5,360Entergy Vermont Yankee APPENDIX BEMERGENCY EQUIPMENT This Appendix contains a list of emergency equipment by location.

Backup equipment isavailable at the Radiation Protection control point. In addition, the resources referenced insubsections 6.2.5 and 10.2 of this Plan are at the disposal of Vermont Yankee in anemergency.

Permanently DefueledEmergency PlanRevision 0Page 47 of 5360Entergy Vermont Yankee APPENDIX B (Continued)

EMERGENCY EQUIPMENT INVENTORY LOCATIONMAIN INNERCONTROL GATEEQUIPMENT ROOM HOUSERespiratory Protection Radiation Monitoring Dosimetry SamplingCommunications Dose Assessment Area MapsEmergency References

• Protective ClothingDecontamination Barrel *Administrative Support *Status Boards *Stack Sampling

• Sampling Cartridges

• _Portable LeadShielding

• Emergency Centers &Emergency Room *KeysStation SamplingCartridges

_Environmental StationKeys _(A more detailed listing of emergency equipment is provided in EPOP-EQUIP-3506, "Emergency Equipment Readiness Check")Permanently DefueledEmergency PlanRevision 0Page 48 of -360Entergy Vermont Yankee APPENDIX B (Continued)

EMERGENCY EQUIPMENT INVENTORY LOCATIONEQUIPMENT Provided by other non-affected Entergy nuclear sites, as neededGammaSpectroscopy High PressureIon ChamberMobileProcessing DLR UnitPersonnel

&Environmental DLRPermanently DefueledEmergency PlanRevision 0Page 49 of -5360IEntergy Vermont Yankee APPENDIX CENVIRONMENTAL LABORATORY ANALYTICAL AND DOSIMETRY SERVICESPermanently DefueledEmergency PlanRevision 0Page 50 of 5360IEntergy Vermont Yankee APPENDIX C (Continued)

GeneralIn the event of a radiological emergency at Vermont Yankee, laboratory services (asdescribed in 6.2.5) are available, on a 24-hour emergency call basis, to perform gammaisotopic analyses on samples taken by the plant's emergency monitoring teams. Portablegamma spectroscopy equipment can be deployed to the plant site to determine thepresence and level of contamination in samples of various media in the event of anaccidental release of radioactive material.

Portable Emergency Analysis Equipment Portable analysis equipment with computerized spectral analysis capability may bedeployed to assist in an emergency response.

A report of plant-related nuclideconcentrations, standard deviation, and Minimum Detectable Concentration (MDC) isforwarded to assessment personnel.

Following a request from Vermont Yankee for assistance in assessing an emergency condition, laboratory personnel will be dispatched to a designated location withinapproximately four (4) to eight (8) hours. Upon arrival, laboratory personnel will determine the presence and level of contamination in samples of various media (air cartridges, airfilters, vegetation, water).Emergency DLR ServicesThe capability exists for the emergency processing of DLRs on a 24-hour per day basis.Emergency workers are instructed to read self-reading dosimeters frequently, and DLRsmay be processed with increased periodicity.

Portable Body Burden ServiceA WBC System is comprised of a portable

detector, interfaced to a PC-based ADCI/MCAand IBM compatible portable computer may be acquired from the other industry facilities.

The analytical methodology provides a whole body scan and identifies activity content ofthe lung, GI, and thyroid.A result report is generated for those plant-related nuclides found to be present at the 99%confidence level.Permanently DefueledEmergency PlanRevision 0Page 51 of5360Entergy Vermont Yankee APPENDIX DLETTERS OF AGREEMENT Permanently DefueledEmergency PlanRevision 0Page 52 of -5,60IEntergy Vermont Yankee APPENDIX D (Continued)

Letters of agreement in effect between Vermont Yankee and the offsite authorities aremaintained in the Emergency Planning Department files. Entergy Operations, Inc.maintains agreements and/or contracts with the following organizations in support ofVermont Yankee Emergency Response.

Letters of Agreement have been ascertained with offsite groups to provide on-site aid in theevent of an emergency situation at Vermont Yankee.Ambulance Service:

Twenty-four (24) hour ambulance service is provided by Rescue Inc.Mutual aid backup from other ambulance services provides for additional emergency medical services, ambulances and EMS personnel.

Onsite procedures contain instructions that cover the call for assistance and the handling of the ambulance service personnel.

Radio communication exists between the ambulance and local hospitals.

Medical:

Onsite procedures contain instructions, which cover the request for medicalassistance and handling of patients.

Hospitals:

Brattleboro Memorial Hospital has agreed to accept patients from VermontYankee who have been injured, contaminated or irradiated.

Fire: Offsite firefighting support is provided by the Vernon and Brattleboro FireDepartments, as resources permit, with mutual aid backup from other fire departments.

Law Enforcement:

When notified that assistance is needed, Security will notify the LeadLocal Law Enforcement Agency (LLEA). The handling of security

matters, including thoseinvolving hostile action, is addressed in the Vermont Yankee Physical Security Plan andare classified as safeguards information.

Permanently DefueledEmergency PlanRevision 0Page 53 of -5360Entergy Vermont Yankee APPENDIX D (Continued)

Letters of Agreement

1. State of Vermont2. State of New Hampshire I-3. Commonwealth of Massachusetts

24. Brattleboro Memorial Hospital35. Rescue, Inc. Ambulance Service46. Vernon Fire Department

57. Brattleboro Fire Department 68_. Town of VernonI79. Department of Energy810. DOE- REAC/TS911. Law Enforcement*

All letters of agreement from Local Law Enforcement Authorities as required by thePhysical Security Plan are classified as Safeguards Information and as such aremaintained by Security.

Permanently DefueledEmergency PlanRevision 0Page 54 of -5360Entergy Vermont Yankee APPENDIX EINDEX OF EMERGENCY PLAN IMPLEMENTING PROCEDURES AND SUPPORT PLANSPermanently DefueledEmergency PlanRevision 0Page 55 of -5360Entergy Vermont Yankee APPENDIX E (Continued)

EMERGENCY PLAN IMPLEMENTING PROCEDURES AP 3125 Emergency Plan Classification and Action Level SchemeEPOP-COMM-3504 Emergency Communications EPOP-EQUIP-3506 Emergency Equipment Readiness CheckOP 3507 Emergency Radiation Exposure ControlOP 3508 Onsite Medical Emergency Procedure OP 3509 Environmental Sample Collection during an Emergency OP 3510 Site Boundary Monitoring AP 3532 Emergency Preparedness Organization OP 3536 In-plant Air Sample Analysis with Abnormal Conditions EPOP-CR-3540 Control Room Actions During an Emergency OP 3547 Security Actions During an Emergency OP 3548 Emergency Termination and RecoveryAP 3554 Emergency Plan TeamsAP 3712 Emergency Plan TrainingAP-10049 Equipment Important to Emergency ResponseEPAP-INFORM-10076 InForm Notification SystemEN-EP-303, Severe Weather RecoveryEN-EP-305, Emergency Planning 10 CFR 50.54(q)

Review ProgramEN-EP-306, Drills and Exercises EN-EP-308, Emergency Planning Critiques EN-EP-309, Fatigue Management for Hurricane Response Activities EN-EP-310, Emergency Response Organization Notification SystemEN-EP-401, Public Use of Emergency Preparedness Owner Controlled AreaEN-EP-606, Pandemic Flu ResponsePermanently DefueledEmergency PlanRevision 0Page 56 of 5360Entergy Vermont Yankee APPENDIX E (Continued)

II. SUPPORT PLANS*The Vermont Yankee Severe Accident Management Program (PP 7019)The Vermont Yankee Physical Security PlanVermont Yankee Fire Protection and Safe Shutdown (SEP-FP-VTY-003)

NRC Incident Response Plan (NUREG-0728)

National Response Framework (January 2008)Procedure for Admission and Management of Radioactively Contaminated Patientsat Brattleboro Memorial Hospital* This list does not reference any of the emergency plan arrangements specified inI Appendices D-C and E--Dof this plan.Permanently DefueledEmergency PlanRevision 0Page 57 of 5460Entergy Vermont Yankee APPENDIX FCROSS-REFERENCE BETWEEN THE PDEP, NUREG-0654/FEMA-REP-1.

the 10 CFR 50.47(b)

PLANNINGSTANDARDS, AND APPENDIX E.IV PLANNINGREQUIREMENTS Permanently DefueledEmergency PlanRevision 0Page 58 of -560Entergy Vermont Yankee APPENDIX F (Continued)

CROSS-REFERENCE BETWEEN THE PDEP. NUREG-0654/FEMA-REP-1.

the 10 CFR50.47(b)

PLANNING STANDARDS.

AND APPENDIX E.IV PLANNING REQUIREMENTS NUREG-0654, Section Planning Planning Requirement VY PDEPII Standard ppandix eqireen VYcPoEEvaluation Criteria (10 CFR 50.47)**

(Appendix E.IV)** Section7.0A (b0(1) A.1 2,4,7 8.08.1.1____ ___ ____ ___ __ ____ ___ ___Fiqure 8.18.08.18.1.1B (1b)(2) A.1. 2, 4, 9; C.1 8.28.3Table 8.110.4Appendix D3.78.1.1C (b)(3) A 8.2.3Appendix CAppendix DD (b) 8.1, 2; C.1, 2 5.0Appendix A8.39.09.2E (b)(5) A.6, 7; C.1,2; D.1, 3; E Table 9.111.1Appendix DAppendix E7.0Table 7.1F (b)(6) C.1, D.1,3; E 9.2Figure 9.112.1.2G ( A.7 LD.2 11.2Permanently DefueledEmergency PlanRevision 0Page 59 of -360Entergy Vermont Yankee APPENDIX F (Continued)

Permanently DefueledEmergency PlanRevision 0Page 60 of -5,360Entergy Vermont Yankee BVY 15-009Docket 50-271Attachment 3Vermont Yankee Nuclear Power StationPermanently Defueled Emergency Action Level Technical BasesRevision 0

SEntergyVermont Yankee Nuclear Power StationPermanently Defueled Emergency Action LevelTechnical BasesRevision 0Prepared by: (later)Planner, Emergency Planning----DateApproved by:Manager, Emergency PlanningDateApproved by:Manager, Operations DatePage 1 of 52 Table of ContentsSection Page1.0 PURPO SE ............................................................................................................................

42.0 DISCUSSIO N .......................................................................................................................

42.1 Perm anently Defueled Station .......................................................................................

42.2 Independent Spent Fuel Storage Installation

................................................................

43.0 KEY TERM INO LO GY USED .........................................................................................

53.1 Em ergency Classification Level .....................................................................................

63.2 Initiating Condition

.......................................................................................................

63.3 Em ergency Action Level ..............................................................................................

74.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS

......................................

74.1 G eneral Considerations

.................................................................................................

74.2 Classification M ethodology

............................................................................................

84.3 Classification of M ultiple Events and Conditions

..........................................................

84.4 Classification of Im m inent Conditions.

.........................................................................

84.5 Emergency Classification Level Upgrading and Downgrading

.....................................

84.6 Classification of Short-Lived Events ..............................................................................

94.7 Classification of Transient Conditions

............................................................................

94.8 After-the-Fact Discovery of an Emergency Event or Condition

..................................

104.9 Retraction of an Em ergency Declaration

....................................................................

1

05.0 REFERENCES

...................................................................................................................

105.1 Developm ental .................................................................................................................

105.2 Im plem enting ...................................................................................................................

105.3 Com m itm ents ..................................................................................................................

106.0 DEFINITIO NS & AC RO NYM S .......................................................................................

117.0 VYNPS-TO-NEI 99-01 EAL CROSS REFERENCE

......................................................

158.0 ATTACHM ENTS .................................................................................................................

158.1 Attachment 1, Recognition Category PD EAL Bases .................................................

16Abnorm al Rad Levels/Rad Effluent

...................................................................................

18PD-AU1.1 Unusual Event ............................................................................................

18PD-AU1.2 Unusual Event ............................................................................................

20PD-AA1.1 Alert ................................................................................................................

22Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 2 of 52 PD-AA1.2 Alert ................................................................................................................

24PD-AA1.3 Alert ................................................................................................................

26PD-AA1.4 Alert ................................................................................................................

28PD-AU2.1 Unusual Event ...........................................................................................

30PD-AU2.2 Unusual Event ...........................................................................................

32PD-AA2.1 Alert ................................................................................................................

34PD-AA2.2 Alert ................................................................................................................

35Hazards and Other Conditions Affecting Plant Safety ....................................................

37PD-HU1.1 Unusual Event ............................................................................................

37PD-HU1.2 Unusual Event ............................................................................................

38PD-HU1.3 Unusual Event ............................................................................................

39PD-HA1.1 Alert ................................................................................................................

40PD-HA1.2 Alert ................................................................................................................

42PD-HU2.1 Unusual Event ............................................................................................

44PD-HU3.1 Unusual Event ............................................................................................

46PD-HA3.1 Alert ................................................................................................................

47System Malfunction

.............................................................................................................

48PD-SU1.1 Unusual Event ............................................................................................

488.2 Attachment 2, Recognition Category E EAL Basis ......................................................

49Independent Spent Fuel Storage Installation

...................................................................

51E-HU1.1 Unusual Event ................................................................................................

51Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 3 of 52 1.0 PURPOSEThis document provides the detailed set of Emergency Action Levels (EALs) applicable to theVermont Yankee Nuclear Power Station (VY) and the associated Technical Bases using theEAL development methodology found in NEI 99-01, "Development of Emergency Action Levelsfor Non-Passive Reactors,"

Revision 6 (NEI 99-01, Rev. 6). As a Permanently Defueled Station,VY will use the Recognition Category "PD" (Permanently Defueled) providing a stand-alone setof ICs/EALS for a permanently defueled nuclear power plant to consider for use in developing asite-specific emergency classification scheme. (Permanently defueled station ICs and EALs areaddressed in Appendix C of NEI 99-01, Rev. 6.) All recommendations for changes to thisdocument or associated implementing procedures are reviewed in accordance with 10 CFR50.54(q).

This document should be used to facilitate review of the VY EALs, provide historical documentation for future reference and serve as a resource for training.

Decision-makers responsible for implementation of AP-3125, Emergency Plan Classification and Action LevelScheme, may use this document as a technical reference in support of EAL interpretation.

The expectation is that emergency classifications are to be made as soon as conditions arepresent and recognizable for the classification, but within 60 minutes or less in all cases ofconditions present.

Use of this document for assistance is not intended to delay the emergency classification.

2.0 DISCUSSION

2.1 Permanently Defueled StationNEI 99-01 provides guidance for an emergency classification scheme applicable to apermanently defueled station.

This is a station that generated spent fuel under a 10 CFR Part50 license, has permanently ceased operations and will store the spent fuel onsite for anextended period of time. The emergency classification levels applicable to this type of stationare consistent with the requirements of 10 CFR Part 50 and NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans andPreparedness in Support of Nuclear Power Plants, Rev. 1" (NUREG-0654).

In order to relax the emergency plan requirements applicable to an operating

station, the ownerof a permanently defueled station must demonstrate that no credible event can result in asignificant radiological release beyond the site boundary.

It is expected that this verification willconfirm that the source term and motive force available in the permanently defueled condition are insufficient to warrant classifications of a Site Area Emergency or General Emergency.

Therefore, the generic Initiating Conditions (ICs) and Emergency Action Levels (EALs)applicable to a permanently defueled station may result in either a Notification of Unusual Event(Unusual Event) or Alert classification.

2.2 Independent Spent Fuel Storage Installation Selected guidance in NEI 99-01, Rev. 6 is applicable to licensees electing to use their 10 CFRPart 50 emergency plan to fulfill the requirements of 10 CFR 72.32 for a stand-alone Independent Spent Fuel Storage Installation (ISFSI).

The emergency classification levelsapplicable to an ISFSI are consistent with the requirements of 10 CFR Part 50. The initiating Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 4 of 52 conditions germane to a 10 CFR 72.32 emergency plan (as described in NUREG-1567) aresubsumed within the classification scheme for a 10 CFR 50.47 emergency plan.The analysis of potential onsite and offsite consequences of accidental releases associated withthe operation of an ISFSI is contained in NUREG-1 140, "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees" (NUREG-1 140).NUREG-1 140 concluded that the postulated worst-case accident involving an ISFSI hasinsignificant consequences to public health and safety. This evaluation shows that the maximumoffsite dose to a member of the public due to an accidental release of radioactive materials would not exceed 1 rem Effective Dose Equivalent.

Regarding the above information, the expectations for an offsite response to an Alert classified under a 10 CFR 72.32 emergency plan are generally consistent with those for an Unusual Eventin a 10 CFR 50.47 emergency plan (e.g., to provide assistance, if requested).

Also, thelicensee's Emergency Response Organization (ERO) required for 10 CFR 72.32 emergency plan is different than that prescribed for a 10 CFR 50.47 emergency plan (e.g., no emergency technical support function).

3.0 KEY TERMINOLOGY USEDThere are several key terms that appear throughout the NEI 99-01, Rev. 6 methodology.

Theseterms are introduced in this section to support understanding of subsequent material.

As an aidto the reader, the following table is provided as an overview to illustrate the relationship of theterms to each other.Emergency Classification LevelUnusual Event AlertInitiating ondition Initiating onditionPermanently Defueled Emergency Action Permanently Defueled Emergency ActionLevel' Level1" Notes 0 Notes* Basis o Basis1 When Making an emergency classification, the Shift Manager/Emergency Director mustconsider all information having a bearing on the proper assessment of an Initiating Condition.

This includes the PD EALs, Notes and the Basis information.

Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 5 of 52 3.1 Emergency Classification LevelOne of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) forgrouping off-normal events or conditions according to (1) potential or actual effects orconsequences, and (2) resulting onsite and offsite response actions.

The emergency classification levels, in ascending order of severity, are:* Unusual Event* Alert3.1.1 Unusual EventEvents are in progress or have occurred which indicate a potential degradation ofthe level of safety of the plant or indicate a security threat to facility protection hasbeen initiated.

No releases of radioactive material requiring offsite response ormonitoring are expected unless further degradation of safety systems occurs.Purpose:

The purpose of this classification is to assure that the first step in futureresponse has been carried out, to bring the operations staff to a state of readiness, and to provide systematic handling of unusual event information and decision-making.3.1.2 AlertEvents are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event thatinvolves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to smallfractions of the EPA PAG exposure levels.Purpose:

The purpose of this classification is to assure that emergency personnel are readily available to respond if the situation becomes more serious or to performconfirmatory radiation monitoring if required, and provide offsite authorities currentinformation on plant status and parameters.

3.2 Initiating Condition An event or condition that aligns with the definition of one of the two emergency classification levels by virtue of the potential or actual effects or consequences.

Discussion:

An Initiating Condition (IC) describes an event or condition, the severity orconsequences of which meets the definition of an emergency classification level. An IC can beexpressed as a continuous, measurable parameter (e.g., radiation monitor readings) or an event(e.g., an earthquake).

Appendix 1 of NUREG-0654 does not contain example EALs for each ECL, but rather Initiating Conditions (i.e., plant conditions that indicate that a radiological emergency, or events that couldlead to a radiological emergency, has occurred).

NUREG-0654 states that the Initiating Conditions form the basis for establishment by a licensee of the specific plant instrumentation readings (as applicable) which, if exceeded, would initiate the emergency classification.

Thus, itis the specific instrument readings that would be the EALs.Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 6 of 52 3.3 Emergency Action LevelA pre-determined, site-specific, observable threshold for an IC that, when met or exceeded, places the plant in a given emergency classification level.Discussion:

EAL statements may utilize a variety of criteria including instrument readings andstatus indications; observable events; results of calculations and analyses; entry into particular procedures; and the occurrence of natural phenomena.

4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 4.1 General Considerations When making an emergency classification, the Emergency Director must consider allinformation having a bearing on the proper assessment of an IC. This includes the EAL plusNotes and the informing Basis information.

All emergency classification assessments should be based upon valid indications, reports orconditions.

A valid indication, report, or condition, is one that has been verified throughappropriate means such that there is no doubt regarding the indicator's operability, thecondition's existence, or the report's accuracy.

For example, validation could be accomplished through an instrument channel check, response on related or redundant indicators, or directobservation by plant personnel.

The validation of indications should be completed in a mannerthat supports timely emergency declaration.

For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 60 minutes, etc.), theEmergency Director should not wait until the applicable time has elapsed, but should declare theevent as soon as it is determined that the condition has exceeded, or will likely exceed, theapplicable time. If an ongoing radiological release is detected and the release start time isunknown, it should be assumed that the release duration specified in the IC/EAL has beenexceeded, absent data to the contrary.

A planned work activity that results in an expected event or condition which meets or exceeds anEAL does not warrant an emergency declaration provided that 1) the activity proceeds asplanned and 2) the plant remains within the limits imposed by the operating license.

Suchactivities include planned work to test, manipulate, repair, maintain or modify a system orcomponent.

In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the operating licenseprovided that the activity proceeds and concludes as expected.

Events or conditions of this typemay be subject to the reporting requirements of 10 CFR 50.72.The assessment of some EALs is based on the results of analyses that are necessary toascertain whether a specific EAL threshold has been exceeded (e.g., gaseous and liquid effluentsampling, etc.); the EAL and/or the associated basis discussion will identify the necessary analysis.

In these cases, the declaration period starts with the availability of the analysis resultsthat show the threshold to be exceeded (i.e., this is the time that the EAL information is firstavailable).

Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 7 of 52 While the EALs have been developed to address a full spectrum of possible events andconditions which may warrant emergency classification, a provision for classification based onoperator/management experience and judgment is still necessary.

The NEI 99-01 schemeprovides the Emergency Director with the ability to classify events and conditions based uponjudgment using EALs that are consistent with the ECL definitions (refer to PD-HU3 and PD-HA3). The Emergency Director will need to determine if the effects or consequences of theevent or condition reasonably meet or exceed a particular ECL definition.

4.2 Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e., therelevant plant indications and reports) to an EAL(s) and determine if the EAL has been met orexceeded.

The evaluation of an EAL(s) must be consistent with the Notes. If an EAL has beenmet or exceeded, then the IC is considered met and the associated ECL is declared inaccordance with plant procedures.

When assessing an EAL that specifies a time duration for the off-normal condition, the EAL timeduration runs concurrently with the emergency notification time duration.

4.3 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met orexceeded EALs. The highest applicable ECL identified during this review is declared.

Forexample:* If an Unusual Event EAL and an Alert EAL are met, an Alert should be declared.

There is no "additive" effect from multiple EALs meeting the same ECL. For example:0 If two Alert EALs are met, an Alert should be declared.

Related guidance concerning classification of rapidly escalating events or conditions is providedin Regulatory Issue Summary (RIS) 2007-02, "Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events."4.4 Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Director must remain alert to eventsor conditions that could lead to meeting or exceeding an EAL within a relatively short period oftime (i.e., a change in the ECL is IMMINENT).

If, in the judgment of the Emergency

Director, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL hasbeen met. While applicable to all emergency classification levels, this approach is particularly important at the higher emergency classification level since it provides additional time forimplementation of protective measures.

4.5 Emergency Classification Level Upgrading and Downgrading An ECL may be downgraded when the event or condition that meets the highest IC and EAL nolonger exists, and other site-specific downgrading requirements are met. If downgrading the ECLPermanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 8 of 52 is deemed appropriate, the new ECL would then be based on a lower applicable IC(s) andEAL(s). The ECL may also simply be terminated.

The following approach to downgrading or terminating an ECL is recommended:

ECL Action When Condition No Longer ExistsUnusual Event Terminate the emergency in accordance withplant procedures Alert Downgrade or terminate the emergency inaccordance with plant procedures.

As noted above, guidance concerning classification of rapidly escalating events or conditions isprovided in RIS 2007-02.4.6 Classification of Short-Lived EventsEvent-based Ils and EALs define a variety of specific occurrences that have potential or actualsafety significance.

By their nature, some of these events may be short-lived and, thus, overbefore the emergency classification assessment can be completed.

If an event occurs thatmeets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration.

Examples of such events would be an earthquake or anexplosion.

4.7 Classification of Transient Conditions Many of the ICs and/or EALs contained in this document employ time-based criteria.

Thesecriteria will require that the IC/EAL conditions be present for a defined period of time before anemergency declaration is warranted.

In cases where no time-based criterion is specified, it isrecognized that some transient conditions may cause an EAL to be met for a brief period of time(e.g., a few seconds to a few minutes).

The following guidance should be applied to theclassification of these conditions.

EAL momentarily met during expected plant response

-In instances where an EAL is briefly metduring an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected, and operatoractions are performed in accordance with procedures.

EAL momentarily met but the condition is corrected prior to an emergency declaration

-If anoperator takes prompt manual action to address a condition, and the action is successful incorrecting the condition prior to the emergency declaration, then the applicable EAL is notconsidered met and the associated emergency declaration is not required.

It is important to stress that the emergency classification assessment period is not a "graceperiod" during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event; emergency classification assessments must be deliberate and timely, with no undue delays.Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 9 of 52 4.8 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the timeof the event or condition.

This situation can occur when personnel discover that an event orcondition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery.

This may be due to the event or condition not beingrecognized at the time or an error that was made in the emergency classification process.In these cases, no emergency declaration is warranted;

however, the guidance contained inNUREG-1 022, "Event Report Guidelines 10 CFR 50.72 and 50.73," is applicable.

Specifically, the event should be reported to the NRC in accordance with 10 CFR § 50.72 within one hour ofthe discovery of the undeclared event or condition.

The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.

4.9 Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed inNUREG-1022.

5.0 REFERENCES

5.1 Developmental

5.1.1 NEI 99-01 Revision 6, Development of Emergency Action Levels for Non-Passive

Reactors, November 20125.1.2 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities 5.1.3 RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications DuringQuickly Changing E vents, February 20075.1.4 NUREG-1 022, Event Reporting Guidelines 10 CFR 50.72 and 50.735.1.5 1- CFR 50.72, Immediate Notification Requirements for Operating Nuclear PowerReactors5.1.6 NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation ofRadiological Emergency Response Plans and Preparedness in Support ofNuclear Power Plants5.1.7 10 CFR 72.32, Emergency Plan5.1.8 NUREG-1567, Spent Fuel Dry Storage Facilities 5.1.9 10 CFR 50.47, Emergency Plans5.1.10 NUREG-1 140, A Regulatory Analysis on Emergency Preparedness for FuelCycle and Other Radioactive Material Licensees

5.2 Implementing

5.2.1 AP-3125 Emergency Plan Classification and Action Level Scheme5.2.2 EAL Comparison Matrix5.2.3 EAL Classification Matrix5.3 Commitments Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 10 of 52 None6.0 DEFINITIONS

& ACRONYMSAcronymsCDE ..................................................................................................

Com m itted Dose Equivalent CFR .................................................................................................

Code of Federal Regulations EAL .........................................................................................................

Em ergency Action LevelECL .............................................................................................

Em ergency Classification LevelEO P ..........................................................................................

Em ergency O perating Procedure EPA ..........................................................................................

Environm ental Protection AgencyFAA ........................................................................................................

Federal Aviation AgencyFBI ...............................................................................................

Federal Bureau of Investigation FEM A ..........................................................................

Federal Em ergency M anagem ent AgencyFSAR ...............................................................................................

Final Safety Analysis ReportISFSI .......................................................................

Independent Spent Fuel Storage Installation IC .....................................................................................................................

Initiating Condition M PF ......................................................................................................

M axim um Probable Floodm rem ............................................................................................

m illi-Roentgen Equivalent M anM SL ....................................................................................................................

M ean Sea LevelNEI .........................................................................................................

Nuclear Energy Institute NO RAD ..............................................................

North Am erican Aerospace Defense Com m andNPP ..............................................................................................................

Nuclear Power PlantNRC ...........................................................................................

Nuclear Regulatory Com m issionODCM/ODAM

....................................................

Off-site Dose Calculation (Assessment)

ManualO RO ...........................................................................................

Off-site Response O rganization PAG .........................................................................................................

Protective Action G uiderem ......................................................................................................

Roentgen Equivalent M anSM ..........................................................................................................................

Shift M anagerTEDE ...........................................................................................

Total Effective Dose Equivalent Definitions The following definitions are taken from Title 10, Code of Federal Regulations, and relatedguidance documents.

AlertEvents are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable lifePermanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 11 of 52 threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION.Any releases are expected to be limited to small fractions of the EPA PAG exposure levels.Unusual EventEvents are in progress or have occurred which indicate a potential degradation of the level ofsafety of the plant or indicate a security threat to facility protection has been initiated.

Noreleases of radioactive material requiring offsite response or monitoring are expected unlessfurther degradation of safety systems occurs.The following are key terms necessary for overall understanding the NEI 99-01 emergency classification scheme.Emergency Action Level (EAL): A pre-determined, site-specific, observable threshold for anInitiating Condition that, when met or exceeded, places the plant in a given emergency classification level.Emergency Classification Level (ECL): One of a set of names or titles established by the USNuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to(1) potential or actual effects or consequences, and (2) resulting onsite and offsite responseactions.

The ECLs, in ascending order of severity, are:" Unusual Event" AlertEmergency Action LevelsA pre-determined, site-specific, observable threshold for an Initiating Condition that, when met orexceeded, places the plant in a given emergency classification level.Initiating Condition (IC)An event or condition that aligns with the definition of one of the two emergency classification levels by virtue of the potential or actual effects or consequences.

Selected terms used in Initiating Condition and Emergency Action Level statements are set in allcapital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings asused in this document.

The definitions of these terms are provided below.CONFINEMENT BOUNDARYThe barrier(s) between areas containing radioactive substances and the environment.

EXPLOSION A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemicalreaction or over pressurization.

A release of steam (from high energy lines or components) or anelectrical component failure (caused by short circuits, grounding, arcing, etc.) should notPermanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 12 of 52 automatically be considered an explosion.

Such events may require a post-event inspection todetermine if the attributes of an explosion are present.FIRECombustion characterized by heat and light. Sources of smoke such as slipping drive belts oroverheated electrical equipment do not constitute FIRES. Observation of flame is preferred butis NOT required if large quantities of smoke and heat are observed.

HOSTAGEA person(s) held as leverage against the station to ensure that demands will be met by thestation.HOSTILE ACTIONAn act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air,land, or water using guns, explosives, PROJECTILES,

vehicles, or other devices used to deliverdestructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTIONshould not be construed to include acts of civil disobedience or felonious acts that are not part ofa concerted attack on the NPP. Non-terrorism-based EALs should be used to address suchactivities, (i.e., this may include violent acts between individuals in the owner controlled area).HOSTILE FORCEOne or more individuals who are engaged in a determined

assault, overtly or by stealth anddeception, equipped with suitable weapons capable of killing,

maiming, or causing destruction.

IMMINENTThe trajectory of events or conditions is such than an EAL will be met within a relatively shortperiod of time regardless of mitigation or corrective actions.INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)A complex that is designed and constructed for the interim storage of spent nuclear fuel andother radioactive materials associated with spent fuel storage.NORMAL LEVELSAs applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.OWNER CONTROLLED AREAThe area outside the Protected Area, owned by Entergy.Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 13 of 52 PROJECTILE An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.PROTECTED AREAAn area which normally encompasses all controlled areas within the security protected areafence as depicted in Drawing 5920-13013, Protected Area Fence.SECURITY CONDITION Any Security Event as listed in the approved security contingency plan that constitutes athreat/compromise to site security, threat/risk to site personnel, or a potential degradation to thelevel of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.UNPLANNED A parameter change or an event that is not 1) the result of an intended evolution or 2) anexpected plant response to a transient.

The cause of the parameter change or event may beknown or unknown.VISIBLE DAMAGEDamage to a component or structure that is readily observable without measurements, testing,or analysis.

The visual impact of the damage is sufficient to cause concern regarding theoperability or reliability of the affected component or structure.

Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 14 of 52 7.0 VYNPS-TO-NEI 99-01 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of a Vermont Yankee EALwithin the NEI 99-01, Rev. 6 IC/EAL identification scheme. Further information regarding thedevelopment of the Vermont Yankee EALs based on the NEI guidance can be found in the EALComparison Matrix (Reference 5.2.2).VY Permanently Defueled IC/EALs NEI 99-01, Rev. 6, Appendix C -Permanently Defueled Station ICs/EALsPD-AUP1 PD-AU 1PD-AA1 PD-AA1PD-AU2 PD-AU2PD-AA2 PD-AA2PD-HU1 PD-HU1PD-HA1 PD-HA1PD-HU2 PD-HU2PD-HU3 PD-HU3PD-HA3 PD-HA3PD-SU1 PD-SU1VY ISFSI ICs/EAL NEI 99-01, Rev. 6, Section 8 -ISFSI ICs/ EALsE-HU1 E-HU18.0 ATTACHMENTS 8.1 Attachment 1, Recognition Category PD EAL Bases8.2 Attachment 2, Recognition Category E EAL BasisVermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 15 of 52 Attachment 1 -Recognition Category PD EAL Bases8.1 Attachment 1 -Recognition Category PD EAL BasesRecognition Category PD provides a stand-alone set of ICs/EALs for a Permanently Defuelednuclear power plant to consider for use in developing a site-specific emergency classification scheme. For development, it was assumed that the plant had operated under a 10 CFR § 50license and that the operating company has permanently ceased plant operations.

Further, thecompany intends to store the spent fuel within the plant for some period of time.When in a permanently defueled condition, the plant licensee typically receives approval fromthe NRC for exemption from specific emergency planning requirements.

These exemptions reflect the lowered radiological source term and risks associated with spent fuel pool storagerelative to reactor at-power operation.

Source terms and accident analyses associated withplausible accidents are documented in the station's Final Safety Analysis Report (FSAR), asupdated.

As a result, each licensee will need to develop a site-specific emergency classification scheme using the NRC-approved exemptions, revised source terms, and revised accidentanalyses as documented in the station's FSAR.Recognition Category PD uses the same ECLs as operating reactors;

however, the source termand accident analyses typically limit the ECLs to an Unusual Event and Alert. The UnusualEvent ICs provide for an increased awareness of abnormal conditions while the Alert ICs arespecific to actual or potential impacts to spent fuel. The source terms and release motive forcesassociated with a permanently defueled plant would not be sufficient to require declaration of aSite Area Emergency or General Emergency.

A permanently defueled station is essentially a spent fuel storage facility with the spent fuel isstored in a pool of water that serves as both a cooling medium (i.e., removal of decay heat) andshield from direct radiation.

These primary functions of the spent fuel storage pool are the focusof the Recognition Category PD ICs and EALs. Radiological effluent IC and EALs were includedto provide a basis for classifying events that cannot be readily classified based on anobservable events or plant conditions alone.Appropriate ICs and EALs from Recognition Categories A, C, F, H, and S were modified andincluded in Recognition Category PD to address a spectrum of the events that may affect aspent fuel pool. The Recognition Category PD ICs and EALs reflect the relevant guidance inthis document (e.g., the importance of avoiding both over-classification and under-classification).

Nonetheless, each licensee will need to develop their emergency classification scheme using the NRC-approved exemptions, and the source terms and accident analysesspecific to the licensee.

Security-related events will also need to be considered.

The following table, Table PD-1: Recognition Category "PD" Initiating Condition Matrix, providesa summary of initiating conditions associated with Recognition Category PD.Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 16 of 52 Attachment 1 -Recognition Category PD EAL BasesTable PD-I: Recognition Category "PD" Initiating Condition MatrixUNUSUAL EVENT ALERTPD-AU1 Release of gaseous or liquid PD-AA1 Release of gaseous or liquidradioactivity greater than 2 times the ODCM radioactivity resulting in offsite dose greaterlimits for 60 minutes or longer, than 10 mrem TEDE or 50 mrem thyroid CDE.PD-AU2 UNPLANNED rise in plant radiation PD-AA2 UNPLANNED rise in plant radiation levels. levels that impedes plant access required tomaintain spent fuel integrity.

PD-HU1 Confirmed SECURITY CONDITION PD-HA1 HOSTILE ACTION within theor threat. OWNER CONTROLLED AREA or airborneattack threat within 30 minutes.PD-HU2 Hazardous event affecting SAFETYSYSTEM equipment necessary for spent fuelcooling.PD-HU3 Other conditions exists which in the PD-HA3 Other conditions exists which in thejudgment of the Emergency Director warrant judgment of the Emergency Director warrantdeclaration of an Unusual Event. declaration of an Alert.PD-SU1 UNPLANNED spent fuel pooltemperature rise.Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 17 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

Initiating Condition:

A -Abnormal Rad Levels/Rad EffluentRelease of gaseous or liquid radioactivity greater than 2 times theradiological effluent Offsite Dose Calculation Manual (ODCM) limits for60 minutes or longer.EAL:PD-AU1.1Reading on an effluent radiation monitor greater than the values shown for 60 minutes orlonger.Gaseous Action ValueGas-1 [RM-17-156]

2 X High AlarmGas-2 [RM-17-157]

2 X High AlarmLiquid Action ValueSW Discharge Hdr Discharge Monitor [RM-17-351]

2 X High AlarmNote 1: The Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes hasbeen exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release durationhas exceeded 60 minutes.Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the releasepath, then the effluent monitor reading is no longer valid for classification purposes.

Vermont Yankee Basis:This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time(e.g., an uncontrolled release).

It includes any gaseous or liquid radiological

release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to preventunintentional

releases, and to control and monitor intentional releases.

The occurrence of anextended, uncontrolled radioactive release to the environment is indicative of degradation inthese features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to theenvironment is established.

If the effluent flow past an effluent monitor is known to have stoppedVermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 18 of 52 Attachment 1 -Recognition Category PD EAL Basesdue to actions to isolate the release path, then the effluent monitor reading is no longer valid forclassification purposes.

Releases should not be prorated or averaged.

For example, a release exceeding 4 times releaselimits for 30 minutes does not meet the EAL.EAL PD-AU 1.1 addresses radioactivity releases that cause effluent radiation monitor readings toexceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically beassociated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).The high alarm setpoint for the Stack Gas Monitor RM-17-156/157 (Gas-1 or Gas-2) isestablished to ensure the ODCM release limits are not exceeded.

(Reference 3)In a permanently shutdown and defueled condition, the only credible scenario for releasing gaswould be to damage spent fuel during handling.

The high alarm setpoint for SW Discharge Hdr Discharge Monitor (RM-1 7-351) is established toensure the ODCM release limits are not exceeded.

(Reference 7)Escalation of the emergency classification level would be via IC PD-AA1.Vermont Yankee Basis Reference(s):

1. VYNPS ODCM2. VYNPS ODCM Table 3.1.2 Gaseous Effluent Monitoring Instrumentation

3. VYNPS ODCM Section 8.2 Gaseous Effluent Instrumentation Setpoints

4. VYNPS ODCM Section 9.2 In-plant Radioactive Gaseous Effluent Pathways5. Alarm Response Sheet (ARS) 9-3-G-7/8

6. VYNPS ODCM Table 3.1.1 Liquid Effluent Monitoring Instrumentation

7. VYNPS ODCM Section 8.1 Liquid Effluent Instrumentation Setpoints

8. VYNPS ODCM Section 9.1 In-plant Radioactive Liquid Effluent PathwaysPermanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 19 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

A -Abnormal Rad Levels/Rad EffluentInitiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times theradiological effluent Offsite Dose Calculation Manual (ODCM) limits for60 minutes or longer.EAL:PD-AU1.2Sample analysis for a gaseous or liquid release indicates a concentration or release rategreater than 2 times the ODCM limits for 60 minutes or longer.Note 1: The Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes hasbeen exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release durationhas exceeded 60 minutes.Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the releasepath, then the effluent monitor reading is no longer valid for classification purposes.

Vermont Yankee Basis:This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time(e.g., an uncontrolled release).

It includes any gaseous or liquid radiological

release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to preventunintentional

releases, and to control and monitor intentional releases.

The occurrence of anextended, uncontrolled radioactive release to the environment is indicative of degradation inthese features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to theenvironment is established.

If the effluent flow past an effluent monitor is known to have stoppeddue to actions to isolate the release path, then the effluent monitor reading is no longer valid forclassification purposes.

Releases should not be prorated or averaged.

For example, a release exceeding 4 times releaselimits for 30 minutes does not meet the EAL.EAL PD-AU1.2 addresses uncontrolled gaseous or liquid releases that are detected by sampleanalyses or environmental

surveys, particularly on unmonitored pathways (e.g., spills ofradioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 20 of 52 Attachment 1 -Recognition Category PD EAL BasesReleases in excess of two times the site ODCM (Reference

3) instantaneous limits that continuefor 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the Unusual Eventemergency class) is not the primary concern here; it is the degradation in plant control implied bythe fact that the release could possibly continue for a prolonged duration.

In a permanently shutdown and defueled condition, the only credible scenario for releasing gaswould be to damage spent fuel during handling.

Escalation of the emergency classification level would be via IC PD-AA1.Vermont Yankee Basis Reference(s):

1. VYNPS ODCM2. VYNPS ODCM Table 3.1.2 Gaseous Effluent Monitoring Instrumentation

3. VYNPS ODCM Section 8.2 Gaseous Effluent Instrumentation Setpoints

4. VYNPS ODCM Section 9.2 In-plant Radioactive Gaseous Effluent Pathways5. ARS 9-3-G-7/8

6. VYNPS ODCM Table 3.1.1 Liquid Effluent Monitoring Instrumentation

7. VYNPS ODCM Section 8.1 Liquid Effluent Instrumentation Setpoints

8. VYNPS ODCM Section 9.1 In-plant Radioactive Liquid Effluent PathwaysVermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 21 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

Initiating Condition:

A -Abnormal Rad Levels/Rad EffluentRelease of gaseous or liquid radioactivity resulting in offsite dosegreater than 10 mrem TEDE or 50 mrem thyroid CDE.EAL:PD-AA1.1Reading on an effluent radiation monitor greater than the values shown for 15 minutes orlonger.Gaseous Action ValueGas-1 [RM-17-156]

9.OE+06 cpmGas-2 [RM-17-157]

9.OE+06 cpmLiquid Action ValueSW Discharge Hdr Discharge Monitor [RM-17-351 192 cpsNote 1: The Emergency Director should declare the Alert promptly upon determining that the applicable time hasbeen exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release durationhas exceeded 15 minutes.Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the releasepath, then the effluent monitor reading is no longer valid for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EAL PD-AAI.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Vermont Yankee Basis:This EAL addresses a release of gaseous or liquid radioactivity that results in detectable levelsoffsite that are below 1% of the EPA PAGs and reflects the condition of an uncontrolled releaseof gaseous or liquid radioactivity that results in detectable levels at the site boundary.

It includesboth monitored and un-monitored releases.

Releases of this magnitude represent an actual orpotential substantial degradation of the level of safety of the plant as indicated by a radiological release that could potentially exceed regulatory limits (e.g., a significant uncontrolled release).

With VY permanently

shutdown, the only radionuclide of any significance available to bereleased in gaseous form is the noble gas Kr-85. Kr-85 decays emitting a low abundance gamma and is therefore not a significant contributor to TEDE.The gaseous release portion of this EAL is not based on any particular dose value, but rather oneffluent radiation monitor readings equivalent to 90% of of the full scale reading of the monitors(Reference 11).The liquid release portion of this EAL is based on a counts per second value equivalent to 10mrem TEDE (Reference 11).Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 22 of 52 Attachment 1 -Recognition Category PD EAL BasesRadiological effluent EALs provide a basis for classifying events and conditions that cannot bereadily or appropriately classified on the basis of plant conditions alone. The inclusion of bothplant condition and radiological effluent EALs more fully addresses the spectrum of possibleaccident events and conditions.

Classification based on effluent monitor readings assumes that a release path to theenvironment is established.

If the effluent flow past an effluent monitor is known to have stoppeddue to actions to isolate the release path, then the effluent monitor reading is no longer valid forclassification purposes.

In a permanently shutdown and defueled condition, the only credible scenario for releasing gaswould be to damage spent fuel during handling.

Vermont Yankee Basis Reference(s):

1. VYNPS ODCM Table 3.1.2 Gaseous Effluent Monitoring Instrumentation

2. VYNPS ODCM Section 8.2 Gaseous Effluent Instrumentation Setpoints

3. VYNPS ODCM Section 9.2 In-plant Radioactive Gaseous Effluent Pathways4. ARS 9-3-G-7/8

5. VYNPS ODCM Table 3.1.1 Liquid Effluent Monitoring Instrumentation

6. VYNPS ODCM Section 8.1 Liquid Effluent Instrumentation Setpoints

7. VYNPS ODCM Section 9.1 In-plant Radioactive Liquid Effluent Pathways8. OP 3513 Evaluations of Offsite Radiological Conditions

9. OP 3510 Offsite and Site Boundary Monitoring

10. OP 3525 Radiological Coordination

11. Calculation:

Emergency Action Levels for Decommissioning for the Stack and Service WaterDischarge Monitors for Vermont YankeePermanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 23 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

A -Abnormal Rad Levels/Rad EffluentInitiating Condition:

Release of gaseous or liquid radioactivity resulting in off site dosegreater than 10 mrem TEDE or 50 mrem thyroid CDE.EAL:PD-AA1.2Dose assessment using actual meteorology indicates doses greater than 10 mrem TEDEor 50 mrem thyroid CDE at or beyond the site boundary.

Note 1: The Emergency Director should declare the Alert promptly upon determining that the applicable time hasbeen exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release durationhas exceeded 15 minutes.Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the releasepath, then the effluent monitor reading is no longer valid for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EAL PD-AA1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Vermont Yankee Basis:This EAL addresses a release of gaseous or liquid radioactivity that results in projected or actualoffsite doses greater than or equal to 1% of the EPA PAGs. It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release thatsignificantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDEwas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.In a permanently shutdown and defueled condition, the only credible scenario for releasing gaswould be to damage spent fuel during handling.

The dose rate EALs are based on a Site Boundary dose rate of 10 mR/hr TEDE or 50 m R/hrCDE thyroid, whichever is more limiting.

Actual meteorology is specifically identified because itgives the most accurate dose assessment.

Actual meteorology (including forecasts) should beused whenever possible.

For the purposes of this EAL the Site Boundary for Vermont Yankee is a 0.35 mile radius aroundthe plant. This corresponds to the Owner Controlled Area fence for sectors 1-12 and thefurthest accessible security barrier in sectors 13-16 (Reference 9).Vermont Yankee Basis Reference(s):

Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 24 of 52 Attachment 1 -Recognition Category PD EAL Bases1. VYNPS ODCM Table 3.1.2 Gaseous Effluent Monitoring Instrumentation

2. VYNPS ODCM Section 8.2 Gaseous Effluent Instrumentation Setpoints

3. VYNPS ODCM Section 9.2 In-plant Radioactive Gaseous Effluent Pathways4. ARS 9-3-G-7/8

5. VYNPS ODCM Table 3.1.1 Liquid Effluent Monitoring Instrumentation

6. VYNPS ODCM Section 8.1 Liquid Effluent Instrumentation Setpoints

7. VYNPS ODCM Section 9.1 In-plant Radioactive Liquid Effluent Pathways8. OP 3513 Evaluations of Offsite Radiological Conditions

9. OP 3510 Offsite and Site Boundary Monitoring

10. OP 3525 Radiological Coordination Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 25 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

A -Abnormal Rad Levels/Rad EffluentInitiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dosegreater than 10 mrem TEDE or 50 mrem thyroid CDE.EAL:PD-AA1.3Analysis of a liquid effluent sample indicates a concentration or release rate that wouldresult in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the siteboundary for one hour of exposure.

Note 1: The Emergency Director should declare the Alert promptly upon determining that the applicable time hasbeen exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release durationhas exceeded 15 minutes.Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the releasepath, then the effluent monitor reading is no longer valid for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EAL PD-AA1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Vermont Yankee Basis:This EAL addresses a release of liquid radioactivity that results in projected or actual offsitedoses greater than or equal to 1% of the EPA PAGs. It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release thatsignificantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDEwas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.The dose rate EALs are based on a Site Boundary dose rate of 10 mR/hr TEDE or 50 mR/hrCDE thyroid, whichever is more limiting.

For the purposes of this EAL the Site Boundary forVermont Yankee is a 0.35 mile radius around the plant. This corresponds to the OwnerControlled Area fence for sectors 1-12 and the furthest accessible security barrier in sectors 13-16 (Reference 9).Vermont Yankee Basis Reference(s):

1. VYNPS ODCM Table 3.1.2 Gaseous Effluent Monitoring Instrumentation

2. VYNPS ODCM Section 8.2 Gaseous Effluent Instrumentation Setpoints Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 26 of 52 Attachment 1 -Recognition Category PD EAL Bases3. VYNPS ODCM Section 9.2 In-plant Radioactive Gaseous Effluent Pathways4. ARS 9-3-G-7/8

5. VYNPS ODCM Table 3.1.1 Liquid Effluent Monitoring Instrumentation

6. VYNPS ODCM Section 8.1 Liquid Effluent Instrumentation Setpoints

7. VYNPS ODCM Section 9.1 In-plant Radioactive Liquid Effluent Pathways8. OP 3513 Evaluations of Offsite Radiological Conditions

9. OP 3510 Offsite and Site Boundary Monitoring 10.OP 3525 Radiological Coordination Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 27 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

Initiating Condition:

A -Abnormal Rad Levels/Rad EffluentRelease of gaseous or liquid radioactivity resulting in offsite dosegreater than 10 mrem TEDE or 50 mrem thyroid CDE.EAL:PD-AA1.4Field survey results indicate EITHER of the following at or beyond the site boundary:

• Closed window dose rates greater than 10 mR/hr expected to continuefor 60 minutes or longerAnalyses of field survey samples indicate thyroid CDE greater than 50mrem for one hour of inhalation Note 1: The Emergency Director should declare the Alert promptly upon determining that the applicable time hasbeen exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release durationhas exceeded 15 minutes.Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the releasepath, then the effluent monitor reading is no longer valid for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EAL PD-AAI.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Vermont Yankee Basis:This EAL addresses a release of gaseous or liquid radioactivity that results in projected or actualoffsite doses greater than or equal to 1 % of the EPA PAGs. It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release thatsignificantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDEwas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.In a permanently shutdown and defueled condition, the only credible scenario for releasing gaswould be to damage spent fuel during handling.

The dose rate EALs are based on a Site Boundary dose rate of 10 mR/hr TEDE or 50 mR/hrCDE thyroid, whichever is more limiting.

For the purposes of this EAL the Site Boundary forVermont Yankee is a 0.35 mile radius around the plant. This corresponds to the OwnerVermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 28 of 52 Attachment 1 -Recognition Category PD EAL BasesControlled Area fence for sectors 1-12 and the furthest accessible security barrier in sectors 13-16 (Reference 9).Vermont Yankee Basis Reference(s):

1. VYNPS ODCM Table 3.1.2 Gaseous Effluent Monitoring Instrumentation

2. VYNPS ODCM Section 8.2 Gaseous Effluent Instrumentation Setpoints

3. VYNPS ODCM Section 9.2 In-plant Radioactive Gaseous Effluent Pathways4. ARS 9-3-G-7/8

5. VYNPS ODCM Table 3.1.1 Liquid Effluent Monitoring Instrumentation

6. VYNPS ODCM Section 8.1 Liquid Effluent Instrumentation Setpoints

7. VYNPS ODCM Section 9.1 In-plant Radioactive Liquid Effluent Pathways8. OP 3513 Evaluations of Offsite Radiological Conditions

9. OP 3510 Offsite and Site Boundary Monitoring

10. OP 3525 Radiological Coordination Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 29 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

A -Abnormal Rad Levels/Rad EffluentInitiating Condition:

UNPLANNED rise in plant radiation levels.EAL:PD-AU2.1a. UNPLANNED water level drop in the spent fuel pool as indicated by ANY of thefollowing:

" Spent Fuel Pool low water level alarm as monitored by LT-1 9-63A and B" Visual observation ANDb. UNPLANNED rise in area radiation levels as indicated by ANY of the following radiation monitors.

" ARM #14 Rx Bldg West Refuel" ARM #15 Spent Fuel FloorVermont Yankee Basis:This IC addresses elevated plant radiation levels caused by a decrease in water level aboveirradiated (spent) fuel or other UNPLANNED events. The increased radiation levels areindicative of a minor loss in the ability to control radiation levels within the plant or radioactive materials.

Either condition is a potential degradation in the level of safety of the plant.A water level decrease will be primarily determined by indications from available levelinstrumentation.

Other sources of level indications may include reports from plant personnel orvideo camera observations (if available).

A significant drop in the water level may also cause anincrease in the radiation levels of adjacent areas that can be detected by monitors in thoselocations.

The effects of planned evolutions should be considered.

Note that PDAU2.1 is applicable only incases where the elevated reading is due to an UNPLANNED water level drop.Loss of inventory from the spent fuel pool may reduce water shielding above spent fuel andcause unexpected increases in plant radiation.

Classification as an Unusual Event is warranted as a precursor to a more serious event.The low water level alarm (SFP level 36 ft. 7 in.) in this EAL refers to the SFP low level alarm(Reference 1).The SFP level is monitored by two transmitters (LT-1 9-63A and B).Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 30 of 52 Attachment 1 -Recognition Category PD EAL BasesAllowing level to decrease could result in spent fuel being uncovered, reducing spent fuel decayheat removal and creating an extremely hazardous radiation environment.

Technical Specifications (Reference

4) require SFP level to be maintained at least 36 ft.Area radiation monitors that may indicate a loss of shielding of spent fuel in the SFP or refueling cavity include (References 3 and 4):" ARM-14 Rx Bldg West Refuel" ARM-15 Spent Fuel PoolThe ARMs monitor the gamma radiation levels in units of mR/hr at selected areas throughout the station.

If radiation levels exceed a preset limit in any channel, the Control Roomannunciator and local alarms will be energized to warn of abnormal or significantly changingradiological conditions.

The alarm limit is normally set at approximately 10 times normalbackground for each channel.

(References 5 and 6)It is rFegnized that so-me plant arca radiation moniorS may not be able to Fr display areading that is 25 m,/hr oer. NORMAL LEVELS. The intent of this IC is to rely on currently installed plant monitors and not to require design changes/backfits.

In cases where an installed area radiation monitor cannot detect or display values at or above 25 mR/hr over NORMALLEVELS, then survey instrument results may be used.Routine and work specific surveys are conducted throughout the station at frequencies specified by the Radiation Protection Superintendent.

Routine surveys are scheduled per the RPDepartment Surveillance Schedule.

Work specific surveys are conducted in accordance withthe Radiation Work Permit (RWP). (Reference 7)Escalation of the emergency classification level would be via IC PD-AA1 or PD-AA2.Vermont Yankee Basis Reference(s):

1. ARS 21009, FPC Alarm Response Sheets2. ON 3157 Loss of Fuel Pool Level3. ON 3153 Excessive Radiation Levels4. Technical Specification Section 3.12.C Fuel Storage Pool Water Level5. ON 3153 Excessive Radiation Levels6. OP 2135 Area Radiation Monitoring System7. OP 4530 Dose Rate Radiation SurveysPermanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 31 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

A -Abnormal Rad Levels/Rad EffluentInitiating Condition:

UNPLANNED rise in plant radiation levels.EAL:PD-AU2.2Area radiation monitor reading or survey result indicates an UNPLANNED rise of 25 mR/hrover NORMAL LEVELS*.* Normal levels can be considered as the highest reading in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> excluding thecurrent peak value.Vermont Yankee Basis:This IC addresses elevated plant radiation levels caused by a decrease in water level aboveirradiated (spent) fuel or other UNPLANNED events. The increased radiation levels areindicative of a minor loss in the ability to control radiation levels within the plant or radioactive materials.

Either condition is a potential degradation in the level of safety of the plant.The effects of planned evolutions should be considered.

Note that PD-AU2.2 excludes radiation level increases that result from planned activities such as use of radiographic sources andmovement of radioactive waste materials.

Loss of inventory from the SFP may reduce water shielding above spent fuel and causeunexpected increases in plant radiation.

Classification as an Unusual Event is warranted as aprecursor to a more serious event.The low water level alarm (SFP level 36 ft. 7 in.) in this EAL refers to the SFP low level alarm(Reference 1).The SFP level is monitored by two transmitters (LT-1 9-63A and B).Allowing level to decrease could result in spent fuel being uncovered, reducing spent fuel decayheat removal and creating an extremely hazardous radiation environment.

Technical Specifications (Reference

4) require SFP level to be maintained at least 36 ft.Area radiation monitors that may indicate a loss of shielding of spent fuel in the SFP or refueling cavity include (References 3 and 4):" ARM-14 Rx Bldg West Refuel" ARM-15 Spent Fuel PoolThe ARMs monitor the gamma radiation levels in units of mR/hr at selected areas throughout the station.

If radiation levels exceed a preset limit in any channel, the Control Roomannunciator and local alarms will be energized to warn of abnormal or significantly changingradiological conditions.

The alarm limit is normally set at approximately 10 times normalbackground for each channel.

(References 5 and 6)it is reognzcd that sompe plant ar.a radiation monitors may not be able to detect Or display a.eading that is 2. m.R/hr evcr NORMAL LEVELS. The intent of this IC is to rely on currently Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 32 of 52 Attachment 1 -Recognition Category PD EAL Basesinstalled plant monitors and not to require design changes/backfits.

In cases where an installed area radiation monitor cannot detect or display values at or above 25 mR/hr over NORMALLEVELS, then survey instrument results may be used.Routine and work specific surveys are conducted throughout the station at frequencies specified by the Radiation Protection Superintendent.

Routine surveys are scheduled per the Radiation Protection Department Surveillance Schedule.

Work specific surveys are conducted inaccordance with the Radiation Work Permit. (Reference 7)Escalation of the emergency classification level would be via IC PD-AA1 or PD-AA2.Vermont Yankee Basis Reference(s):

1. ARS 21009, FPC Alarm Response Sheets2. ON 3157 Loss of Fuel Pool Level3. ON 3153 Excessive Radiation Levels4. Technical Specification Section 3.12.C Fuel Storage Pool Water Level5. ON 3153 Excessive Radiation Levels6. OP 2135 Area Radiation Monitoring System7. OP 4530 Dose Rate Radiation SurveysVermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 33 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

A- Abnormal Rad Levels/Rad EffluentInitiating Condition:

UNPLANNED rise in plant radiation levels that impedes plant accessrequired to maintain spent fuel integrity.

EAL:PD-AA2.1UNPLANNED dose rate greater than 15 mR/hr in ANY of the following areas requiring continuous occupancy to maintain control of radioactive material or operation of systemsneeded to maintain spent fuel integrity:

0 Control RoomVermont Yankee Basis:This IC addresses increased radiation levels that impede necessary access to areas containing equipment that must be operated manually or that requires local monitoring, in order to maintainsystems needed to maintain spent fuel integrity.

As used here, 'impede' includes hindering orinterfering, provided that the interference or delay is sufficient to significantly threaten necessary plant access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider thecause of the increased radiation levels and determine in another IC may be applicable.

Areas that meet this threshold include the Control Room. There are no permanently installed Control Room area radiation monitors that may be used to assess this EAL threshold.

Therefore these thresholds must be assessed via local radiation survey (Reference 1).An emergency declaration is not warranted if any of the following conditions apply:" The increased radiation levels are a result of a planned activity that includescompensatory measures which address the temporary inaccessibility of a room or area(e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or record keepingnature (e.g., normal rounds or routine inspections).

" The access control measures are of a conservative or precautionary nature, and wouldnot actually prevent or impede a required action.Vermont Yankee Basis Reference(s):

1. OP 4530 Dose Rate Radiation SurveysVermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 34 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

A -Abnormal Rad Levels/Rad EffluentInitiating Condition:

UNPLANNED rise in plant radiation levels that impedes plant accessrequired to maintain spent fuel integrity.

EAL:PD-AA2.2Survey results that indicate an UNPLANNED rise of 100 mR/hr over NORMAL LEVELS*that impedes access to ANY of the following areas needed to maintain control ofradioactive material or operation of systems needed to maintain spent fuel pool integrity.

• Spent Fuel Pool Pump Area* Normal levels can be considered as the highest reading in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> excluding thecurrent peak value.Vermont Yankee Basis:This IC addresses increased radiation levels that impede necessary access to areas containing equipment that must be operated manually or that requires local monitoring, in order to maintainsystems needed to maintain spent fuel integrity.

As used here, 'impede' includes hindering orinterfering, provided that the interference or delay is sufficient to significantly threaten necessary plant access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider thecause of the increased radiation levels and determine in another IC may be applicable.

Areas that meet this threshold include the Spent Fuel Pool Pump Area. There are nopermanently installed Spent Fuel Pool Pump Area area radiation monitors that may be used toassess this EAL threshold.

Therefore, these thresholds must be assessed via local radiation survey (Reference 1).For EAL PD-AA2.2, an Alert declaration is warranted if entry into the affected room/area is, ormay be, procedurally required at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of theincreased radiation levels. Access should be considered as impeded if extraordinary measuresare necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply:" The increased radiation levels are a result of a planned activity that includescompensatory measures which address the temporary inaccessibility of a room or area(e.g., radiography, spent filter or resin transfer, etc.).* The action for which room/area entry is required is of an administrative or record keepingnature (e.g., normal rounds or routine inspections).

Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 35 of 52 Attachment 1 -Recognition Category PD EAL Bases* The access control measures are of a conservative or precautionary nature, and wouldnot actually prevent or impede a required action.Vermont Yankee Basis Reference(s):

1. OP 4530 Dose Rate Radiation SurveysVermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 36 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

H -Hazards and Other Conditions Affecting Plant SafetyInitiating Condition:

Confirmed SECURITY CONDITION or threat.EAL:PD-HU1.1A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by theSecurity Shift Supervisor.

Vermont Yankee Basis:This IC addresses events that pose a threat to plant personnel or the equipment necessary tomaintain cooling of spent fuel, and thus represent a potential degradation in the level of plantsafety. Security events which do not meet one of these EALs are adequately addressed by therequirements of 10 CFR 73.71 or 10 CFR 50.72.Timely and accurate communications between Security Shift Supervision and the Control Roomis essential for proper classification of a security-related event. Classification of these events willinitiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template forthe Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [andIndependent Spent Fuel Storage Installation Security Program].

PD-HU1.1 references the Security Shift Supervisor because these are the individuals trained toconfirm that a security event is occurring or has occurred.

Training on security eventconfirmation and classification is controlled due to the nature of Safeguards and 10 CFR 2.390information.

Emergency plans and implementing procedures are public documents; therefore, EALs shouldnot incorporate Security-sensitive information.

This includes information that may beadvantageous to a potential adversary, such as the particulars concerning a specific threat orthreat location.

Security-sensitive information should be contained in non-public documents suchas the Physical Security Plan.OP 3132, Operations Department Response to Security Events, (Reference

3) providesguidance for response to security related events based on contingency events at the VermontYankee Plant.Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HA1.Vermont Yankee Basis Reference(s):

1. VYNPS Physical Security Plan2. OP 3132 Operations Department Response to Security Events3. SP 0904 Contingency Procedures and Events4. ON 3177 Operations Response to Aircraft ThreatsPermanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 37 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

H -Hazards and Other Conditions Affecting Plant SafetyInitiating Condition:

Confirmed SECURITY CONDITION or threat.EAL:PD-HU1-.2 Notification of a credible security threat directed at the site.Vermont Yankee Basis:This IC addresses events that pose a threat to plant personnel or the equipment necessary tomaintain cooling of spent fuel, and thus represent a potential degradation in the level of plantsafety. Security events which do not meet one of these EALs are adequately addressed by therequirements of 10 CFR 73.71 or 10 CFR 50.72.Timely and accurate communications between Security Shift Supervision and the Control Roomis essential for proper classification of a security-related event. Classification of these events willinitiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template forthe Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [andIndependent Spent Fuel Storage Installation Security Program].

PD-HU1.2 addresses the receipt of a credible security threat. The credibility of the threat isassessed in accordance with OP 3132, Operations Department Response to Security Events,and SP 0904, Contingency Procedures and Events.Emergency plans and implementing procedures are public documents; therefore, EALs shouldnot incorporate Security-sensitive information.

This includes information that may beadvantageous to a potential adversary, such as the particulars concerning a specific threat orthreat location.

Security-sensitive information should be contained in non-public documents suchas the Physical Security Plan.OP 3132, Operations Department Response to Security Events, (Reference

3) providesguidance for response to security related events based on contingency events at the VermontYankee Plant.Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HA1.Vermont Yankee Basis Reference(s):

1. VYNPS Physical Security Plan2. OP 3132 Operations Department Response to Security Events3. SP 0904 Contingency Procedures and Events4. ON 3177 Operations Response to Aircraft ThreatsPermanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 38 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

H -Hazards and Other Conditions Affecting Plant SafetyInitiating Condition:

Confirmed SECURITY CONDITION or threat.EAL:PD-HU1 .3A validated notification from the NRC providing information of an aircraft threat.Vermont Yankee Basis:This IC addresses events that pose a threat to plant personnel or the equipment necessary tomaintain cooling of spent fuel, and thus represent a potential degradation in the level of plantsafety. Security events which do not meet one of these EALs are adequately addressed by therequirements of 10 CFR 73.71 or 10 CFR 50.72.Timely and accurate communications between Security Shift Supervision and the Control Roomis essential for proper classification of a security-related event. Classification of these events willinitiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template forthe Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [andIndependent Spent Fuel Storage Installation Security Program].

PD-HU1.3 addresses the threat from the impact of an aircraft on the plant. The NRC HOO willcommunicate to the licensee if the threat involves an aircraft.

The status and size of the planemay also be provided by the NORAD through the NRC. Validation of the threat is performed inaccordance with ON 3177, Operations Response to Aircraft Threats.Emergency plans and implementing procedures are public documents; therefore, EALs shouldnot incorporate Security-sensitive information.

This includes information that may beadvantageous to a potential adversary, such as the particulars concerning a specific threat orthreat location.

Security-sensitive information should be contained in non-public documents suchas the Physical Security Plan.OP 3132, Operations Department Response to Security Events, (Reference

3) providesguidance for response to security related events based on contingency events at the VermontYankee Plant.Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HA1.Vermont Yankee Basis Reference(s):

1. VYNPS Physical Security Plan2. OP 3132 Operations Department Response to Security Events3. SP 0904 Contingency Procedures and Events4. ON 3177 Operations Response to Aircraft ThreatsPermanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 39 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

H -Hazards and Other Conditions Affecting Plant SafetyInitiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA orairborne attack threat within 30 minutes.EAL:PD-HA1.1A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Security Shift Supervisor.

Vermont Yankee Basis:This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response andassistance due to the possibility of the attack progressing to the PROTECTED AREA, or theneed to prepare the plant and staff for a potential aircraft impact.Timely and accurate communications between Security Shift Supervision and the Control Roomis essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template forthe Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [andIndependent Spent Fuel Storage Installation Security Program].

As time and conditions allow, these events require a heightened state of readiness by the plantstaff and implementation of onsite protective measures (e.g., evacuation, dispersal orsheltering).

The Alert declaration will also heighten the awareness of OROs, allowing them to bebetter prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, orotherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples includethe crash of a small aircraft, shots from hunters, physical disputes between employees, etc.Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.PD-HAI.1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in theOWNER CONTROLLED AREA. This includes any action directed against an ISFSI that islocated within the OWNER CONTROLLED AREA.The NRC HOO will communicate to the licensee if the threat involves an aircraft.

The status andsize of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNERCONTROLLED AREA was intentional (i.e., a HOSTILE ACTION).

It is expected, although notcertain, that notification by an appropriate Federal agency to the site would clarify this point. Inthis case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. Theemergency declaration, including one based on other ICs/EALs, should not be unduly delayedwhile awaiting notification by a Federal agency.Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 40 of 52 Attachment 1 -Recognition Category PD EAL BasesEmergency plans and implementing procedures are public documents; therefore, EALs shouldnot incorporate Security-sensitive information.

This includes information that may beadvantageous to a potential adversary, such as the particulars concerning a specific threat orthreat location.

Security-sensitive information should be contained in non-public documents suchas the Security Plan.OP 3132, Operations Department Response to Security Events (Reference

2) providesguidance for response to security related events based on contingency events at VY.Vermont Yankee Basis Reference(s):

1. VYNPS Physical Security Plan2. OP 3132 Operations Department Response to Security Events3. ON 3177 Operations Response to Aircraft ThreatsVermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 41 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

H -Hazards and Other Conditions Affecting Plant SafetyInitiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA orairborne attack threat within 30 minutes.EAL:PD-HA1.2A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.Vermont Yankee Basis:This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response andassistance due to the possibility of the attack progressing to the PROTECTED AREA, or theneed to prepare the plant and staff for a potential aircraft impact.Timely and accurate communications between Security Shift Supervision and the Control Roomis essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template forthe Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [andIndependent Spent Fuel Storage Installation Security Program].

As'time and conditions allow, these events require a heightened state of readiness by the plantstaff and implementation of onsite protective measures (e.g., evacuation, dispersal orsheltering).

The Alert declaration will also heighten the awareness of OROs, allowing them to bebetter prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, orotherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples includethe crash of a small aircraft, shots from hunters, physical disputes between employees, etc.Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71 or 10 CFR 50.72.PD-HA1.2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes.

The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness.

This EAL is met when the threat-related information has been validated inaccordance with ON 3177, Operations Response to Aircraft Threats.The NRC HOO will communicate to the licensee if the threat involves an aircraft.

The status andsize of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNERCONTROLLED AREA was intentional (i.e., a HOSTILE ACTION).

It is expected, although notcertain, that notification by an appropriate Federal agency to the site would clarify this point. Inthis case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. Theemergency declaration, including one based on other ICs/EALs, should not be unduly delayedwhile awaiting notification by a Federal agency.Permanently Defueled EAL Technical BasesVermont Yankee Nuclear Power Station Rev. 0Page 42 of 52 Attachment 1 -Recognition Category PD EAL BasesEmergency plans and implementing procedures are public documents; therefore, EALs shouldnot incorporate Security-sensitive information.

This includes information that may beadvantageous to a potential adversary, such as the particulars concerning a specific threat orthreat location.

Security-sensitive information should be contained in non-public documents suchas the Security Plan.OP 3132, Operations Department Response to Security Events (Reference

2) providesguidance for response to security related events based on contingency events at VY.Vermont Yankee Basis Reference(s):

1. VYNPS Physical Security Plan2. OP 3132 Operations Department Response to Security Events3. ON 3177 Operations Response to Aircraft ThreatsVermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 43 of 52 Attachment 1 -Recognition Category PD EAL BasesH -Hazards and Other Conditions Affecting Plant SafetyCategory:

Initiating Condition:

Hazardous event affecting equipment necessary for spent fuel cooling.EAL:PD-HU2.1a. The occurrence of ANY of the following hazardous events:" Seismic Event (earthquake)

• Internal or external flooding event" River water level >250 ft. MSL (plant grade)* Intake water level < 210 ft. MSL" High winds or tornado strike* FIRE* EXPLOSION

" Other events with similar hazard characteristics as determined by the Shift ManagerANDb. The event has damaged at least one train of a system needed for spent fuel cooling.ANDc. The damaged train(s) cannot, or potentially cannot, perform its designed functionbased on EITHER:0 Indications of degraded performance e VISIBLE DAMAGEVermont Yankee Basis:This IC addresses a hazardous event that causes damage to at least one train of a systemneeded for spent fuel cooling.

The Service Water System and SFP Cooling systems are thesystems necessary to maintain SFP cooling.

The damage must be of sufficient magnitude thatthe system(s) train cannot, or potentially cannot, perform its design function.

This condition reduces the margin to a loss or potential loss of the fuel clad barrier, and therefore represents apotential degradation of the level of safety of the plant.Plant Grade is 250 ft. MSL. The maximum water level experienced at the site was 231.4 ft. MSL.The Maximum Probable Flood is 252.5 ft. MSL. Since the entrances to all structures containing equipment necessary for cooling are at elevation 252.5 ft. MSL, they are protected against theMPF. However, water level in excess of plant grade may result in a loss of accessibility.

(References 1, 2, 3) Gradients, ranging from 248 feet to 254 feet, are available on the north sideof the intake structure wall to assist in classifying this event.Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 44 of 52 Attachment 1 -Recognition Category PD EAL BasesIntake water level less than 210 feet indicates low river water conditions which may threaten theoperability of the spent fuel pool cooling system. Intake Bay Level Gauge LI-104-9 on ControlRoom Panel CRP-9-6 as well as direct observation at the intake structure can be used toascertain this initiating condition threshold.

For EAL PD-HU2.1a, the last bullet is not intended to address component failures within thesystem such as pump bearing failures, electrical grounds or shorts in a pump, failure of valves,etc. Declaration of an event due to the failure of a component would be based on PD-SU1.1.

For EAL PD-HU2.1c, the first bullet addresses damage to a system that is in service/operation since indications for it will be readily available.

For EAL PD-HU2.1c, the second bullet addresses damage to a system that is not inservice/operation or readily apparent through indications alone. Operators will make thisdetermination based on the totality of available event and damage report information.

This isintended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level could, depending upon the event, be based onany of the Alert ICs; PD-AA1, PD-AA2, PD-HA1 or PD-HA3.Vermont Yankee Basis Reference(s):

1. OP 3127, Natural Phenomena

2. FSAR Section 2.4.3.43. FSAR Section 2.4.84. ON 3148, Loss of Service WaterVermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 45 of 52 Attachment 1 -Recognition Category PD EAL BasesH -Hazards and Other Conditions Affecting Plant SafetyCategory:

Initiating Condition:

Other conditions exist which in the judgment of the Emergency Directorwarrant declaration of an Unusual Event.EAL:PD-HU3.1Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which indicate a potential degradation of the levelof safety of the plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expectedunless further degradation of safety systems occurs.Vermont Yankee Basis:This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrantdeclaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Unusual Event.The Emergency Director is the designated onsite individual having the responsibility andauthority for implementing the Vermont Yankee Emergency Plan. The Shift Manager (SM)initially acts in the capacity of the Emergency Director and takes actions as outlined in theEmergency Plan implementing procedures.

If required by the emergency classification or ifdeemed appropriate by the Emergency

Director, emergency response personnel are notifiedand instructed to report to their emergency response locations.

In this manner, the individual usually in charge of activities in the Control Room is responsible for initiating the necessary emergency

response, but plant management is expected to manage the emergency responseas soon as available to do so in anticipation of the possible wide-ranging responsibilities associated with managing a major emergency (Reference 1).Vermont Yankee Basis Reference(s):

1. Vermont Yankee Emergency Plan Section 8.0, Organization Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 46 of 52 Attachment.

1 -Recognition Category PD EAL BasesCategory:

Initiating Condition:

EAL:H -Hazards and Other Conditions Affecting Plant SafetyOther conditions exist which in the judgment of the Emergency Directorwarrant declaration of an Alert.PD-HA3.1Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which involve a potential substantial degradation of the level of safety of the plant or indicate a security event that involves probable lifethreatening risk to site personnel or damage to site equipment because of HOSTILEACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Vermont Yankee Basis:This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrantdeclaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.The Emergency Director is the designated onsite individual having the responsibility andauthority for implementing the Vermont Yankee Emergency Plan. The SM initially acts in thecapacity of the Emergency Director and takes actions as outlined in the Emergency Planimplementing procedures.

If required by the emergency classification or if deemed appropriate by the Emergency

Director, emergency response personnel are notified and instructed to reportto their emergency response locations.

In this manner, the individual usually in charge ofactivities in the Control Room is responsible for initiating the necessary emergency

response, but Plant Management is expected to manage the emergency response as soon as available todo so in anticipation of the possible wide-ranging responsibilities associated with managing amajor emergency.

Vermont Yankee Basis Reference(s):

1. Vermont Yankee Emergency Plan Section 8.0, Organization Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 47 of 52 Attachment 1 -Recognition Category PD EAL BasesCategory:

S -System Malfunction Initiating Condition:

UNPLANNED spent fuel pool temperature rise.EAL:PD-SU1.1UNPLANNED spent fuel pool temperature rise to greater than 1500F.Vermont Yankee Basis:This IC addresses a condition that is a precursor to a more serious event and represents apotential degradation in the level of safety of the plant. If uncorrected, boiling in the pool willoccur, and result in a loss of pool level and increased radiation levels.Whenever irradiated fuel is stored in the spent fuel pool, the pool water temperature shall bemaintained below 1500F. The Spent Fuel Pool Cooling System is designed to maintain the poolwater temperature below 1250F (Reference 1).Escalation of the emergency classification level would be via IC PD-AA1 or PD-AA2.Vermont Yankee Basis Reference(s):

1. Vermont Yankee Technical Specifications Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 48 of 52 Attachment 2 -Recognition Category E EAL Basses8.2 Attachment 2 -Recognition Category E EAL BasisRecognition Category E provides a set of ICs/EALs for an ISFSI. An ISFSI is a complex that isdesigned and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

A significant amount of the radioactive materialcontained within a cask must escape its packaging and enter the biosphere for there to be asignificant environmental effect resulting from an accident involving the dry storage of spentnuclear fuel. Formal offsite planning is not required because the postulated worst-case accidentinvolving an ISFSI has insignificant consequences to the public health and safety.An Unusual Event is declared on the basis of the occurrence of an event of sufficient magnitude that a loaded cask confinement boundary is damaged or violated.

This includes classification based on a loaded fuel storage cask confinement boundary loss leading to the degradation ofthe fuel during storage or posing an operational safety problem with respect to its removal fromstorage.Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 49 of 52 Attachment 2 -Recognition Category E EAL BassesTable E-1: Recognition Category "E" Initiating Condition MatrixUNUSUAL EVENTE-HU1 Damage to a loaded caskCONFINEMENT BOUNDARY.

Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 50 of 52.

Attachment 2 -Recognition Category E EAL BassesE -Independent Spent Fuel Storage Istallation Damage to a loaded cask CONFINEMENT BOUNDARYCategory:

Initiating Condition:

EAL:E-HU1.1Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading greater than two times the ISFSI Technical Specification allowable levels.Two times the ISFSI Technical Specification allowable levels equate to:a 2.88 mR/hr on the top of the overpackor* 1.90 mR/hr on the side of the overpack, excluding inlet and outlet ducts.Vermont Yankee Basis:This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of astorage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storagebeginning at the point that the loaded storage cask is sealed. The issues of concern are thecreation of a potential or actual release path to the environment, degradation of one or more fuelassemblies due to environmental

factors, and configuration changes which could causechallenges in removing the cask or fuel from storage.The existence of "damage" is determined by radiological survey. The Technical Specification multiple of two times is used here to distinguish between non-emergency and emergency conditions.

The emphasis for this classification is the degradation in the level of safety of thespent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized thatin the case of extreme damage to a loaded cask, the fact that the dose rate limit is exceededmay be determined based on measurement of a dose rate at some distance from the cask.Minor surface damage that does not affect the storage cask boundary is excluded from thescope of this EAL.Two times the ISFSI Technical Specification allowable levels equate to:a 2.88 mR/hr on the top of the overpackor* 1.90 mR/hr on the side of the overpack, excluding inlet and outlet ducts. (Reference 1)Security-related events for ISFSIs are covered under IC PD-HU1 and PD-HA1.Vermont Yankee Basis Reference(s):

1. Entergy Nuclear 10 CFR 72.212 Evaluation Report Appendix G VY Specific Information forISFSIs Utilizing the Holtec, International HI-STORM 100 Cask System2. VYNPS Procedure 2530 Radiological Monitoring for Dry Fuel StorageVermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 51 of 52 Attachment 2 -Recognition Category E EAL Basses3. VYNPS Procedure DP 3201 Equipment Handling and Storage Abnormal Conditions

4. VYNPS Procedure OP3127 Natural Phenomena Vermont Yankee Nuclear Power StationPermanently Defueled EAL Technical BasesRev. 0Page 52 of 52 BVY 15-009Docket 50-271Attachment 4Vermont Yankee Nuclear Power StationList of Regulatory Commitments BVY .15-009 / Attachment 4 / Page 1 of 2List of Regulatory Commitments This table identifies actions discussed in this letter for which Entergy commits to perform.

Anyother actions discussed in this submittal are described for the NRC's information and are notcommitments.

TYPE(Check one) SCHEDULED ONE-TIME CONTINUING COMPLETION DATECOMMITMENT ACTION COMPLIANCE (If Required)

The procedure regarding Initial Radiological Dose Projection will be developed considering that after permanent shutdownand removal of fuel from the reactor, theonly viable accident scenario is a Fuel x June 30, 2015Handling Accident in the spent fuel pool andwill be provided to the NRC in asupplemental response by June 30, 2015(RAI-1 8).VY will develop the format and content ofthe initial and follow-up messages and Xprovide the proposed messages to May 31,2015responsible offsite authorities for reviewprior to May 31, 2015 (RAI-23).

Letters of Agreement in support of thePermanently Defueled Emergency Plan willbe developed with consideration given toNRC-approved Regulatory Exemptions andthe Permanently Defueled Emergency Action Levels still under NRC review. VY x June 30, 2015will provide the Letters of Agreement to theNRC in a supplemental response to thisRequest for Additional Information by June30, 2015 (RAI-23 and 32).VY will develop a procedure establishing the format and content of initial and follow-up messages and the frequency at whichthe messages are provided.

The procedure will address the permanently shutdown anddefueled condition and the format and Consistent with thecontent of the initial and follow-up imples entationimplementation messages will be mutually agreed upon x schedule for thewith responsible offsite authorities in approvedaccordance with the guidance contained in amendment Planning Standard E, Evaluation Criterion 1of NUREG-0654/FEMA-REP-1, "Criteria forPreparation and Evaluation of Radiological Emergency Response Plans andPreparedness in Support of Nuclear PowerPlants" (November 1980) (RAI-23).

BVY 15-009 / Attachment 4 / Page 2 of 2TYPE(Check one) SCHEDULED ONE-TIME CONTINUING COMPLETION DATECOMMITMENT ACTION COMPLIANCE (If Required)

A comprehensive response to RAI-24,including any identified revisions to thePDEP, will be provided in a supplemental x June 30, 2015response by June 30, 2015 (RAI-24).

Revisions to AP 3712 and the Emergency Plan Training Program Description will bedeveloped to support the Permanently x June 30, 2015Defueled Emergency Plan and will beprovided to the NRC in a supplemental response by June 30, 2015 (RAI-29).