treat as sensitiveplan, revision 39, including the change memo and the 10 cfr 50.54(q) evaluation...

TREAT ASSENSITIVEINFORMATION

MHG1Cross-Out

v-mEntergyEntergy Nuclear NortheastEntergy Nuclear Operations, Inc.Vermont Yankee322 Governor Hunt Rd.P.O. Box 157Vernon, VT 05354Tel 802-257-771 1

April 28, 2004BVY 04-038

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555

Subject: Vermont Yankee Nuclear Power StationLicense No. DPR-28 (Docket No. 50-271)Vermont Yankee Emeraencv Plan Chanues

In accordance with 10 CFR 50.54(q), enclosed is the latest change to the Vermont Yankee EmergencyPlan, Revision 39, including the change memo and the 10 CFR 50.54(q) Evaluation Checklist.

These changes were determined to not need prior NRC review and approval.

If you have any questions, please contact AudraBrattleboro office at (802) 258-4177.

Williams, Emergency Planning Coordinator, in our

Sincerely,

ori Tkaczyk;Emergency Planning Manager

Attachmentscc: USNRC Region I Administrator

USNRC Resident Inspector - VYNPSUSNRC Project Manager - .VYNPS (no attachments)David M. Silk, Senior Emergency Preparedness Specialist,

USNRC Region 1Vermont Department of Public Service

� \X �-.5

ENTERGY VERMONT YANKEEEMERGENCY PLAN FILING INSTRUCTIONS

April 28,2004Change #43

*Note: Appendix A, EAL Drawing from AP 3125 will be revised separately.

Cover Sheet Replace E-Plan Approval Sheet, Effective Date 09/24/03 withE-Plan Approval Sheet, Effective 04/28/04.

Revision Summary Insert, behind Cover Sheet, Revision Summary page i of i

Table of Contents Replace pages i-vii, Rev. 38 with pages i-vii, Rev. 39.

1.0 INTRODUCTION Replace page 1, Rev. 38 with page 1, Rev. 39.'

2.0 DEFINITIONS Replace pages 2-4, Rev. 38 -with pages 2-4, Rev. 39.

3.0 SUMMARY OF EMERGENCY Replace pages 5-8, Rev. 38 with pages 5-8, Rev. 39.PLAN

4.0 THE AREA Replace pages 9-22. Rev. 38 with pages 9-22 Rev. 39.

5.0 EMERGENCY Replace pages 23-25, Rev. 38 with pages 23-25, Rev. 39.CLASSIFICATION SYSTEM

6.0 EMERGENCY RESPONSE Replace pages 26-36, Rev. 38 with pages 26-36, Rev. 39.FACILITIES AND EQUIPMENT

> 7.0 COMMUNICATIONS Replace pages'37-42, Rev. 38 with pages 37-42, Rev. 39.

8.0 ORGANIZATION Replace pages 43-68, Rev. 38 with pages 43-69, Rev. 39.

9.0 EMERGENCY RESPONSE Replace pages 69-77, Rev. 38 with pages 70-78, Rev. 39.

10.0 RADIOLOGICAL ASSESSMENT Replace pages 78-90, Rev. 38 with pages 79-91, Rev. 39.& PROTECTIVE MEASURES

11.0 EMERGENCY NOTIFICATION Replace pages 91-93, Rev. 38 with pages 92-94, Rev. 39.& PUBLIC INFORMATION

12.0 MAINTAINING EMERGENCY Replace pages 94-99, Rev. 38 with pages 95-100, Rev. 39.PREPAREDNESS

APPENDIX A Replace page 100, Rev. 38 with page 101, Rev. 39. DO NOTREMOVE APPENDIX A. AP 3125, REV. 19 DRAWING.

APPENDIX B Replace pages 102-104, Rev. 38 with pages 103-105, Rev. 39.

APPENDIX C Replace pages 105-106, Rev. 38 with pages 106-107, Rev. 39.

APPENDIX D Replace pages 107-126, Rev. 38 with pages 108-110, Rev. 39.

APPENDIX E Replace pages 127-162, Rev. 38 with pages 111-146, Rev. 39.

APPENDIX F Replace pages 163-170, Rev. 38 with pages 147-154 Rev. 39.

j APPENDIX G Replace pages 171-173, Rev. 38 with pages 155-157, Rev. 39.

APPENDIX H Replace pages 174-182, Rev. 38 with pages 158-166, Rev. 39.

Entergy Nuclear NortheastEntergy Nuclear Operations, Inc.Vermont Yankee

- - 322 Governor Hunt Rd.E n'PRO. Box 157Vernon, VT 05354Tel 802-257-7711

April 28, 2004BVY 04-038

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555

Subject: Vermont Yankee Nuclear Power StationLicense No. DPR-28 (Docket No. 50-271)Vermont Yankee Emersencv Plan Changes

In accordance with 10 CFR 50.54(q), enclosed is the latest change to the Vermont Yankee EmergencyPlan, Revision 39, including the change memo and the 10 CFR 50.54(q) Evaluation Checklist.

These changes were determined to not need prior NRC review and approval.

If you have any questions, please contact Audra Williams, Emergency Planning Coordinator, in ourBrattleboro office at (802) 258-4177.

Sincerely,

oriTkaczykEmergency Planning Manager

Attachmentscc: USNRC Region 1 Administrator

USNRC Resident Inspector - VYNPSUSNRC Project Manager -.VYNPS (no attachments)David M. Silk, Senior Emergency Preparedness Specialist,

USNRC Region 1Vermont Department of Public Service

CONTROLLED DOCUMENT REVISION REQUEST FORM

SECTION ONE: Rcquest for Current Document (Completed by Sponsoring Department)

(A) Controlled Document Title (B) Current Revision NumberEMERGENCY PLAN REV. 39

(C) Sponsoring Organization (D) TypingCompletionNeeded(Date) (E) 3 Hard Copy(Allow sufficient processing time for DCC personnel) El Electronic

EMERGENCY PLANNING APRIL 9,2004

(F) Originator Name (Print) Originator Signatur! . Date of RequestAudra Williams 3/16/04

SECTION TWO: First Draft Typing (Completed by DCC)

I(A) DCC Date Received03iIahneo41

(B) Draft Completed by,k)J MJ. Pi.e.L 4o

(C) Date Draft CompletedI 03qh1/9lnnOi

SECTION THREE: Approval and Distribution (Completed by Sponsoring Department)

(A) Proofread by Originator (print/sign/date)

Aucker VVI1Ltiar A m &UaJ2 32&a(B) Distribution Submission Date (C) Date Required for Issue (Effective Date)4 (Allow 10 working days from date) 42 .8 -(D) Safety Evaluation Per AP 6002, "Preparing 50.59 Evaluations"

El D50.59 Screening completed and attached, Safety Evaluation NOT requiredEl 50.59 Evaluation completed and attachedW NIA

(E) IOCFR50.54(q) Evaluation

l X Emergency Plan: lOCFR50.54(q) evaluation completed per AP 3532 and attachedEl Emergency Plan Implementing Procedure: lOCFR50.54(q) evaluation completed per AP 3532 and attachedEl N/A .

I

.I

SECTION FOUR: Distribution (Completed by DCC)

Date Distributed

4/198og i ;

VYAPF 6805.07AP 6805 Rev. 20Page I of ILPC #1

10 CFR 50.54(q) Evaluation Checklist

List of Emergency Plan Section(s)/Emergency Plan Implementing Procedure(s) or any other document to beevaluated. (Include Title and Revision No.):

Emergency Plan, Rev. 39, Change #44

A. Screening Evaluation

Based on a review of the following questions, determine if the change has the potential to affect our ability tomeet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50.

A "YES" answer to any part of the questions requires that a written evaluation be done to determine whetherthe effectiveness of the Emergency Plan was decreased as specified in Section B of this checklist.

A "NO" answer to all questions requires no written evaluation as specified in Section B of this checklist.

ICould the proposed change affect our ability to meet the followingstandards of IOCFR50.47(b):.

(1) Assignment of Emergency Response Organization responsibilities

(2) Assignment of on-shift Emergency Response Organization personnel

(3) Arrangements for Emergency Response Support and Resources

(4) Emergency Classification and Action levels, including facility systemand effluent parameters

(5) Notification Methods and Procedures

(6) Emergency Communications among principal response organizationsand the public

(7) Public Education and Information

(8) Adequacy of Emergency Facilities and Equipment

(9) Adequacy of Accident Assessment methods, systems and equipment

(10) Plume exposure pathway EPZ protective actions

(11) Emergency Worker Radiological Exposure Control

(12) Medical Services for contaminated injured individuals

(13) Recovery and Reentry Plans

(14) Emergency response periodic drills and exercises

(15) Radiological Emergency Response Training

(16) Plan development, review and distribution

I YES NO |

X

, X - '

.~ X.

XX

X 'XX

'XX X

X

X

xx I

VYAPF 3532.01AP 3532 Rev. 11Page I of 3

10 CFR 50.54(q) Evaluation Checklist (Continued)

YES NO

2. Could the change affect our ability to meet the followingrequirements of Appendix E to 1OCFR50

(1) Section IV. A - Organization

(2) Section IV. B - Assessment Actions

(3) Section IV. C - Activation of Emergency Organizations

(4) Section IV. D - Notification Procedures

(5) Section IV. E - Emergency Facilities and Equipment

(6) Section IV. F -Training

(7) Section IV. G -Maintaining Emergency Preparedness

(8) Section IV. H -Recovery

I. . X . . . .

-x

x - IX .I

X I

X I

.x

X I

X IB. Effectiveness Determination

For each applicable (i.e., a "yes" answer specified) standard to IOCFR50.47(b) and Appendix E to10CFR50 identified from Section A above, complete the evaluation form below to determine whetherthe change decreases the effectiveness of the Emergency Plan and whether it continues to meet thestated applicable standard or requirement.

A facsimile of the evaluation form may be used as needed and attached to this checklist.

For applicable item 10CFR50.47(b)(1)(3)(8) and Appendix E, Section IV. A. C and E of Section A above,this change f DOES Z DOES NOT decrease the effectiveness of the Emergency Plan andZ DOES D DOES NOT continue to meet the stated applicable standard or requirement.

BASIS FOR ANSWER:Added Mechanical Maintenance to the Repair & Corrective Actions section for the 60 min response. This was omitted duringthe last revision when Table 8.4 was added.

See attached for Frarnatome removaijustification.

Chemistry surveillance #5073 includes the actual use of the post-accident sampling systemu.i Therefore, it is not necessary toinclude actual sampling and risk exposure for an additional drill. Actual sampling will be credited during the surveillance andsampling during the drills will be simulated.

The Communications Assistant position was removed as the responsibilities are being performed by other members of theERO. OP 3545 will have a figure depicting phones to be tested and it will be the responsibility of the EOF to complete this atthe time of the room setup. Three part message forms can be picked up by the few individuals who still use them. All phonesand radios that need to be manned are assigned per other appendices of this procedure. Establishment of radiocommunications is the responsibility of the Rad Coordinator and the radio operator. Recording the date, time, partiesinvolved for each incoming/outgoing message is the responsibility of each of the other positions as defined in the otherappendices.

VYAPF 3532.01AP 3532 Rev. 11Page 2 of 4


': ! .

The EOF Coordinator's Assistant position was removed and the responsibilities became part of the EOF Coordinator position.This position was established prior to the E-Plan Duty Teams. The initial intent of the position was to be filled by whoeverarrived first. They were to start setup and then inform the EOF Coordinator of any pertinent information upon his/her arrival.Because the EOF Coordinator is part of an E-Plan Duty Team, the expectation is that he/she would arrive within an hourwhich would now be prior to the Assistant. The couple of tasks that the Assistant had to perform were assumed by the EOFCoordinator.

Conclusion (Fill out appropriate information)

The changes made do not decrease the effectiveness of the Emergency Plan and continueto meet the standards of 1OCFR50.47(b) and the requirements of Appendix E to10CFR50.

The changes made do decrease the effectiveness of the Emergency Plan and decrease ourability to meet the standards of 1OCFR50.47(b) and the requirements of Appendix E to10CFR50. The following course of action is recommended:

El Revise proposed changes to meet applicable standards and requirements.

El Cancel the proposed changes. ,

E . Process proposed changes for NRC approval prior to implementation inaccordance with 10CFR50.54(q).

C. Impact on Other Documents (TRM, Tech Specs)

Keywords used in search:_

El This change does not affect any other documents.

3 This change does affect other documents.

- Doument(s) affected: EPIPs

Section(s) affected:_

D. Impact on the Updated FSAR

Use AP 6036 to determine if the proposed E-Plan change modifies existing UFSAR informationor requires the addition of new UFSAR information and initiate UFSAR change(s) as required.

Keywords used in UFSAR search: does not affect UFSAR

''' '

:

-

VYAPF 3532.01AP 3532 Rev. 11Page 3 of 4


Additional Comments:

. , . - .. -. -,. . ' -' ,

Prepared By: AudraWilliams a4LtO(aL/W' Date: 4/12/04_(Print/Sign) U

rd-&;2 < Date: 41l41oqReviewed By: ad z(Emergency Plan Coordinator) (Print/Sigh)

.

VYAPF 3532.01AP 3532 Rev. 11Page4 of 4

To: File

From: Lori A. Tkaczyk

Subject: 50-54(q) Justification for Removal of Framatome Services

This assessment was undertaken to evaluate the role of the FramatomeEngineering Support Center (ESC) within the Entergy Nuclear Vermont Yankee(ENVY) Emergency Plan,-and the need for the continued availability of the ESCto support station emergency responses. Comments from both ENVY andFramatome personnel, as well as Continuous Process Improvement (CPI)results, indicate that the ESC provides minimal value to the existing emergencyresponse capabilities of the station.

This situation is due to several factors:

Framatome's routine support of ENVY has diminished over the years, and willlikely be further reduced in the future. Many Framatome personnel with ENVY-related experience have left the firm. The emergency engineering (technical)support functions which were performed in the ESC were incorporated into the' station's procedures.

Framatome also provides emergency response support at the Technical SupportCenter (TSC) (i.e., the Rad Advisor, Nuclear Safety Advisor, System Advisor),the Emergency Operations Facility (EOF) (i.e., Rad Advisor, TLD Coordinator,Environmental Sample Coordinator) and the Westboro laboratory (i.e.,environmental analysis). The personnel support for the TSC and EOF will bereplaced by support from other Entergy resources. The laboratory services,which are not associated with the ESC, are not part of this assessment and willbe retained. No resources are being deleted.

Historically, because Vermont Yankee did not have an on-site engineeringorganization, engineering and technical support was out-sourced and contractedthrough Yankee Nuclear Services Division (YNSD) to satisfy technical staffingrequirements. The Engineering Support Center was established atYNSD toprovide this support. Duke Engineering &Services (DE&S) assumed this rolewhen they acquired YNSD. DE&S subsequently sold to Framatome ANP. TheESC is a legacy facility that adds little value to the station's current emergencyresponse capabilities; the elimination of the ESC would not adversely affectthese capabilities.

Vermont Yankee now has an on-site engineering organization. This EngineeringSupport Group is defined in the Plan. Drill and exercise experience has shownENVY ERO personnel are fully capable of performing radiological assessment

and meteorology functions without support from Framatome. There are EROpersonnel trained and qualified to perform radiological assessments assigned tothe Control Room, TSC and EOF. These facilities possess the necessaryradiological assessment software, and ready access to meteorologicalinformation. Should more detailed meteorological information or relatedexpertise be required by the EOF, the National Weather Service can becontacted. There is no unique service or expertise that Framatome supplies inthese areas.

Depending upon the emergency conditions and the response needs, the ENVYERO can be augmented by manpower and equipment support arranged throughthe Institute of Nuclear Power Operations (INPO), as well as the Entergy WhitePlains Office and other members of the fleet.

If the State of New Hampshire, State of Vermont, or Commonwealth ofMassachusetts requests additional support staff or resources, INPO or ENVYWhite Plains can assist in meeting these requests through industry mutualassistance.

There is no regulatory requirement for the Engineering Support Center. Thecriteria for technical expertise and accident assessment are embedded intoNUREG-0654 guidance, ll.B.8, "Each licensee shall specify the contractor andprivate organizations who may be requested to provide technical assistance toand augmentation of the emergency organization."

The input to the Implementation Plan was developed by analyzing theemergency support services provided by FRAMATOME and identifying theequivalents in place and any additional actions necessary to effect the change.

The mobile personnel TLD processing at the EOF, mobile whole body counter,the environmental sample analyses services provided by the EnvironmentalLaboratory at Westboro, and, the use of the Alternate Joint News Center atMarlborough are retained. In addition, the supply and processing of TLDs for thestates of MA and VT emergency workers are provided by the Environmental Lab.These services are to be continued under a separate contract.

Memorandum

DATE: April 13, 2004

TO: PORC

FROM: Audra Williams, Emergency Plan On-Site Coord.

SUBJECT: Emergency Plan Change #*4t'3

1hf7Iu'

INTRODUCTION:

The latest revisions to the Emergency Plan are comprised of changes that do not decrease theeffectiveness of the Plan which continues to meet the standards of 10 CFR 50.47(b) and therequirements of Appendix E to 10 CFR 50. An AP 6002 Applicability Determination indicatesthat changes to the E-Plan are evaluated through the 50.54(q) process. A 10 CFR 50.54(q)Evaluation Checklist is attached.

CHANGE SUMMARY:

* Table of Contents

Removed the Mutual Assistance Agreement and replaced it with the Environmental LabAnalytical and Dosimetry Services portion that Framatome still provides per contract.

* Section 3.7, Technical Support

Removed reference to Appendix D.

Section 7.1 Nuclear Alert System

Added the new NAS system. Added that backup to NAS and Commercial phones is thesatellite phone.

Section 7.7 Satellite Phones

Added this section on the new satellite phones.

* Table 7.1 Vermont Yankee Emergency Communications Matrix

Added the satellite phone locations to each of the ERFs.

Figure 7.1 Plant to Sate Notification Channels

Added the satellite phone link.

* Figure 7.2 Coordination Channels with States

Page 1 of 2

Extended the NAS line to include MA EOC.

Section 8.4.3 Additional Support

Replaced the reference to the DE&S Mutual Assistance Agreement with the CorporateSupport Center procedure.

* Table 8.4 Minimum Staffing Requirements for the ENVY ERO

Added Mechanical Maintenance to the Repair & Corrective Actions section for the 60 minresponse.

• Figure 8.5 Emergency Operations Facility Organization

Replaced the DE&S Mutual Asst Agreement with the Corporate Support Center

* Section 9.2.4 General Emergency Response

Removed the EOF Coordinator's Asst and Communications Asst positions.

* Section 12.1.6 Health Physics Drills

Removed the requirement that one drill include a PASS sample.

. Appendix.D

Removed the DE&S Mutual Assistance Agreement and replaced it with the Environmentallab information.

Appendix E Letters of Agreement

Replaced the annual INPO letter with the latest version.

Appendix G Index of Emergency Plan Implementing Procedures and Support Plans

Removed the DE&S Mutual Assistance Agreement and replaced it with the CorporateSupport Center Procedure.

Page 2 of 2

I

EMERGENCY PLAN

ENTERGY VERMONT YANKEE

VERNON, VERMONT

REVISION 39

Aiiwn WdIllotm. idha'lmt'- 3*2k'0$1

PREPARER:

REVIEWED:

APPROVED:

APPROVED:

Emergency Plan Coordinator (Print/Sign) Date

M~ovi. M. paul6 k 4.Uv~~f-. M4-v' Q60q-60q ? L/.q..o4K lant 0 era* s Review Committee (Pri f/Sign) DateGeneral Manager (Print/Sign) Date

Site V r T iAc WPr tP iDSie Vic Presi I PrtSn'De

Effective Date 04/28/2004

ENTERGY VERMONT YANKEE EMERGENCY PLAN

REVISION SUMMARY

DATE REVISION'. DESCRIPTION

04/28/04 39 Replaced Framatome ANS services and the DE&S MutualAssistance Agreement with the Corporate Service Center from WhitePlains. Updated information about the NAS to the new NAS systemthat was installed. Added Mechanical Maintenance to the Repair &Corrective Actions section for the 60 min. response in Table 8-4.Removed the EOFC Asst. and Communications positions. Removedrequirement for drills to include a PASS sample.

Emergency PlanRevision 39Revision SummaryPage i of i

Entergy Vermont Yankee

TABLE OF CONTENTS

1.0 INTRODUCTION .......................... 1

2.0 DEFINITIONS ............ 2

3.0 SUMMARY OF EMERGENCY PLAN ........................ 53.1. Objectives .................................. 53.2. Actions In An Emergency .................................. 63.3. Emergency Response Facilities .................................. 63.4. Mobilization .................................. 73.5. State Government Notification And Response .................................. ; . 73.6. Federal Government Notification and Response .................................. 83.7. Technical Support ........................................ 8

4.0 THE AREA ...... 94.1. The Site ........................................ 94.2. Area Characteristics, Land Use and Demography ........................................ 94.3. Emergency Planning Zones ....................................... 10

5.0 EMERGENCY CLASSIFICATION SYSTEM . . ........................... 235.1. Unusual Event ........................................ 23

5.1.1. Unusual Event (Terminated).............. ............ 235.2. Alert ...... 245.3. Site Area Emergency ................................................. 245.4. General Emergency .. 255.5. Emergency Classification System Review By State Authorities . .25

6.0 EMERGENCY RESPONSE FACILITIES AND EQUIPMENT . ..................................... 266.1. Emergency Response Facilities ..................... 26

6.1.1. Technical Support Center .................................. 266.1.2. The Operations Support Center .................................. 276.1.3. Emergency Operations Facility/Recovery Center ............................... 286.1.4. Deleted .................................. 296.1.5. Joint News Center ................................... 296.1.6.. Coordination of.Radiological Data ...................... 29

6.2. Assessment Capability ....................;....306.2.1. Process Monitors ............. 306.2.2. Radiological Monitors ............. 306.2.3. Meteorological Capability ................................ 316.2.4. Fire Detection Devices .326.2.5. Post-Accident Sampling .326.2.6. Facilities and Equipment for Offsite Monitoring .32

Emergency PlanRevision 39Table of ContentsPage i of vii


TABLE OF CONTENTS (Continued)

7.0 COMMUNICATIONS ............................... 377.1. Nuclear Alert System .............................. 377.2. Utility Microwave and Radio Systems .............................. 377.3. Mobile UHF Radio System .............................. 387.4. Plant Intercom System .................... ; 387.5. NRC Telephone System ..................... ; 387.6. Commercial Telephone System .397.7. Satellite Phones .397.8. Emergency Power Supply For Communications ................................. 397.9. Facsimile Transmission ................................. 397.10. Emergency Response Data System ............................. 39

8.0 ORGANIZATION ................................ 438.1. Normal Plant Organization ........................ 438.2. Emergency Response Organization ........................ 43

8.2.1. Site Recovery Manager ........................... 448.2.2. TSC Coordinator ........................... 458.2.3. Plant Emergency Director ........................... 478.2.4. EOF Coordinator ........................... 488.2.5. Operations Support Center Coordinator ........................... 498.2.6. Radiological Assistant ........................... 508.2.7. Radiological Coordinator ........................... 508.2.8. Purchasing Coordinator. ....... .... 518.2.9. Security Coordinator .;. . ... . .528.2.10. Nuclear Information Director .528.2.11. Decision Maker .528.2.12. Engineering Support Group .53

8.3. Recovery Organization ......................................... 538.4. Extensions of Vermont Yankee Emergency Organization . ................................. 54

8.4.1. Local Service ........................................ 548.4.2. Federal Government Support ........................................ 548.4.3. Additional Support ........................................ 55

8.5. Coordination With State Government Authorities . .............................. 55

9.0 EMERGENCY RESPONSE . . . ............................ 709.1. Emergency Condition Recognition and Classification .............. ....................... 709.2. Activation of the Emergency Organization . . ........................... 70

9.2.1. 'Unusual Event Response ;..;;.........' 709.2.2. Alert Response .. 729.2.3. Site Area Emergency Response .. 739.2.4. General Emergency Response .. 74

9.3. Emergency De-Escalation and Termination Criteria . ................................... 74

Emergency PlanRevision 39Table of ContentsPage ii of vii



10.0 RADIOLOGICAL ASSESSMENT AND PROTECTIVE MEASURES ........................... 7910.1. Radiological Assessment ............................................................ 79

10.1.1. Initial Offsite Radiological Dose Projection Capability ........................ 7910.1.2. Variable Trajectory Atmospheric Dispersion/Dose Projection10. Capability ................... ; 8010.1.3. Evaluation of Offsite Air'Samples ....... ............ 80

10.2. Protective Action Recommendation Criteria .8110.3. Radiological Exposure Control .8210.4. Protective Measures .82

10.4.1. Site Personnel Accountability .................................. 8210.4.2. Site Egress Control Methods .................................. 8310.4.3. Decontamination Capability .................................. 8310.4.4. Use of Onsite Protective Equipment and Supplies ............................. 8310.4.5. Fire Protection Equipment .................................. 83

10.5. Aid to Affected Personnel .. 8410.5.1. Medical Treatment ................................................. 8410.5.2. Medical Transportation ................................................. 84

11.0 EMERGENCY NOTIFICATION AND PUBLIC INFORMATION . .................................. 9211.1. Emergency Notifi6ation ................................................. 9211.2. Public Notification ................................................. 9211.3. Public Information ................................................. 93

12.0 MAINTAINING EMERGENCY PREPAREDNESS ....................................... 9512.1. Drills and Exercises 95

12.1.1. Radiation Emergency Drills and Exercises .9512.1.2. Communication Tests ................... 9512.1.3. Fire Drills .9612.1.4. Medical Drills .9612.1.5. Radiological Monitoring Drills .9612.1.6. Health Physics Drills .9612.1.7. Scenarios .9712.1.8. Evaluation of Exercises .9812.1.9. Emergency Plan Audit .98

12.2. Training ........ 9912.3. Review and Updating of Plan and Procedures . ..; ............................. 99-12.4. Maintenance and Inventory of Emergency Equipment and Supplies .. ' 10012.5. Responsibility for the Planning Effort ..............................;.;.;.;.100

Emergency PlanRevision 39

K) Table of ContentsPage iii of vii


TABLE OF CONTENTS (Continsued)

APPENDICES

APPENDIX A

APPENDIX B

APPENDIX C

IAPPENDIX D

APPENDIX E

APPENDIX F

APPENDIX G

APPENDIX H

Emergency Classification System and Emergency Action Levels

Emergency Equipment

Initial Offsite Dose Rate Estimation

Environmental Laboratory Analytical and Dosimetry Services

Letters of Agreement

Evacuation Time Estimates

Index of Emergency Plan Implementing Procedures and SupportPlans

Public Notification System

Paae

101

103

106

108

111

147

155

.158

Emergency PlanRevision 39Table of ContentsPage iv of vii



LIST OF TABLES

Table 4.1

Table 4.2

Table 4.3

Table 7.1

Table 8.1

Table 8.2

Table 8.3

Table 8.4

Table 9.1

Table 10.1.1

Table 10.1.2

Table 10.2

Table 10.3

Table of Land Use

1990 Population Distribution Within the 50-Mile EPZ of Vermont Yankee

Vermont Yankee "Plume Exposure" Emergency Planning Zone (10 Mile)Considerations

Vermont Yankee Emergency Communications Matrix

Emergency Organization Staffing Assignments

(Deleted)

A Summary of Offsite Coordination

Minimum Staffing Requirements for the ENVY ERO

Vermont Yankee Emergency Response

..EPA Protective Action Guidelines

Recommended Derived Intervention Level (DIL) or Criterion for EachRadionuclide Group

Emergency Dose Limits

Emergency Center Habitability and Protective Action Criteria

Emergency PlanRevision 39Table of ContentsPage v of vii



LIST OF FIGURES

Figure 4.1 Vermont Yankee Site

Figure 4.2 Population Center and Special Interest Areas Within the 50 Mile EPZ

Figure 4.3 1990 Population Distribution Within 0-5 Miles of Vermont Yankee



Figure 4.6 Sector Nomenclature for Vermont Yankee Plume Exposure EPZ

Figure 4.7 Vermont Yankee Plume Exposure Emergency Planning Zone

Figure 4.8 Vermont Yankee 50 Mile Ingestion Pathway Emergency Planning Zone

Figure 6.1 Location of State and Company Emergency Operating Centers AroundVermont Yankee

Figure 6.2 Technical Support Center Layout

Figure 6.3 Operations Support Center Layout

Figure 6.4 Emergency Operations Facility/Recovery Center Layout

Figure 7.1 Plant to State Notification Channels

Figure 7.2 Coordination Channels with States

Figure 8.1 Normal On-Shift Emergency Organization

Figure 8.2 Vermont Yankee Emergency Management Organization

Figure8.3 ' Technical Support Center"Emergency Organization

Figure 8.4 Operations Support Center Emergency Organization

Figure 8.5 Emergency Operations Facility Organization

Figure 8.6 (Deleted)

| Figure 8.7 Joint News Center OrganizationEmergency PlanRevision 39Table of ContentsPage vi of vii



Figure 9.1

Figure.10.1

Figure 10.2

Figure 10.3

LIST OF FIGURES (Continued)

Notification Plan

. Vermont Yankee Emergency Dose Rate Nomogram

Field Sample Thyroid Dose Nomogram

Medical Facilities within 50 Miles of Vermont Yankee Capable Of HandlingEmergency Medical Cases

Emergency PlanRevision 39Table of ContentsPage vii of vii


1.0 INTRODUCTION

In the event of an emergency at the Vermont Yankee Nuclear Power Station, officials fromVermont Yankee, local towns, the states of Vermont, New Hampshire and Massachusetts, aswell as federal assistance resources, are mobilized to assess conditions and protect the healthand safety of the public. This document outlines the emergency response actions that aretaken by Vermont Yankee and the manner in which this response interfaces with offsiteresponse actions.

This Emergency Plan is only a part of the overall response to an emergency at VermontYankee. Each community within about a 10-mile radius of the plant and the states(Massachusetts, New Hampshire, and Vermont) have developed emergency response plansto be implemented if the need arises. In addition, federal agencies have specified their nuclearpower plant emergency response roles and capabilities in the federal Radiological EmergencyResponse Plan.

The objective of this document is to outline the overall response of the Company to anemergency at the site. If an abnormal situation develops, automatic initiation of plant safetysystems takes place and plant operators take corrective action according to specificemergency operating procedures. The purpose of these emergency operating procedures isto describe corrective actions necessary to restore normal plant safety margins. Theemergency operating procedures also lead to the activation of the Emergency Plan inaccordance with a prescribed set of emergency implementing procedures. The EmergencyPlan summarizes Vermont Yankee's emergency implementing procedures and thereby theoverall response to an emergency at the site.

Emergency PlanRevision 39Page 1 of 166


2.0 DEFINITIONS

Alert - Indicates a substantial degradation of plant safety margins which could affect onsitepersonnel safety, could require offsite impact assessment, but is not likely to require offsitepublic protective action.

Assessment Actions - Those actions Which are take to effectively define the'emergencysituation necessary for decisions on specific emergency measures.

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

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

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

Emergency Action Levels - Specific instrument readings, system or event observation and/orradiological levels which initiate event classification, notification procedures, protective actions,and/or mobilization of the emergency response organization. These are specific thresholdreadings or observations indicating system failures or abnormalities.

Emergency Assistance Personnel - Vermont Yankee personnel who are assigned a role inthe Emergency Response Organization.

Emergency Classification - Emergencies are classified into four categories, UNUSUALEVENT, ALERT, SITE AREA EMERGENCY and GENERAL EMERGENCY.

Emergency Implementing Procedure - Specific action taken by the plant staff to activate andimplement this Emergency Plan.

Emergency Operations Centers -Areas designated by the statellocal representatives asEmergency Plan assembly areas for their respective staffs.

Emergency Operating Procedu'res -'The outline of specific corrective actions to be taken byplant operators in response to abnormal operating conditions.'



Emergency Operations Facilitv - A center established to coordinate the deployment ofemergency response personnel, to evaluate offsite accident conditions and to maintaincommunications with offsite authorities.

Emergency Planning Zone - The areas for which planning is recommended to assure thatprompt and effective actions can be taken to protect the public in the event of an accident.The two zones are the 10-mile radius plume exposure pathway zone and the 50-mile radiusingestion pathway zone.

Emergency Response Organization - Organization comprised of Emergency AssistancePersonnel who would respond and assist in a classified emergency situation.

Engineering Support Group - An engineering group established to provide emergencysupport for plant assessment and recovery operations.

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. The systemhas four channels which provide separate and independent page and intercommunicationcapabilities.

General Emergency - A General Emergency involves substantial core degradation or meltingwith potential for loss of containment integrity.

Ingestion Exposure PathwaV - The pathway in which individuals receive a radiation dose dueto internal deposition of radioactive materials from inigestion of contaminated water, foods, ormilk.

Joint News Center - A center dedicated to the news media for the purpose of disseminatingand coordinating information concerning accident conditions. Activities conducted within thiscenter will be the responsibility of the Nuclear Information Director (Director of Public Affairs ordesignee).

Operations Support Center - An emergency center established for available skilledemergency personnel (i.e., additional operations and support personnel). The OperationsSupport Center Coordinator directs activities within this center.

Plume Exposure Pathway - The pathway in which individuals receive a radiation dose due to:a) whole body external exposure due to gamma radiation from the plume and from depositedmaterial; and b) inhalation exposure from the passing radioactive plume.

Proiected Dose - This is the amount of radiation does estimated at the onset of any accidentalradiological release. Is includes all the radiation does 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 likely occur ifsuch actions were not undertaken.

Protective Action Guides - Projected radiological dose values to the public which warrantprotective actions following an uncontrolled release of radioactive materials. Protective actionswould be warranted provided the reduction in the individual dose is not offset by excessiverisks to individual safety in implementing such actions.

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

Recovery Center - An area established within the Emergency Operations facility for thepurpose of planning recovery actions. The Site Recovery Manager directs the activities of thiscenter.

Severe Accident Management - Process that management uses to evaluate and respond toan accident that has deteriorated to a condition where the EOPs are exited and the SevereAccident Guidelines are used.

Site - That property within the fenced boundary of Vermont Yankee which is owned by theCompany.

Site Area Emergencv - a Site Area Emergency indicates an event which involves likely oractual major failure of plant functions needed for the protection of the public.

Technical Support Center - An in-plant center established in close proximity to the ControlRoom that has the capability to acquire plant parameters for post-accident evaluation bytechnical and recovery assistance personnel. The Technical Support Center Coordinatordirects activities within this center.

Total Effective Dose Equivalent (TEDE) - The sum of the deep dose equivalent from externalsources and the committed effective dose equivalent from internal exposures.

Unusual Event - An Unusual event indicates a potential degradation of plant safety marginswhich is not likely to affect personnel onsite or the public offsite or result in radioactive releasesrequiring offsite monitoring.

Unusual Event (Terminated) - A condition that warrants an Unusual event declaration, butwas immediately rectified, such that the condition no longer existed by the time of declaration.The event or condition did not affect personnel onsite or the public offsite, or result inradioactive releases requiring offsite monitoring.



3.0 SUMMARY OF EMERGENCY PLAN

3.1. Obiectives

Safety systems at Vermont Yankee are designed to prevent and/or mitigate accidentalradioactive releases. Accordingly, the probability for a release of radioactivity resulting in apublic hazard is very small. As a precautionary measure, however, this Emergency Planspecifies response actions if the safety systems are degraded or fail.

The purpose of this Emergency Plan is to classify emergencies according to severity, to assignresponsibilities, and to clearly outline the most effective actions to safeguard the public andplant personnel in the unlikely event of an incident at Vermont Yankee. Detailed emergencyprocedures at Vermont Yankee are followed by plant personnel to notify and activate theonsite and offsite emergency organizations. These procedures are summarized in thisEmergency Plan.

The basic objectives of this plan are:

1) To establish a system for identification and classification of the emergency conditionand initiation of response actions;

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 onsite and offsite surveillance activities toassess the extent and 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 in limitingthe 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, and local authorities andagencies for offsite emergency response;

-.8) To develop a communications network between the plant and offsite authorities to-provide prompt notification of emergency situations; ::

9) To develop a training and Emergency Plan exercise program to assure constanteffectiveness of the plan; and

10) To keep the public informed in a timely manner to preclude misinformation and bolsterconfidence in the emergency response.

Emergency PlanRevision 39Page5of166


Emergencies at nuclear power plants are classified into the following four major categories (asset forth in Section 5.0): Unusual Event, Alert, Site Area Emergency, and General Emergency.Depending on the emergency classification, different levels of plant and offsite response arerequired. Activation of emergency facilities takes place in accordance with the classification ofemergency response.

3.2. Actions In An Emergency

If an emergency condition develops, the Shift Manager or the senior licensed individual in theControl Room, assumes the responsibilities of the Plant Emergency Director. This individual isresponsible for initiating emergency actions to limit the consequences of the incident and tobring the plant into a stable condition. The individual must:

1) Recognize the emergency condition by observation of Emergency Action Levels;

2) Classify the accident in accordance with the emergency classification system;

3) Initiate emergency operating procedure(s) applicable to the event;

4) Activate the plant emergency alarm system;

5) Notify state authorities in Vermont, New Hampshire and Massachusetts using theNuclear Alert System (Orange Phone);

6) Notify the NRC using the Emergency Notification System;

7) Use the plant pager system to notify appropriate personnel as set forth in Figure 9.1 andTable 9.1;

8) Depending on the emergency classification, initiate the procedures which activate theTechnical Support Center, the Emergency Operations Facility/Recovery Center, theOperations Support Center, and the Joint News Center; and

9) Direct and coordinate all emergency response efforts until overall responsibility isassumed by the TSC Coordinator or the Site Recovery Manager.

3.3. Emergency Response Facilities

The emergency response facilities, which are utilized by the emergency response.organization, are described in Section 6.0. Depending on the emergency classification,different facilities are activated and utiliz6d. Key site and offsite personnel are quicklydispatched to these facilities to perform accident assessments, implement corrective actions,analyze accident data, and provide public information support.



3.4. Mobilization

The mobilization scheme is based on the emergency notification system shown in Figure 9.1.Table 9.1 identifies the personnel notified. The notification system utilizes the plant publicaddress system (Gai-Tronics), dedicated telephone lines, and radio pager devices (beepers) tonotify and mobilize personnel. Key Vermont Yankee and support personnel carry radio pagersto expedite the mobilization process during off-hours. Depending upon the-emergencyclassification, different levels of mobilization are implemented. The mobilization schemeensures that specific technical disciplines identified by Table B-1 of NUREG-0654 can beaugmented within appropriate time frames. Table 8.4 outlines the minimum staffingrequirements for the Emergency Response Organization at Vermont Yankee. Table 9.1summarizes the response to the four classes of emergencies described in Section 5.0.

3.5. State Government Notification And Response

Vermont Yankee's Emergency Plan interfaces with the state emergency response plans ofVermont, New Hampshire and Massachusetts. Local town governments, in coordination withthe emergency management agencies of these states, have plans, which if the need arises,contain instructions to carry out specific protective measures dependent upon variousemergency conditions.

Vermont Yankee is responsible for conveying specific accident information, radiologicalassessment information, and protective action recommendations to the State of Vermont,State of New Hampshire, and Commonwealth of Massachusetts. It is the responsibility ofeach respective state Department of Public Health to evaluate this information and makeappropriate recommendation regarding public protective actions in accordance with their plansand procedures.

A cooperative arrangement exists among the Vermont, New Hampshire and MassachusettsState authorities and Vermont Yankee Nuclear Power Station concerning radiologicalemergency preparedness. Vermont Yankee's emergency classification system and notificationmessages are reviewed and approved by these states in accordance with the terms specifiedin the Letter of Agreement found in Appendix E. Each state is committed to dispatchingrepresentatives to the plant's Emergency Operations Facility/Recovery Center when conditionswarrant. Vermont Yankee's Joint News Center provides the opportunity for joint utility, stateand federal press briefings to be held.

.. .- ... - , .- ..s. . .. . . : :



3.6. Federal Government Wotification and Response

As soon as an event is classified into one of the four categories of emergencies, notification tothe NRC is made using the Emergency Notification System. Once notified of an emergency,the NRC evaluates the situation and determines the appropriate NRC response. Dependingon the severity of the accident and the emergency classification declared, the NRC activatestheir incident response operations in accordance with the NRC Incident Response Plan. TheNRC notifies the Federal Emergency Management Agency (FEMA) and other appropriatefederal agencies to activate the federal emergency response organization in accordance withthe Federal Radiological Emergency Response Plan (FRERP). The FRERP makes availablethe resources and capabilities of 12 federal agencies to support plant, state and localgovernments. Principal participants are the NRC, FEMA, Department of Energy (DOE), andEnvironmental Protection Agency (EPA).

3.7. Technical Support

Technical and manpower support are provided to the Vermont Yankee plant through supportplans listed in Appendix G. Support beyond this level is arranged through the Institute ofNuclear Power Operations (INPO).

.. . . . . .



4.0 THE AREA

4.1. The Site

Vermont Yankee Nuclear Power Station is located on the west bank of the Connecticut Riverimmediately upstream of the Vernon Hydrostation, in the town of Vernon, Vermont. TheVermont Yankee Nuclear Power Station is a boiling water reactor having a thermal ratedpower of 1593 MWt and a gross electrical output of 550 MWe. The station, shown in Figure4.1, is located on about 125 acres in Windham County, and is owned by Vermont Yankee, withthe exception of a narrow strip of land between the Connecticut River and the Vermont Yankeeproperty for which it has perpetual rights and easements from the owner, New England PowerCompany.

4.2. Area Characteristics, Land Use and Democraphy

The site, also shown in Figure 4.1, is bounded by the Connecticut River (Vernon Pond) on theeast, by farm and pasture land mixed with wooded areas on the north and south, and by thetown of Vernon on the west. Warwick and Northfield State Forests (approximately 8 milessouthwest of the site), Green Mountain National Forest (approximately 18 miles southwest ofthe site) and the Pisgah Mountain Range (northeast of the site) limit the population density andland use within a 50-mile radius of the site. Most of the land around the sire is undeveloped.Table 4.1 characterizes the land use within 25 miles of the plant. The developed land is usedfor agricultural, dairying, and for residential areas within small villages. The primaryagricultural crop is silage corn, which is stored for year-round feed for milk cows.

The nearest house is 1,300 feet from the Reactor Building and is one of several west of thesite. The Vernon Elementary School (approximate enrollment of 250 pupils) is about 1,500feet from the Reactor Building. The nearest hospital, Brattleboro Memorial, is approximatelyfive (5) miles north-northwest form the site. The nearest dairy farm is approximately 1/2-milenorthwest of the site. Additional dairy farms are located within a 5-mile radius of the plant.The largest sports facility in the vicinity is the Hinsdale Raceway, located approximately three(3) miles from the site. For racing events, the average attendance is approximately 4,000. Anursing home is located 2 miles south of the plant. These areas have been noted since theyhave required special planning consideration by offsite authorities in the event of a radiologicalemergency at Vermont Yankee.

Figure 4.2 shows an overall perspective of the area within 50 miles of Vermont Yankee. Theaverage population density within a 10-mile radius of Vermont Yankee for 1990 was estimatedto be 105 people per square mile. Figures 4.3, 4.4, and 4.5 provide the 1990 populationdistribution within a 5-, 10-, and 50-mile radius of the Vermont Yankee Nuclear Power Station.Table 4.2 summarizes these data.



4.3. Emergency Planning Zones

The NRC/EPA Task Force Report on Emergency Planning, "Planning Basis for theDevelopment of State and Local Government Radiological Emergency Response Plans inSupport of Light-Water Nuclear Power Plants" (NUREG-0396) established the size of planningzones for which predetermined emergency actions should be prepared. These planning zoneswere selected based upon the knowledge of the potential consequences, timing and releasecharacteristics of a spectrum of accidents (including core melt scenarios), regardless of the lowprobability of occurrence. As a result, an Emergency Planning Zone concept was developed,both for short-term plume exposure and for the longer-term ingestion exposure pathways.

Emergency Planning Zones (EPZs) are defined as the areas for which planning is needed toassure that prompt and effective actions can be taken to protect the public in the event of anaccident. The size of the Emergency Planning Zones represents the extent of detailedplanning which should be performed to assure an adequate response. Dependent upon theseverity of the accident, protective actions are generally limited to only portions of thedesignated EPZs, but as the need arises, actions are undertaken for the entire zones.

As a means of defining selected areas within the planning zones, Vermont Yankee divides theplanning zones into sectors of 22 1/2 degrees centered on the 16 standard compass directions(see Figure 4.6). Each sector is identified by a letter ("I" and "O" are not used) and/or thestandard compass direction. Distance from the plant is defined in terms of miles radiallyoutward from the plant.

Vermont Yankee, for the purpose of radiological protection, is responsible for exercising directcontrol over the emergency activities within the exclusion area' shown in Figure 4.1. Means ofcontrolling access on the river is the responsibility of the State of New Hampshire.

In accordance with the recommended planning bases, Vermont Yankee has expanded itsprevious planning considerations by defining two Emergency Planning Zones. The plumeexposure EPZ, shown in Figure 4.7, is an area designated by the jurisdictional boundaries ofthose communities which are within a radial distance of 10 miles from the plant site. The sizeof the zone is based on the following considerations: 1) projected doses estimated for mostaccidents would not exceed the EPA Protective Action Guides outside the zone; 2) detailedplanning within this area would provide a substantial base for expansion of response efforts inthe event that it is necessary; 3) planning within this area recognizes all jurisdictional restraintsimposed by the zone designation. Table 4.3 lists the local communities that are affected bythis designation, the wind direction which would potentially affect these communities if a'release occurs, and the sector/distance identification representing each of these communities.As specified in the state plans, communities within the plume exposure EPZ are alerted if amajor accident at Vermont Yankee occurs. Communities within this zone have their own localradiological response plans.



The ingestion exposure pathway Emergency Planning Zone, shown in Figure 4.8, is an areawithin a 50-mile radius from the plant site. The size of the zone is based on the fact that thedownwind range within which significant contamination could occur would generally be limitedto this distance because of wind shifts and travel periods. In addition, projected doses fromcontamination outside this zone would not exceed the Department of Health and HumanServices' ingestion pathway Protective Action guides. Four states (Vermont, New Hampshire,Massachusetts, and New York) are responsible for coordinating and implementing protectiveactions within this area. Precautionary measures relative to livestock feeds, milk products,garden produce, and potable water supplies are implements in this area to the extent dictatedby the release conditions.

i



TABLE 4.1

TABLE OF LAND USE

(Square Miles)

: Distance from Site

Land Use

Residential

Commercial and Industrial

Agricultural

Road

Public

Undeveloped

0-10 Miles

30.2

1.3

25.9

6.0

7.2

243.4

10-25 Miles

79.2

7.7

143.8

21.6

78.3

1318.4

1-25 Miles

109.4

9.0

169.7

27.6

85.5

1561.8

TOTAL 314.0 .1649.0. 1963.0



TABLE 4.2

1990 POPULATION DISTRIBUTION WITHIN THE 50-MILEEPZ OF VERMONT YANKEE

-POPULATION TOTALS BY ZONE

RingMiles

0-11-22-33-44-55-10

10-2020-3030-4040-50

Population

4542352179114893393

23510104415136579324069837647

CumulativeMiles

0-10-20-30-40-5

0-100-200-300-400-50

Population

4542806459760869479329891374042739835980521435699

POPULATION TOTALS BY SECTOR

Total Population Total Population

Sector 0-50 Miles Sector 0-50 Miles

ABCDE

. .F

GH

(N)(NNE)(NE)(ENE)(E)(ESE)(SE)

(SSE)

4724836206413905025879304188056

- 13350159636

JKLMNP .

-. QR

(S)(SSMW(SW)(WSW)

(A(WNW)(NW)(NNW)

459545117432298078439642118324321522719143



TABLE 4.3

VERMONT YANKEE

"PLUME EXPOSURE" EMERGENCY PLANNING ZONE (10 MILE) CONSIDERATIONS

COMMUNITIESINVOLVED

1.

2.

3.

4.5.

1.2.

3.

4.

5.

Brattleboro, VT

Dummerston, VT

Guilford, VTHalifax, VTVernon, VT

Chesterfield, NHHinsdale, NH

Richmond, NHSwanzey, NHWinchester, NH

APPROPRIATE SECTORIDENTIFICATION*

P (7-10), R and Q (4-10)

Rand A (8-10)L (3-5), M, N and P (2-9), Q (3-6)M (9-10), N and P (8-10)F (0-2), G and H (0-4), J (0-3), Kand L (0-4), M, N, and P (0-3), Qand R (0-4)

A and B (5-10), C (6-10)R, A, and B (0-6), C (0-4), D andE (0-3), F (1-4), G (2-5)D,E,andF(9-10)

* C (8-1 0),.D (9-1 0)R (6-8), A and B (5-10), C (6-10)

Al,FECTED BY WINDSBLOWING FROM

ESE - SSE - SSWNNE - SSEENE - SE

ALL DIRECTIONS

SSE - WSW

ALL DIRECTIONSWSW- WNW

SSW-W

S-NW

NNW- ENENNE-E

NNW- NNEN - E

WNW- NNEW- NNW.N - NE..

1. Bernardston, MA J (3-9), K (3-10), L (3-8)2. Colrain, MA L and M (9-10)

3. Gill, MA H and J (7-10)

4. Leyden, MA K (7-10), L and M (5-10)

5. Northfield, MA G (4-10), H (3-10), J (3-7)

6. Warwick, MA t and G (6-10)

7. Greenfield, MA J and K (8-10)

*Numbers in parentheses represent approximate miles from plant.



Figure 4.1.I. . .Y

Vermnont Yankee Site



v N+UIQSPITAL A

RUTLAND

I.I

, ,g R) CNMRD14,0001,.> RESERVOIR * _ LA t fVlA

AlbanN BRAT/LEBOR0 RES

I 1/ ~VT WGM-N

J.8 GREeEL_ 1NORIFIEDIAS

DAM

Emrgc PELn

WRevision 39

P 16 WOCE1E6/ _ RESERVOIR Ito CWCOPEE S 9

_,_,,_,_MASS_ rPNF~ MASS_ ,_,

CONN. A t ON -R

RES DAM

Figure 4.2

Population Center and Special Inte rest Areas Within the 50 Mile EPZ

'Emergency Plan- . Revision 39

Page 16 of 166tntergy vermont Yanvee

N

WNW(P)

W72(N)

-(M)

WSW

ENE(D)

E

252 (E)

: ESE/.(F)

Figure 4.3

1990 Population DistributionWithin 0 -5 Miles of Vermont Yankee



N

14

(N W ......... ....

W ... ... . . .... .(N) 54 ..: .-. 2958 (E

- . : .. . -

Figure 4.4

1990 Population DistributionWithin 0 -10 Miles of Vermont Yankee



N ... . ..

WNW(P) I

W1127

(N)

. 51

: -(M)\. I .*-~ WSW

ENE(D)

Eo (E)

ESE(F)

Figure 4.5

1990 Population DistributionWithin 10 - 50 Miles of Vermont Yankee



348 3/4 N 11 114*

281 114 ..... -,. 4* s

WW\ (N) . (J -H (E /S

25.34..... *..... ( )

191 114- S 168374

NOTE: Each sector is 22%O2 and is designated by either a letter ("i" and "0" not used) or astandard compass direction identification.

Figure 4.6

Sector Nomenclature for Vermont Yankee.* Plume Exposure EPZ



0 5 -lo . 15

Figure 4.7

Vermont Yankee Plume Exposure Emergency Planning Zone

* Only those portions of the communities that are within a 10-mile radius have been coveredby the Public Notification System. All communities within this EPZ Boundary designationhave developed an emergency plan.



0 10 20 30 40 50

Miles

Figure 4.8

Vermont Yankee 50 Mile Ingestion PathwayEmergency Planning Zone

Emergency Plan* Revision 39

Page 22 of 166Entergy Vermont Yankee

5.0 EMERGENCY CLASSIFICATION SYSTEM

The wide spectrum of component or system failures, or other occurrences that couldpotentially reduce plant safety margins, needs to be categorized. For this reason, aclassification system has been defined which categorizes incidents according to severity intothe following four classes: Unusual Event, Alert, Site Area Emergency, and GeneralEmergency.

The incidents leading to each of the four emergency classifications are further identified bycertain measurable and observable indicators of plant conditions called Emergency ActionLevels (EALs) listed in Appendix A. Emergency Action Levels defined in Appendix A aid theoperator in recognizing the potential of an incident immediately and assure that the first step inthe emergency response is carried out. The classification of the event may change as theconditions change.

The VY EALS were derived from example initiating conditions in NUREG-0654, Rev. 1. TheEAL bases are derived from NUMARC/NESP-007, Rev. 2.

5.1. Unusual Event

AN UNUSUAL EVENT INDICATES A POTENTIAL DEGRADATION OF PLANTSAFETY MARGINS WHICH IS NOT LIKELY TO AFFECT PERSONNELONSITE OR THE PUBLIC OFFSITE OR RESULT IN RADIOACTIVERELEASES REQUIRING OFFSITE MONITORING.

Unusual Event conditions do not cause serious damage'to the plant and may not require achange in operational status. The purpose of the Unusual Event declaration is to: 1) ensurethat the first step in any response later found to be necessary has been carried out; 2) bringthe operating staff to a state of readiness; and 3) ensure that appropriate offsite notificationshave been made in the event that additional support is required.

See Appendix A for a complete list of Emergency Action Levels corresponding to an UnusualEvent.

5.1.1. Unusual Event (Terminated)

If a condition that warrants an Unusual Event declaration has occurred, and was immediatelyrectified such that the condition no longer existed by the time of declaration, this UnusualEvent classification' is referred to as an'Unusual Event (Terminated).

The event or condition did not affect personnel onsite or the public offsite, or result inradioactive releases requiring offsite monitoring.



5.2. Alert

AN ALERT INDICATES A SUBSTANTIAL DEGRADATION OF PLANTSAFETY MARGINS WHICH COULD AFFECT ONSITE PERSONNEL SAFETY,COULD REQUIRE OFFSITE IMPACT ASSESSMENT, BUT IS NOT LIKELY TOREQUIRE OFFSITE PUBLIC PROTECTIVE ACTION. ANY RELEASESEXPECTED TO BE LIMITED TO SMALL FRACTIONS OF THE EPAPROTECTIVE ACTION GUIDELINE EXPOSURE LEVELS.

Plant response and offsite notifications associated with this event classification assure thatsufficient emergency response personnel, both onsite and offsite, are mobilized and respondto event conditions. Actual releases of radioactivity which exceed Technical Specificationlimits may be involved, thus radiation monitoring and dose projection may be an integralportion of the emergency response required. Plant emergency response facilities are activatedat this classification. Activation of the Joint News Center at this classification is optional.

See Appendix A for a complete list of Emergency Action Levels corresponding to an Alert.

5.3. Site Area Emergency

A SITE AREA EMERGENCY INDICATES AN EVENT WHICH INVOLVESLIKELY OR ACTUAL MAJOR FAILURES OF PLANT FUNCTIONS NEEDEDFOR THE PROTECTION OF THE PUBLIC. ANY RELEASES NOT EXPECTEDTO EXCEED EPA PROTECTIVE ACTION GUIDELINE EXPOSURE LEVELSEXCEPT NEAR SITE BOUNDARY.

The events included in this category represent a potential for offsite releases which couldimpact the public to the extent that protective actions may be necessary. The purpose of theSite Area Emergency declaration is to: 1) ensure that all plant emergency response elementsare mobilized; 2) ensure that monitoring teams have been dispatched, if needed; 3) ensurethat in-plant protective measures have been taken; 4) provide for direct interface with offsitegovernmental response organizations; and 5) provide updates for the public through offsiteofficials.

See Appendix A for a complete list of Emergency Action Levels corresponding to Site AreaEmergency.



5.4. General Emergency

A GENERAL EMERGENCY INVOLVES SUBSTANTIAL COREDEGRADATION OR MELTING WITH POTENTIAL FOR LOSS OFCONTAINMENT INTEGRITY. RELEASES CAN BE REASONABLYEXPECTED TO EXCEED EPA PROTECTIVE ACTION GUIDELINEEXPOSURE LEVELS OFFSITE FOR MORE THAN THE IMMEDIATE SITEAREA.

The purpose of the General Emergency declaration is to: 1) ensure that appropriate offsiteofficials are adequately advised as to the extent of plant degradation; 2) provide consultationwith offsite authorities in establishing appropriate protective actions for the public; 3) provideupdates for the public through offsite authorities; and 4) ensure that all emergency responseorganizations and resources are being applied to accident mitigation.

See Appendix A for a complete list of Emergency Action Levels corresponding to a GeneralEmergency.

5.5. Emergency Classification System Review By State Authorities

The emergency classification system specified above, as well as the EALs presented inAppendix A, are reviewed and concurred with the state authorities of Vermont, NewHampshire, and Massachusetts.



6.0 EMERGENCY RESPONSE FACILITIES AND EQUIPMENT -

Following the declaration of an emergency, the activities of the emergency responseorganization are coordinated in a number of emergency response facilities. Figure 4.1 showsthe relative locations of Vermont Yankee's onsite emergency response facilities. Figure 6.1represents the locations of the offsite support organizations' Emergency Operations Centersrelative to Vermont Yankee. Descriptions of Vermont Yankee facilities and assessmentcapabilities are presented below.

6.1. Emergency Response Facilities

The emergency response organization is activated, in part or wholly, dependent upon theoperating crew's recognition of Emergency Action Levels (EALs) which represent a particularemergency condition.. Facility activation may be modified or suspended if the safety ofpersonnel may be jeopardized by a security event or other event hazardous to personnel.Classification and subsequent declaration of the appropriate emergency condition by the ShiftManager transforms the Control Room complex into an emergency control center. Initially, theControl Room crew coordinates all phases of emergency response and corrective actionrequired to restore the plant to a safe condition. The Control Room staffs attention focuses onregaining plant control as emergency response personnel report and are delegated emergencyfunctions. The following describe each emergency response facility location.

6.1.1. Technical Support Center

A Technical Support Center (TSC) has been established to direct post-accident evaluation andassist in recovery operations of the plant. The TSC is located on'the second floor of theAdministration Building in close proximity to the Control Room and is radiologically habitable tothe same degree as the Control Room for postulated accident conditions. This center isestablished under the supervision of the TSC Coordinator (i.e., the General Manager or adesignated alternate), and staffed by members of the TSC organization shown in Figure 8.3. Aportion of the TSC, as shown in Figure 6.2, is assigned for NRC Incident Response Teammembers who may be dispatched to the plant. The TSC has the capability to monitor variousplant parameters needed to evaluate accident conditions by accessing the plant processcomputer and using the diagnostic capability that its staff offers. The TSC staff can accessmore computer capabilities through the support plans listed in Appendix G.

At maximum capacity, the center accommodates more than 25 personnel, but communicationswith the Enrgineering Sup"port Group reduces the necessity for a large number of technicalsupport personnel at the TSC.



Upon activation, the TSC provides the main communication link between the plant, the ControlRoom, the NRC, the Emergency Operations Facility/Recovery Center and the Engineering

K> Support Group. Details of this communications capability are described in Section 7.0. Theplant print files are located within the TSC boundary, and contain pending and as-built systemand equipment drawings, system flow diagrams, isometrics, cable/wiring diagrams, equipmentoutline drawings, UFSAR, Emergency Plan and plant procedures.

The'TSC is activated by the TSC'Coordinator when a plant'condition exists which requiresongoing technical evaluation (i.e., Alert, Site Area or General Emergency conditions). TheTSC may be activated by the TSC Coordinator under an Unusual Event if conditions warrantsuch an action. The TSC has the capability to assess radiological conditions. Thisassessment capability consists of monitoring for direct radiation and airborne particulates, andsampling and analysis for airborne radiolodine. Appendix B lists emergency equipment foundin the TSC.

If staffing of the TSC is not possible due to a security event or other hazardous conditions,ERO personnel will be notified to report to an alternate location.

The TSC is deactivated by the Site Recovery Manager or the TSC Coordinator, depending onthe emergency class, when the plant conditions have stabilized such that continuous technicalassessment is no longer required.

6.1.2. The Operations Support Center

The Operations Support Center (OSC), which'is located on the first floor of the Administration.) Building, provides a general assembly area for Chemistry, Radiation Protection; Maintenance,

Operations, and I&C Personnel (see Figure 6.3). It is staffed with sufficient in-plant personnelrequired to effect protective and corrective actions in support of the emergency situation. AnOperations Support Center Coordinator directs the activities of this center from either the TSCor the OSC. In-plant phone extensions and a page/intercom system provide communicationcapability at the OSC. Emergency equipment listed in Appendix B has been provided withadditional back-up capability provided at the Radiation Protection control point. If conditionswarrant evacuation of this center, the Emergency Operations Facility/Recovery Centerassumes OSC functions. The OSC remains active and staffed until terminated by the TSCCoordinator.

If staffing of the OSC is not possible due to a security event or other hazardous conditions,ERO personnel will be notified to report to an alternate location.

K) Emergency PlanRevision 39Page 27 of 166


6.1.3. Emergency Operations Facility/Recovery Center

The Emergency Operations Facility/Recovery Center (EOF/RC) is located at the VermontYankee Training Center on Old Ferry Road in Brattleboro, Vermont, approximately 8.75 milesfrom the plant site (See Figure 6.1). The EOF has a radiation protection factor of 5 and aventilation system equipped with HEPA filters which can be isolated. The Commission hasapproved this as the primary facility with no backup up EOF necessary.- (NW 84-44,February 27, 1984) The overall responsibility for the functions performed in the EOF/RCbelongs to the Site Recovery Manager.

The Site Recovery Manager acts as the principal spokesperson for Vermont Yankeeconcerning all issues where an interface with offsite government authorities is required. TheEOF Coordinator is responsible for continuous evaluation of all licensee activities related to anemergency having, or potentially having, environmental radiological consequences. TheEOF/RC has sufficient space and design to accommodate the emergency responseorganization and responding representatives from government and industry who areresponsible for limiting offsite consequences (see Figure 6.4). The EOF/RC providesinformation needed by federal, state, and local authorities for implementation of their offsiteEmergency Plans, and a centralized meeting location for key representatives from theagencies.

The EOF/RC maintains extensive communications capability with all emergency responsefacilities. Section 7.0 details the extent of this capability. Site access and control, doseassessment, sample analysis, decontamination, and recovery planning activities are directedfrom various locations within the EOF/RC. The EOF/RC serves as the primary evacuation,re-assembly, and off-duty augmentation personnel assembly point. Public informationstatements concerning the plant emergency status are transmitted from the EOF/RC to theJoint News Center for release to the public.

The following copies of emergency planning documents are available in the EOF/RC:

* Site Emergency Plan and Implementing Procedures* Area Maps* State and Local Emergency Plans* UFSAR

Emergency equipment and supplies are maintained at the EOF/RC, including equipmentnecessary to assess radiological habitability. This consists of monitoring for direct radiationand sarripling and analysis for airborne radioparticulates and radioiodine!' For a list of EOF/RCemergency equipment, see Appendix B.



6.1.4. Deleted

K> 6.1.5. Joint News Center

The Joint News Center (JNC) provides a centralized location for conducting joint state, federaland Vermont Yankee emergency news briefings in a manner to avoid hampering ongoingemergency response proceedings. It is expected that state and federal public informationpersonnel will operate from the JNC.

The initial designated location of the JNC is the Vermont Yankee Training Center located inBrattleboro, Vermont. If accident conditions (plume trajectory) jeopardize the habitability of thisfacility, the alternate JNC in Marlborough, Massachusetts would be utilized.

At the JNC,'the Nuclear Information Director (who is Vermont Yankee's Director of PublicAffairs or designee) coordinates the generation and issuance of press releases concerningplant emergency conditions to the media. Prior to their release to the media, the SiteRecovery Manager or designee approves releases.

The JNC will be activated upon an emergency classification of Site Area Emergency or higherexcept as noted below.

Activation of the JNC is optional prior to a Site Area Emergency and is dependent on theescalation of the event and/or public interest. Prior to the activation of the JNC, the Director ofPublic Affairs or designee would be coordinating press releases from his/her routine operationslocation.

6.1.6. Coordination of Radiological Data

Centralized coordination of the offsite radiological assessment effort with all organizationsinterested in and/or performing assessments is of importance to ensure that the data and itsinterpretation are reviewed by all parties. The number and type of organizations performingthis effort vary with time and following accident declaration and offsite notification. Initially,plant emergency response personnel are the only organization performing this function andthey are directed from, and their results evaluated, at the EOF/RC. State authorities join theEOF/RC monitoring and assessment activities. Federal response agencies would augmentplant and state radiological assessment efforts upon their arrival.

Plant and state monitoring efforts are coordinated at the EOF/RC. All samples are screenedfor activity levels in the field. Positive results require additional analysis at the EOF/RC.Analysis is completed in two phases. Initially, the sanr'ple is evaluated for radioiodineconcentration levels using gamma energy analyses instrumentation. Having completed thisanalysis, total isotopic determination of activity levels is conducted using a GE(Li) system. TheEOF/RC sampling capability is greatly enhanced by coordinating sample transfer and analysiswith the Environmental Laboratory.



When federal resources respond, a more suitable location than the EOF/RC may be needed.As stated by the Department of Energy (DOE), the agency charged with the lead of the federaloffsite monitoring resources, this effort would be established at some location in the generalvicinity of the plant site that was adequate for the equipment and manpower deployed.Arrangements will be made for such a location with DOE and the states when it is required.Wherever this function is located, the basic objective is to assure monitoring efforts from allorganizations are coordinated.

6.2. Assessment Capability

The activation of the Emergency Plan and the continued assessment of accident conditionsrequire extensive monitoring and assessment capabilities. The essential monitoring systemsneeded for recognition of abnormal events by the plant operators are incorporated in theEmergency Action Levels specified in Appendix A. This section briefly describes monitoringsystems as well as other assessment capabilities.

6.2.1. Process Monitors

Plant process monitors capability includes indications provided from various monitors locatedthroughout the plant systems. Parameters monitored include pressure, temperature, flow, andequipment operating status. Vermont Yankee has also augmented these monitoring systemswith the instrumentation to detect inadequate core cooling.

The manner in which process monitors are used for accident recognition and classification isgiven in the detailed Emergency Action Level listings in Appendix A.

6.2.2. Radiological Monitors

A number of radiation monitors and monitoring systems are provided on process and effluentliquid and gaseous lines that serve directly or indirectly as discharge route for radioactivematerials. These monitors, which include Control Room readout and alarm functions, exist inorder that appropriate action can be initiated to limit fuel damage and/or contain radioactivematerial.

These monitors include:

1. Main steam line radiation monitoring system,2. Air ejector off-gas radiation monitoring system,

- 3. Process and liquid effluent radiation monitors,4. Containment atmosphere radiation monitoring system,5. Reactor Building ventilation radiation monitoring system, and6. Plant stack radiation monitoring system.

Specific details on these monitoring systems such as location, type, etc., are contained in theplant Updated Final Safety Analysis Report (UFSAR).



In addition to installed monitoring systems, Vermont Yankee has augmented onsiteradiological assessment capability to include high-range containment and stack radiationmonitoring; improved in-plant iodine detection capability; and arrangements for containmentatmosphere and reactor water samples.

6.2.3. Meteorological Capability

Vermont Yankee maintains a 305-foot primary meteorological tower from which the followingparameters are measured:

Wind speed at the 35 and 297 foot levels,

Wind direction at the 35 and 297 foot levels,

Ambierit temperature at the 35 foot level, and

Vertical temperature difference between the 35 and 200-foot levels and the 35and 297 foot levels.

In addition, precipitation and barometric pressure are measured on the ground.

Fifteen-minute averages of the meteorological data are automatically displayed in the ControlRoom and the EOF/RC. These meteorological data are used to calculate offsite dispersionparameters on a real-time basis at the EOF/RC during accident conditions.

Vermont Yankee also maintains onsite a 140 foot back-up meteorological tower from which thefollowing parameters are measured:

* Wind speed at the 100 foot level,

* Wind direction at the 100 foot level, and

* Vertical temperature difference between the 33 - and 135-foot levels.

This tower serves as a back-up to the primary tower should it fail. The meteorological datafrom the back-up tower are displayed on video graphic recorders located in the Control Room.

In addition, Vermont Yankee has the capability to access additional meteorological informationthrough offsite support services. This information can be forwarded to VY dose assessmentpersonnel upon request.



6.2.4. Fire Detection Devices

Vermont Yankee has an extensive fire detection network which utilizes a combination ofsmoke detectors, thermal detectors, infrared detectors, ultraviolet detectors, and "rate of rise"detectors, as well as fire system status alarms as a means of providing plant operators withcomplete fire status information. This system is described in PP 7011, Vermont Yankee FireProtection and Appendix R Program.

These detection systems, in addition to providing alarm indications in the Control Room,activate automatic fire suppression systems in certain vital areas within the plant.Supplementing these systems are dry chemical and CO2 extinguishers, standpipe systems,and a continuously available fire brigade.

6.2.5. Post-Accident Sampling

Post-accident sampling capability provides for emergency sample collection of containmentatmosphere, plant stack halogen and particulate components, and primary coolant.Management implements radiological precautions to limit whole body exposure to 5rem/individual for sampling and analyses conducted using these systems.

6.2.6. Facilities and Equipment for Offsite Monitoring

States Emergency Management and/or the system load dispatcher provides reportsconcerning natural occurrences or severe weather conditions that may affect the plant area.Offsite fire departments of Vernon and Brattleboro notify the plant of any fire which might havean impact on the plant. Local Law Enforcement Agencies notify Plant Security of any-situationin the area which might have an impact on the plant.

In addition to offsite monitoring equipment at the EOF/RC, Vermont Yankee maintains anoffsite environmental monitoring program. Radiological environmental monitoring stations forthe site and surrounding area monitor the environment under normal and accident conditions.Radiological environmental monitoring stations have been established in accordance withTechnical Specification (Technical Requirements Manual) requirements.

Vermont Yankee has full access to the services of the Environmental Lab in Westboro,Massachusetts which provides 24-hour service for emergency environmental samples andpersonnel dosimetry analysis. The Environmental Lab provides mobile equipment as detailedin Appendix D. The capabilities of the Westboro Environmental Lab constitute a full spectrumof analytical radioassay measurements on environmental sample media..A full'service TLDprocessing capability also exists at the Lab. p m A f e

Additional offsite monitoring equipment and capability can be provided by federal agencies inaccordance with the Federal Radiological Emergency Response Plan. As discussed inSection 6.1.6, this additional capability is integrated into existing efforts.



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Location of State and Company Emergency Operating Centersaround Vermont Yankee



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Technical Support Center Layout



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Operations Support Center Layout



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7.0 COMMUNICATIONS

Ku The plant staff has available various means of communication systems for effectivecommunications and coordination with offsite and onsite response organizations and/or teams.

A summary of the communication systems is defined in the communication matrix provided inTable 7.1 and outlined below.

7.1. Nuclear Alert System

The Nuclear Alert System (NAS), originating in the Control Room, is a system of dedicatedphone circuits independent of the normal land line phone system. The NAS is used to notifythe State Police of Vermont, Massachusetts, and New Hampshire of any emergency. Thissystem is a secure (dedicated) communications arrangement and is installed for' the primarypurpose of initial notification of the States, via State Police, by the plant operators.

This system is manned on a 24-hour basis on both ends - the Control Room and the StatePolice dispatching points. The activation of the public notification system starts with this24-hour State police link. NAS is tested monthly between the plant and the State Policeagencies.

The Nuclear Alert System also links the Control Room, the Emergency Operating Centers andIncident Field Offices of Massachusetts, New Hampshire, and Vermont, and the EmergencyOperations Facility/Recovery Center (EOF/RC). This communication system incorporates allthe principal emergency response centers into a sin