DCL-16-120, Independent Spent Fuel Storage Installation - Emergency Plan Implementing Procedures Updates

Independent Spent Fuel Storage Installation - Emergency Plan Implementing Procedures Updates

ML16337A356
Person / Time
Site:	Diablo Canyon
Issue date:	11/17/2016
From:	Ginn M Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
DCL-16-120, DIL-16-018
Download: ML16337A356 (97)

Text

Pacific Gas and Electric Company"'

Michael A. Ginn Diabla Canyon Power Plant Manager P.O. Bax 56 Emergency Planning Avila Beach, GA 93424 605.545.6300 Internal: 691.6300 Fax: 605.545.6265 November 17, 2016 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 U.S. Nuclear Regulatory Commission 10 CFR 50.54, 10 CFR 72.32 ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Docket No. 72-26, Materials License No. SNM-2511 Diablo Canyon Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Updates

Dear Commissioners*and Staff:

In accordance with 10 CFR 50.54 and the requirements of 10 CFR 72.32, Pacific Gas and Electric Company (PG&E) is providing a summary of the analysis of changes to Emergency Plan (E-Plan) Implementing Procedures EP G-2, "Interim Emergency Response Organization," EP G-3, "Emergency Notification of Off-Site Agencies,"

EP G-4, "Assembly and Accountability," EP EF-1, "Activation and Operation of the Technical Support Center," EP EF-2, "Activation and Operation of the Operational Support Center," EP EF-3, "Activation and Operation of the Emergency Operations Facility," and EP EF-9, "Backup Emergency Response Facilities."

The associated enclosures are listed below:

Enclosure Title 1 Diablo Canyon Power Plant Emergency Plan Implementing Procedures, Revision Numbers for Emergency Plan Implementing Procedures 2 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-2, Revision 50, "Interim Emergency Response Organization" 3 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-3, Revision 59, "Emergency Notification of Off-Site Agencies" 4 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-4, Revision 29, "Assembly and Accountability" A member of the STARS Alliance Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

Document Control Desk PG&E Letter DCL-16-120 November 17, 2016 PG&E Letter DIL-16-018 Page2 Enclosure Title 5 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-1, Revision 52, "Activation and Operation of the Technical Su ort Center

6 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-2, Revision 39, "Activation and Operation of the 0 erational Su ort Center

7 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-3, Revision 44, "Activation and Operation of the Erner enc Operations Facili 8 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-9, Revision 12, "Backu Erner enc Res onse Faciliti PG&E evaluated the changes for a reduction in effectiveness, as defined in 10 CFR 50.54(q), and concluded that the changes do not reduce the effectiveness of the E-Plan. The E-Plan continues to meet the requirements in Appendix E to 10 CFR Part 50 and the planning standards of 10 CFR 50.47(b). Therefore, prior NRC approval of the associated changes was not required.

This update does not contain any privacy and proprietary information in accordance with NRC Generic Letter 81-27, "Privacy and Proprietary Material in Emergency Plans."

• PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.

If there are questions regarding this update, please contact me at (805) 545-3446.

Sincerely, Michael A. Ginn Emergency Planning Manager aph8/6470/50876578,50876579,50876502, 50876575,50876501,50876576,50876577 Enclosures cc/enc: John M. Goshen, P.E., NMSS Project Manager Kriss M. Kennedy, NRC Region IV Administrator Qhristopher W. Newport, NRC Senior Resident Inspector Balwant K. Singal, NRC Senior Project Manager Senior Emergency Preparedness Inspector (RGN-IV/DR)

A member of the STARS Alliance Callaway

• Diablo Canyon

• Palo Verde* Wolf Creek

Enclosure 1 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Revision Numbers for Emergency Plan Implementing Procedures

Enclosure 1 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Proc. No. Rev. Title OM10.ID1 14 Maintaining Emergency Preparedness OM10.DC1 8 Emergency Preparedness Drills and Exercises EP G-1 44 Emergency Classification and Emergency Plan Activation EP G-2* 50 Interim Emergency Response Organization EP G-3* 59 Emergency Notification of Off-Site Agencies EP G-4* 29 Assembly and Accountability EP G-5 14 Evacuation of Non-Essential Site Personnel EP OR-3 10 Emergency Recovery EP RB-1 8 Personnel Dosimetry EP RB-2 8 Emergency Exposure Guides EP RB-3 7 Stable Iodine Thyroid Blocking EP RB-4 5 Access to and Establishment of Controlled Areas Under Emergency Conditions EP RB-5 8 Alternate Personnel Decontamination Facilities EP RB-8 27 Instructions for Field Monitoring Teams EP RB-9 15 Calculation of Release Rate EP RB-10 19 Protective Action Recommendations EP RB-11 14 Emergency Offsite Dose Calculations EP RB-12 11 Plant Vent Iodine and Particulate Sampling During Accident Conditions EP RB-14 9 Core Damage Assessment Procedure EP RB-14A 2 Initial Detection of Fuel Cladding Damage EP RB-15 15 Post Accident Sampling System EP RB-16 14 Operating Instructions for the EARS Computer Program EP R-2 33 Release of Airborne Radioactive Materials Initial Assessment EP R-3 9 Release of Radioactive Liquids EP R-7 16A Off-Site Transportation Accidents EP EF-1* 52 Activation and Operation of the Technical Support Center EP EF-2* 39 Activation and Operation of the Operational Support Center EP EF-3* 44 Activation and Operation of the Emergency Operations Facility EP EF-4 20 Activation of the Off-Site Emergency Laboratory EP EF-9* 12 Backup Emergency Response Facilities EP EF-10 17 Activation and Operation of the Joint Information Center EP EF-11 2 Alternate Emergency Response Facilities/ Incident Command Post (ICP)

• Revised Document Page 1 of 1

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-2, Revision 50 Interim Emergency Response Organization

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-2. Revision 50 Original Content Content Change Change Number I Type of Change I Reason for Change - Note at top of Attachment 1 - Note attop of page Change #1 - Sponsor edit - no change in intent with page 1 1 respect to the Emergency Plan (E-Plan).

NIA- new content added Steps in this checklist may need to Added in note to be consistent with other implementing be performed in an order other than procedures. The note informs the user that steps may listed based on sequence of events. need to be performed in a different order than listed because emergencies vary. Note provides clarity to the user that they do not have to abide by strict place keeping if the sequence of events they are faced with do not line up with the way the procedure is ordered. - Step 1.a - 1.a-4) Attachment 1 -*Step 1.a - 1.a-1 ).a) Change #2 - Sponsor edit - no change in intent with respect to the E-Plan.

N/A- new content added a. Emergency Classification [TIME CRITICAL] Reformatted the attachment to "bin" like tasks with each

a. Classify and declare an other based on user feedback to improve performance.

emergency condition within 15 1) Classify and declare emergency This change includes a new "bin" for emergency minutes per EP G-1. conditions within 15 minutes per classification.

EP G-1.

1) Date/Time of Event: Added in the "[TIME CRITICAL]" phrase to make it clear a) Document: that emergency classification requires a high level of

2) Emergency Action Level (EAL):

• Date/Time of Event: attention.

• Emergency Action Level

3) Date/Time of Classification: (EAL): There is no change of intent as the requirements for

• Date/Time of Classification: emergency classification are not altered in any way. This

4) Upgrade Criteria:

• Upgrade Criteria: change continues to provide alignment with the content of the current E-Plan.

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Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change - step 1.c- 1.c.7) Attachment 1 - step 1.b - 1.b.4) Change #3 - Sponsor edit - no change in intent with respect to the E-Plan.

c. Initiate ERO actions: b. Initiate ERO Actions Reformatted the attachment to "bin" like tasks with each NOTE: VANS should be activated NOTE:VANS should be activated other based on user feedback to improve performance.

immediately after an event immediately after an event declaration (Alert or higher). declaration (Alert or higher). Added in the phrase "or other qualified operator" for voice activated notification system (VANS) activation to account

1) Ensure Communicator #2 1) Direct Communicator #2, or other for situations in which Communicator #2 may not activate activates VANS per Attachment qualified operator, to activate VANS VANS. Multiple operators are trained and qualified on the

3. per Attachment 3. activation of VANS. This change aligns with E-Plan Section 5 and Appendix F for on-shift responsibilities.

2) Ensure Communicator #1 2) Direct available operator to make completes the Emergency a Public Address Announcement The actions to make the PA announcement and send out Notification Form (ENF) for per Attachment 6. the SmartMSG were moved up in the sequence of steps approval per Attachment 2.T30899 as they belong next to the activation of VANS as they are

3) Direct available operator to send also means by which the ERO are notified ..

3) Direct Shift Phone Talker to a SmartMSG pa~er message per make offsite verbal notifications to Attachment 1o.T 6779 Revision 49 step 1.c.3) was relocated to step 1.d.3) in the County and State Revision 50 based on reformatting of the attachment.

per Attachment 11.r04380 4) Update the Control Room (unless time critical actions are being Revision 49 steps 1.c.4) and 1.c.5) were relocated to

4) Direct the Work Control Shift performed). steps 1.e.1) and 1.e.2) respectively in Revision 50 based Foreman to initiate Attachment 4. Record Time: on reformatting of the attachment.

5) Direct a Work Control Lead Revision 49 step 1.c.6) was relocated to step 1.c.1) in (WCL), or other licensed Revision 50 based on reformatting of the attachment.

operator, to initiate Attachment 5.

Revision 49 step 1.c. 7) was relocated to step 1.e.3) in

6) IF a General Emergency is Revision 50 based on reformatting of the attachment.

declared, THEN determine There is no change of intent as all of the actions are still AND approve protective action beina performed. The relocation of the steps from j

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Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change recommendation (PAR) per EP Revision 49 to Revision 50 is acceptable because the RB-10. attachment is a guideline and not necessarily a step by step sequence of instructions. Many of the tasks get

7) Initiate logging declarations implemented in parallel, which is hard to reflect in the and actions taken. procedure. The time requirements for all of the tasks remain the same. There are no changes to the start or stop times for any task in the attachment.

This change continues to provide alignment with the content of the current E-Plan. - step 1.c.6) Attachment 1 - step 1.c - 1.c.1 ).a) Change #4 - Sponsor edit - no change in intent with respect to the E-Plan.

NIA- new content added c. Emergency Protective Actions

[TIME CRITICAL] Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

6) IF a General Emergency is 1) IF GENERAL EMERGENCY This change includes a new "bin" for PARs.

declared, declared, THEN determine THEN determine and approve Added in the "[TIME CRITICAL]" phrase to make it clear AND approve protective action protective action recommendation th_at PARs require a high level of attention.

recommendation (PAR) per EP (PAR) per EP RB-10.

RB-10. Added in "Obtain independent recommendation if time permits" to be consistent with other implementing NIA- new content added a) Obtain independent procedures for the TSC and EOF decision/makers.

recommendation if time permits.

There is no change of intent as the requirements for PARs are not altered in any way. The assignments of responsibilities for PARs are not altered by this change.

This change continues to provide alignment with the content of the current E-Plan.

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Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change - steps 1.c.2) and Attachment 1 - step 1.d - 1.d.1 ).b) Change #5 - Sponsor edit - no change in intent with 1.c.3) respect to the E-Plan.

d. Emergency Notifications [TIME NIA- new content added CRITICAL] Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

NIA- new content added 1) Complete offsite notifications This change includes a new "bin" for emergency within 15 minutes of event notifications.

declaration per EP G-3.

2) Ensure Communicator #1 Added in the phrase "or other qualified operator for completes the Emergency a) Direct Communicator #1 , or other notifications to account for situations in which Notification Form (ENF) for qualified operator, to complete the Communicator #1 may not fill out the ENF. Multiple approval per Attachment 2.T30899 Emergency Notification Form ~NFJ operators are trained and qualified on filling out the ENF.

3089 for approval per Attachment 2. This change aligns with E-Plan Section 5 and Appendix F

3) Direct Shift Phone Talker to for on-shift responsibilities.

make offsite verbal notifications to b) Direct Shift Phone Talker, or the County and State other qualified operator, to make Added in the phrase "or other qualified operator" for per Attachment 11.T04380 offsite verbal notifications to the notifications to account for situations in which Shift Phone Coun~ and State per Attachment Talker may not make the phone calls to the County and 11.T04 80 State. Multiple operators are trained and qualified on making the phone calls to the County and State. This change aligns with E-Plan Section 5 and Appendix F for on-shift responsibilities. - Multiple steps Attachment 1 - step 1.e - 1.e.3) Change #6 - Sponsor edit - no change in intent with respect to the E-Plan.

NIA- new content added e. Additional Actions:

Reformatted the attachment to "bin" like tasks with each 1.c.4) Direct Work Control Shift 1) Direct Work Control Shift other based on user feedback to improve performance.

Foreman (WCSFM) to initiate Foreman (WCSFM) to initiate This change includes a new "bin" for additional actions. . Attachment 4.

Multiple steps were relocated. There is no change of 1.c.5) Direct a Work Control Lead 2) Direct Work Control Lead (WGL), intent as all of the actions are still being performed. The (WGL), or other licensed or other licensed operator, to initiate relocation of the steps from Revision 49 to Revision 50 is 4 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change operator, to initiate Attachment 5. Attachment 5. acceptable because the attachment is a guideline and not necessarily a step-by-step sequence of instructions.

1.c.7) Initiate logging declarations Many of the tasks getimplemented in parallel, which is and actions taken 3) Log declarations, decisions, and hard to reflect in the procedure. The time requirements actions taken. for all of the tasks remain the same. There are no changes to the start or stop times for any task in the attachment. This change continues to provide alignment with the content of the current E-Plan .

. Attachment 1 - step 1.d - 1.d.3) Attachment 1 - step 2.a - 2.a.1 ).b) Change #7 - Sponsor edit - no change in intent with respect to the E-Plan.

CA.UTION: Special consideration CAUTION: Special consideration should be given to performing should be given to performing The PA message and SmartMSG steps were relocated Assembly, Accountability and/or Assembly, Accountability and/or (see Change #3).

evacuation when the action place evacuation when the action place personnel in danger (security personnel in danger (security event, Assembly and accountability actions were relocated from event, toxic gases, fires, weather toxic gases, fires, weather initial actions to subsequent actions based on reformatting conditions, etc.). conditions, etc.). of the attachment to "bin" like tasks with each other based on user feedback to improve performance. This change

d. Inform plant personnel of the a. Assembly and Accountability includes a new "bin" for assembly and accountability.

emergency as follows:

1) IF SAE, GE, security event, or There is no change of intent as all of the actions

1) IF SAE, GE, security event, or any other event warranting associated with assembly and accountability are still any other event warranting Assembly and Accountability, being performed. The relocation of the steps from the last Assembly and Accountability as THEN initiate Assembly and step of the initial actions to the first step of subsequent determined by SM, Accountability PER EP G- actions is acceptable because the attachment is a THEN initiate Assembly and 4. T36223ff04336 guideline and not necessarily a step-by-step sequence of Accountability PER EP G-4.T36223 instructions.

a) Record time of site emergency a) Record time of site emergency signal activation The intent of initial actions is to group tasks that need to signal activation be performed within the first 15 minutes of entering the

2) IF not implementing EP G-4, b) Direct Communicator #2, or other E-Plan. Assembly and accountability is a task that has a THEN direct an operator to available operator, to complete EP 30-minute requirement, which is beyond the 15-minute 5 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change initiate Attachment 6, "Public G-4 (Form 69-13231), initial action threshold.

Address Announcement "Accountability Roster."

Templates."T35779 The time requirements for assembly and accountability remain the same. There are no changes to the start or

3) Direct an operator to send a stop times. This change does not alter any pager message to the entire site responsibilities currently assigned for performing through the SmartMSG system assembly an,d accountability.

per Attachment 1o.T36779 This change continues to provide alignment with the content of the current E-Plan. - step 2.b Attachment 1 - step 2.b - 2.b.2) Change #8 - Sponsor edit - no change in intent with respect to the E-Plan.

N/A- new content added b. Early Work Release and Site Evacuation Reformatted the attachment to "bin" like tasks with each

b. Evaluate initiation of an early other based on user feedback to improve performance.

work release, or site evacuation. 1) IF at a UE or Alert, This change includes a new "bin" for early work release (Refer to EP G-5.)T04336 THEN evaluate early work release and site evacuation. /

per EP G-5.T04336 Added in specific criteria for early work release for the

2) IF at a SAE or GE, Unusual Event (UE) and Alert levels, which is when an THEN evaluate site evacuation per early work release is applicable per EP G-5. Also added EP 8 _5 _T04336

• in specific criteria for site evacuation for the Site Area Emergency (SAE) and General Emergency (GE) levels, which is when a site evacuation is applicable per EP G-5.

This change does not create any new requirements or responsibilities. This change aligns EP G-2 with existing content in EP G-5.

This change continues to provide alignment with the content of the current E-Plan.

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Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change - step 2.c Attachment 1 - step 2.c -2.c.1) Change #9 - Sponsor edit - no change in intent with respect to the E-Plan.

N/A- new content added C. Emergency Exposures Reformatted the attachment to "bin" like tasks with each

c. Authorize exceeding normal 1) Authorize exceeding normal dose other based on user feedback to improve performance.

dose limits, if required. (Refer to limits, if required (PER EP RB This change includes a new "bin" for emergency EP RB-2 .)ro4336 2.)T04336 exposures.

Made an editorial change: "Refer" changed to "PER" to align with other implementing procedures.

This change continues to provide a!ignment with the content of the current E-Plan. - step 2.d Attachment 1 - step 2.d - 2.d.1) Change #10 - Sponsor edit - no change in intent with respect to the E-Plan.

N/A- new content added d. Administration of Kl Reformatted the attachment to "bin" like tasks with each

d. Authorize Kl administration, if 1) Authorize Kl administration, if other based on user feedback to improve performance.

reauired. (Refer to EP RB- required (PER EP RB-3.)r04336 This change includes a new "bin" for administration of 3.) to4336 potassium iodide (Kl).

Made an editorial change: "Refer" changed to "PER" to align with other implementing procedures.

This change continues to provide alignment with the content of the current E-Plan. - step 2.e Attachment 1 - step 2.e - 2.e.1) Change #11 - Sponsor edit - no change in intent with respect to the E-Plan. '

N/A - new content added e. Control Room Habitability Reformatted the attachment to "bin" like tasks with each 7 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change

e. IF in Mode 3 (Recirc) 1) IF in Mode 3 (Recircj ventilation, other based on user feedback to improve performance.

ventilation, THEN evaluate need for sampling This change includes a new "bin" for control room THEN evaluate need for sampling Control Room air quality for C02 habitability.

Control Room air quality for Cb 2 build-up.

build-up. (REFER to OP H-5:1V). This change continues to provide alignment with the (REFER to OP H-5:1V). content of the current E-Plan. - step 2.f Attachment 1 - step 2.f- 2.f.1) Change #12 - Sponsor edit - no change in intent with respect to the E-Plan.

N/A- new content added f. Other Duties Reformatted the attachment to "bin" like tasks with each

f. Authorize overtime and other 1) Authorize overtime and other other based on user feedback to improve performance.

expenses associated with expenses associated with This change includes a new "bin" for other duties. This establishing and maintaining an establishing and maintaining an change continues to provide alignment with the content of appropriate site emergency appropriate site emergency the current E-Plan.

organization. organization. - step 2.h Attachment 1 - step 2.g - 2.g.1) Change #13 - Sponsor edit- no change in intent with respect to the E-Plan.

N/A ~new content added g. Emergency Termination Reformatted the attachment to "bin" like tasks with each

h. For termination of an 1) For termination of an UNUSUAL other based on user feedback to improve performance.

UNUSUAL EVENT, initiate EVENT, initiate Attachment 7 (Form This change includes a new "bin" for emergency (Form 69-21273), 69-21273), "Guidelines for termination.

"Guidelines for Terminating an Terminating an Unusual Event."

Unusual Event" Step was also relocated from 2.h to 2.g to improve flow.

This is a subsequent action that has no time requirement; therefore, there is no impact on relocating it. This change continues to provide alignment with the content of the current E-Plan.

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Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change - step 2.g - 2.g.2) Attachment 1 - step 2.h - 2.h.1 ).c) Change #14 - Sponsor edit- no change in intent with respect to the E-Plan.

NIA - new content added h. Command and Control Turnover Reformatted the attachment to "bin" like tasks with each

g. When ready to turn over 1) WHEN the SEC or ED is ready to other based on user feedback to improve performance.

Command and* Control of the take command and control, This change includes a new "bin" for command and emergency, then perform all of THEN: control turnover.

the following:

a) Use EP EF-1 (Form 69-20437), Step was also relocated from 2.g to 2.h to improve flow.

1) Use EP EF-1 (Form 69-20437), "Command and Control Turnover This is a subsequent action that has no time requirement; "Command and Control Turnover Checklist" to turnover therefore, there is no impact on relocating it.

Checklist," to turnover responsibilities responsibilities. Added in a new step for the Shift Manager (SM) to update b) Update the CR that you have the crew on the transfer of command and control to NIA - new conter:it added turned over command and control enhance the guidance for improved recognition of what E-and include which duties the CR is Plan tasks the control room is responsible for after responsible for. turnover.

2) Ensure that copies of ENFs c) Ensure that copies of ENFs This change continues to provide alignment with the created in the Control Room have created in the Control Room have content of the current E-Plan.

been provided to the been provided to the TSC and EOF.

TSC and EOF. - step 3.a - 3.a.1) Attachment 1 - step 3.a - 3.a.2).a)_ Change #15 - Sponsor edit - no change in intent with

&3.b-3.b.1) respect to the E-Plan.

NIA- new content added a. Plant Monitoring and Assessment Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

a. Continue reviewing EP G-1 1) Continue reviewing EP G-1 EAL This change includes a new "bin" for plant monitoring and EAL criteria. criteria. assessment.

1) Report any potential changes a) Report changes in any of the Steps 3.a and 3.b from Revision 49 were combined into in event classification to the Site following to the Site Emerqency *step 3.a in Revision 50. Both of these tasks are ongoing 9 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change Emergency Coordinator or Coordinator or Emergency Director actions that have no time requirements; therefore, there is Emergency Director (2002 (2002 Bridgeline is,preferred): no impact on combining them.

Bridgeline is preferred).

• Escalations in event classification This change continues to provide alignment with the

• Concurrent EAL thresholds content of the current E-Plan.

b. Monitor radiological effluent that are met conditions.

2) Continue monitoring radiological effluent conditions.

1) Report significant changes to the Radiological Advisor in the a) Report significant changes in TSC (2002 Bridgeline is r(!diological effluent conditions to the preferred). Radiological Advisor in the TSC (2002 Bridgeline is preferred). - steps 3.c and 3.d Attachment 1 - step 3.b - 3.b.2) Change #16 - Sponsor edit - no change in intent with respect to the E-Plan.

N/A- new content added b. Plant Priorities Reformatted the attachment to "bin" like tasks with each

c. Assist the TSC in determining 1) Assist the TSC in determining other based on user feedback to improve performance.

station priorities for repair and station priorities for repair and This change includes a new "bin" for plant priorities.

mitigation actions onsite (2002 mitigation actions onsite (2002 Bridgeline is preferred). Bridgeline is preferred). This change continues to provide alignment with the content of the current E-Plan.

d. Brief the TSC Operations 2) Brief the TSC Operations Advisor Advisor of significant changes in of significant changes in plant/system/ equipment status plant/system/equipment status and and actions being taken in the actions being taken in the Control Control Room. Room. - step 3.e Attachment 1 - step 3.c - 3.c.1) Change #17 - Sponsor edit - no change in intent with respect to the E-Plan.

N/A - new content added c. Periodic Briefs 10 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change Reformatted the attachment to "bin" like tasks with each

e. Perform periodic intra-facility 1) Perform periodic intra-facility other based on user feedback to improve performance.

teleconference I video conference teleconference I video conference This change includes a new "bin" for periodic briefs.

tailboards. Refer to EP EF-3 tailboards. Refer to EP EF-3 (Form This change continues to provide alignment with the (Form 69-20788), "Emergency 69-20788), "Emergency Response content of the current E-Plan.

Response Facility Tailboard Facility Tailboard Checklist."

Checklist." - note at top of Attachment 2 - note at top of page 1 Change #18 - Sponsor edit - no change in intent with page 1 respect to the E-Plan.

Steps in this checklist may need to N/A- new content added be performed in an order other than Added in note to be consistent with other implementing listed based on sequence of events. procedures. The note informs. the user that steps may need to be performed in a different order than listed because emergencies vary. The note provides clarity to the user that they do not have to abide by strict place keeping if the sequence of events they are faced with do not line up with the way the procedure is ordered. - step 2.a.5) Attachment 2 - step 2.a.5) Change #19 - Sponsor edit - no change of intent with respect to the E-Plan.

Ensure that the Shift Phone Ensure that the Shift Phone Talker Talker completes verbal completes verbal notifications to the Added in the words "or less" to align with the notification notifications to the County and County and State within procedure EP G-3.

State within approximately 45 approximately 45 minutes.or less of minutes of the previous verbal the previous verbal notification. There is no change of intent as the requirement is not notification. altered as follow-up notifications.are still required to be completed approximately every 45 minutes. This change continues to provide alignment with the content of the current E-Plan.

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Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change - note at top of Attachment 3 - note at top of page 1 Change #20 - Sponsor edit - no change in intent with page 1 respect to the E-Plan.

Steps in this checklist may need to NIA- new content added be performed in an order other than Added in note to be consistent with other implementing listed based on sequence of events. procedures. The note informs the user that steps may need to be performed in a different order than listed because emergencies vary. Note provides clarity to the user that they do not have to abide by strict place keeping if the sequence of events they are faced with do not line up with the way the procedure is ordered. - step 1.b.2) Attachment 3 - step 1.b.2) Change #21 - Sponsor edit - no change in intent with respect to the E-Plan.

IF the initial event classification is Activate VANS immediately after an ALERT or higher, time of classification for ALERT or Reformatted step to clean it up and make it simpler and THEN activate VANS immediately higher. more direct to enhance user performance. The intent of after time of classification. the step remains unchanged.

This change continues to provide alignment with the content of the current E-Plan. - step 1.b.3) Attachment 3 - step 1.b.3) Change #22 - Sponsor edit - no change in intent with respect to the E-Plan.

IF the event classification is an Activate VANS as soon as possible UNUSUAL EVENT, after time of classification for Reformatted step to clean it up and make it simpler and THEN activate VANS as soon as UNUSUAL EVENT. more direct to enhance user performance. The intent of possible. the step remains unchanged.

This change continues to provide alignment with the content of the current E-Plan.

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Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change - step 1.b.6).b) Attachment 3 - step 1.b.4) - Change #23 - Sponsor edit - no change in intent with 1.b.4).a) respect to the E-Plan.

6) Determine appropriate VANS scenario ID: 4) Determine appropriate VANS Reformatted step to clean it up and make it simpler and scenario ID: more direct to enhance user performance. The intent of b) Non-Security Event Scenarios the step remains unchanged. The step was relocated to (1) 0112: Non-Security a) NON-SECURITY Event make the flow of the procedure line up better with the UNUSUAL EVENT with no further Scenarios performance of the task of activating VANS. This change action required

• 0112: Non-Security UNUSUAL continues to provide alignment with the content of the (2) 2012: Non-Security EVENT with no further action current E-Plan.

UNUSUAL EVENT with ERO required reporting to their emergency

• 2012: Non-Security UNUSUAL response facilities EVENT with ERO reporting to (3) 0113: Non-Security ALERT, emergency response facilities SITE AREA EMERGENCY, or

• 0113: Non-Security ALERT, GENERAL SITE AREA EMERGENCY, or EMERGENCY GENERAL EMERGENCY - step 1.b.6).a) Attachment 3 - step 1.b.4).b) Change #24 - Sponsor edit - no change in intent with respect to the E-Plan.

a) Security Event Scenarios b) SECURITY Event Scenarios (1) 1010: Security UNUSUAL

• 1010: Security UNUSUAL . Reformatted step to clean it up and make it simpler and EVENT EVENT more direct to enhance user performance. The intent of (2) 0114: Security ALERT, SITE

• 0114: Security ALERT, SITE the step remains unchanged. The step was relocated to AREA EMERGENCY, or AREA EMERGENCY, or make the flow of the procedure line up better with the GENERAL GENERAL EMERGENCY performance of the task of activating VANS.

EMERGENCY (3) 1012: ERO Notification '-Content relocated (see change# The "ERO Notification Homeland Security Elevated Homeland Security Elevated 25) Threat Alert" was moved from the security events heading Threat Alert to the non-emergency events heading where it belongs.

An elevated homeland security threat is not a declared emergency by itself and as such the scenario ID belongs under the non-emergency heading.

13 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018

• Original Content Content Change Change Number I Type of Change I Reason for Change This change continues to provide alignment with the content of the current E-Plan. - step 1.b.6).d) Attachment 3 - step 1.b.4).d) Change #25 - Sponsor edit - no change in intent with respect to the E-Plan.

d) Non-Emergency Scenarios d) Non-Emergency Scenarios (1) 0111: 1 Hr. 14 Hr./ 8 Hr. Non-

• 0111: 1 Hr./ 4 Hr./ 8 Hr. Non- Reformatted step to clean it up and make it simpler and Emergency Notification Emergency Notification more direct to enhance user performance. The intent of (2) 0555: 12Kv Power Outage

• 0555: 12Kv Power Outage Call the step remains unchanged. The step was relocated to Call out out make the flow of the procedure line up better with the (3) 0777: OCC Call out

• 0777: OCC Call out performance of the task of activating VANS.

(4) 0999: DCPP Fire Fighters Call .

• 0999: DCPP Fire Fighters Call out *out This change continues to provide alignment with the (5) 0116: Congregate Care

• 0116: Congregate Care Callout content of the current E-Plan.

Callout

• 1012: ERO Notification Content relocated (see change Homeland Security Elevated

1. 24) Threat Alert

• 1007: Training Scenario ~ I (6) 1007: Training Scenario - step 1.b.4) - Attachment 3 - step 1.b.5) - Change #26 - Sponsor edit - no change in intent with 1.b.5) 1.b.5).a) respect to the E-Plan. *

4) Determine appropriate "On the 5) Determine which "On the fly Reformatted step to clean it up and make it simpler and fly Template" to use: Template" to use: more direct to enhance user performance. The intent of a) IF a non-security event,

• TEMPLATE 1: Non-Security the step remains unchanged. The step was relocated to THEN use applicable non- UNUSUAL EVENT make the flow of the procedure line up better with the security event template.

• TEMPLATE 2: Non-Security performance of the task of activating VANS.

b) IF a security event, ALERT or HIGHER.

THEN use the security event

• TEMPLATE 3: ALL Security The different on-the-fly templates were designated as 1-4 template. Events. to help differentiate them based upon user feedback.

14 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change c) IF event has been terminated,

• TEMP LATE 4: Emergency event THEN use the event termination termination. This change continues to provide alignment with the template. content of the current E-Plan.

a) Obtain information from the SM

5) Obtain enough information or Communicator #1 to fill out from the SM or Communicator #1 template.

to fill out applicable "On the fly Message" template. - Non-Security Attachment 3 - Non-Security Change #27 - Sponsor edit - no change in intent with UNUSUAL EVENT template UNUSUAL EVENT template respect to the E-Plan.

N/A- new content added Changes made: Reformatted template to make the flow better with the

• Reformatted template performance of the task of activating VANS.

• Added TEMPLATE 1" The different on-the-fly templates were designated as 1-4 to help differentiate them based upon user feedback.

This change continues to provide alignment with the content of the current E-Plan. - Non-Security Attachment 3 - Non-Security Change #28 - Sponsor edit - no change in intent with ALERT or HIGHER template ALERT or HIGHER template respect to the E-Plan.

N/A- new content added Changes made: Reformatted template to make the flow better with the

• Reformatted template performance of the task of activating VANS.

• Added "TEMPLATE 2" The different on-the-fly templates were designated as 1-4 to help differentiate them based upon user feedback.

This change continues to provide alignment with the content of the current E-Plan.

15 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change - Security Event Attachment 3 - Security Event Change #29 - Sponsor edit - no change in intent with template template respect to the E-Plan.

N/A - new content added Changes made: Reformatted template to make the flow better with the

• Reformatted template performance of the task of activating VANS.

• Added "TEMPLATE 3" The different on-the-fly templates were designated as 1-4 to help differentiate them based upon user feedback.

This change continues to provide alignment with the content of the current E-Plan. - Emergency Event Attachment 3 - Emergency Event Change #30 - Sponsor edit - no change in intent with Termination template Termination template respect to the E-Plan.

N/A- new content added Changes made:

Reformatted template

• Added "TEMPLATE 4" Reformatted template to make the flow better with the performance of the task of activating VANS.

The different on-the-fly template_s were designated as 1-4 to help differentiate them based upon user feedback.

This change continues to provide alignment with the content of the current E-Plan. - step 1.c.1 ).b) Attachment 3 - step 1.c.1. a)* . Change #31 - Sponsor edit - no change in intent with respect to the E-Plan.

b) Correct scenario ID determined a) Correct scenario ID determined from step 1.b.6) above: from step 1.b.4) above Reformatted step to clean it up and make it simpler and more direct to enhance user performance. The intent of the step remains unchanged. The step was relocated to make the flow of the procedure line up better with the performance of the task of activating VANS.

16 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change

- This change continues to provide alignment with the content of the current E-Plan. - step 1.c.1) .a) Attachment 3 - step 1.c.1. b) Change #32 - Sponsor edit - no change in intent with respect to the E-Plan.

a) Correct on-the-fly template b) Correct on-the-fly template filled filled out from step 1.b.5) above. out from step 1.b.5) above Reformatted step to clean it up and make it simpler and more direct to enhance user performance. The intent of

~

the step remains unchanged. The step was relocated to make the flow of the procedure line up better with the performance of the task of activating VANS.

This change continues to provide alignment with the content of the current E-Plan. - step 1.c.6) - Attachment 3 - step 1.c.6) - Change #33 - Sponsor edit - no change in intent with 1.c.6).d) 1.c.6).c) respect to the E-Plan.

6) Listen to the prompts. 6) Listen to the prompts. Reformatted step to clean it up and make it simpler and more direct to enhance user performance. The intent of a) Press "2", to record on-the-fly a) Press "2", to record on the fly the step remains unchanged. The step was relocated to message. message. make the flow of the procedure line up better with the performance of the task of activating VANS.

b) Wait for prompt. b) When prompted, record message using template. This change continues to provide alignment with the c) Record message using content of the current E-Plan.

applicable template c) Then press "#."

d) Then press "#." - new step Attachment 3 - step 1.c. 7) - Change #34 - Sponsor edit - no change in intent with 1.c.7).b).(1) respect to the E-Plan.

N/A- new content added 17 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for

,- Change

7) The system should replay the Added in new step to fix an issue identified by the end recorded on-the-fly message and user. This prompt exists in the VAN_$_ activation process ask if it is correct: but it was missing from the procedure. This change makes the procedurE! accurate for the task of activating a) If correct, press "1" for yes. VANS.

b) If incorrect, press "2" for no. This change continues to provide alignment with the content of the current E-Plan.

(1) The system will direct you to re-record the message. - st~p 1..~ Attachment 3 - step 2.a Change #35 - Sponsor edit - no change in intent with respect to the E-Plan.

IF Assembly and Accountability is IF Assembly and Accountability is initiated, initiated, Assembly and accountability actions were relocated from THEN fax the on-shift THEN fax the on-shift accountability the last step of initial actions to the first step of accountability roster to the DCPP roster to the DCPP Watch subsequent actions based on reformatting of the Watch Commander at (x3115) Commander at (x3115) within 15 attachment within 15 minutes from the time minutes from the time the site the site emergency signal was emergency signal was sounded, per There is no change of intent as all of the actions sounded, per EP G-4. EP G-4. associated with assembly and accountability are still being performed. The relocation of the steps from initial actions to subsequent actions is acceptable because the intent of initial actions is to group together tasks that need to be performed within the first 15 minutes of entering the E-Plan. Assembly and accountability is a task that has a 30-minute requirement, which is beyond the 15-minute initial action threshold.

The time requirements for assembly and accountability remain the same. There are no changes to the start or stop times. This change does not alter any responsibilities currently assigned for performing 18 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change assembly and accountability.

This change continues to provide alignment with the content of the current E-Plan. - note at top of Attachment 4 - note at top of page 1 Change #36 - Sponsor edit - no change in intent with page 1 respect to the E-Plan.

Steps in this checklist may need to N/A- new content added be performed in an order other than Added in note to be consistent with other implementing listed based on sequence of events. procedures. The note informs the user that steps may need to be performed in a different order than listed because emergencies vary. Note provides clarity to the user that they do not have to abide by strict place keeping if the sequence of events they are faced with do not line up with the way the procedure is ordered. - step 1.a Attachment 6 - step 1.a Change #37 - Sponsor edit - no change in intent with respect to the E-Plan.

a. For Security events, GO TO a. IF security event, Section 2. THEN GO TO step 2. Reformatted step to clean it up and make it simpler and more direct to enhance user performance. The intent of the step remains unchanged. This change continues to

~

provide alignment with the content of the current E-Plan. - steps 1.b - Attachment 6 - step 1.b - Change #38 - Sponsor edit - no change in intent with 1.d.2).c). 1.b.3).a).(2) respect to the E-Plan.

b. Based upon plant conditions, b. Based upon plant ~onditions, use Reformatted steps to clean them up and make them use one of the following one of the. following templates to -simpler and more direct to enhance user performance.

templates to develop a PA develop and make a PA The intent of the steps remains unchanged. The same message. T36779 message:r367 ~ 9

• actions are taken at the same emergency classification levels.

c. For an UNUSUAL EVENT or 1) UNUSUAL EVENT use 19 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change ALERT: TEMPLATE A. The non-security PA templates were designated as A-D to help differentiate them based upon user feedback.

1) Make a PA announcement 2) ALERT use TEMPLATE B.

using the appropriate template .. Relocated "repeat the announcement" from the body of the instruction into the body of the templates to improve

2) Repeat the PA announcement. usability.

CAUTION: Assembly, CAUTION: Assembly, Accountability This change continues to provide alignment with the Accountability and/or evacuation and/or evacuation when in a content of the current E-Plan.

when in a security event or other security event or other hazardous hazardous condition (i.e., toxic condition (i.e., toxic gases, fires or gases, fires or weather weather conditions) may place conditions) may place personnel personnel in danger.

in danger.

3) SITE AREA EMERGENCY or

d. When a SITE AREA GENERAL EMERGENCY:

EMERGENCY or GENERAL EMERGENCY is declared, a) Determine if it is safe to move determine if it is safe to move personnel.T3B779 personnel. T35779 (1) IF NOT safe to move personnel, THEN make a PA announcement

1) IF it is NOT safe to move using TEMPLATE C.

personnel:

a) Make a PA announcement using the "NOT SAFE TO MOVE PERSONNEL" template. (2) IF safe to move personnel, THEN make a PA announcement b) Repeat the PA announcement. using TEMPLATE D, AND sound the site emergency '

2) IF it is safe to move personnel: signal for 60 seconds.

a) Make a PA announcement using the "SAFE TO MOVE 20 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change PERSONNEL" template.

b) Sound the site emergency signal for 60 seconds.

c) Repeat the PA announcement. - UNUSUAL Attachment 6 - UNUSUAL EVENT Change #39 - Sponsor edit - no change in intent with EVENT template template respect to the E-Plan.

N/A - new content added Changes made: Reformatted template to make the flow better with the

• Added "TEMPLATE A" performance of the task of making a public announcement

• Added "repeat the (PA).

announcement"

• Reformatted template Relocated "repeat the announcement" from the body of the instruction into the body of the template to improve usability.

The PA templates were designated as A-D to help differentiate them based upon user feedback.

This change continues to provide alignment with the content of the current E-Plan. - ALERT template Attachment 6 - ALERT template Change #40 - Sponsor edit - no change in intent with respect to the E-Plan.

NIA - new content added Changes made:

• Added "TEMPLATE B" Reformatted template to make the flow better with the

• Added "repeat the performance of the task of making a PA.

announcement"

• Reformatted template Relocated "repeat the announcement" from the body of the instruction into the body of the template to improve usability.

21 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change The PA templates were designated as A-D to help differentiate them based upon user feedback.

This change continues to provide alignment with the content of the current E-Plan. - SITE AREA Attachment 6 - SITE AREA Change #41 - Sponsor edit - no change in intent with EMERGENCY or GENERAL EMERGENCY or GENERAL respect to the E-Plan.

EMERGENCY & Not Safe to EMERGENCY & Not Safe to Move Move Personnel template Personnel template Reformatted template to make the flow better with the performance of the task of making a PA.

N/A- new content added Changes made:

• Added "TEMPLATE C" Relocated "repeat the announcement" from the body of

• Added "repeat the the instruction into the body of the template to improve announcement" usability.

• Reformatted template The PA templates were designated as A-D to help differentiate them based upon user feedback.

This change continues to provide alignment with the content of the current E-Plan. - SITE AREA Attachment 6- SITE AREA Change #42 - Sponsor edit - no change in intent with EMERGENCY or GENERAL EMERGENCY or GENERAL respect to the E-Plan.

EMERGENCY & Safe to Move EMERGENCY & Safe to Move Personnel template Personnel template Reformatted template to make the flow better with the performance of the task of making a PA.

NIA- new content added Changes made:

• Added "TEMPLATE D" Relocated "repeat the announcement" from the body of

• Added "repeat the the instruction into the body of the template to improve announcement" usability.

• Reformatted template The PA templates were designated as A-D to help 22 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Chanae differentiate them based upon user feedback.

This change continues to provide alignment with the content of the current E-Plan. - step 2.a Attachment 6 - step 2.a Change #43 - Sponsor edit - no change in intent with respect to the E-Plan.

a. For Aircraft based threats, use a. IF aircraft based threat, -

PA messaae scripts located in CP THEN GO TO CP M-15A for PA Reformatted step to clean it' up and make it simpler and M-15A.T357'1 9 message scripts.r36779 more direct to enhance user performance. The intent of the step remains unchanged. This change continues to provide alignment with the content of the current E-Plan. - step 2.b - Attachment 6 - step 2.b - Change #44 - Sponsor edit - no change in intent with 2.d.2).d) 2.b.2).b).(3) respect to the E-Plan.

b. For a non-Aircraft based threat, b. Determine if it is safe to move Reformatted steps to clean them up and make them determine if it is safe to move personnel.r36779 simpler and more direct to enhance user performance.

personnel. T35779 The intent of the steps remains unchanged. The same

c. IF NOT safe to move 1) IF NOT safe to move personnel, actions are taken at the same emergency classification personnel: THEN make PA announcement levels.

1) Develop and make a PA using TEMP LATE E.

announcement using template A The security event PA templates were designated as E-G "SECURITY NOT SAFE to help differentiate them based upon user feedback.

TO MOVE PERSONNEL".

Relocated "repeat the announcement" from the body of

2) Repeat the PA announcement. the instruction into the body of the templates to improve

2) IF safe to move personnel: usability.

d. IF safe to move personnel: a) UNUSUAL EVENT make PA This change continues to provide alignment with the announcement using TEMPLATE F. content of the current E-Plan.

1) For an UNUSUAL EVENT:

23 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change a) Develop and make a PA announcement using template B "SECURITY UNUSUAL EVENT SAFE TO MOVE PERSONNEL". b) ALERT, SITE AREA b) Repeat the PA announcement. EMERGENCY or GENERAL EMERGENCY:

2) For an ALERT, SITE AREA EMERGENCY or GENERAL (1) Make PA announcement using EMERGENCY: TEMPLATE G.

a) Develop and make a PA announcement using template C "SECURITY ALERT (2) Sound the Site Emergency OR HIGHER SAFE TO MOVE Signal for 60 seconds.

PERSONNEL".

b) Sound the Site Emergency Signal for 60 seconds. (3) GO TO CP M-15A Attachment 20 for subsequent actions.

c) Repeat the PA announcement.

d) Go to CP M-15A Attachment 20 for subsequent actions. - Security Event & Attachment 6 - Security Event & Change #45 - Sponsor edit - no change in intent with Not Safe to Move Personnel Not Safe to Move Personnel respect to the E-Plan.

template template Reformatted template to make the flow better with the N/A - new content added Changes made: performance of the task of making a PA.

• Changed "TEMPLATE A" to "TEMPLATE E" Relocated "repeat the announcement" from the body of

• Added "repeat the the instruction into the body of the template to improve 24 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change announcement" usability.

• Reformatted template The security event PA templates were designated as E-G to help differentiate them based upon user feedback.

This change continues to provide alignment with the content of the current E-Plan. - Security Attachment 6 - Security UNUSUAL Change #46 - Sponsor edit - no change in intent with UNUSUAL EVENT & Safe to EVENT & Safe to Move Personnel respect to the E-Plan.

Move Personnel template template Reformatted template to make the flow better with the N/A- new content added Changes made: performance of the task of making a PA.

• Added*Changed "TEMPLATE B" to Relocated "repeat the announcement" from the body of "TEMPLATE F" the instruction into the body of the template to improve

• Added "repeat the usability.

announcement"

• Reformatted template The security event PA templates were designated as E-G to help differentiate them based upon user feedback.

This change continues to provide alignment with the content of the current E-Plan. - Security ALERT Attachment 6 - Security ALERT or Change #47 - Sponsor edit - no change in intent with or HIGHER & Safe to Move HIGHER & Safe to Move Personnel respect to the E-Plan. ,

Personnel template template Reformatted template to make the flow better with th~

N/A- new content added Changes made: performance of the task of making a PA. *

• Changed "TEMPLATE C" to "TEMPLATE G" Relocated "repeat the announcement" from the body of

• Added "repeat the the instruction into the body of the template to improve announcement" usability.

25 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change

• Reformatted template The security event PA templates were designated as E-G to help differentiate them based upon user feedback.

This change continues to provide alignment with the content of the current E-Plan. - new step Attachment 6 - step 3 Change #48 - Sponsor edit - no change in intent with respect to the E-Plan.

N/A - new content added PUBLIC ADDRESS SYSTEM UNAVAILABILITY Reformatted step to clean it up and make it simpler and more direct to enhance user performance. The intent of the step remains unchanged.

This step did not belong in section 2 which is for security events. This step is generic guidance that is applicable to all situations and as such needed its own section.

This change continues to provide ~lignmentwith the content of the current E-Plan. - step 2.e Attachment 6 - step 3.a Change #49 - Sponsor edit - no change in intent with respect to the E-Plan.

e. IF the public address system is a. IF the public address system is unavailable, unavailable, Added in the use of SmartMSG as another means of THEN call the DCPP Security THEN use SmartMSG to communicating with plant staff in the event that the PA Watch Commander (x3330) and communicate with plant staff, system is unavailable. SmartMSG is an existing request the following: AND call the DCPP Security Watch communications tool that is available in the Control Room.

Commander (x3330) and request It uses the pager system to send a message to all the following: personnel onsite with pagers.

Operators are trained on the use of this system.

26 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change This change continues to provide alignment with the content of the current E-Plan. - step 2.f -2.f.1) Attachment 6 - step 3.b - 3.b.3) Change #50 - Sponsor edit - no change in intent with respect to the E-Plan ..

f. IF the public address system b. IF the public address system AND security are unavailable, AND security are unavailable, Reformatted step to clean it up and make it simpler and THEN email the above PA THEN: more direct to enhance user performance. The intent of message to "DCPP *NPG _, the step remains unchanged.

Nuclear Power Generation 1) Use SmartMSG to communicate Business with plant staff. Added in the use of SmartMSG as another means of Unit" and, communicating with plant staff in the event that the PA

2) Email the content of the system is unavailable. SmartMSG is an existing

1) Add the PA message to bridge applicable PA message to "DCPP communications tool that is available in the Control Room.

line ext. 2800: *NPG Nuclear Power Generation It uses the pager system to send a message to all Business Unit". personnel onsite with pagers.

3) Add the content of the applicable Operators are trained on the use of this system.

PA message to bridge line ext.

2800: This change continues to provide alignment with the content of the current E-Plan. -:- step 2.e Attachment 7 - step 2.e Change #51 - Sponsor edit - no change in intent with respect to the E-Plan.

e. Notify Senior Plant e. Notify Senior Plant Management Management and PG&E External and PG&E External Removed the reference to attachment 8 because it is Communications that the event Communications that the event has unnecessary. The personnel that would be tasked with has been terminated by activating been terminated by activating VANS the action to activate VANS are familiar with where the VANS per Attachment 8 using using SCENARIO ID 0200. procedure guidance is that provides direction. The intent SCENARIO ID 0200. of the step remains unchanged.

This change continues to provide alignment with the content of the current E-Plan.

27 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change - step 1.b.2) - Attachment 8 - step 1.b - 1.b.1) Change #52 - Sponsor edit - no change in intent with 1.b.2).c) respect to the E-Plan.

b. Determine appropriate VANS

b. Determine appropriate VANS scenario ID: Reformatted step to clean it up and make it simpler and scenario ID: more direct to enhance user performance. The intent of

1) NON-SECURITY Event the step remains unchanged. The step was relocated to

2) NON-SECURITY Event Scenarios make the flow of the procedure line up better with the Scenarios

• 0112: Non-Security UNUSUAL performance of the task of activating VANS.

a) 0112: Non-Security UNUSUAL EVENT with no further action EVENT with no further action required This change continues to provide alignment with the required

• 2012: Non-Security UNUSUAL content of the current E-Plan.

b) 2012: Nori-Security UNUSUAL EVENT with ERO reporting to EVENT with ERO reporting to their normal emergency their normal emergency response response facilities facilities

• 0113: Non-Security ALERT, c) 0113: Non-Security ALERT, SITE AREA EMERGENCY, or SITE AREA EMERGENCY, or GENERAL EMERGENCY GENERAL EMERGENCY - step 1.b.1) - Attachment 8 - step 1.b.2) Change #53 - Sponsor edit - no change in intent with 1.b.1 ).c) respect to the E-Plan.

2) SECURITY Event Scenarios

1) Security Event Scenarios Reformatted step to clean it up and make it simpler and

• 1010: Security UNUSUAL more direct to enhance user performance. The intent of a) 1010: Security UNUSUAL --._ EVENT the step remains unchanged. The step was relocated to EVENT

• 0114: Security ALERT, SITE make the flow of the procedure line up better with the b) 0114: Security ALERT, SITE AREA EMERGENCY, or performance of the task of activating VANS.

AREA EMERGENCY, or GENERAL EMERGENCY GENERAL EMERGENCY Content relocated (see change# The "ERO Notification Homeland Security Elevated c) 1012: ERO Notification 54) Threat Alert" was moved from the security events heading Homeland Security Elevated to the non-emergency events heading where it belongs.

Threat Alert An elevated homeland security threat is not a declared emergency by itself and as such the scenario ID belonQs 28 of 31

Enclosure 2 PG&E Letter DCL-16-120

. PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change under the non-emergency heading.

This change continues to provide alignment with the content of the current E-Plan. - step 1.b.4) - Attachment 8 - step 1.b.4) Change #54 - Sponsor edit - no change in intent with 1.b.4).f) respect to the E-Plan.

4) Non-Emergency Scenarios

4) Nqn-Emergency Scenarios

• 0111: 1 Hr. I 4 Hr. I 8 Hr. Non- Reformatted step to clean it up and make it simpler and a) 0111: 1 Hr. I 4 Hr. I 8 Hr. Non- Emergency Notification more direct to enhance user performance. The intent of Emergency Notification

• 0555: 12Kv Power Outage Call the step remains unchanged. The step was relocated to b) 0555: 12Kv Power Outage Call out make the flow of the procedure line up better with the out

• 0777: OCC Call out performance of the task of activating VANS.

c) 0777: OCC Call out

• 0999: DCPP Fire Fighters Call d) 0999: DCPP Fire Fighters Call out This change continues to provide alignment with the out

• 0116: Congregate Care Callout ~ content of the current E-Plan.

e) 0116: Congregate Care Callout

• 1012: ERO Notification f) 1007: Training Scenario Homeland Security Elevated Threat Alert

• .1007: Training Scenario - step 1.h - 1.h.4) Attachment 8 - step 1.h - 1.h.3) Change #55 - Sponsor edit - no change in intent with respect to the E-Plan.

h. Listen to the prompts. h. Listen to the prompts.

Reformatted step to clean it up and make it simpler and

1) Press "2", to record on-the-fly 1) Press "2", to record on the fly more direct to enhance user performance~ The intent of message. message. the step remains unchanged. The step was relocated to make the flow of the procedure line up better with the

2) Wait for prompt. 2) When prompted, record message performance of the task of activating VANS.

using applicable template.

3) Record message using This change continues to provide alignment with the applicable template 3) Then press"#." content of the current E-Plan.

29 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change

4) Then press "#." - new step Attachment 8 - step 1.i - 1.i.2).a) Change #56 - Sponsor edit - no change in intent with respect to the E-Plan.

N/A- new content added i. The system should replay the recorded on-the-fly message and Added in new step to fix an issue identified by the end ask if it is correct: user. This prompt exists in the VANS activation process but it was missing from the procedure. This change

1) If correct, press "1" for yes. makes the procedure accurate for the task of activating VANS.

2) If incorrect, press "2" for no.

This change continues to provide alignment with the a) The system will direct you to re- content of the current E-Plan.

record the message. 1 - note at top of Attachment 11 - note at top of page Change #57 - Sponsor edit - no change in intent with page 1 1 respect to the E-Plan.

N/A- new content added Steps in this checklist may need to Added in note to be consistent with other implementing be performed in an order o.ther than procedures. The note informs the user that steps may listed based on sequence of events. need to be performed in a different order than listed because emergencies vary. Note provides clarity to the user that they do not have to abide by strict place keeping

.if the sequence of events they are faced with do not line up with the way the procedure is ordered.* 1 - step 2 note Attachment 11 - step 2 note Change #58 - Sponsor edit - no change of intent with respect to the E-Plan.

Follow-up notifications per EP G- Follow up notifications per EP G-3 3 (Form 69-21638), "DCPP (Form 69-21638), "DCPP Follow Up Added in the words "or less" to align with the notification Follow-Up Emergency Notification Emergency Notification Form", procedure EP G-3.

Form", should be performed should be performed approximately 30 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change approximately every 45 minutes. every 45 minutes or less. (Refer to There is no change of intent as the requirement is not (Refer to EP G-3.) EP G-3.) altered as follow-up notifications are still required to be completed approximately every 45 minutes. This change continues to provide alignment with the content of the current E-Plan.

31 of 31

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-3, Revision 59 Emergency Notification of Off-Site Agencies

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G~3. Revision 59 Content Change Change Number I Type of Change I Reason for Original Content Change Step 2.1.1.a 1st bullet Step2.1.1.a 1st bullet Change #1 - Sponsor edit - no change in intent with respect to the Emergency Plan (E-Plan).

• A new emergency

• A new emergency classification classification level level (ECL) Added in acronym for emergency classification level for consistency and alignment with writer's guide.

Step 2.1.1.a.1.b) Step 2.1.1.a.1.b) Change #2 - Sponsor edit- no change in intent with respect to the E-Plan.

On-Going Event: This is used On-Going Event: This is used when when tile DCPP Station is already the DCPP Station is already in a Cleaned up the language around upgrading to a in a declared emergency. This . declared emergency. This gives higher classification level to remove the term "on gives notice of an upgrade to an notice of an upgrade to a higher either unit" based on user feedback that it is potentially emergency classification level on emergency classification level or a misleading. For example if U1 was in an alert and either Unit, or a new PAR. The new PAR. The message number of an then U2 met the conditions for an alert the Revision 58 message number of an On-Going On-Going Event is the next sequential language infers that upgrade would be required which Event is the next sequential number. is incorrect. Revision 59 fixes the language to be number. consistent with the DCPP classification process, which only escalates to higher levels based on changes in classification level at the site; not on each individual unit.

This change continues to provide alignment with the content of the current E-Plan.

Step 2.1.1.b 1st paragraph Step 2.1.1.b 1st paragraph Change #3 - Sponsor edit - no change of intent with respect to the E-Plan.

Follow-Up Notifications: Follow-Up Notifications: Required to Required to be performed be performed approximately every Added in the words "or less of the previous verbal approximately every 45 minutes or less of the previous notification" to clarify the time requirements for follow-45 minutes during an ongoing verbal notification during an ongoing up notifications. Feedback from the users of the 1of10

Enclosure 3 PG&E Lette~ DGL-16-120 PG&E Letter DIL-16-018 Content Change Change Number I Type of Change I Reason for Original Content Change event using Attachment 4 (Form event using Attachment 4 procedure was that it wasn't specifically clear on when 69-21638), (Form 69-21638), "DCPP Follow-Up the clock starts for the next follow-up. This change "DCPP Follow-Up Emergency Emergency Notification Form." provides enhanced language to clarify the Notification Form." requirements.

There is no change of intent as the requirement is not altered as follow-up notifications are still required to be completed approximately every 45 minutes. This

,~*

change continues to provide alignment with the content of the current E-Plan.

Step 2.1.1.b 2no paragraph Step 2.1.1.b 2na paragraph Change #4 - Sponsor edit - no change of intent with respect to the E-Plan.

The appropriate notification is a The appropriate notification is a Follow-Up ENF due to a Follow-Up ENF due to a significant Changed the phrase "secondary ECL" to "concurrent significant change in plant change in plant conditions (message EAL". Feedback from the users of the procedure was conditions (message number 4). number 4). This is an example of that it wasn't specifically clear on what a secondary This is an example of meeting a meeting a concurrent EAL. ECL was. The term concurrent EAL was decided secondary EGL. upon as it provides a better description of the condition in which another EAL at the same classification level is met compared to the previous language.

This change is an enhancement to improve use by the ERO. This change has no impact on the E-Plan as the terms *"secondary EGL" and "concurrent EAL" do not appear anywhere in the E-Plan.

Step 2.1.2 -Step 2.1.2 Change #5 - Sponsor edit - no change of intent with respect to the E-Plan.

The official notification to the The official notification to the NRG is NRG is made when the NRG is made when the NRG is called. The Editorial chanQe to correct lanQuaQe that is not 2of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018

- Content Change Change Number I Type of Change I Reason for Original Content Change called. The ENF DCPP ENF is not used by the NRC. technically correct. The Revision 58 language "ENF Form is not used by the NRC. form" was repetitive in the ENF stands for emergency notification form, so the rev 58 language read as emergency notification form.

The Revision 59 change corrects the grammatical error.

Step 2.1.4 Step 2.1.4 Change #6 - Sponsor edit - no change of intent with respect to the E-Plan.

San Luis Obispo County (SLO) San Luis Obispo County (SLO) and and the State of California are to the State of California are to be The last bullet "Corrections for an inaccurate PAR" be notified within 15 minutes of: notified within 15 minutes of: was removed from this section as it was erroneously

• An initial classification of an

• An initial classification of an added in the previous Revision 57. The intent of the emergency emergency Revision 57 addition was to provide some type of

• A new PAR

• A new PAR guidance for the ERO on how to handle an inaccurate

• Changes to emergency

• Changes to emergency PAR as nothing existed prior to Revision 57.

classification levels classification levels

• Changes to PARs

• Changes to PARs There is no E-Plan requirement to correct inaccurate

• Corrections for an inaccurate PARs within 15 minutes. Feedback from the ERO PAR identified that this 5th bullefwas confusing as they were unsure if they were forced into a 15-minute clock for something that had no defined requirement in the E-Plan.

A concurrent change was made to Section 6.3 under Revision 59 as well to clarify the process for correcting inaccurate PARs.

This change is an enhancement to improve use by the ERO. This change has no impact on the E-Plan as the process for correcting inaccurate PARs is not 3of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DI L-16-018 Content Change Change Number I Type of Change I Reason for Original Content Change described in the E-Plan.

Step 6.1.3 Step 6.1.3 Change #7 - Sponsor edit - no change of intent with respect to the E-Plan.

Within 15 minutes of EGL or [TIME CRITICAL]: Within PAR declaration, SLO County 15 minutes of new EGL or new PAR Added in "[TIME CRITICAL]" to identify the need for and the State of declaration, SLO County and the urgency on initial notifications as they need to be California shall be notified by State of California shall be notified by completed within 15 minutes.

transmittal of information on an transmittal of information on an approved Form.T32164 approved Form.T32164 Added in "new ECL" and "new PAR" to clarify the language and address user feedback that the wording could be enhanced.

This change is an enhancement to improve use by the ERO. This change has no impact on the content of the current E-Plan.

Step 6.2.3 Step 6.2.3 Change #8 - Sponsor edit - no change of intent with respect to the E-Plan.

Perform a follow-up notification Perform follow-up notifications a~~roximatel~ ever~ 45 a~~roximatel~ eve~ 45 minutes or Guidance was re-written to provide enhanced details minutes or less. less of the previous verbal and clearer instructions for when to perform follow-up notification. notifications.

a. Some conditions (not all) that a. Routine Follow-Up notifications Added in the words "or less of the previous verbal may trigger making a follow-up indicate that conditions are stable and notification" to clarify the time requirements for follow-notification in have not significantly changed since up notifications. Feedback from the users of the less than 45 minutes are: the last notification. procedure was that it wasn't specifically clear on when the clock starts for the next follow-up. This change

1. (Primary Reason) Change in b. Some conditions (not all) that may provides enhanced language to clarify the Radiological Release status trigger making an expedited follow-up requirements.

(start, or stop) notification in less than 45 minutes 4of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Content Change Change Number I Type of Change I Reason for Original* Content Chanae are: There is no change of intent as the requirement is not

2. Change in unit status (mode * (Primary Reason) change in altered as follow-up notifications are still required to be change for affected or unaffected radiological release status (start, completed approximately every 45 minutes. This unit) or stop) change continues to provide alignment with the

• Change in unit status (e.g. mode content of the current E-Plan.

3. Change in spent fuel pool change for affected or unaffected conditions unit, loss of important plant The five examples under the section on when to components or systems) perform follow-up notifications in less than 45 minutes

4. Notification of meeting

• Concurrent EALs met (e.g. Alert were enhanced based upon user feedback. All of the additional secondary ECLs declared on Unit 1, then Alert met Revision 58 content remains in Revision 59 with the on Unit 2 would be a concurrent addition of clarifying content. The exceptions being:

5. A correction for an inaccurate EAL with no declaration needed PAR but Follow-Up ENF needed to

• The removal of the "correction for an inaccurate communicate change to offsite PAR". Refer to Change #6 for additional details on agencies) this.

• Change in spent fuel pool

• The inclusion of the "Declared Emergency conditions Classification Level (ECL) that was not

• Declared Emergency communicated due to being immediately Classification Level (ECL) that surpassed by a higher ECL". This bullet was was not communicated due to added to provide an additional example of when being immediately surpassed by a the offsite agencies should be notified sooner than higher ECL (e.g. Alert declared at the 45 minute requirement.

0815; SAE declared at 0820; only communicated SAE; Follow-Up These changes align with the E-Plan Section 4.1.2.3.6 ENF needed to convey Alert was which states that at the Alert level or higher DCPP met and was declared) plant staff will provide, "periodic plant status updates to off-site authorities (approximately every 45 minutes

c. Follow-up notifications to an off-site or immediately if situation warrants)."

agency may be waiv.ed or extended to intervals greater than 45 minutes if The E-Plan does not specify which conditions would the off-site agency agrees. require expedited follow-up notifications. The examples provided in Revision 59 align with agreed 5of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter Dl°L-16-018 Content Change Change Number I Type of Change I Reason for Original Content Change upon conditions with the offsite agencies on when expedited follow-ups should be done.

Step 6.2.4 Perform the following Step 6.3 Correcting Errors on Change #9 - Sponsor edit - no change of intent to correct previously transmitted Previously Transmitted ENFs or with respect to the E-Plan.

ENFs: Follow-Up ENFs This content was added in the previous Revision 57.

a. Provide a verbal 6.3.1 Provide a verbal The intent of the Revision 57 addition was to provide update/correction to the County, update/correction to the County, some type of guidance for the ERO on how to handle State, and NRC State, and NRC an inaccurate ENF that had been transmitted to offsite agencies as nothing existed prior to Revision 57 on

b. Create a new ENF to correct 6.3.2 For corrections to an incorrect how to handle that situation.

the issue PAR:

There is no E-Plan requirement to correct inaccurate

1. Use an initial or follow-up form a. IF the correct PAR is more notifications.

to correct the issue based on conservative (i.e. includes more PAZs which form contained the original or more protective actions) than the This change is an enhancement to improve use by the error. previously transmitted incorrect PAR, ERO. This change has no impact on the E-Plan as THEN send an updated initial ENF to the process for correcting inaccurate notifications is correct the issue. not described in the E-Plan, nor is it described in any regulatory guidance or requirements.

b. lE the correct PAR is less conservative (i.e. includes less PAZs or less protective actions) than the ,

previously transmitted incorrect PAR, THEN the previously transmitted PAR should remain on all subsequent ENFs and Follow-Up ENFs.

1. The verbal update is the only update allowed, as once a PAR is issued for an area (PAZ or ocean) it 6of10

Enclosure 3 PG&E Letter DCL-16-120

. PG&E Letter DIL-16-018 Content Change Change Number I Type of Change I Reason for Original Content Change stays in effect for the duration of the event..

6.3.3 For all corrections other than PAR corrections, send an initial or follow-up ENF to correct the issue, based on which type of ENF contained the original error.

Step 6.2.5 Relocated to step 6.2.3.c Change #10 - Sponsor edit - no* change of intent with respect to the E-Plan.

Follow-up notifications to an off-site agency may be waived or Step was relocated verbatim. This* is an editorial extended to intervals greater than change that was done to move the instruction to the 45 minutes if the off-site agency applicable section of the procedure.

agrees.

The relocation does not alter any requirements or timeliness aspects associated with the performance of follow-up notifications. step 1.a Attachment 2 step 1.a Change #11 - Sponsor edit - no change of intent with respect to the E-Plan.

a. Follow-Up Notifications are a. Follow-Up Notifications are made made using Form 69-21638 using Form 69-21638 approximately Refer to Change #8 for details associated with this approximately every 45 every 45 minutes or less of the change.

minutes (time may be changed previous verbal notification (time may based upon agreement with be changed based upon agreement Change #11 is a copy and paste of the Change #8 offsite agencies) OR when with offsite agencies) OR when content for alignment throughout the procedure.

significant changes to event or significant changes to event or plant plant status occur. Examples of status occur. Examples of significant significant changes are: changes are:

7of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Content Change Change Number I Type of Change I Reason for Original Content Change

1) Change of plant operating 1) Change in radiological release mode status (start, or stop)

2) Change of radiological release 2) Change in unit status (e.g., mode status change for affected or unaffected unit, loss of important plant components or

3) Evacuation of onsite Personnel systems)

4) Call for outside assistance 3) Concurrent EALs met (e.g., Alert (Fire, Ambulance or Police) declared on Unit 1, theri Alert met on Unit 2 would be a concurrent EAL with

5) Notification of meeting no declaration needed but Follow-Up secondary ECLs ENF needed to communicate change to offsite agencies)

4) Change in spent fuel pool condffions *

5) Declared Emergency Classification Level (ECL) that was not communicated due to being immediately surpassed by a higher ECL (e.g. Alert declared at 0815; SAE declared at 0820; only communicated SAE; Follow-Up ENF needed to convey Alert was met and was declared) block 4 instructions Attachment 2 block 4 instructions Change #12 - Sponsor edit - no change of intent with respect to the E-Plan.

"Change in Plant Status" is used "Change in Plant Status" is used for:

for:

• Change in radioloQical release Refer to Change #8 for details associated with this 8of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Content Change Change Number I Type of Change I Reason for Original Content Change

• Change in radiological release status (start, or stop) change.

status (start or stop)

• Change in unit status (e.g. mode

• Unit mode change (affected or change for affected or unaffeded Change #12 is a copy and paste of the Change #8 unaffected unit) unit, loss of important plant content for alignment throughout the procedure.

• Change in Spent Fuel Pool components or systems) ,.-

(SFP) Condition

• Concurrent EALs met (e.g. Alert

• Or significant plant status declared on Unit 1, then Alert met changes on Unit 2 would be a concurrent EAL with no declaration needed but Follow-Up ENF needed to communicate change to offsite agencies)

• Change in spent fuel pool conditions

• Declared Emergency Classification Level (ECL) that was not communicated due to being immediately surpassed by a higher ECL (e.g. Alert declared at 0815; SAE declared at 0820; only

/

communicated SAE; Follow-Up ENF needed to convey Alert was met and was declared)

~ block 7 instructions Attachment 2 block 7 instructions Change #13 - Sponsor edit - no change of intent with respect to the E-Plan.

N/A new content added PIC data may be found at:

• httg ://gd nserver/P IC. asgx Added in instructions on where to obtain pressurized

• FMT Communicator in the UDAC ion chamber (PIC) data based on user feedback.

• Rad Data Processor in the TSC This change is an enhancement to improve use by the ERO. This chanQe has no impact on the content of 9of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DI L-16-018 Content Change Change Number I Type of Change I Reason for Original Content Change

.. the current E-Plan . step 3.d.1 Attachment 5 step 3.d.1 Change #14 - Sponsor edit- no change of intent with respect to the E-Plan.

"Routine update" - Used routine "Routine update" - Used for routine updates provided - every 45 updates provided - every 45 minutes Added in the words "or less of the previous verbal minutes. or less of the previous verbal notification" to clarify the time requirements for follow-*

notification. up notifications. Feedback from the users of the procedure was that it wasn't specifically clear on when the clock starts for the next follow-up. This change provides enhanced language to clarify the requirements.

There is no change of intent as the requirement is not altered as follow-up notifications are still required to be completed approximately every 45 minutes. This change continues to provide alignment with the content of the current E-Plan. step 3.g.1 Attachment 5 step 3.g.~ Change #15 - Sponsor edit - no change of intent with respect to the E-Plan.

N/A new content added 1) PIC data may be found at:

• htt12://12dnserver/PIC.as12x Added in instructions on where to obtain PIC data

• FMT Communicator in the UDAC based on user feedback.

• Rad Data Processor in the TSC This change is an enhancement to improve use by the ERO. This change has no impact on the content of the current E-Plan.

10of10

Enclosure 4 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-4, Revision 29 Assembly and Accountability

Enclosure 4 PG&E Letter DCL-16:-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-4, Revision 29 Original Content Content Change Change Number I Type of Change I Reason for Change Step 15 Assembly Area Leader Step 15 Assembly Area Leader Change #1 - Editorial change with no change of Checklist Checklist intent.

NIA - New Content CAUTION: The second floor SAPN 50846295 - Task 2 - "Insert a caution prior to breezeway, between building 109 and step 15.1" building 119, should not be used as an assembly area. Building 109 and 119, 2nd floor breezeway Evaluation Summary:

In order to be an assembly area the breezeway is required to provide life safety exits, designed for exiting. This breezeway was not designed to as an assembly area. Per guidance from the CBC (California Building Code) in order for using this space as an assembly area we need to meet all the requirements of an assembly area. There heed to be exits that lead you directly away from the building into

~

a safe haven location.

Since the current door location led you back into a building this does not qualify as an assembly area.

Per code, you are not allow the exit people into buildings as part of the egress pattern. There are no exit signs and the doors swings in the wrong direction.

Also the exit path directing them back into the building is not fire rated. This space does not and was not desioned to be an"assembly area.

1 of 6

Enclosure 4 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change

Title:

Assembly and Accountablity

Title:

Assembly and Accountability Change #2 - Editorial change with no change of intent.

50846295 - Task 4 - The title of the procedure is spelled wrong. Specifically, the word accountability.

Step 2.1.16 Step 2.1.16 Change #3 - Process change with no change of intent.

If a radiological release is in If a radiological release is in progress, progress, radiological monitors Viewpoint will be used to monitor RDS31, remote radiation monitors, are now installed will be dispatched to the assembly assembly area dose rates, or in the assembly areas. Viewpoint is a software areas to check dose rates are radiological monitors will be dispatched program that allows for remote monitoring of the within acceptable limits. In the to the assembly areas to check dose radiation monitors. A chemistry and radiation event dose rates exceed rates, to ensure dose rates are within protection (C&RP) technician is not needed at the acceptable limits, personnel will acceptable limits. In the event dose assembly areas unless dose rates exceed 3 mR/hr or be evacuated as quickly as rates exceed acceptable limits, dose rates are not available on Viewpoint. In these possible. personnel will be evacuated as quickly cases an air sample would need to be performed by.a as possible. C&RP technician.

This change enhances an existing process through the use of new technology that is available at the assembly areas. This change does not remove or alter the requirement to monitor the assembly areas, nor does it remove or alter the thresholds at which additional monitoring actions are required at the assembly areas (i.e., above 3mR/hr). If the new monitors are available, they will be used to provide real time monitorinQ of the assembly areas. If they are 2 of 6

Enclosure 4 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change not available, then a radiation protection (RP) technician will be dispatched to the assembly areas to perform general area surveys as they currently do.

Reference SAPN 50452062, Task 16.

Step 3.7 Step 3.7 Change #4 - Process change with no change of intent.

3.7.1 Performing general area 3. 7 .1 Monitoring the assembly area surveys of the on-site assembly dose rates on Viewpoint, Or locally if RDS31, remote radiation monitors, are now installed areas. viewpoint is unavailable. in the assembly areas. Viewpoint is a software program that allows for remote monitoring of the 3.7.3 Performing air sampling at 3.7.2 Performing general area surveys radiation monitors. A C&RP technician is not needed the onsite assembly areas, as of the on-site assembly areas, as at the assembly areas unless dose rates exceed necessary. necessary. 3 mR/hr or dose rates are not available on Viewpoint.

In these cases an air sample would need to be 3.7.3 Performing air sampling at the performed by a C&RP technician.

onsite assembly areas, as necessary.

This change enhances an existing process through the use of new technology that is available at the assembly areas. This change does not remove or

• alter the requirement to monitor the assembly areas, nor does it remove or alter the thresholds at which additional monitoring actions are required at the assembly areas (i.e., above 3mR/hr). If the new monitors are available, they will be used to provide real time monitoring of the assembly areas. If they are not available, then a RP tech will be dispatched to the assembly areas to perform general area surveys as they currently do. Reference SAPN 50452062, Task 16.

3 of 6

Enclosure 4 PG&E Letter DCL-16-120.

PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change Step 10.1.3.a.1.a Step 10.1.3.a.1.a Change #5 - Process change with no change of intent.

Dispatch available RP technician Ensure Radiation Protection is following to assembly areas to perform Section 16, "Radiation Protection RDS31, remote radiation monitors, are now installed general area survey using Section Checklist." in the assembly areas. Viewpoint is a software 16, "Radiation Protection program that allows for remote monitoring of the Checklist." radiation monitors. A C&RP technician is not needed at the assembly areas unless dose rates exceed 3 mR/hr or dose rates are not available on Viewpoint.

In these cases an air sample would need to be performed by a C&RP technician.

This change enhances an existing process through the use of new technology that is available at the assembly areas. This change does not remove or alter the requirement to monitor the assembly areas, nor does it remove or alter the thresholds at which additional monitoring actions are required at the assembly areas (i.e., above 3mR/hr). If the new monitors are available, they will be used to provide real time monitoring of the assembly areas. If they are not available, then a RP tech will be dispatched to the assembly areas to perform general area surveys as they currently do. Reference SAPN 50452062, Task 16.

4 of 6

Enclosure 4 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change Section 16 Radiation Protection Section 16 Radiation Protection Change #6 - Process change with no change of Checklist Checklist intent.

RDS31, remote radiation monitors, are now installed 16.1 Initial Actions 16.1.1 Monitor the assembly area dose in the assembly areas. Viewpoint is a software 16.1.1 Perform assembly area rates on Viewpoint. program that allows for remote monitoring of the monitoring: a. IF the assembly area dose rates are radiation monitors. A C&RP technician is not needed

a. Obtain dose rate instrument. not available on Viewpoint, OR dose at the assembly areas unless dose rates exceed

b. Obtain air sampling equipment. rates exceed 3 mR/hr, THEN direct a 3 mR/hr or dose rates are not available on Viewpoint.

c. Go to assigned assembly area C&RP tech to the affected assembly In these cases an air sample would need to be (Building 109, Building 119 and/or areas to perform the following: performed by a C&RP technician.

Warehouse 1. Obtain dose rate instrument.

B) and perform the following: 2. Obtain air sampling equipment. This change enhances an existing process through

1. Perform a general area dose 3. Go to assigned assembly area the use of new technology that is available at the rate survey to determine (Building 109, Building 119 and/or assembly areas. This change does not remove or background radiological Warehouse B) and perform the alter the requirement to monitor the assembly areas, conditions. following: nor does it remove or alter the thresholds at which

2. IF any radiation above normal a) Perform a general area dose rate additional monitoring actions are required at the background detected, survey to determine background assembly areas (i.e., above 3mR/hr). If the new THEN recommend restrictions on radiological conditions. monitors are available, they will be used to provide eating and drinking. b) IF any radiation above normal real time monitoring of the assembly areas. If they are

3. IF general area dose rates background detected, THEN not available, then a RP tech will be dispatched to the exceed 3mR/hr,THEN recommend restrictions on eating and assembly areas to perform general area surveys as immediately inform the Control drinking. they currently do. Reference SAPN 50452062, Room orTSC. c) IF general ~rea dose rates exceed Task 16.

a) Start air sampling of the 3mR/hr, THEN immediately notify the assembly*area for radioiodine Control Room or TSC.

d. Report assembly area 1) Start air sampling of the assembly monitoring results to the TSC area for radioiodine Radioloqical Advisor or Shift 4. Report assembly area monitoring 5 of 6

Enclosure 4 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change Manager. results to the TSC Radiological Advisor or Shift Manager.

16.2 Subsequent Actions 16.2 Subsequent Actions 16.2.1 Continue Monitoring Assembly Area: 16.2.1 Continue Monitoring Assembly Area on Viewpoint, or locally:

a. Inform Assembly Area Leader of survey results. a. Notify Assembly Area Leader of local survey results.

b. For further instructions or resource requests, contact the b. For further instructions or resource Control Room or requests, contact the Control Room or TSC. TSC.

c. Continue to monitor assembly c. Continue to monitor assembly area areas until directed otherwise by until directed otherwise by the Shift Manager or SEC.

the Shift Manager or SEC.

Step 1.4 - deleted, not a rewrite N/A revision Change #7 - Editorial and formatting changes Section 11.3.2, steps are a, b, c ... not 1, 2, 3 6of6

Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-1, Revision 52 Activation and Operation of the Technical Support Center

Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-1, Revision 52 Change Number I Type of Change I Reason for Original Content Content Change Change 3.16.2 Directing clerical staff to 3.16.2 Directing clerical administrative requested emergency response staff to requested emergency response Change #1 - Editorial change with no change of facilities. facilities. intent.

Reflect title change made in 2012 for all DCPP IBEW Physical Clerical staff from "Clerical" to "Administrative" and "Clerk" with "Adm in". Refer to SAPN 50449609, Task 17.

3.17 TSC clerical is responsible 3.17 TSC Admin Assistant is responsible Change #2 - Editorial change with no change of for providing clerical support to for providing administrative support to intent.

the TSC staff. the TSC staff.

Reflect title change of Company Emergency Operations Center m*ade in 2014 in the Company Emergency Response Plan. Refer to SAPN 50449609, Task 25.

6.17 TSC Clerical Support 6.17 TSC Administrative Support Change #3 - Editorial change with no change of 6.17.1 Upon declaration of an 6.17.1 Upon declaration of an intent.

emergency, use Attachment 17, emergency, use Attachment 17, "TSC "TSC Clerical Support Checklist," Administrative Support Checklist," Form Reflect title change made in 2012 for all DCPP IBEW Form 69 21165, to guide 69 21165, to guide performance of Physical Clerical staff from "Clerical" to "Administrative" performance of required actions. required actions. and "Clerk" with "Admin". Refer to SAPN 50449609, Task 17.

1 of 6

Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change Site Emergency Coordinator Site Emergency Coordinator Checklist Change #4 - Process change with no change of Checklist

3. Situational Actions intent.

3. Situational Actions a) Risk Significant Actions Change is being made to delineate that an a) Risk Significant Actions (Classification, Notification, Dose independent peer check is needed, if time permits.

(Classification, Notification, Assessment, PARs)

The Operations Advisor is not considered a peer as Dose Assessment, PARs)*

1) Classify and declare an they report to the SEC and are located in the same

1) Classify and declare an emergency condition within 15 facility. The Operations Advisor is properly trained to emergency condition within minutes per EP G-1. perform the task and should be conferred with prior to a 15 minutes per EP G-1. REFER TO Tab 12. declaration being made. This change does not alter REFER TO Tab 12. the authority or responsibility of the Operations Advisor

a. Confer with Ops Advisor on EALs.

or the SEC with respect to performing their emergency a) If time permits, get at

b. If time permits, get at least one assignments in accordance with the E-Plan.

least one peer check from peer check from ED and/or SM on Ops Advisor, ED, and/or SM EAL recommendation.

on EAL recommendation.

Operations Advisor Checklist Operations Advisor Checklist Change #5 - Process change with no change of

2. Ongoing Actions 2. Ongoing Actions intent.

b. Assist the SEC with b. Confer with the SEC on Change is being made to delineate that an evaluating plant evaluating plant conditions independent peer check is needed, if time permits.

conditions against EALs against EALs and upgrade criteria The Operations Advisor is not considered a peer as and upgrade criteria as as needed.

they report to the SEC and are located in the same needed.

facility. The Operations Advisor is properly trained to perform the task and should be conferred with prior to a declaration being made. This change does not alter the authority or responsibility of the Operations Advisor or the SEC with respect to performing their emergency as~ianments in accordance with the E-Plan.

2 of 6

Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change Site Emergency Coordinator Site Emergency Coordinator Checklist Change #6 - Editorial change with no change of Checklist

2. Ongoing Actions intent.

2. Ongoing Actions NOTE: Direct the communications The information pertaining to both routine and NOTE: Direct the advisor to perform routine and expedited expedited notifications exists in EP G-3. This change communications advisor to follow-up offsite notifications to County, is being made for consistency between EP G-3 and perform routine follow-up offsite State, and NRC officials per EP G-3.

EP EF-1.

notifications to County, State, REFER TO Tab 10 and 11.

and NRC officials per EP G-3.

REFER TO Tab 10 and 11.

TSC Director Checklist TSC Director Checklist Change #7 - Editorial change with no change of

2. Ongoing Actions 2. Ongoing Actions intent.

NOTE: DCPPeme~ency NOTE: DCPP emergency notifications The statement "or less" already exists in EP G-3.

notifications to the County and to the County and State are required to Adding "or less" in this note brings EP EF-1 in line with State are required to be be completed within 15 minutes following EP G-3 to provide better alignment between the completed within 15 minutes the declaration of a new event procedures. ,

following the declaration of a new classification or new PAR at the GE level event classification or new PAR (notifications to the NRG within one at the GE level (notifications to hour). Follow-up notifications should be the NRC within one hour). made approximately every 45 minutes or Follow-up notifications should be less.

made approximately every 45 minutes.

Communications Advisor - TSC Communications Coordinator Checklist Change #8 - Editorial change with no change of Checklist

2. Onaoina Actions intent.

3 of 6

Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change

2. Ongoing Actions b. Until relieved by the EOF, ensure The statement "or less" already exists in EP G-3.

the County and State are notified of

b. Until relieved by the EOF, Adding "or less" in this note brings EP EF-1 in line with new classification levels or new ensure the County and State EP G-3 to provide better alignment between the PARS within 15 minutes of are notified of new procedures.

classification levels or new declaration (one hour for NRC), and PARS within 15 minutes of updated on 45 minute or less intervals.

declaration (one hour for NRC), and updated on 45 minute intervals.

Agency/ENS Communicator Agency/ENS Communicator Checklist Change #9 - Editorial change with no change of Checklist

1. Initial Actions intent.

1. Initial Actions

g. IF requested to assist with The statement "or less" already exists in EP G-3.

g. IF requested to assist off-site agency emergency Adding "or less" in this note brings EP EF-1 in line with with off-site agency notifications, EP G-3 to provide better alignment between the emergency notifications, THEN complete the notifications procedures.

THEN complete the per EP G-3, "Emergency notifications per EP G-3, Notification of Off-Site Agencies." '

"Emergency Notification REFER TO Tabs 2, 3, and 4.

of Off-Site Agencies."

3) Follow-up notifications should REFER TO Tabs 2, .3, be made within approximately and 4.

45 minutes or less.

3) Follow-up notifications should be made within approximately 45 minutes.

4 of 6

Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change Administrative Advisor Checklist Administrative Advisor Checklist Change #1 O - Editorial change with no change of

1. Initial Actions 1. Initial Actions intent.

d. Determine clerical d. Determine administrative staffing Reflect title change made in 2012 for all DCPP IBEW staffing needs in each of needs in each of the following Physical Clerical staff from "Clerical" to "Administrative" the following facilities by facilities by contacting the and "Clerk" with "Admin". Refer to SAPN 50449609, contacting the appropriate appropriate position:

Task 17.

position:

f. Assign administrative personnel to:

f. Assign clerical

j. Establish 24-hour shift manning personnel to:

schedules (12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts) for the

j. Establish 24-hour shift TSC, OSC, EOF, and JIC.

manning schedules Coordinate with each facility.

(12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts) for the REFER TO Tab 2.

TSC, OSC, EOF, and JIC.

1) For the OSC, walk down and work Coordinate with each with the OSC administrative staff to facility. REFER TO Tab 2.

develop the list.

1) For the OSC, walk down and work with the OSC clerical staff to develop the list.

TSC Clerical Support Position TSC Administrative Support Position Change #11 - Editorial change with no change of Binder Tab Index Binder Tab Index intent.

EP EF-1, Form 69-21165, "TSC EP EF-1, Form 69-21165, "TSC Clerical Support Checklist" Administrative Support Checklist" Reflect title change made in 2012 for all DCPP IBEW Physical Clerical staff from "Clerical" to "Administrative" and "Cl.erk" with "Admin". Refer to SAPN 50449609, 5 of 6

Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change Task 17.

6 of 6

Enclosure 6 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-2, Revision 39 Activation and Operation of the Operational Support Center

Enclosure 6 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-2. Revision 39 Original Content Content Change Change Number I Type of Change I Reason for Change Step 2.h.4 Attachment 1 Step 2.h.4 Change #1 - Administrative with no change of intent.

Updated team status Updated team status and estimated completion time SAPN 50872299 recommends including the team estimated completion time Objective 1.5.2 Demonstration Criteria 8 requirement in EP EF-2.

I Step 1.e Attachment 6 Step 1.e Change #2 - Process with no change of intent. I New Content Update the Emergency Planning Zone SAPN 50872109 requests that updating 'wind chart be (EPZ) map with the wind direction. Wind added to one of the coordinator's checklists.

direction may be obtained from the PON Server or the Rad Data Processor.

1) Check that the wind direction indicated on the OSC EPZ,map corresponds with the TSC EPZ map. Step 2.d Attachment 6 Step 2.d Change #3 - Process with no change of intent.

New Content Monitor the wind direction from the PON SAPN 50872109 requests that updating wind chart be Server or the Rad Data Processor. added to one of the coordinator's checklists.

1) Update the EPZ map with the wind 1 of 2

Enclosure 6 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change direction.

2) Check that the wind direction indicated on the OSC EPZ map corresponds with the TSC EPZ map. 0 Attachment 10 Change #4 - Administrative with no change of Team Return and Debrief Team Return and Debrief intent.

10 Mission 10 Mission Status: SAPN 50872171 "9/21/16 DR EP EF-2 Debrief Status: Process" recommends that Attachment 10 "Team Pre-Departure Checklist," be updated to include debriefing 11 Return Time:- - - - the teams with the appropriate coordinators.

Debrief Time: - - 11 Return Time:- - -

Debrief By: _ __ 12 Debrief With:

[ ] l&C/MM/Elect/Chem Coordinator

[ ] SRPC (Rad Teams)

[ ] Team Coordinator Att 1, position binder:

NIA tab #2 - changed title of AD2.ID1 to Change #5 -Administrative with no change of Procedure and Work Plan Use and intent.

Adherence tab #9 - changed from Attachment 24 to Multiple editorial and formatting changes Form 69-21676 Position binder tab 4 - Attachment 12 to form 69-20512 2 of 2

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plah Implementing Procedure EP EF-3, Revision 44 Activation and Operation of the Emergency Operations Facility

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-3, Revision 44 Change Number I Type of Change I Reason for Original Content Content Change Change 3.17 EOF clerical support is 3.17 EOF administrative support is responsible for providing responsible for providing Change #1 - Editorial change with no change of communications, copying, communications, copying, distribution, intent.

distribution, and other and other administrative support to the administrative support to the EOF EOF staff as needed. Reflect title change made in 2012 for all DCPP IBEW staff as needed. Physical Clerical staff from "Clerical" to "Administrative" and "Clerk" with "Admin". Refer to SAPN 50449609, Task 17.

3.20.1 Providing a single point of 3:20.1 Providing a single point of Change #2 - Editorial change with no change of contact between the EOF and the contact between the EOF and the intent.

corporate emergency response company emergency operations center. center. Reflect title change of Company Emergency Operations 3.20.3 Responding to the 3.20.3 Responding to the company Center made in 2014 in the Company Emergency corporate emergency operations emergency operations center when Response Plan. Refer to SAPN 50449609, Task 25.

center when requested or directed requested or directed to do so.

to do so.

EOF Clerical Support 6.17 EOF Administrative Support Change #3 - Editorial change with no change of intent.

Reflect title change made in 2012 for all DCPP IBEW Physical Clerical staff from "Clerical" to "Administrative" and "Clerk" with "Admin". Refer to SAPN 50449609, Task 17.

1of23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change Emergency Director Checklist Emergency Director Checklist Change #4 - Administrative change with no change

1. Classify and declare an. 2. Classify and declare an of intent.

emergency condition within emergency condition within 15 15 minutes per EP G-1. minutes per EP G-1. Change is being made to delineate that an independent REFER TO Tab 4. REFER TO Tab 4. peer check is needed, if time permits. The EOF Director is not considered a peer as they report to the ED and a) If time permits, obtain at , a. Confer with EOF Director on are located in the same facility. The EOF Director is least one peer check from EALs.

properly trained to perform the task and should be EOF Director, SEC, and/or

b. If time permits, obtain at least conferred with prior to a declaration being made. This SM on EAL recommendation.

one peer check from SEC and/or change does not alter the authority or responsibility of SM on EAL recommendation. the EOF Director or the ED with respect to performing their emergency assignments in accordance with the E-Plan.

, Emergency Director Checklist Emergency Director Checklist Change #5 - Editorial change with no change of

6. Direct the following individuals 6. Direct the following individuals to intent.

to make announcements: make PA announcements: r Editorial change to add PA in front of announcement to be consistent with designation in sections a) and b).

Emergency Director Checklist Emergency Director Checklist Change #6 - Editorial change with no change of 9.) Direct Communications 9.) Direct Communications Coordinator intent.

Coordinator to perform routine to perform routine and expedited '

follow-up offsite notifications to follow-up offsite notifications to County, The information pertaining to both routine and expedited County, State, and NRC officials State, and NRC officials per EP G-3. notifications exists in EP G-3. This change is being 2 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change per EP G-3. REFER TO Tab 7. REFER TO Tab 7. made for consistency between EP G-3 and EP EF-3.

Emergency Director Checklist Emergency Director Checklist Change #7 - Administrative change with no change

b. Other Functions and b. Other Functions and of intent.

Responsibilities Responsibilities Added FMT's to clarify that they are included as offsite

1) Personnel Protective 1) Personnel Protective emergency workers. This is a clarification and does not Measures Measures impact the tasks the ED performs.

a) Authorize emergency a) Authorize emergency exposures as needed exposures as needed per per EP RB-2. REFER TO EP RB-2. REFER TO Tab 8.

Tab8.

b) Authorize administration of b) Authorize potassium iodide (Kl) to PG&E administration of offsite emergency workers potassium iodide (Kl) to (including FMTs) per EP RB-3.

PG&E offsite emergency REFERTO Tab 9.

workers per EP RB-3.

REFER TO Tab 9.

Emergency Director Checklist Emergency Director Checklist Change #8 - Editorial change with no change of

b. Other Functions and b. Other Functions and intent.

Responsibilities Responsibilities EP G-5 designates that the ED is provided information

2) Site Evacuation 2) Early Work Release or Site on and coordination of both Early Work Release and Evacuation

.a) lE informed by SEC of Site Evacuation. This change is being made for pending Site Evacuation of a) lE informed by SEC of consistency between EP G-5 and EP EF-3.

non-essential personnel pending Early Work Release or 3 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change from DCPP, Site Evacuation of non-essential THEN: personnel from DCPP, THEN:

(1) Ensure evacuation is coordinated with County. (1) Ensure Early Work Release or Site Evacuation is (2) Notify company coordinated with County.

spokesperson of upcoming site (2) Notify company evacuation. spokesperson of upcoming Early Work Release or Site Evacuation.

~

EOF Director Checklist EOF Director Checklist Change #9 - Administrative change with no change New content g. Assign individuals to maintain facility of intent.

status boards (e.g. Electrical Bus Loads, Sequence of Events, ENF Added step 1.g to formalize a process already in place.

Tracking, Unit 1 and 2 Plant Status). Change is being made to align with position expectations and for clarity. This is not a change of intent within the E-Plan as the responsibilities have not changed. This is an administrative task and does not require any specific qualification.

EOF Director Checklist EOF Director Checklist Change #10 - Administrative change with no change New content 4) Ensuring all facility status boards of intent.

are being maintained.

Added step 2.d.4 to formalize a process already in place. Change is being made to align with position expectations and for clarity. This is not a cham::ie of 4 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change intent within the E-Plan as the responsibilities have not changed. This is an administrative task and does not require any specific qualification.

Radiological Manager Checklist Radiological Manager Checklist Change #11 - Editorial change with no change of

f. Check the following staffing f. Check the following staffing intent.

positions have been filled (* positions have been filled (*

designates "minimum designates "minimum staffing" Reflect title change made in 2012 for all DCPP IBEW staffing" position.) position.) Physical Clerical staff from "Clerical" to "Administrative" and "Clerk" with "Admin". Refer to SAPN 50449609 task

7) UDAC Clerk 7) UDAC Admin Assistant 17.

FMT Coordinator Checklist FMT Coordinator Checklist Change #12 - Editorial*change with no change of

i. Establish EOF/EOC i. Establish EOF/EOC radiological intent.

radiological protection*. protection.

This is a reference to a San Luis Obispo (SLO) County

2) Complete County 2) Complete County form. SLO County renamed the form and this change is Exposure Tracking Agency Personnel being made to accurately reflect the new form name.

Sheet and submit Exposure Log and submit copy to Emergency copy to Emergency Worker Exposure Worker Exposure Coordinator (EWEC) Coordinator (EWEC) via via County UDAC County UDAC

-Coordinator. REFER Coordinator. REFER TO TO Tab 5. Tab5.

5 of 23

Enclosure 7 PG&E Letter DCL-16-120 .

PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change FMT Coordinator Checklist FMT Coordinator Checklist Change #13 - Editorial change with no change of

a. Dispatch and coordinate a. Dispatsh and coordinate activities of intent.

activities of FMTs and offsite FMTs and offsite emergency lab.

emergency lab. Reflect title change made in 2012 for all DCPP IBEW

8) Provide copies, or direct UDAC Physical Clerical staff from "Clerical" to "Administrative"

8) Provide copies, or direct Admin Assistant to provide copies, and "Clerk" with "Ad min". Refer to SAPN 50449609, UDAC Clerk to provide of F,MT Data Sheets to the Task 17.

copies, of FMT Data Sheets following individuals:

to the following individuals: .

9) Maintain, or direct the UDAC

9) Maintain, or direct the Admin Assistant to maintain, FMT UDAC Clerk to maintain, FMT and UDAC status boards (team and U DAC status boards assignment and location).

(team assignment and location).

FMT Coordinator Checklist FMT Coordinator Checklist Change #14 - Editorial change with no change of NOTE:UDAC Clerk may assist NOTE:UDAC Admin Assistant may intent.

with communication requirements assist with communication for this function. requirements for this function. Reflect title change made in 2012 for all DCPP IBEW Physical Clerical staff from "Clerical" to "Administrative"

• and "Clerk" with "Admin". Refer to SAPN 50449609, Task 17.

FMT Coordinator Position Binder FMT Coordinator Position Binder Tab Change #15 - Editorial change with no change of Tab Index Index intent.

Form CC-12, "County Exposure Form 2, "Agency Personnel Exposure Tracking Sheet" (111.06, HP-11) Log" (111.06, HP-11) This is a reference to a San Luis Obispo (SLO) County 6 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change form. SLO County renamed the form and this change is being made to accurately reflect the new form name.

EOF Security Liaison Checklist EOF Security Liaison Checklist Change #16 - Process change with no change of New content b. Coordinate with County for Early intent.

Work Release and Site Evacuations.

This change is being made to reflect an enhancement request from the ERO. The security liaison may be available to support coordination of early work release I site evacuation. As such this guidance is being added to the checklist as an option to assist in the process if available. Refer to SAPN 5086829.

Communications Coordinator Communications Coordinator Checklist Change #17 - Editorial change with no change of Checklist

1. Initial Actions intent.

I 1. Initial Actions

d. Obtain all Emergency Reflect title change made in 2012 for all DCPP IBEW

d. Obtain all Emergency Notification Forms (ENF) from the Physical Clerical staff from "Clerical" to "Administrative" Notification Forms (ENF) from ENF software program.

and "Clerk" with "Admin". Refer to SAPN 50449609, the ENF software program.

1) Approved ENFs may be Task 17.

1) Approved ENFs may be obtained by clicking the "View/Edit obtained by clicking the Archived Notification Form Events" "View/Edit Archived link in the ENF software program.

Notification Form Events" link a) Have support staff (Admin) in the ENF software program.

distribute hard copies of all a) Have support staff ENFs.

(clerks) distribute hard

2) Notify support staff (Admin) that copies of all ENFs.

7 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for

/ Original Content Content Change Change you are to immediately receive

2) Notify support staff (clerks) copies of all emergency .

that you are to immediately notifications received by fax.

receive copies of all emergency notifications received by fax.

Communications Coordinator Communications Coordinator Checklist Change #18 - Administrative change with no change Checklist

2. Ongoing Actions of intent.

2. Ongoing Actions NOTE: Notifications to the County and The statement "or less" already exists in EP G-3.

NOTE: Notifications to the State are required to be completed Adding "or less" in this note brings EP EF-3 in line with County and State are required to within 15 minutes from the time of a EP G-3 to provide better alignment between the be completed within 15 minutes new eme~gency classification or PAR.

procedures.

from the time of a new emergency Follow up notifications should be made classification or PAR. Follow up within approximately 45 minutes or less notifications should be made of the last notification.

within approximately 45 minutes of the last notification.

Communications Coordinator Communications Coordinator Checklist Change #19 _Editorial change with no change of Checklist

2. Ongoing Actions intent.

2. Ongoing Actions

b. Oversee transmittal and Reflect title change made in 2012 for all DCPP IBEW

b. Oversee transmittal and distribution of notifications.

Physical Clerical staff from "Clerical" to "Administrative" distribution of notifications.

3) Provide or direct Offsite and "Clerk" with "Admin". Refer to SAPN 50449609,

3) Provide or direct Offsite Communicator to provide a copy of Task 17.

Communicator to provide a completed notification forms to coov of completed notification EOF Admin Assistant for 8 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Change Number I Type of Change I Reason for Content Chan*ge Change forms to EOF Clerk for distribution and posting.

distribution and posting.

Communications Coordinator Communications Coordinator Checklist Change #20 - Editorial change with no change of Checklist

2. Ongoing Actions intent.

2. Ongoing Actions

b. Oversee transmittal and The statement "or less" already exists in EP G-3.

b. Oversee transmittal and distribution of notifications.

Adding "or less" in this note brings EP EF-3 in line with distribution of notifications.

,* 4) Ensure follow-up emergency EP G-3 to provide better alignment between the

4) Ensure follow-up notifications are issued procedures.

emergency notifications are approximately every 45 minutes or issued approximately every less.

45 minutes.

Offsite Communicator Checklist Offsite Communicator Checklist Change #21 - Editorial change with no change of

1. Initial Actions 1. Initial Actions intent.

f. Coordinate with EOF clerk f. Coordinate with EOF Admin Reflect title change made in 2012 for all DCPP IBEW and UDAC clerk to ensure Assistant and UDAC Admin Assistant Physical Clerical staff from "Clerical" to "Administrative" copies of ENFs are to ensure copies of ENFs are and "Clerk" with "Admin". Refer to SAPN 50449609, immediately distributed to the immediately distributed to the EOF Task 17.

EOF staff upon receipt. staff upon receipt.

Offsite Communicator Checklist Offsite Communicator Checklist Change #22 - Editorial change with no change of

2. Ongoing Actions 2. Ongoing Actions intent.

NOTE: Notifications to the NOTE: Notifications to the County and The statement "or less" already exists in EP G-3.

County and State are required to State are required to be completed Adding "or less" in this note brings EP EF-3 in line with be completed within 15 minutes within 15 minutes from the time of a 9 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change from the time of a new emergency new emergency classification or PAR. EP G-3 to provide better alignment between the classification or PAR. Follow up Follow up notifications should be made procedures.

notifications should be made within approximately 45 minutes or less within approximately 45 minutes of the last notification ...

of the last notification.

Offsite Communicator Checklist Offsite Communicator Checklist Change #23 - Editorial change with no change of

2. Ongoing Actions 2. Ongoing Actions intent.

b. Transmit, receive, and b. Transmit, receive, and document The statement "or less" already exists in EP G-3.

document notification notification information.

Adding "or less" in this note brings EP EF-3 in line with information.

8) Assist in completing follow-up EP G-3 to provide better alignment between the

8) Assist in completing emergency notifications to be issued procedures.

follow-up emergency approximately every 45 minutes or notifications to be issued less.

approximately every 45 minutes.

Government Relations Government Relations Coordinator Change #24 - Administrative change with no change Coordinator Checklist Checklist of intent.

1. Initial Actions 1. Initial Actions Reflect specific location in General Office of Emergency

g. Provide initial notification g. Provide initial notification to Operations Center where videoconference and to company personnel as company personnel as follows:

teleconference capability exists. Videoconference is set follows:

2) Initiate videoconference or up with automatic connection to this location. This

2) Initiate videoconference or teleconference contact with change enhances the capability to effectively teleconference contact with government relations - communicate with the General office.

government relations representatives in Sacramento, 10 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Chang~

Change representatives in Washington, and PG&E General Sacramento, Washington, Office Emergency Operations and PG&E General Office to Center (EOC) to provide initial provide initial event status event status and establish a and establish a schedule for schedule for communications communications updates. updates.

New content Government Relations Coordinator Change #25 - Process change with no change of Checklist intent

1. Initial Actions Role of GOTL is evolving as the Company Emergency

h. Make contact with General Response Plan (ERP) is developed. ERP designates Office Technical Liaison (GOTL) point at which the Company EOC will activate in the and request that they report to event of an incident at DCPP. If Company EOC is PG&E General Office and act as a activated they expect a Nuclear Liaison to respond to liaison to company EOC.

the EOC to provide information between the EOF and

1) Maintain contact with GOTL to EOC. The GOTL acts as the Nuclear Liaison. The ensure that they are kept informed Government Relations Coordinator provides the link to of event status. the GOTL for providing information on the event. Both the Government Relations Coordinator and GOTL checklists are being revised to support this change.

This revision is necessary to clarify information exchange and dissemination between the EOF and the Company EOC.

This is not a change of intent within the E-Plan as the responsibilities have not changed. The change adds clarity and alignment with the ERP.

11 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change Government Relations Government Relations Coordinator Change #26 - Process change with no change of Coordinator Checklist Checklist intent

2. Continuing Actions 2. Continuing Actions Role of GOTL is evolving as the Company Emergency

a. Monitor actions and events a. Monitor actions and events from Response Plan (ERP) is developed. ERP designates from EOF to provide EOF to provide information to other point at which the Company EOC will activate in ~he information to other government relations representatives, event of an incident at DCPP. If Company EOC 1s government relations GOTL and JIC personnel.

activated they expect a Nuclear Liaison to respond to representatives, and JIC the EOC to provide information between the EOF and personnel.

EOC. The GOTL acts as.the Nuclear Liaison. The Government Relations Coordinator provides the link to the GOTL for providing information on the event. Both the Government Relations Coordinator and GOTL checklists are being revised to support this change.

This revision is necessary to clarify information exchange and dissemination between the EOF and the Company EOC.

This is not a change of intent within the E-Plan as the responsibilities have not changed. The change adds clarity and alignment with the ERP.

Government Relations Government Relations Coordinator Change #27 - Editorial change with no change of Coordinator Checklist Checklist intent.

2. Continuing Actions 2. Continuing Actions Change title of Policy Group Chair to Company EOC

d. Update the Policy Group d. Update the Company EOC Incident Commander and specify GOTL rather than Chair of designee, and Incident Commander or GOTL (if designee to reflect updates in the Company Emergency External Communications activated), and External 12 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change and Coordination Center Communications and Coordination Response Plan. Refer to SAPN 50449609, Task 25.

(EXCCC) (if activated) at Center (EXCCC) (if activated) at least every classification least every classification change of change of the following: the following:

e. Obtain information from the e. Obtain information from the Policy Group Chair (or Company EOC Incident designee) regarding: Commander or GOTL (if activated), regarding:

Government Relations Content moved to section 1.h Change #28 - Process change with no change of Coordinator Checklist intent.

2. Continuing Actions Content moved to initial actions. The role of the GOTL

f. IF requested by Policy evolved when the Company Emergency Response Plan Group Chair (or designee) to (ERP) was modified to comply with the Incident provide a liaison at company Command System (ICS). The ERP designates point at EOC or PG&E General which the Company EOC will activate in the event of an Office, incident at DCPP. If Company EOC is activated they THEN contact General Office expect a Nuclear Liaison to respond to the EOC to Technical Liaison to report to provide information between the EOF and EOC. This is PG&E General Office.

an automatic action and does not need to be requested.

This is not a change of intent within the E-Plan as the responsibilities have not changed. The change adds clarity and alignment with the ERP.

13 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change Government Relations Government Relations Coordinator Change #29 - Editorial change with no change of Coordinator Checklist Checklist intent.

2. Continuing Actions 2. Continuing Actions This change is correcting a typo which left off a letter.

g. Communicate PG&E public g. Communicate PG&E public information from JIC to information from JIC to County County EOC and EOF EOC and EOF personnel.

personnel.

1) Represent JIG in interactions

1) Represent JIC in with EOF and County Public interactions with EO and Information Manager (PIM) in County Public Information EOG.

Manager (PIM) in EOC.

EOF Security Checklist EOF Security Checklist Change #30 - Editorial change with no change of

1. Initial Actions 1. Initial Actions intent.

c. Initiate and maintain a c. Initiate and maintain a position log This change is correcting a grammatical error.

position log (use Emergency (use Emergency Log Sheets) to*

Log Sheets) to documenting documentffi§-significant actions significant actions performed performed and communications related and communications related to your position. REFER TO Tab 1.

to your position. REFER TO Tab 1.

EOF Security Checklist EOF Security Checklist Change #31 - Administrative change with no change

1. Initial Actions 1. Initial Actions of intent.

e. Setup e. Setup 14 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change

1) Use Attachment 3, 1) Use Attachment 3, "Emergency This change is being made as he position vests contain "Emergency Operations Operations Facility Security Set an ID of the position and the need for ID badges is Facility Security Set Up," of Up," of this procedure as guidance redundant. In addition, PG&E is no longer responsible this procedure as guidance to to position access tables and for checking in county staff or visitors. PG&E is only position access tables and chairs at facility entry point.

responsible for maintaining a list of PG&E and NRC chairs at facility entry point. REFER TO Tab 2.

personnel that are reporting to the EOF. None o_f ~~~

REFER TO Tab 2.

2) Obtain position vests, tables changes to this checklist change or add respons1b1ht1es

2) Obtain position vests and and chairs and ID badges. and there is no impact on the E-Plan. Refer to SAPNs ID badges. 50872169 and 5082167.

31 Locate access list. and EOF ID

3) Locate access lists and badges.

EOF ID badges.

EOF Security Checklist EOF Security Checklist Change #32 - Process change with change of intent

2. Ongoing Actions 2. Ongoing Actions This change is needed to bring the procedure up to date

a. Provide building access a. Provide building access controls with upgrades that have occurred. The position vests controls for PG&E and for PG&E and NRC personnel contain an ID of the position and the reed for ID badges NRC personnel to EOF. to EOF.

is redundant. In addition, PG&E is no longer

1) Check for proper access 1) Check for proper access responsible for checking in county staff or visitors.

identification: identification: PG&E is only responsible for maintaining a list of PG&E a) PG&E ID badge. a) PG&E ID badge. and NRC personnel that are reporting to the EOF.

None of the changes to this checklist change or add b) EOF ID badge. b) EOF ID badge. responsibilities and there is no impact on the E-Plan.

.c) NRC ID badge. c) NRC ID badge . Refer to SAPNs 50872169 and 5082167.

d) Name appears on d) Name appears on visitor list. visitor list.

2) Record entry and exit time 2) Record entrv and exit time of 15 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change of individuals entering and individuals entering and exiting exiting EOF EOF on access list.

3) Personnel not having a) Do not delay facility activation to approved ID or on access list record entry times. Allow PG&E may be granted access by badged personnel to bypass, and EOF Director. obtain entry times from EOF sign-in board after facility activation.

EOF Administrative Support EOF Administrative Support Checklist Change #33 - Editorial change with no change of Checklist

1. Initial Actions intent.

1. Initial Actions

e. Coordinate with other Reflect title change made in 2012 for all DCPP IBEW

e. Coordinate with other Administrative staff and Physical Clerical staff from "Clerical" to "Administrative" Clerical staff and Emergency Emergency Director and "Clerk" with "Admin". Refer to SAPN 50449609 Director Administrative Administrative Assistant to Task 17.

Assistant to assume one of assume one of the following the following support roles: support roles:

1) EOF Clerk (REFER TO 1) EOF Adm in Assistant (REFER step 2.b) TO step 2.b)

2) UDAC Clerk (REFER TO 2) UDAC Admin Assistant steps 1.f and 2.c) (REFER TO steps 1.f and 2.c)

f. UDAC Clerk: f. UDAC Admin Assistant:

1) Report to Radiological 1) Report to Radiological Manager and inform him or Manager and inform him or her her that you are performing that you are performing UDAC UDAC Clerk duties. Admin Assistant duties.

16 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change

. Change EOF Administrative Support EOF Administrative Support Checklist Change #34 - Editorial change with no change of Checklist

2. Ongoing Actions intent.

2. Ongoing Actions

b. EOF Admin Assistant:

Reflect title change made in 2012 for all DCPP IBEW

b. EOF Clerk:

c. UDAC Admin Assistant: Physical Clerical staff from "Clerical" to "Administrative"

c. UDAC Clerk: and "Clerk" with "Admin". Refer to SAPN 50449609,

d. Position Relief Turnover

d. Position Relief Turnover Task17.

3) Notify the individual specified

3) Notify the individual that you have turned over your specified that you have ERO responsibilities.

turned over your ERO a) EOF Admin Assistant - notify responsibilities.

EOF Director a) EOF Clerk - notify EOF b) UDAC Admin Assistant-Director notify Radiological Manager b) UDAC Clerk- notify Radiological Manager EOF Clerical Support Position EOF Administrative Support Position Change #35 - Editorial change with no change of Binder Tab Index Binder Tab Index intent.

EP EF-3, Form 69-21134, "EOF EP EF-3, Form 69-21134, "EOF Clerical Support Checklist" Administrative Support Checklist" Reflect title change made in 2012 for all DCPP IBEW Physical Clerical staff from "Clerical" to "Administrative" and "Clerk" with "Admin". Refer to SAPN 50449609, Task 17.

17 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018

• Change Number I Type of Change I Reason for Original Content Content Change Change Emergency Director Admin Emergency Director Admin Assistant Change #36 - Administrative change with no change Assistant Checklist Checklist of intent

1. Initial Actions 1. Initial Actions Change is being made to align with position

c. Check in with ED and c. Check in with ED and EOF expectations and to reorder steps for clarity. This is not EOF Director. Director.

a change of intent within the E-Plan as the

1) Confirm role expectations d. Maintain Phone coverage. responsibilities have not changed. The change adds .

for: clarity and alignment.

e. Verify that the EOF director a) Phone Coverage has assigned individuals to b) White board maintain status boards.

communications (Admin. f. Maintainffi9 ED log.

Assistant or EOF Director).

c) Maintaining ED log.

Emergency Director Admin Emergency Director Admin Assistant Change #37 - Editorial change with no change of Assistant Checklist Checklist intent.

1. Initial Actions 1. Initial Actions Reflect title change made in 2012 for all DCPP IBEW

e. Assign clerical to e. Assign administrative support Physical Clerical staff from "Clerical" to "Administrative" location/department as to location/department as and "Clerk" with "Admin". Refer to SAPN 50449609, needed: needed:

Task 17.

g. Contact Administrative Advisor at Tse;.

g. Contact Administrative

1) Administrative Advisor Advisor at TSC.

may provide:

1) Administrative Advisor may a) Additional clerical 'Provide:

18 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change support for the EOF.

a) Additional

2. Ongoing Actions administrative support for

b. Ensure EOF clerical the EOF.

staff is adequate to 2. Ongoing Actions support ERO functions.

b. Ensure EOF administrative support is adequate to support ERO functions.

General Office Technical Liaison General Office Technical Liaison Change #38 - Process change with no change of Checklist Checklist intent.

1. Initial Actions 1. Initial Actions The role of the GOTL evolved when the Company

g. IF requested by Policy g. IF requested report to Emergency Response Plan (ERP) was modified to Group Chair (or designee) Company EOG and act as comply with the Incident Command System (ICS). T~e to provide a liaison at liaison.

ERP designates point at which the Company EOC will company EOD or PG&E

h. Upon arrival at Company activate in the event of an incident at DCPP. If General Office, EOG, establish contact with the Company EOC is activated they expect a Nuclear THEN report to PG&E following: Liaison to respond to the EOG to provide information General office. between the EOF and EOC. This is an automatic action

1) Incident Commander

2. Continuing Actions and does not need to be requested.

2)0perations Section Chief

a. Monitor actions and The change adds clarity and alignment with the ERP.

events from EOF to i. Provide event status update to provide information to the Company EOG.

corporate response. j. Contact Government personnel.

Relations Coordinator in EOF

1) Coordinate with EOF to remain current on events Director and Engineering and response actions taking Liaison to develop place at site.

19 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change

• Change information about

2. Continuing Actions

• significant emergency

a. Monitor actions and events events.

from EOF to provide information to corporate response -

c. Evaluate and respond to personnel.

external company issues

1) Coordinate with Government and inform the ED of Relations. Coordinator to corporate status and develop information about decisions.

significant emergency events.

d. Assist the Government

c. Evaluate and respond to Relations Coordinator with external company issues and updating the Policy Group inform the Government Chair, or designee, and Relations Coordinator of External Communications corporate status and decisions.

and Coordination Center (EXCCC) (if activated) at

d. Update the Company EOC least every classification Incident Commander, or change of the following:

designee, and External Communications and

e. Position Relief Turnover Coordination Center (EXCCC)

3) Notify EOF Director that (if activated) at least every you have turned over your classification change of the ERO responsibilities.

following:

e. Position Relief Turnover

3) Notify Government Relations Coordinator that you have turned over your ERO 20 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change responsibilities.

General Office Technical Liaison General Office Technical Liaison Change #39 - Administrative change with no change Checklist Checklist of intent

3. Situation Actions 3. Situation Actions Content was moved into Sections 1.g, h, I, and j of the

a. IF travel to the corporate Content relocated to Section 1.g, h, i checklist as position is expected to travel to Company emergency operations and j.

Emergency Operations Center upon request. Role of center has been GOTL is evolving as the Company Emergency requested, Response Plan (ERP) is developed. ERP designates THEN upon arrival at G.O.

point at which the Company EOC will activate in ~he EOC, establish contact event of an incident at DCPP. If Company EOC 1s with the following:

activated they expect a Nuclear Liaison to respond to

b. Corporate Security the EOG to provide information between the EOF and EOG. This is now an initial action as opposed to a

c. Lead officers in the situational specific.

Operations group

d. Officers in the policy group

e. Provide lead officers status update.

f. Contact Government Relations Coordinator in '

EOF to remain current on events and response actions taking place at site.

/

21 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Change Number I Type of Change I Reason for Content Change Change 4 FMT Briefing Attachment 24 FMT Briefing Sheet Part Change #40 - Administrative change with no change Sheet Part 2 2 of intent New content Verify thateach FMT member completes Record of Distribution of This change is being made to ensure that Kl Potassium Iodide (Kl) form 69-9395 Authorization for the PG&E Field Monitoring Teams and review the Kl Consumer Package (FMT) is documented and that FMTs are provided the Insert. Tell them "Do not ingest Kl until IOSAT Kl pharmaceutical precautions as directed by directed". EP RB-3. In addition this change adds in missing language with respect to turn-back values. These changes clarify and align requirements with EP RB-3.

Gamma instrument exposure rate There is no effect on the implementation of the E Plan.

turn-back values:

20 mr/hr for offsite FMTs unless told otherwise

/

,' 200 mr/hr for onsite FMTs unless told otherwise Communications Coordinator Communications Coordinator Checklist Change #41 - Editorial Change with no change in Checklist 1.lnitial Actions intent.

1.lnitial Actions

g. Perform the following bridge line Change is being made to correct a typo in a position,

g. Perform the following monitoring actions:

title. Refer to SAPN 50449609, Task 27.

bridge line monitoring 2)Monitor or have the Offsite actions:

Communicator monitor bridge line 2)Monitor or have the Offsite x2002 Coordinator monitor bridge line x2002 22 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content

• Content Change Change 0 Dose Assessment Attachment 30 Dose Assessment Data Change #42 - Editorial change with no change in Data Sheet Sheet intent.

ESE distribute copies to: Admin Assistant distribute copies to:

Change is being made to correct an obsolete position title and replace with appropriate position title. Refer to SAPN 50449609, Task 13.

3. RESPONSIBILITIES 3. RESPONSIBILITIES Change #43 - Administrative change with no change 3.1 O EOF security liaison is 3.1 O EOF security liaison is of intent.

responsible for: responsible for:

This change is being made to align EP EF-3 with 3.10.2 This position is not an 3.10.2 Deleted content Section 5 of the E-Plan step 3.10.2 is no longer ERO minimum staff or ERO necessary as Revision 4.15 to E-Plan Section 5 made support staff position. This the Security Liaison position an ERO support staff position serves an advisory position. Refer to SAPN 50449609, Task 14.

role only and would be called out as needed.

23 of 23

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-9, Revision 12 Backup Emergency Response Facilities

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-9, Revision 12 Original Content Content Change Change Number I Type of Change I Reason for Change N/A Procedure converted to new template. Change #1 - Editorial change with no Editorial changes made throughout change of intent.

procedure. Converted procedure to new template and made editorial changes to align with AD1 .ID1 requirements.

Section 2.1 Section 2.1 Change #2 - Process change with no The characteristics of an alternative facility The characteristics of a backup facility change of intent.

should include: 1) accessibility, 2) should include: SAPN 50432078, Task 3, states that communication links with the EOF, control EP EF-9 should be revised to replace

• Accessibility room, and security [ ... ] plan mitigative the term ~lternative with backup so as actions).

• Communication links with other to reduce confusion between the two.

facilities (e.g. EOF) control rc;>om, and security EP Rulemaking established a new definition of alternate facility, and the

• [ ... ] alternate TSC/OSC is discussed in

• plan mitigative actions) . EP EF-11, not EP EF-9. Replacing alternative with backup restores the original intent, which is aligned with the DCPP E-Plan as well as industry guidance.

Section 2.3 Section 2.3 Change #3 - Process change with Designated on-site ERFs and their backup Designated ERFs and their backup facilities change of intent.

facilities include the following: include the following: During the Ocean PAR Root Cause Extent of Condition, it was determined 1 of 8

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change ERF Prim First Second ERF Prim First Second that DCPP was not fully implementing Function ary Backup Backup Function ary Backup Backup the commitment in the E-Plan for a Facili Facili backup Emergency Operations Facility ty ty (EOF). This was documented in SAPN 50627794, tasks 11 and 78, and is now Control Con tr Hot S/D (None) Control Con tr SM/SFM - (None) being tracked via SAPN DA 50796556.

Room al Panel Room al Hot S/D Section 7 .1. 7 .2 of the E-Plan (Revision Rao (SM/SFM); Rao Panel 4.20) states that the Energy Education m TSC (SM, m SM, STA, Center (EEC) is the first choice for a STA, SFM) SFM- backup EOF, and Section 7.1.8.2 states TSC that the Electrical Control Center TSC TSC Control Hot S/D Room Panel_ TSC TSC Min. Staff- Min. Operations (ECCO) could be used as a (Min. (Min. - 104' Control Staff - backup location for the EOF.

Staff); Staff.); Buttr Room Hot S/D This revision adds the EOF as a TM/Trng. EOF ess Support Panel designated ERF and identifies the first Bldg. (Supper Area Staff - Support backup as the EEC, and the second (Supp.) t) )

Bldg. 109 Staff - backup as SLO ECCO. This ensures EOF that the commitment in the DCPP.

OSC- osc 140' Adminis E-Plan is fully implemented.

Command - 104' Turbine tration OSC- osc 140' Adm in is Note that SAPN 50432078, Task 4, also Center Buttr Building - Building Command - 104' Turbine tration ess documents that the EEC should be Northeast Room Center Buttr Building - Building listed as the first choice for the backup Area Corner 215 ess Northeast Room EOF.

Area Corner 215 OSC- Mai osc 140' Canyon ntenance - 104' Turbine Rm/Trn OSC- Mai osc 140' Canyon SAPN 50432078, Task 2, states that Assembly Buttr Building - g Bldg ntenance - 104' Turbine . Rm or TM/Trng Bldg" is vague, and Area ess Northeast Craft Buttr Building - Training recommends that it should be referred Area Corner Assembly ess Northeast Bldg. to as "Bldg. 109." This revision also Area Area Corner 109 2 of 8

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original~ Content Change Change Number I Type of Change I

---

Reason for Change

~ .

CR/OSC- Con tr OPs 119' CR/OSC- Con tr OPS

- - 19~- -- incorporates this enhancement, as well Nuclear cl Ready Turbine Nuclear cl Ready Work -as-otheLs to clarify locations and Operator Roe Room Building Operator Roe Room Control increase reaaability.____ --

Assembly m Ofc/Cyn Assembly m Center The words "on-site" were removed; as_ -

Area Rm Area or the EOF is not onsite and it is no longer Canyon applicable.

OSC- 85' 140' TSC Rm These changes are being made to align C&RP Acee Access Lab with the current DCPP E-Plan, or are Technicia SS Control OSC- 85' 140' TSC clearly enhancements for procedure n Contr C&RP Acee Access Lab usability; therefore, there is no impact Assembly cl Technicia SS Control on how the E-Plan meets the planning Area n Contr standards, functions or elements.

Assembly al Area EOF EOF Energy SLO Education ECCO-Center- PG&E Ontario Service Road Center S.

Higuera Section 2.4 Section 2.4 Change #4 - Process change with Control Room Function, TSC Function, & Control Room Function & TSC Function change of intent.

Access Control Function Tables Tables SAPN 50432078, Task 5, documents that EP EF-9 should be updated to

• Deleted "Black Net phone" remove "Black Net phones," that were Access Control Function Table 3 of 8

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change

• Changed "PICs" to "PEDs" removed from the Control Room and have not been in service since 2001.

This is documented in AR A0503950.

)

The Black Net function provided a direct link between the Control Room and the County and State EOC - this capability remains available today via automatic tie lines (ATL).

Removal of the Black Net phone system was previously evaluated under 10 CFR 50.54q 2015-65. The current E-Plan makes no mention of the Black Net system. The Black Net function provided a direct link between the CR and the County Emergency Operations Center (EOC) and the State EOC. This capability remains available today via dedicated lines; it just isn't called Black Net anymore. The proposed change removes a piece of equipment that has not been used since at least 2001. All other existing phone capabilities will remain available and unchanged.

Therefore, the proposed change continues to provide for the requisite systems for prompt communication to emergency response personnel.

PICs were changed to PEDs as PICs are obsolete.

4 of 8

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason fQr Change The proposed change is being made to ensure that the procedure remains technically accurate by removing a piece of equipment that is no longer used.

Section 4.2 Section 3.2 Change #5 - Process change with NIA - New content Added "EOF I Emergency Director" change of intent.

During the Ocean PAR Root Cause Extent of Condition, it was determined that DCPP was not fully implementing the commitment in the E-Plan for a backup Emergency Operations Facility (EOF). This was documented in SAPN 50627794, Tasks 11 and 78, and is now being tracked via SAPN DA 50796556.

Section 7 .1. 7 .2 of the E-Plan (rev 4.20) states that the Energy Education Center (EEC) is the first choice for a backup EOF, and Section 7.1.8.2 states that the Electrical Control Center Operations (ECCO) could be used as a backup location for the EOF.

EP EF-9 is being revised to incorporate the backup EOF. This change is being made to fully implement the backup EOF, and as such, the E-Plan commitment.

5 of 8

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change There is no impact on how the E-Plan meets the planning standards, functions or elements.

Section 5.1 Section 6.1 Change #6 - Editorial change with no A backup ERF shall be activated when an A backup ERF shall be activated when a change of intent.

ERF is determined uninhabitable or primary ERF is determined uninhabitable or "Primary" being added for clarification otherwise may not start up or continue otherwise may not start up or continue only - no change of intent.

operations: See Section 2.1 above for the operations. See Section 2.1 above for the recommended succession of ERFs. recommended succession of ERFs.

Section 5.3 Section 6.4 Change #7 - Process change with 5.3.1 Backup Control Room: 6.4.1 Backup Control Room: OP AP-BA change of intent.

OP AP-BA 6.4.2 Backup TSC: Attachment 1 During the Ocean PAR Root Cause 5.3.2 Backup TSC: Attachment 7 .1 6.4.3 Backup OSC: Attachment 2 Extent of Condition, it was determined that DCPP was not fully implementing 5.3.3 Backup OSC: Attachment 7.2 6.4.4 Backup Access Control: the commitment in the E-Plan for a 5.3.4 Backup Access Control: Attachment 3 backup Emergency Operations Facility Attachment 7.3 6.4.5 Backup EOF: Attachment 5 (EOF). This was documented in SAPN 50627794, Tasks 11 and 7B, and is now being tracked via SAPN 50796556.

Section 7 .1. 7 .2 of the E-Plan (Revision 4.20) states that the Energy Education Center (EEC) is the first choice for a backup EOF, and Section 7.1.B.2 states that the Electrical Control Center Operations (ECCO) could be used as a 6 of B

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change backup location for the EOF.

EP EF-9 is being revised to incorporate the backup EOF. This change is being made to fully implement the backup EOF, and as such, the E-Plan commitment.

There is no impact on how the E-Plan meets the planning standards, functions or elements.

Section 6, Records Section 7.1 & 7.2, Records Change #8 - Editorial change with no Checklists completed due to use of this Documents generated by this procedure change of intent.

procedure in a drill or actual event shall be during drills are non-quality records and are Updated the records section to align forwarded to the Emergency Planning maintained per emergency preparedness with other E-Plan Implementing Manager for entry into Records administrative procedures. Procedures and AD10.ID2. This Management System. Documents generated by this procedure change aligns the EP EF-9 with the during actual events are non-quality records current plant process.

and are maintained for the life of the plant, per AD10.102, "Storage and Control of Non-quality Assurance Records."

Attachments 1, 2, 3, and 4 Reformatted attachments 1, 2, 3, and 4 in Change #9 - Editorial change with no accordance with AD1 .101 requirements for change of intent.

new template. Attachments reformatted to comply with AD1 .101 requirements. Editorial changes were made throughout attachments as well.

7 of 8

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content Content Change Change Number I Type of Change I Reason for Change N/A - New Content Attachment 5 Change #10 - Process change with Added new attachment, "Backup EOF change of intent.

Activation" During the Ocean PAR Root Cause Extent of Condition, it was determined that DCPP was not fully implementing the commitment in the E-Plan for a backup Emergency Operations Facility (EOF). This was documented in SAPN 50627794, Tasks 11 and 78, and is now being tracked via SAPN 50796556.

Section 7 .1. 7 .2 of the E-Plan (Revision 4.20) states that the Energy Education Center (EEC) is the first choice for a backup EOF, and Section 7.1.8.2 states that the Electrical Control Center Operations (ECCO) could be used as a backup location for the EOF.

EP EF-9 is being revised to incorporate the backup EOF. This change is being made to fully implement the backup EOF, and as such, the E-Plan commitment.

There is no impact on how the E-Plan meets the planning standards, functions or elements.

8 of 8