DCL-19-002, Emergency Plan Implementing Procedure Update

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Emergency Plan Implementing Procedure Update
ML19015A378
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 01/15/2019
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-19-002, DIL-19-001
Download: ML19015A378 (40)
v • d • e


Text

Pacific Gas and Electric Company~

January 15, 2019 PG&E Letter DCL-19-002 PG&E Letter DI L-19-001 Michael A. Ginn Manager Emergency Planning Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 805.545.3446 Internal: 691.3446 Fax: 805.545.6265 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 10 CFR 50.54, 10 CFR 72.32 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 Update

Dear Commissioners and Staff:

In accordance with 10 CFR 50.54(q)(5) and the requirements of 10 CFR 72.32, Pacific Gas and Electric Company (PG&E) hereby provides a summary of the analysis of changes to Emergency Plan (E-Plan) Implementing Procedures. Those procedures include EP EF-1, Revision 56, "Activation and Operation of the Technical Support Center," EP EF-9, Revision 13, "Backup Emergency Response Facilities,"

and EP RB-17, Revision 2, "Operating Instructions for QuickDose."

The associated enclosures are listed below:

  • - Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-9, Revision 13, "Backup Emergency Response Facilities."

A member of the STARS Alliance Callaway* Diablo Canyon

  • Palo Verde* Wolf Creek

Document Control Desk January 15, 2019 Page 2 PG&E Letter DCL-19-002 PG&E Letter DI L-19-001

  • - Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-17, Revision 2, "Operating Instructions for QuickDose."

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 of 10 CFR 50 and the planning standards of 10 CFR 50.47(b). Therefore, prior NRG approval of the associated changes was not required.

This update does not contain any privacy and proprietary information in accordance with NRG 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,

__/IAJL ll\\ G-,>.

Michael A. Ginn Emergency Planning Manager armb/4743/ 51010282, 51011536, and 51011537 Enclosures cc/enc: William C. Allen, NMSS Project Manager Scott A. Morris, NRG Region IV Administrator Christopher W. Newport, NRG Senior Resident Inspector Balwant K. Singal, NRG Senior Project Manager Senior Emergency Preparedness Inspector (RGN-IV/DR)

A member of the STARS Allia nce Callaway

  • Diablo Canyon
  • Palo Ver de

Proc. No.

OM10.ID1 OM10.DC1 EP G-1 EP G-2 EP G-3 EP G-4 EP G-5 EP OR-3 EP RB-1 EP RB-2 EP RB-3 EP RB-4 EP RB-5 EP RB-8 EP RB-10 EP RB-12 EP RB-14 EP RB-14A EP RB-15 EP RB-16 EP RB-17 EP R-2 EP R-3 EP R-7 EP EF-1 EP EF-2 EP EF-3 EP EF-4 EP EF-9 EP EF-10 EP EF-11 PG&E Letter DCL-19-002 PG&E Letter DI L-19-001 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Rev.

18 10 45 51 60 30 16 10 8

8 9

5 9

29 21 12 10 3

15 16 2*

36 9

18 56*

40 47 21 13*

17 2

Title Maintaining Emergency Preparedness Emergency Preparedness Drills and Exercises Emergency Classification and Emergency Plan Activation Interim Emergency Response Organization Emergency Notification of Off-Site Agencies Assembly and Accountability Evacuation of Non-Essential Site Personnel Emergency Recovery Personnel Dosimetry Emergency Exposure Guides Stable Iodine Thyroid Blocking Access to and Establishment of Controlled Areas Under Emergency Conditions Alternate Personnel Decontamination Facilities Instructions for Field Monitoring Teams Protective Action Recommendations Plant Vent Iodine and Particulate Sampling During Accident Conditions Core Damage Assessment Procedure Initial Detection of Fuel Cladding Damage Post Accident Sampling System Operating Instructions for the EARS Computer Program Operating Instructions for QuickDose Release of Airborne Radioactive Materials Initial Assessment Release of Radioactive Liquids Off-Site Transportation Accidents Activation and Operation of the Technical Support Center Activation and Operation of the Operational Support Center Activation and Operation of the Emergency Operations Facility Activation of the Off-Site Emergency Laboratory Backup Emergency Response Facilities Activation and Operation of the Joint Information Center Alternate Emergency Response Facilities/ Incident Command Post (ICP)

Change Original Content (Rev 55)

Revised Content (Rev 56) 1 8.16 8.16 SAMG DFC, "TSC Diagnostic Flow Chart,"

DPG, "Diagnostic Process Guideline," Plant Plant Manual Volume 3E Manual Volume 3E 2

2.c.1) PA announcements should be made at 2.c.1) PA announcements (REFER TO Tab least hourly to update staff on the emergency

5) should be made at least hourly to update status or as soon as possible for the staff on the emergency status or as soon as following: REFER TO Tab 5.

possible for changes in any of the following:

a) A significant change in plant radiological Emergency classification and protective conditions.

action recommendations b) A change in emergency action level Radiological release status

( escalation or de-escalation).

Other plant conditions that may be hazardous to plant personnel (e.g. toxic gases, chemical spills)

Routine updates (at least hourly) when conditions are stable 3

TSC Director Position Binder Tab Index TSC Director Position Binder Tab Index Tab 1: EP G-4, "Assembly and Tab 1: Emergency Log Sheets Accountability" Tab 2: EP G-4, "Assembly and Tab 2: Emergency Log Sheets Accountability" Page 1 of 3 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Modified content Editorial change to update the procedure title of the TSC's entry point into SAMGs.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content Changes made to align the TSC Director instructions with the SEC instructions for when to make PA announcements.

This change does not alter the content, frequency, or responsibilities associated with PA announcements made by the TSC during emergencies.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content Editorial change to swap the order of Tabs 1 and 2 in the TSC Director position binder to align with all other position binders which have log sheets under Tab 1.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Change Original Content (Rev 55)

Revised Content (Rev 56) 4 3.c. IF directed by the TSC director, 3.c. IF directed by the TSC director, THEN direct the reactor engineer to enter the THEN direct the reactor engineer to enter the SAMG DFC "TSC Diagnostic Flowchart" DPG, "Diagnostic Process Guideline,"

(Plant Manual Volume 3E).

(Plant Manual Volume 3E).

5 0 0 2.g. IF directed by the engineering advisor, 2.g. IF directed by the engineering advisor, THEN assume the role of SAM evaluator and THEN assume the role of SAM evaluator and enter the SAMG DFC "TSC Diagnostic enter the DPG, "Diagnostic Process Flowchart," (Plant Manual Volume 3E).

Guideline" (Plant Manual Volume 3E).

REFER TO Tab 4.

REFER TO Tab 4.

6 O 0 Reactor Engineer Position Binder Tab Index Reactor Engineer Position Binder Tab Index Tab 4: SAMG DFC, "TSC Diagnostic Tab 4: DPG, "Diagnostic Process Guideline" Flowchart" (Volume 3E)

(Volume 3E) 7 4 4 N/A - added new content

b. Consider the need for days off and reduction in hours worked during extended events.

Page 2 of 3 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Modified content Editorial change to update the procedure title of the TSC's entry point into SAMGs.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content Editorial change to update the procedure title of the TSC's entry point into SAMGs.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content Editorial change to update the procedure title of the TSC's entry point into SAM Gs.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Added content Added a new step for users of the attachment to consider the need for days off and changing the number of hours worked during extended events.

Change Original Content (Rev 55)

Revised Content (Rev 56)

Page 3 of 3 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-9, Revision 13 "Backup Emergency Response Facilities"

Change Original Content (Rev 12)

Revised Content (Rev 13) 1 1.2 1.2 This procedure has been converted; This procedure was rewritten; therefore, therefore, revision bars are not included.

revision bars are not included.

2 N/A-Added new content 2.1 General Guidelines

(

3 6.1 2.1.1 A backup ERF shall be activated when a Backup ERFs are activated when a primary primary ERF is determined uninhabitable or ERF is determined uninhabitable or otherwise may not start up or continue otherwise may not start up or continue operations. Refer to Section 2.3 for the operations.

recommended succession of ERFs.

Page 1 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Modified content.

Step was modified based on the scope of Revision 13, which was a re-write and not a template conversion.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Added content.

Reformatted Section 2 to align with other EPIPs which have a general discussion or guideline section followed by a definitions section.

This change also results in the renumbering of all subsequent steps.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Relocated and modified content.

Content was relocated from Section 6 to Section 2. The language was modified to improve readability. No change in requirements was made.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Change Original Content (Rev 12)

Revised Content (Rev 13) 4 2.3 Second Backup - EOF 2.1.4 Second Backup - EOF SLO ECCO - PG&E Service Center S.

PG&E SLO Service Center S. Higuera Higuera 5

NIA-Added new content 2.2 Definitions 6

3.2 2.2.1 ERF Lead Supervisor ERF Lead: The lead ERO position for a given Control Room Shift Manager ERF.

TSC Site Emergency Coordinator

  • CR: Shift Manager osc OSC Director TSC: Site Emergency Coordinator Access Control Site RP Coordinator OSC: OSC Director EOF Emergency Director EOF: Emergency Director Access Control: Site Radiation Protection Coordinator Page 2 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Modified content.

Changed the name of second backup EOF location to align with E-Plan section 7.1.8.2.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Added content.

Reformatted Section 2 to align with other EPIPs which have a general discussion or guideline section followed by a definitions section.

This change also results in the renumbering of all subsequent steps.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Relocated content.

Relocated ERF lead designator from the responsibilities section to the definitions section.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Change Original Content (Rev 12)

Revised Content (Rev 13) 7 2.5

2.2 Habitability

A facility is deemed habitable Habitability: A facility is deemed habitable when its occupants may perform their when its occupants may perform their intended functions within (including, as intended functions within (including, as applicable, access and exit) without undue applicable, access and exit) without undue risk from toxic, flammable, explosive, risk from toxic, flammable, explosive, radiological or other hazards. Given the large radiological or other hazards. Given the large potential variances in plant emergency risk potential variances in plant emergency risk and necessary facility occupancy times to and necessary facility occupancy times to respond appropriately, absolute numerical respond appropriately, absolute numerical limits for these hazards are not pre-specified limits for these hazards are not pre-specified in this procedure. Refer to Section 3.2 for in this procedure.

determination of habitability and relocation.

8 NIA-Added new content 3.1 Shift Manager (SM) is responsible for:

3.1.1 Determining Control Room habitability.

3.1.2 Determining the need to relocate Control Room personnel to a backup location.

9 3.1 3.2 The Site Emerqencv Coordinator (SEC) is Site emerqencv coordinator (SEC) is Page 3 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Modified content.

Removed the reference to section 3.2.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Added new content.

Added in a new responsibility section to align EP EF-9 with other E-Plan implementing procedures format and structure.

The content of step 3.1.1 was derived from the table that was contained in Revision 12 step 3.2 which identified the SM as being responsible for determining ERF habitability.

The content of step 3.1.2 was developed based on guidance and actions from OP AP-8A, "Control Room Inaccessibility -

Establishing Hot Standby."

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Added new content.

Added in a new responsibility section to align

Change Original Content (Rev 12)

Revised Content (Rev 13) responsible for determining relocation responsible for:

necessary for on-site ERFs.

3.2.1 Determining TSC habitability.

3.2.2 Determining the need to relocate TSC personnel to a backup location.

3.2.3 Authorizing the relocation of other on-site ERO personnel as requested.

10 N/A-Added new content 3.3 Emergency director (ED) is responsible for:

3.3.1 Determining EOF habitability.

3.3.2 Determining the need to relocate EOF personnel to a backup location.

Page 4 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change EP EF-9 with other E-Plan implementing procedures format and structure.

The content of step 3.2.1 was derived from the table that was contained in Revision 12 step 3.2 which identified the SEC as being responsible for determining ERF habitability.

The content of step 3.2.2 was developed for consistency and aligns with the existing signature responsibility in attachment 1, which is the SEC.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Added new content.

Added in a new responsibility section to align EP EF-9 with other E-Plan implementing procedures format and structure.

The content of step 3.3.1 was derived from the table that was contained in Revision 12 step 3.2 which identified the ED as being responsible for determining ERF habitability.

The content of step 3.3.2 was developed for consistency and aligns with the existing signature responsibility in attachment 5, which is the ED.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Change Original Content (Rev 12)

Revised Content (Rev 13) 11 N/A-Added new content 3.4 OSC director is responsible for:

3.4.1 Determining OSC habitability.

3.4.2 Requesting SEC authorization to relocate OSC personnel to a backup location.

12 N/A - Added new content 3.5 Site radiation protection coordinator (OSC) is responsible for:

3.5.1 Determining 85' access control habitability.

3.5.2 Requesting SEC authorization to relocate 85' access control to a backup location.

Page 5 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Added new content.

Added in a new responsibility section to align EP EF-9 with other E-Plan implementing procedures format and structure.

The content of step 3.4.1 was derived from the table that was contained in Revision 12 step 3.2 which identified the OSC Director as being responsible for determining ERF habitability.

The content of step 3.4.2 was developed for consistency and aligns with the existing step in Attachment 2. This new step also maintains alignment with the SEC responsibility under 3.2.2.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Added new content.

Added in a new responsibility section to align EP EF-9 with other E-Plan implementing procedures format and structure.

The content of step 3.5.1 was derived from the table that was contained in Revision 12 step 3.2 which identified the Site Radiation Protection Coordinator as being responsible for determining access control habitability.

The content of step 3.5.2 was developed for consistency and aligns with the existing step in Attachment 3. This new step also

Change Original Content (Rev 12)

Revised Content (Rev 13) 13 3.2 N/A-Removed content The lead supervisor is responsible for determining ERF habitability for that facility (subject to Section 6.2):

ERF Lead Supervisor Control Room Shift Manager TSC Site Emergency Coordinator osc OSC Director Access Control Site RP Coordinator EOF Emergency Director 14

4. Prerequisites
4. Prerequisites None 4.1 Any ERF has been deemed uninhabitable or unable to perform ongoing operations in support of emergency response.

15 6.2 6.1 An ERF shall be declared uninhabitable by An ERF shall be declared uninhabitable by the following:

the following (if time permits):

6.2.1 The Emerqencv Director (EOF is 6.1.1 CR: The SM Page 6 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change maintains alignment with the SEC responsibility under 3.2.2.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Removed content.

This step was removed because it became duplicative as the content of this step was relocated to steps 3.1.1, 3.2.1, 3.3.1, 3.4.1, and 3.5.1.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Added content.

Added in a new prerequisite to make it clear for the ERO when they should be entering this procedure.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Changed full titles to acronyms. Added in the other ERFs and their designated ERF lead.

Removed the requirement to obtain SM/SEC/ED consent.

Change Original Content (Rev 12)

Revised Content (Rev 13) activated and time permits).

6.1.2 TSC: The SEC 6.2.2 The SEC or Shift Manager (EOF not activated or time does not permit ED 6.1.3 OSC: The OSC director consent).

6.1.4 EOF: The ED 6.2.3 The ERF lead supervisor (time does not 6.1.5 Access Control: Site radiation permit SEC/SM consent). Refer to Section protection coordinator 3.2.

16 6.3 N/A - Removed content.

The Site Emergency Coordinator (SEC) shall, in general, determine relocation necessary for on-site ERFs. If time permits and the EOF is activated with the Emergency Director (ED) present, the SEC should obtain the ED's consent.

17 6.4 The backup ERF shall be activated using the N/A-Removed content.

references listed below.

NIA-Added new content.

6.2 Shift Manager (SM) 6.4.1 Backup Control Room: OP AP-8A 6.2.1 Use OP AP-8A, "Control Room Inaccessibility - Establishing Hot Standby" to guide performance of required actions.

NIA-Added new content.

6.3 Site Emergency Coordinator (SEC) 6.4.2 Backup TSC: Attachment 1 6.3.1 Use Attachment 1, "Backup TSC Activation" to guide performance of required actions.

NIA-Added new content.

6.4 OSC Director Page 7 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Removed content.

Content was removed because it was duplicative of the responsibilities established in Section 3.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Reworded and reformatted the step to align it with other EPIPs that use multiple attachments to implement actions.

Removed the lead instruction to activate the backup ERF using the references. The intent of the instruction (to use the correct attachment) is maintained through the modified instructions provided which direct the different facilities to the applicable attachment.

Added in ERO position titles as well to establish who should be getting the attachments out. This change aligns with other EPIPs.

Change Original Content (Rev 12)

Revised Content (Rev 13) 6.4.3 Backup OSC: Attachment 2 6.4.1 Use Attachment 2, "Backup OSC Activation" to guide performance of required actions.

NIA-Added new content.

6.5 Site Radiation Protection Coordinator 6.4.4 Backup Access Control: Attachment 3 6.5.1 Use Attachment 3, "Backup Access Control Activation" to guide performance of required actions.

NIA-Added new content.

6.6 Individual Assigned to Activate the Virtual Emergency Response Facility (VERF)

NIA - Added new content.

6.6.1 Use Attachment 4, "Activation of a Virtual Emergency Response Facility (VERF)" to guide performance of required actions.

NIA-Added new content.

6.7 Emergency Director (ED) 6.4.5 Backup EOF: Attachment 5 6.7.1 Use Attachment 5, "Backup EOF Activation" to guide performance of required actions.

18 7.1 7.1 Documents generated by this procedure Documents generated by this procedure during drills are non-quality records and are during drills are non-quality good business maintained per emergency preparedness records and are maintained per OM10.ID1,

administrative procedures.

"Maintaining Emergency Preparedness."

19

8. References
8. References None 8.1 CP M-15A, "Site Specific Security Threat

- Initial Response (1 0CFR2.390)"

Page 8 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Added in Attachment 4 to the listing for the VERF as there was no discreet instruction that directed use of Attachment 4 in Revision 12.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

This step was changed for consistency with other EPIPs.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Added content.

Added in procedures that were referenced throughout EP EF-9 for consistency with other EPIPs.

Change Original Content (Rev 12)

Revised Content (Rev 13) 8.2 EP EF-1, "Activation and Operation of the Technical Support Center" 8.3 EP EF-2, "Activation and Operation of the Operational Support Center" 8.4 EP EF-3, "Activation and Operation of the Emergency Operations Facility" 8.5 EP G-3, "Emergency Notification of Off-Site Agencies" 8.6 OP AP-SA, "Control Room Inaccessibility

- Establishing Hot Standby" 20 NOTE 1: Use this attachment in conjunction NOTE 1: Use this attachment in conjunction with EP EF-1.

with EP EF-1.

N/A - Added new content.

NOTE 2: Steps in this checklist may be performed in an order other than listed or they may be omitted if not applicable.

NOTE 2: The TSC first backup facility is the NOTE 3: Circumstances may dictate using Control Room for the minimum staff different facilities besides those listed in this personnel and other appropriate facilities for procedure.

the TSC support staff. The second backup is the Hot Shutdown Panel for the minimum staff personnel and the EOF for the TSC support staff. Circumstances may dictate using these out of order, or using different facilities. In such a case, use the following instructions as much as possible.

N/A-Added new content.

NOTE 4: This checklist may be performed by anyone in the TSC as directed by the SEC.

21 Page 9 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified and added content.

Added in a new Note 2 to align EP EF-9 with other EPIPs that allow the ERO to use the checklists in any order necessary during an emergency.

Note 3 was reworded based on the content of the old Note 2.

Added a new Note 4 to make it clear that anyone may perform the actions required in the checklist as delegated by the SEC.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Change Original Content (Rev 12)

Revised Content (Rev 13) 1.a. If time permits and the EOF is activated

1. Obtain SEC authorization to relocate the with the ED present, obtain SEC or ED TSC (if time permits).

consent for TSC relocation.

a. Date:
b. Time:
c. SEC Name:

22 6.3 However, in cases of rapidly escalating or

2. lE events in progress are rapidly escalating highly dangerous or potentially dangerous or pose an imminent risk to TSC personnel, conditions, the lead supervisor in each facility THEN TSC evacuation may be done prior to may order evacuation prior to receiving receiving SEC authorization.

SEC/ED authorization.

23 NOTE 2: The TSC first backup facility is the

3. Select a backup TSC location based on Control Room for the minimum staff the following guidance:

personnel and other appropriate facilities for the TSC support staff. The second backup is ERF First Backup Second the Hot Shutdown Panel for the minimum Function Backup staff personnel and the EOF for the TSC support staff.

Page 10 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Revised the step based on other changes made in EP EF-9 that allow anyone to perform this attachment.

Added in substeps a - c to document the date, time, and SEC name to ensure the SEC is involved in the decision to relocate the TSC in the event the checklist is performed by an ERO member other than the SEC.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Relocated and modified content.

Relocated content from Section 6 into the attachment to ensure the guidance is consistently used.

Reworded step to improve readability.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Relocated and modified content.

Relocated the direction for selecting backup ERF locations from the note to the instruction section.

The locations were formatted into a table to improve use.

Added in the new substep a. to provide

Change 24 25 Original Content (Rev 12)

NIA-Added new content.

1.b. Declare the TSC evacuation and relocation to the TSC staff using the plant PA 1.d. Consider taking the survey instruments from the TSC.

Revised Content (Rev 13)

TSC Min. Staff:

Control Room Support Staff:

Bldg. 109 Min. Staff: Hot S/D Panel Support Staff:

EOF

a. Other essential personnel appropriate to the event (in addition to Min Staff) should be considered Min Staff with respect to where they are directed to go.
4. Update TSC personnel on the decision to evacuate and relocate the TSC.
5. Direct TSC personnel to determine which materials and equipment to take such as:

Position binders Hard copy drawings EAL wall charts Other procedure binders RP supplies (survey instruments, Kl, TLDs, PEDs, PCs, respiratory protection, etc.)

Laptops/cell phones/satellite phones/radios Page 11 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change direction to the ERO on how to handle responders other than min staff that have been deemed essential for the events in progress.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Revised the step for improved readability.

The use of the plant PA system was removed from this step as the proper tool.is an update within the facility. The use of the plant PA is done under subsequent steps to notify other facilities on-site.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Modified step for the ERO to consider taking supplies with them in the event they have to leave their primary facility.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Change Original Content (Rev 12)

Revised Content (Rev 13) 26 1.b. Post the abandoned facility entrances

6. Direct TSC personnel to post facility with signs indicating the uninhabitable status entrances with signs indicating the and facility relocation.

uninhabitable status and facility relocation.

27 1.b. Notify the EOF if activated. Notify the

7. Notify the following facilities of the decision Control Room and, if activated, the OSC.

to evacuate and relocate the TSC.

Control Room (using plant PA or other available method)

OSC (if activated, using plant PA or other available method)

EOF (if activated, using any available method) 28 1.c. Direct the minimum TSC staffing per EP

8. Direct TSC personnel to relocate to EF-1 to the Control Room, Hot Shutdown selected backup location.

Panel, or other appropriate facility, plus other essential personnel appropriate to the event response.

1.d. Direct TSC support staff to relocate to other appropriate facilities.

29 1.e. When the backup TSC facility is

9. Notify the following facilities when the operational, notify the Control Room and, as backup TSC facility is operational:

Page 12 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Modified content.

Reworded step to improve readability and to make the step directed.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Reworded step to improve readability. Added in guidance on options for methods the ERO may use to perform the notifications.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Combined two steps into one to remove unnecessary content.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Reworded and reformatted step to improve readability. Separated the NRC notification

Change Original Content (Rev 12)

Revised Content (Rev 13) appropriate, the OSC and EOF. Make a plant

  • Control Room (using plant PA or other PA announcement if possible. Direct available method) notification of the County, State and NRG.

OSC (if activated, using plant PA or other available method)

EOF (if activated, using any available method)

10. Direct notification of all of the following per guidance in EP G-3:
a. County (using any available method)
b. State (using any available method)
c. NRG (using any available method) 30 Completed By: Site Emergency Coordinator Completed By:

31 NOTE 1: Use this attachment in conjunction NOTE 1: Use this attachment in conjunction with EP EF-2.

with EP EF-2..

N/A-Added new content.

NOTE 2: Steps in this checklist may be performed in an order other than listed or they may be omitted if not applicable.

NOTE 2: The OSC first backup facility is the NOTE 3: Circumstances may dictate using office on the north end of the Turbine different facilities besides those listed in this Building (140' elevation) and the second is procedure, such as the 85' Machine Shop.

the Administration Buildinq Room 215.

Page 13 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change into its own step.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Removed the SEC title from the completed by signature line. The SEC still has to authorize the relocation of the TSC.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified and added content.

Added in a new note 2 to align EP EF-9 with other EPIPs.

Note 3 was reworded based on the content of the old Note 2. The intent remains the same.

The specific backup facility locations were removed from the note as they were relocated to the instructions on the attachment where they belong. Added a new Note 4 to make it clear that anyone may perform the actions required in the checklist

Change Original Content (Rev 12)

Revised Content (Rev 13)

Circumstances may dictate using these out of order, or using a different facility, such as the 85' Machine Shop. In such a case, use the following instructions as much as possible.

NIA-Added new content.

NOTE 4: This checklist may be performed by anyone in the OSC as directed by the OSC Director.

32 1.a. If time permits, obtain SEC or Shift

1. Obtain SEC authorization to relocate the Manager consent for OSC relocation.

OSC (if time permits).

a. Date:
b. Time:
c. SEC Name:

33 6.3 However, in cases of rapidly escalating or

2. lE events in progress are rapidly escalating highly dangerous or potentially dangerous or pose an imminent risk to OSC personnel, conditions, the lead supervisor in each facility THEN OSC evacuation may be done prior to may order evacuation prior to receiving receiving SEC authorization.

SEC/ED authorization.

Page 14 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change as delegated by the OSC Director.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Revised the step based on other changes made in EP EF-9 that allow anyone to perform this attachment. The revised step continues to require obtaining SEC authorization to relocate the OSC. The conditional action to obtain SM consent was removed.

Added in substeps a - c to document the date, time, and SEC name to ensure the SEC is involved in the decision to relocate the OSC.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Relocated and modified content.

Relocated content from Section 6 into the attachment to ensure the guidance is consistently used.

Reworded step to improve readability and make it action oriented.

This change does not affect how the

Change Original Content (Rev 12)

Revised Content (Rev 13) 34 NOTE 2: The OSC first backup facility is the

3. Select a backup OSC location based on office on the north end of the Turbine the following guidance:

Building (140' elevation) and the second is the Administration Building Room 215.

ERF First Second Function Backup Backup osc 140' Administration Command Turbine Building Center Building Room 215 Northeast Corner osc 140' Canyon Rm Maintenance Turbine or Craft Building Training Bldg.

Assembly Northeast 109 Area Corner CR/OSC OPS 119' Work Nuclear Ready Control Operator Room Center or Assembly Canyon Rm Area N/A - Added new content.

a. Other essential personnel appropriate to the event (in addition to Min Staff) should be considered Min Staff with respect to where they are directed to go.

35 1.b. Declare the OSC evacuation and

4. Update OSC personnel on the decision to Page 15 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Relocated and modified content.

Relocated the direction for selecting backup ERF locations from the note to the instruction section.

The locations were formatted into a table to improve use.

Added in the new substep a. to provide direction to the ERO on how to handle responders other than min staff that have been deemed essential for the events in progress.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Revised the step for improved readability.

Change Original Content (Rev 12)

Revised Content (Rev 13) relocation to the OSC staff.

evacuate and relocate the OSC.

36 1.c. Consider taking the survey instruments

5. Direct OSC personnel to determine which and supplies from the OSC - 140' Buttress materials and equipment to take such as:

Area.

Position binders Hard copy drawings Other procedure binders RP supplies (survey instruments, Kl, TLDs, PEDs, PCs, respiratory protection, etc.)

Laptops/cell phones/satellite phones/radios 37 1.b. Post the abandoned facility entrances

6. Direct OSC personnel to post facility with signs indicating the uninhabitable status entrances with signs indicating the and facility relocation.

uninhabitable status and facility relocation.

38 1.b. Notify the Control Room and, if available,

7. Notify the following facilities of the decision the SEC. Request the CR or TSC to make a to evacuate and relocate the OSC:

PA announcement of the OSC relocation.

Control Room (using any available method)

TSC (if activated, usinq any available Page 16 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change The intent of the step remains the same.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Modified step for the ERO to consider taking supplies with them in the event they have to leave their primary facility.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Reworded step to improve readability and to make the step directed.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Reworded step to improve readability. Added in guidance on options for methods the ERO may use to perform the notifications.

Added in the EOF notification.

Change Original Content (Rev 12)

Revised Content (Rev 13) method)

EOF (if activated, using any available method)

a. Request the CR or TSC to make a PA announcement to notify the site about the OSC relocation.

39 1.c. Direct at least the minimum OSC staffing

8. Direct OSC personnel to relocate to per EP EF-2 to the 140' Turbine Building selected backup location (northeast corner), the Administration Building Room 215 or other appropriate facility.

1.d. Direct any extra OSC staffing to the Administration Building Room 215, Training Buildinq or other appropriate facility_

40 1.e. When the backup OSC facility is

9. Notify the following facilities when the operational, notify the Control Room and, if backup OSC facility is operational:

activated, the TSC.

Control Room (using any available method)

TSC (if activated, using any available method)

EOF (if activated, using any available method)

a. Request the CR or TSC to make a PA announcement to notify the site about the backup OSC being operational.

Page 17 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Separated the direction to have the CR or TSC make a plant PA into its own step.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Combined two steps into one to remove unnecessary content.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Reworded step to improve readability. Added in guidance on options for methods the ERO may use to perform the notifications.

Added in the EOF notification as the EOF should have a general awareness of ERFs that are being relocated.

Added in a new step to have the CR or TSC make a plant PA into its own step.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Change Original Content (Rev 12)

Revised Content (Rev 13) 41 Completed By: OSC Director Completed By:

42 NOTE 1: Use this attachment in conjunction NOTE 1: Use this attachment in conjunction with EP EF-2.

with EP EF-2.

NIA-Added new content.

NOTE 2: Steps in this checklist may be performed in an order other than listed or they may be omitted if not applicable.

NOTE 2: The 85' Access Control first backup NOTE 3: Circumstances may dictate using facility is the 140' Access Control and the different facilities besides those listed in this second is the TSC Lab. Circumstances may procedure.

dictate using these out of order, or using a different facility. In such a case, use the following instructions as much as possible.

43 1.a. If time permits, obtain SEC or SM

1. Obtain SEC authorization to relocate consent for Access Control relocation.

Access Control (if time permits).

a. Date:
b. Time:
c. SEC Name:

Page 18 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Modified content.

Removed the OSC Director title from the completed by signature line.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified and added content.

Added in a new Note 2 to align EP EF-9 with other EPIPs.

Note 3 was reworded based on the content of the old Note 2. The intent remains the same.

The specific backup facility locations were

.- removed from the note.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Revised the step based on other changes made in EP EF-9. The conditional action to obtain SM consent was removed.

Added in substeps a - c to document the date, time, and SEC name to ensure the SEC is involved in the decision to relocate Access Control.

Change Original Content (Rev 12)

Revised Content (Rev 13) 44 6.3 However, in cases of rapidly escalating or

2. lE events in progress are rapidly escalating highly dangerous or potentially dangerous or pose an imminent risk to personnel, conditions, the lead supervisor in each facility THEN evacuation of Access Control may be may order evacuation prior to receiving done prior to receiving SEC authorization.

SEC/ED authorization.

45 NOTE 2: The 85' Access Control first backup

3. Select a backup Access Control location facility is the 140' Access Control and the based on the following guidance:

second is the TSC Lab.

ERF Function First Second Backup Backup C&RP 140' TSC Lab Technician Access Assembly Area Control 46 1.b. Declare the Access Control evacuation

4. Update Access Control personnel on the and relocation to the Access Control staff.

decision to evacuate and relocate Access Page 19 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-0O1 Description of Change This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Relocated and modified content.

Relocated content from Section 6 into the attachment to ensure the guidance is consistently used.

Reworded step to improve readability and make it action oriented.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Relocated and modified content.

Relocated the direction for selecting backup ERF locations from the note to the instruction section.

The locations were formatted into a table to improve use.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Revised the step for improved readability.

The intent of the step remains the same.

Change Original Content (Rev 12)

Revised Content (Rev 13)

Control.

47 N/A-Added new content

5. Direct Access Control personnel to determine which materials and equipment to take such as:

Procedures Hard copy drawings RP supplies (survey instruments, Kl, TLDs, PEDs, PCs, respiratory protection, etc.)

Laptops/cell phones/satellite phones/radios 48 1.b. Post the abandoned facility entrances

6. Direct Access Control personnel to post with signs indicating the uninhabitable status facility entrances with signs indicating the and facility relocation.

uninhabitable status and facility relocation.

49 1.b. Notify the Control Room and, if available,

7. Notify the following facilities of the decision the SEC. Request the CR or TSC to make a to evacuate and relocate Access Control:

PA announcement of the Access Control Control Room relocation.

TSC (if activated)

OSC (if activated)

EOF (if activated)

Page 20 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Added new content.

Added step for the ERO to consider taking supplies with them in the event they have to leave their primary facility.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Reworded step to improve readability and to make the step directed.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Reworded step to improve readability.

Reformatted step to break out the facilities that need to be notified.

Added in the OSC and the EOF to the list of facilities to be notified.

Change Original Content (Rev 12)

Revised Content (Rev 13)

a. Request the CR or TSC to make a PA announcement to notify the site about Access Control being relocated.

50 1.c. Direct at least the minimum Access

8. Direct Access Control personnel to Control staffing to the 140' Access Control, relocate to selected backup location.

the TSC Lab, or other appropriate facility.

51 1.d. When the backup Access Control is

9. Notify the following facilities when the operational, notify the Control Room and, if backup Access Control facility is operational:

activated, the TSC and OSC.

Control Room TSC (if activated)

OSC (if activated)

EOF (if activated)

a. Request the CR or TSC to make a PA announcement to notify the site about the backup Access Control being operational.

52 Page 21 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Separated the direction to have the CR or TSC make a plant PA into its own step.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Reworded step to improve readability.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Reworded and reformatted step to improve readability.

Added in the EOF as a facility to be notified when the backup access control is operational.

Added in a new step to have the CR or TSC make a plant PA into its own step.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Change Original Content (Rev 12)

Revised Content (Rev 13)

Completed By: Site RP Coordinator Completed By:

53 NOTE 1: Use this attachment may be used in NOTE 1: Use this attachment in conjunction conjunction with CP M-15A.

with CP M-15A.

N/A-Added new content.

NOTE 2: Steps in this checklist may be performed in an order other than listed or they may be omitted if not applicable.

NOTE 2: Circumstances may dictate NOTE 3: Circumstances may dictate establishing Virtual ERF in a parking lot or in establishing the VERF in a parking lot or in a a location other than those specified in this location besides those listed in this procedure.

procedure.

The equipment will support efforts to 1)

NOTE 4: The equipment will support efforts communicate with the Control Room, EOF to 1) communicate with the Control Room, and Security; 2) notify offsite response EOF and Security; 2) notify offsite response organizations; 3) assist engineering to begin organizations; and 3) assist engineering to planning mitigative actions.

begin planning mitigative actions.

54 1.a. Obtain the VERF Equipment box from

1. Obtain the VERF Equipment box from the the storage room.

storage room (critique room off the main floor of the simulator in building 109).

Page 22 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Removed the Site RP Coordinator title from the completed by signature line.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified and added content.

Revised Note 1 to remove "may be used" as it was unnecessary.

Added in a new Note 2 to align EP EF-9 with other EPIPs that allow the ERO to use the checklists in any order necessary during an emergency.

The old Note 2 was split into two notes (3 and 4) and was revised to improve readability.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Added in more details about the VERF storage location to improve ERO understanding.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional

Change Original Content (Rev 12)

Revised Content (Rev 13) 55 1.b. Setup the computer equipment as

2. Setup the computer equipment as needed.

needed.

56 1.c. Activate the communications equipment

3. Activate the communications equipment as as needed.

needed.

57 1.d. Assess the capabilities of the VERF.

4. Assess the capabilities of the VERF.

58 1.e. Notify the emergency response facilities

5. Notify the emergency response facilities of of the capabilities and the location the VERF the capabilities and the location the VERF is Page 23 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change evaluation required.

Modified content.

Numbering change only. No change in content.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Numbering change only. No change in content.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Numbering change only. No change in content.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Added in "using any available method" as the VERF mav be located in a parkinq lot or

Change Original Content (Rev 12)

Revised Content (Rev 13) is established.

established using any available method.

59 NOTE 1: Use this attachment in conjunction NOTE 1: Use this attachment in conjunction with EP EF-3.

with EP EF-3.

NIA-Added new content.

NOTE 2: Steps in this checklist may be performed in an order other than listed or they may be omitted if not applicable.

NOTE 2: The EOF backup facility is the NOTE 3: Circumstances may dictate using Energy Education Center for the minimum different facilities besides those listed in this staff personnel and other appropriate procedure.

facilities for the EOF support staff.

Circumstances may dictate using different facilities. In such a case, use the following instructions as much as possible.

NIA-Added new content.

NOTE 4: This checklist may be performed by anyone in the EOF as directed by the ED.

60 1.a. Inform SEC and Shift Manager of need

1. Obtain ED authorization to relocate the to implement EOF relocation.

EOF.

a. Date:
b. Time:
c. ED Name:

Page 24 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change some other outdoor location that does not have a landline phone available.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified and added content.

Added in a new Note 2 to align EP EF-9 with other EPIPs that allow the ERO to use the checklists in any order necessary during an emergency.

Note 3 was reworded based on the content of the old Note 2. The intent remains the same.

The specific backup facility locations were removed from the note.

Added a new Note 4 to make it clear that anyone may perform the actions required in the checklist as delegated by the ED.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Revised the step based on other changes made in EP EF-9 that allow anyone to perform this attachment. The revised step continues to require obtaining ED authorization to relocate Access Control.

The action to inform the SEC and SM were relocated to subsequent steps.

Change Original Content (Rev 12)

Revised Content (Rev 13) 61 6.3 However, in cases of rapidly escalating or

2. lE events in progress are rapidly escalating highly dangerous or potentially dangerous or pose an imminent risk to EOF personnel, conditions, the lead supervisor in each facility THEN EOF evacuation may be done prior to may order evacuation prior to receiving receiving ED authorization.

SEC/ED authorization.

62 NOTE 2: The EOF backup facility is the

3. Select a backup EOF location based on Energy Education Center for the minimum the following guidance:

staff personnel and other appropriate facilities for the EOF support staff.

ERF First Backup Second Function Backup EOF Energy PG&E SLO Education Service Center Center Ontario Road South Higuera Page 25 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Added in substeps a - c to document the date, time, and ED name to ensure the ED is involved in the decision to relocate the EOF.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Relocated and modified content.

Relocated content from Section 6 into the attachment to ensure the guidance is consistently used.

Reworded step to improve readability and make it action oriented.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Relocated and modified content.

Relocated the direction for selecting backup ERF locations from the note to the instruction section.

The locations were formatted into a table to improve use.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Change Original Content (Rev 12)

Revised Content (Rev 13) 63 1.b. Announce the EOF evacuation and

4. Update EOF personnel on the decision to relocation to the EOF staff using the facility evacuate and relocate the EOF.

PA.

64 1.d. Consider taking the FMT Kits from the

5. Direct EOF personnel to determine which EOF.

materials and equipment to take such as:

Position binders Hard copy drawings EAL wall charts Other procedure binders RP supplies (survey instruments, Kl, TLDs, PEDs, PCs, respiratory protection, etc.)

Laptops/cell phones/satellite phones/radios FMT Kits 65 1.b. Post the abandoned facility entrances

6. Direct EOF personnel to post facility with signs indicating the uninhabitable status entrances with signs indicating the and facility relocation.

uninhabitable status and facility relocation.

Page 26 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Modified content.

Revised the step for improved readability.

The intent of the step remains the same.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Modified step for the ERO to consider taking supplies with them in the event they have to leave their primary facility.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Reworded step to improve readability and to make the step directed.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Change Original Content (Rev 12)

Revised Content (Rev 13) 66 1.b. Announce the EOF evacuation and

7. Notify the following facilities of the decision relocation to the EOF staff using the facility to evacuate and relocate the EOF:

PA Notify the Control Room and the TSC.

Control Room (using any available method)

TSC (if activated, using any available method)

OSC (if activated, using any available method) 67 1.c. Direct the minimum EOF staffing per EP

8. Direct EOF personnel to relocate to EF-3 to the Energy Education Center, or selected backup location.

other appropriate facility, plus other essential personnel appropriate to the event response.

1.d. Direct EOF support staff to relocate to other appropriate facilities.

68 1.e. When the backup EOF facility is

9. Notify the following facilities when the operational, notify the Control Room and, as backup EOF facility is operational:

appropriate, the TSC. Direct notification of Control Room (using any available the County, State and NRC of the backup method) facility location.

TSC (if activated, using any available method)

OSC (if activated, using any available method)

10. Direct notification of all of the following per guidance in EP G-3:

Page 27 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Modified content.

Reworded step to improve readability.

Reformatted step to break out the facilities and personnel that need to be notified.

Added in the OSC to the list of facilities to be notified if the EOF is relocated.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Combined two steps into one to remove unnecessary content.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content.

Reworded and reformatted step to improve readability.

Added in the OSC to the list of facilities to be notified when the backup EOF is operational.

Separated the NRC notification into its own step.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-

Change Original Content (Rev 12)

Revised Content (Rev 13)

a. County (using any available method)
b. State (using any available method)
c. NRC (using any available method) 69 Completed By: Emergency Director Completed By:

Page 28 of 28 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change specific commitments. No additional evaluation required.

Modified content.

Removed the Emergency Director title from the completed by signature line.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Summary of the Analysis of Changes to PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Emergency Plan Implementing Procedure EP RB-17, Revision 2 "Operating Instructions for QuickDose"

Change Original Content (Rev 1)

Revised Content (Rev 2) 1 6.1 6.1 Performing Dose Assessment using Performing Manual Dose Assessment QuickDose Calculations using QuickDose T36219fT36221 fT36230fT04396 2

6.1.4 - Table 6.1.4 - Table Other Release Paths Other Release Paths LOCA ----+ H2 Purge line----+ PV (done per LOCA ----+ H2 Purge line ----+ PV (done per SAMG SCG-02)

SAMG SAG 07 or SAG 08) 3 6.2.6 6.2.6 Path 4, 6, 7, or 11 - Select "Aux Building Path 4, 6, 7, or 11 - Select "Aux Building Filtration" if either:

Filtration" if any of the following:

VCT or LHUT tank rupture (HEPA VCT or LHUT tank rupture (HEPA filtration is always aligned) filtration is always aligned)

Auxiliary building ventilation is in iodine Auxiliary building ventilation is in iodine removal mode as verified by Control removal mode as verified by Control Room Room H2 purge line vent per SAMG SAG 07 or SAG 08 Page 1 of 2 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Modified content Added in missing Procedure Commitment Database (PDC) numbers.

Added in the word "manual" and the word "calculations" to align the step with the newly added in PCD numbers.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content Editorial change to update the procedure titles of the SAMGs that could result in venting containment through the H2 purge line.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Added content Added in the third bullet to align this section of the procedure with existing guidance from Section 6.6.3f.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Change Original Content (Rev 1)

Revised Content (Rev 2) 4 6.6.3f.

6.6.3f.

Select FILTERED for H2 purge line vent per Select FILTERED for H2 purge line vent per SAMG SCG-2 only SAMG SAG 07 or SAG 08 5, Step 3, 3rd bullet, Step 3, 3rd bullet Make predictions at the time of the accident Make predictions at the time of the accident to provide a quick upper limit dose (TEDE to provide a quick upper limit dose (TEDE and Thyroid CDE) result, but should only be and Thyroid CDE) result, but should only be used if a more accurate method is used if a more accurate method is unavailable, or until a more accurate means unavailable, or until a more accurate means of determining dose is used.

of determining dose is used.T36219 Page 2 of 2 PG&E Letter DCL-19-002 PG&E Letter DIL-19-001 Description of Change Modified content Editorial change to update the procedure titles of the SAMGs that could result in venting containment through the H2 purge line.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Modified content Added in PCD numbers.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

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