DCL-22-077, Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update

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Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update
ML22272A280
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 09/28/2022
From: Warwick A
Pacific Gas & Electric Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
DCL-22-077, DIL-22-011
Download: ML22272A280 (29)
v • d • e


Text

Pacific Gas and Electric Company"'

Andrew M. Warwick Diablo Canyon Power Plant Manager P.O. Box 56 Nuclear Emergency Planning Avila Beach, CA 93424 805 .545.3865 Andre w.Warwick@pge.com PG&E Letter DCL-22-077 PG&E Letter DIL-22-01 1 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 Update

Dear Commissioners and Staff:

In accordance with the requirements of 10 CFR 50.54(q)(5) and 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 listed in the below enclosures:

  • Enclosure 1 - Diablo Canyon Power Plant Emergency Plan Implementing Procedures, Revision Numbers for Emergency Plan Implementing Procedures.
  • Enclosure 2 - Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-2, Revision 44, "Activation and Operation of the Operational Support Center."
  • Enclosure 3 - Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-3, Revision 50, "Activation and Operation of the Emergency Operations Facility."

PG&E evaluated the changes per the requirements of 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 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."

A member of the STARS Allian c e Callaway

  • Diablo Canyon
  • Pa lo Ve rde
  • Wolf Cr ee k

Document Control Desk PG&E Letter DCL-22-077 Page 2 PG&E Letter DIL-22-011 PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.

IUhere are questions regarding this update, please contact me at (805) 305-5313.

Sincerely, Andrew M. Warwick Date Manager, Emergency Planning armb/51163755 & 51163756 Enclosures cc/enc: William C. Allen, NMSS Project Manager Mahdi 0. Hayes, NRC Senior Resident Inspector Sean D. Hedger, Senior Emergency Preparedness Inspector (RGN-IV/DR)

Samson S. Lee, NRC Project Manager Scott A. Morris, NRC Region IV Administrator A member of the STARS Allian ce Callaway

  • Diablo Canyon
  • Palo Verde
  • Wolf Creek

Enclosure 1 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Revision Numbers for Emergency Plan Implementing Procedures

Enclosure 1 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Proc. No. Rev. Title OM10.ID1 19 Maintaining Emergency Preparedness OM10.DC1 11 Emergency Preparedness Drills and Exercises EP G-1 46 Emergency Classification and Emergency Plan Activation EP G-2 55 Interim Emergency Response Organization EP G-3 63 Emergency Notification of Off-Site Agencies EP G-4 31 Assembly and Accountability EP G-5 16 Evacuation of Non-Essential Site Personnel EP OR-3 10 Emergency Recovery EP RB-1 8 Personnel Dosimetry EP RB-2 9 Emergency Exposure Guides EP RB-3 10 Stable Iodine Thyroid Blocking EP RB-4 6 Access to and Establishment of Controlled Areas Under Emergency Conditions EP RB-5 9 Alternate Personnel Decontamination Facilities EP RB-8 30 Instructions for Field Monitoring Teams EP RB-10 21 Protective Action Recommendations EP RB-12 12 Plant Vent Iodine and Particulate Sampling During Accident Conditions EP RB-14 12 Core Damage Assessment Procedure EP RB-14A 3 Initial Detection of Fuel Cladding Damage EP RB-15 16 Post Accident Sampling System EP RB-16 18 Operating Instructions for the EARS Computer Program EP RB-17 2 Operating Instructions for QuickDose EP R-2 38 Release of Airborne Radioactive Materials Initial Assessment EP R-3 9 Release of Radioactive Liquids EP R-7 19 Off-Site Transportation Accidents EP EF-1 60 Activation and Operation of the Technical Support Center EP EF-2 44* Activation and Operation of the Operational Support Center EP EF-3 50* Activation and Operation of the Emergency Operations Facility EP EF-4 23 Activation of the Off-Site Emergency Laboratory EP EF-9 13 Backup Emergency Response Facilities EP EF-10 19 Activation and Operation of the Joint Information Center EP EF-11 4 Alternate Emergency Response Facilities / Incident Command Post (ICP)

  • Revised Document Page 1 of 1

Enclosure 2 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-2, Revision 44 Activation and Operation of the Operational Support Center

Enclosure 2 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Change Previous Content (Rev 43) New Content (Rev 44) Description of Change Number

1. Attachment 2, step 1.e.1) b. Attachment 2, step 1.e.1) a. Added suggested location to stage maintenance teams if the default location is IF building 102 (I&C Shop Bldg.) is a safe (1) IF building 102 (I&C Shop Bldg.) is a safe not safe.

location to stage personnel, location to stage personnel, THEN consider staging mechanical THEN consider staging mechanical This change does not affect how the maintenance craft personnel in maintenance craft personnel in conference current Emergency Plan (E-Plan) meets conference room 102-2-203 (x4420). room 102-2-203 (x4420). any planning standard functions, elements, or site-specific commitments.

(2) IF building 102 is not a safe location, No additional evaluation required.

THEN consider using the Ops work control center on the 119 elevation of the turbine building, or other suitable location based on input from the SRPC.

2. Attachment 3, step 1.d.1) b. Attachment 3, step 1.d.1) a. Added suggested location to stage maintenance teams if the default location is IF building 102 (I&C Shop Bldg.) is a safe (1) IF building 102 (I&C Shop Bldg.) is a safe not safe.

location to stage personnel, location to stage personnel, THEN consider staging electrical THEN consider staging electrical This change does not affect how the maintenance craft personnel in maintenance craft personnel in conference current E-Plan meets any planning conference room 102-2-203 (x4420). room 102-2-203 (x4420). standard functions, elements, or site-specific commitments. No additional (2) IF building 102 is not a safe location, evaluation required.

THEN consider using the Ops work control center on the 119 elevation of the turbine building, or other suitable location based on input from the SRPC.

3. Attachment 4, step 1.c.1) b. Attachment 4, step 1.c.1) a. Added suggested location to stage maintenance teams if the default location is IF building 102 (I&C Shop Bldg.) is a safe (1) IF building 102 (I&C Shop Bldg.) is a safe not safe.

location to stage personnel, location to stage personnel, THEN consider staging instrument and THEN consider staging instrument and This change does not affect how the current E-Plan meets any planning

Enclosure 2 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 control craft personnel in conference control craft personnel in conference room standard functions, elements, or site-room 102-2-203 (x4420). 102-2-203 (x4420). specific commitments. No additional evaluation required.

(2) IF building 102 is not a safe location, THEN consider using the Ops work control center on the 119 elevation of the turbine building, or other suitable location based on input from the SRPC.

4. Attachment 5, step 2 Note Attachment 5, step 2 Note Changed "guideline" to "limit" and removed last sentence of the note to make it All RCA qualified personnel are All RCA qualified personnel are consistent with other changes made in this automatically authorized to receive a dose automatically authorized to receive a dose revision specific to admin dose limits.

up to, but not exceeding, the DCPP up to, but not exceeding, the DCPP administrative guideline for calendar year administrative limit for calendar year Refer to 50.54(q) 2022-29 for evaluation of exposure of 4 rem TEDE during an Alert exposure of 4 rem TEDE during an Alert or changes to admin dose limits.

or higher emergency classification event, higher emergency classification event, EXCEPT as may be limited by lifetime EXCEPT as may be limited by lifetime and This change does not affect how the and current year occupational dose current year occupational dose already current E-Plan meets any planning already received or other restrictions such received or other restrictions such as a standard functions, elements, or site-as a declared pregnancy. This guideline is declared pregnancy. specific commitments.

derived from the DCPP administrative limit of 4.5 rem TEDE subtracting a 500 mrem margin.

5. Attachment 5, step 2.c.2)a)(1) Attachment 5, step 2.c.2)a)(1) Restructured the Diablo Canyon Power Plant (DCPP) Specific Source Term Dose Attachment 12, step 1 Attachment 12, step 1 Conversion Factors table to improve usability. Clarified that the Core, Gap, and Attachment 15, Table 2 Attachment 15, Table 2 Design Bases (DB) Radiological Control Standards (RCS) entries are for non-steam Non-SGTR Accidents generator tube rupture (SGTR) accidents.

Core Core Added the narrow range levels associated Gap Gap with each SGTR level category (normal, DB RCS DB RCS empty, and flooded).

SGTR Accidents - No Fuel Damage SGTR Normal (No Fuel Damage) 13%< NR level <96%

Enclosure 2 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 SGTR Empty (No Fuel Damage) NR level <13% (Empty) This change improves the usability of the SGTR Flooded (No Fuel Damage) NR level >96% (Flooded) Dose Conversion Factors chart. The SGTR Accidents - With Fuel Damage change does not alter, add, remove, or SGTR Normal (Fuel Damage) 13%< NR level <96% otherwise impact any process or value.

SGTR Empty (Fuel Damage) NR level <13% (Empty)

SGTR Flooded (Fuel Damage) NR level >96% (Flooded) This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

6. Attachment 5, step 2.j Attachment 5, step 2.j Modified the DCPP Emergency Plan Implementing Procedure (EPIP) EP OR-3, recovery phase per EP OR-3 recovery phase per EP OR-3 Emergency Recovery, attachment number Attachment 9.4. REFER TO Tab 10. Attachment 4. REFER TO Tab 10. to match the current format.

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

7. Attachment 5, step 3.b.1)b) Attachment 5, step 3.b.1)b) Modified the DCPP EPIP EP RB-2, Emergency Exposure Guides, attachment EP RB-2, Attachment 9.6, "Emergency EP RB-2, Attachment 6, "Emergency number to match the current format.

Exposure Guidelines" REFER TO Tab 8. Exposure Guidelines" REFER TO Tab 8.

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

8. Attachment 5, step 3.c. Attachment 5, step 3.c. Added a step to proactively move staged personnel into the Technical Support Center
1) IF the potential for airborne 1) IF the potential for airborne contamination (TSC)/Operational Support Center (OSC) contamination exists where teams are exists where teams are performing work, habitability enclosure if plant conditions have performing work, and time considerations degraded such that the likelihood of a

Enclosure 2 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 and radiological conditions permit air THEN obtain air samples as time and radiological release occurring could have sampling, radiological conditions permit. significant impacts on staging areas.

THEN obtain air samples.

NOTE: Consider the occupancy limits of the This change does not affect how the TSC/OSC enclosure (posted at the TSC current E-Plan meets any planning entry door and the OSC 104' turbine building standard functions, elements, or site-entry door) when evaluating relocation of specific commitments. No additional staged craft/teams to the TSC/OSC. evaluation required.

2) IF fuel damage has occurred on any Unit, THEN evaluate relocating all staged craft/teams to the TSC/OSC enclosure.
9. Attachment 5, Site Radiation Protection Attachment 5, Site Radiation Protection Modified the EP RB-2 attachment numbers Coordinator Position Binder Tab Index Coordinator Position Binder Tab Index to match the current format.

Tab 9: EP RB 2, Attachment 9.6, "DCPP Tab 9: EP RB 2, Attachment 6, "DCPP This change does not affect how the Emergency Exposure Guidelines" Emergency Exposure Guidelines" current E-Plan meets any planning standard functions, elements, or site-Tab 13: EP RB 2, Attachment 9.3, "OSC Tab 13: EP RB 2, Attachment 3, "OSC Site specific commitments. No additional Site Radiation Protection Coordinator Radiation Protection Coordinator Checklist" evaluation required.

Checklist"

10. Attachment 12 step 4.a. Attachment 12 step 4.a. Changed total effective dose equivalent (TEDE) and Thyroid committed dose
a. For PG&E employees without a. For PG&E employees without authorized equivalent (CDE) admin limits to match other authorized emergency limits: emergency limits: sections of EPIP EP EF-2, Activation and Operation of the Operational Support
1) TEDE limit at ALERT or higher = 4,500 1) TEDE limit at ALERT or higher = 4,000 - Center, and to align with EP RB-2.

- YTD TEDE YTD TEDE Refer to 50.54(q) 2022-29 for evaluation of

2) Thyroid CDE limit = 45,000 - YTD 2) Thyroid CDE limit = 40,000 - YTD TEDE changes to admin dose limits.

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

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-3, Revision 50 Activation and Operation of the Emergency Operations Facility"

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Change Previous Content (Rev 49) New Content (Rev 50) Description of Change Number

1. Attachment 4, Emergency Director Attachment 4, Emergency Director Checklist Added an actionable step to an already Checklist existing classification declaration process, 2.a.2) Perform an update in the EOF aligning with guidance in Diablo Canyon 2.a.2) Perform an update in the EOF command room stating: Power Plant (DCPP) Departmental command room stating: a) Time of declaration Administrative Procedure OP1.DC10, a) Time of declaration b) Classification Conduct of Operations.

b) EAL c) EAL c) Upgrade criteria d) Affected unit(s) This change clarifies and expands upon the e) Upgrade criteria procedural guidance available for what to include during a verbal update for a new classification declaration, so that all parties hearing the declaration are clear on the time of declaration, new classification, new emergency action level (EAL), affected unit(s), and upgrade criteria.

This change does not affect how the current Emergency Plan (E-Plan) meets the applicable planning standard functions, elements, or site-specific commitments. This change does not require any further evaluation.

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011

2. Attachment 4, Emergency Director Attachment 4, Emergency Director Revised emergency termination language Checklist Checklist and added a note to align with already existing emergency termination and 3.d. Emergency Termination 3.d. Terminating or Downgrading from an downgrade processes in procedures
1) WHEN plant is in stable, Emergency Classification Level (ECL) DCPP Emergency Plan Implementing shutdown, safe Procedure (EPIP) EP G-1, Emergency condition, Classification and Emergency Plan NOTE: Only the ED can THEN terminate the event per Activation, and in DCPP EPIP EP OR-3, terminate or downgrade from an EP OR-3. ALERT or higher ECL. Emergency Recovery.

REFER TO Tab 11.

1) IF plant conditions are stabilized or 50.54(q) Screening Evaluation Form improving, 2019-26, EP G-1, Revision 46 THEN assess for Terminating or Downgrading from the ECL, per the This change implements 50.54(q) following: Screening Evaluation Form 2019-26,
  • EP G-1, section 6.3. REFER TO Tab 4.

EP G-1, Revision 46. This change

  • EP OR-3. REFER TO Tab 11.

does not affect how the current E-Plan meets the applicable planning standard functions, elements, or site-specific commitments.

Attachment 5, EOF Director Checklist Attachment 5, EOF Director Checklist Added and updated language to clarify Off-Site Emergency Lab (OEL) Analyst 1.f.1)c) Check with Radiological 1.f.1)c) Check with Radiological Manager position is now a pool position held by Manager that UDAC staff has arrived that UDAC staff has arrived and are ready Chemistry and Radiation Protection and are ready to assume their to assume their assigned duties: (C&RP) Technicians as well as by qualified assigned duties:

  • Dose Assessment Coordinator Emergency Response Organization (ERO)
  • Dose Assessment Coordinator
  • HPN Communicator members, per 54(q) 2021-11, OEL
  • HPN Communicator
  • FMT Coordinator Analysts from Dedicated to Pooled
3.
  • FMT Coordinator
  • FMT Communicator position.
  • FMT Communicator
  • Management FMT Offsite (2)
  • Management FMT Offsite (2)
  • FMT Leads (2) - C&RP Technicians 50.54(q) Screening Evaluation Form 2021-
  • OEL Analyst - C&RP Technician 11, OEL Analysts from Dedicated to Technicians OR qualified ERO member Pooled position.

Attachment 6, Radiological Manager Attachment 6, Radiological Manager This change implements 50.54(q)

Checklist Checklist Screening Evaluation Form 2019-26, EP G-1 Revision 46. This change does

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 1.e. Ensure UDAC staff have arrived 1.e. Ensure UDAC staff have arrived and not affect how the current E-Plan meets and are ready to assume their are ready to assume their assigned duties: the applicable planning standard assigned duties:

  • Dose Assessor functions, elements, or site-specific
  • Dose Assessor
  • Dose Assessment Coordinator commitments.
  • Dose Assessment Coordinator
  • HPN Communicator
  • HPN Communicator
  • FMT Coordinator
  • FMT Coordinator
  • FMT Communicator
  • FMT Communicator
  • Management FMT Offsite (2)
  • Management FMT Offsite (2)
  • FMT Leads (2) - C&RP Technicians
  • OEL Analyst - C&RP Technician Technicians OR qualified ERO member , FMT Coordinator Attachment 9, FMT Coordinator Checklist Checklist 1.e. Confirm the following positions are 1.e. Confirm the following positions are staffed:

staffed: 1) Onsite Field Monitoring Team (1-

1) Onsite Field Monitoring Team (1- C&RP technician and 1-MGMT FMT C&RP technician and 1-MGMT Onsite, dispatched from the OSC)

FMT Onsite, dispatched from the 2) Four (4) Offsite PG&E FMT OSC) members (2-C&RP technicians and 2-

2) Four (4) Offsite PG&E FMT MGMT FMTs Offsite) members (2-C&RP technicians and 3) County FMT members 2-MGMT FMTs Offsite) 4) FMT Communicator
3) County FMT members 5) OEL Analyst - C&RP Technician OR
4) FMT Communicator qualified ERO member
5) OEL Analyst

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Attachment 14, Communications Attachment 14, Communications This change aligns DCPP EPIP EP EF-3 ,

Coordinator Coordinator Activation and Operation of the Emergency Operations Facility, with the process Attachment 15, Offsite Communicator Attachment 15, Offsite Communicator already in DCPP EPIP EP G-3, Emergency Notification of Off-Site Agencies, that if the 2.b.3) IF County EOC is activated, 2.b.3) IF County EOC is activated, County Emergency Operations Center THEN: THEN: (EOC) is activated, and the Emergency a) Make 5 copies of approved ENF. a) Make 5 copies of the approved ENF. Operations Facility (EOF) has the b) Deliver 5 copies to Advisor to the b) Deliver 5 copies to the County notification function, the EOF County. Emergency Services Director (ESD). communicators provide the approved c) Brief Advisor to the County on ENF c) Perform County notifications to the Emergency Notification Form (ENF) to and

4. specifics. County ESD, per EP G-3. make notifications to the County ESD.

d) Write time Advisor to the County d) Ensure UDAC Coordinator is starts verbal notification to the provided a copy of approved ENF. This change aligns EOF communicator County ESD on ENF original. directives with 50.54(q) 2022-30, EP G-3 e) Ensure UDAC Coordinator is Revision 63.

provided a copy of approved ENF.

This change implements 50.54(q)

Screening Evaluation Form 2022-30, EP G-3, Revision 63. This change does not affect how the current E-Plan meets the applicable planning standard functions, elements, or site-specific commitments.

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Attachment 16, Advisor to the County Attachment 16, Advisor to the County Added EP G-3 as a reference for the already existing process of the Advisor to the County 1.e. Obtain contact numbers as required 1.e. Obtain contact numbers as required assisting the County EOC in interpretation of using Nuclear Emergency Response using Nuclear Emergency Response technical information, including event Communications (NERC) Directory. REFER Communications (NERC) Directory. REFER information/changes included in DCPP TO Tab 6. TO Tab 7. ENFs.

Attachment 16, Advisor to the County Attachment 16, Advisor to the County Added link to ENF software program website 1.f. Contact Sheriff Watch Commander to 1.f. Contact Sheriff Watch Commander to for faster access to approved ENFs.

obtain copies of Emergency Notification obtain copies of Emergency Notification Forms (ENFs). Forms (ENFs). This change does not affect how the

1) Approved ENFs may be obtained by 1) Approved ENFs may be obtained from current E-Plan meets the applicable clicking the "View/Edit Archived http://wwwnpg/epnf, "View/Edit Archived planning standard functions, elements, or Notification Form Events" link in the ENF Notification Form Events" function in the site-specific commitments. This change software program. ENF software program. does not require any further evaluation.

Attachment 16, Advisor to the County Attachment 16, Advisor to the County 5.

2.b.1) Coordinate with EOF Director, 2.b.1) Coordinate with EOF Director, Radiological Manager, and Communications Radiological Manager, and Communications Coordinator for advising county on following: Coordinator for advising county on following:

a) Emergency Classification Levels a) Emergency Notification Forms (ENFs)

(ECLs). REFER TO Tab 3. and Follow-Up Emergency Notification b) Protective Action Recommendations Forms (Follow-Up ENFs). REFER TO (PARs). REFER TO Tab 4. Tab 4.

c) Plant information (use source of b) Emergency Classification Levels information job aid). REFER TO Tab 5. (ECLs). REFER TO Tab 3.

d) Radiological release status. c) Protective Action Recommendations e) DCPP emergency response activities (PARs). REFER TO Tab 5.

(early work release or site evacuation). d) Plant information (use source of information job aid). REFER TO Tab 6.

e) Radiological release status.

f) DCPP emergency response activities (early work release or site evacuation).

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 6, Advisor to the County Attachment 16, Advisor to the County Advisor to the County Position Tab Index Advisor to the County Position Tab Index Tab Contents Number* Tab Contents Number*

No. No.

    • EP EF-3, Form 69-20892, 2 ** EP EF-3, Form 69-20892, 2 "Advisor to the County Checklist" "Advisor to the County Checklist" 1 Emergency Log Sheets 20 1 Emergency Log Sheets 20 2 EP EF-1, Form 69-20437, 5 2 EP EF-1, Form 69-20437, 5 "Command and Control Turnover "Command and Control Turnover Checklist" Checklist" 3 EP G-1, "Emergency 1 3 EP G-1, "Emergency 1 Classification and Emergency Classification and Emergency Plan Activation" Plan Activation" 4 EP RB-10, "Protective Action 1 4 EP G-3, "Emergency Notification 1 Recommendations" of Off-Site Agencies" 5 Advisor to the County Source of *** 5 EP RB-10, "Protective Action 1 Information Job Aid Recommendations" 6 Nuclear Emergency Response 1 6 Advisor to the County Source of ***

Communications (NERC) Information Job Aid Directory 7 Nuclear Emergency Response 1 Communications (NERC)

Directory

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Attachment 17, Gov Rel Coordinator Attachment 17, Gov Rel Coordinator Clarifies the directive in Initial Actions to Checklist Checklist notify ANI and NEI of event and to coordinate with the Engineering Liaison(s) to 1.i. Provide initial notification to 1.i. Provide initial notification to prevent duplication of the task.

non-company organizations as follows: non-company organizations as follows:

1) Notify American Nuclear Insurers 1) Coordinate with the Engineering Added actionable steps to the existing (ANI) of declared event. Liaison(s) to notify the following of the process of the Gov Rel continuing to update
2) Notify Nuclear Energy Institute declared event: NEI and WebEOC INPO boards throughout (NEI) of the declared event.
  • American Nuclear Insurers (ANI) the event.
3) If required, update and maintain the
  • Nuclear Energy Institute (NEI) following WebEOC boards, to notify 2) If required, update and maintain the This change does not affect how the Institute of Nuclear Power Operations following WebEOC boards, to notify current E-Plan meets the applicable (INPO) of the declared event: Institute of Nuclear Power Operations planning standard functions, elements, or a) DCPP Significant Events (INPO) of the declared event: site-specific commitments. This change b) DCPP Plant Status to INPO a) DCPP Significant Events does not require any further evaluation.

b) DCPP Plant Status to INPO 6.

Attachment 17, Gov Rel Coordinator Attachment 17, Gov Rel Coordinator Checklist Checklist 2.c. Update ANI when new major events 2.c. Update non-company organizations occur such as upgrade in classification, when new major events occur, such as radiological releases, PARs, or follow-up upgrade in classification, radiological information such as termination of the releases, PARs, or follow up information, event. such as termination of the event:

1) Coordinate with the Engineering Liaison(s) to update the following:
  • American Nuclear Insurers (ANI)
  • Nuclear Energy Institute (NEI)
2) If required, update INPO by updating the following WebEOC boards:

a) DCPP Significant Events b) DCPP Plant Status to INPO Attachment 5, EOF Director Checklist Attachment 5, EOF Director Checklist 7.

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 1.g. Assign individuals to maintain facility 1.g. Assign individuals to maintain facility Clarified that WebEOC is considered a status boards (e.g., Electrical Bus Loads, status boards (e.g., WebEOC, Electrical Bus status board to be maintained and updated Sequence of Events, ENF Tracking, Loads Board, EOF Status Board, Notification the titles of the EOF facility status boards.

Unit 1 and 2 Plant Status). Board, and Meteorology Board).

This change does not affect how the current E-Plan meets the applicable Attachment 21, ED Admin Assistant Attachment 21, ED Admin Assistant planning standard functions, elements, or Checklist Checklist site-specific commitments. This change does not require any further evaluation.

1.e. Ensure the EOF Director has assigned 1.e. Ensure the EOF Director has assigned individuals to maintain status boards. individuals to maintain status boards (including WebEOC).

Attachment 17, Gov Rel Checklist Attachment 17, Gov Rel Checklist Moved the directive to request that the GOTL report to the PG&E company EOC 1.j. Make contact with General Office 1.j. Maintain contact with GOTL to ensure from the Government Relations Coordinator Technical Liaison (GOTL) and request they are kept informed of event status. Checklist to the Emergency Director that they report to PG&E General Office Checklist, based on an existing process.

and act as a liaison to company EOC.

1) Maintain contact with GOTL to Per the E-Plan Sections 5.8 and 5.8.1, the ensure that they are kept informed of GOTL coordinates with the Gov Rel event status. Coordinator to ensure alignment between DCPP and corporate response, but the ED 8.

is responsible for ensuring the coordination Attachment 4, ED Checklist Attachment 4, ED Checklist of DCPP emergency actions with those of General Office support through the PG&E New addition 1.k. Contact the General Office Technical Liaison EOC.

(GOTL) and direct them to report to the PG&E General Office and act as a liaison to the This change does not affect how the company EOC, if necessary. current E-Plan meets the applicable planning standard functions, elements, or site-specific commitments. This change does not require any further evaluation.

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Attachment 1, RMS Power Sources Attachment 1, RMS Power Sources Removed repetitive entries for radiation monitors which have a Radiation Display See Appendix A of this change summary See Appendix A of this change summary Unit (RDU) in the Control Room that is table. table. powered by a non-vital bus with a battery backup and replaced them with an asterisk and associated note stating the same information. Removed the Bus I column as it is no longer needed.

Removed RDU entries for RM-44A and RM-44B and did not include the asterisk as the instruments and RDUs are powered by the same bus so having the information that the RDUs have a battery backup is not actionable.

These changes were made based on operating experience during drills and 9.

exercises where dose assessors misread the Radiation Monitoring System (RMS)

Power Sources chart believing that instruments that were on deenergized buses were available due to the "Battery Backup" entry for the associated RDU.

The information of which specific bus and whether the instrument's RDU has a battery backup is generally not useful to the dose assessors as they do not rely upon the control room indications but rather peripheral information systems like RMDDT and Emergency Assessment and Response System (EARS). If the control room displays were required due to a loss of those peripheral information systems, the lack of power to the displays or lack of power to the

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 instruments themselves would be self-evident.

This change does not affect how the current E-Plan meets the applicable planning standard functions, elements, or site-specific commitments. This change does not require any further evaluation.

N/A, new content Attachment 2, Note 2 Added a new note providing detailed explanation of the GE/GW exhaust fans, The GE/GW penetration area on each unit E-160 and E-161, how they are powered, has dedicated exhaust fans E-160 and E- and their expected condition.

161. Under normal conditions, one of these fans in always in service. The Control Room Changed to the path 5 vs path 9 does not have remote indication of the status determination for a steam release to the of E-160 and E-161. E-160 is energized by GE/GW area from "GE/GW exhaust fans non-vital 480V bus E and E-161 is energized (E-160 or E-161) running?" to "E-160&161 by non-vital 480V bus D. If both non-vital OR non-vital 480V buses deenergized buses on the affected Unit are energized (Note 2)" and swapped the Yes and No and the GE/GW exhaust fans are not known directions. Based on operating experience to have been removed from service, then it during drills and exercises, dose assessors can be assumed that one of the fans is were challenged when trying to determine

10. running. the status of E-160 and E-161 due to unfamiliarity with the system and lack of Attachment 2, Leak Path Flowchart Attachment 2, Leak Path Flowchart control room indications. The revised decision block and associated note provide See Appendix B of this change summary See Appendix B of this change summary more decision-making detail to enable dose table. table. assessors to be more successful when determining if the plant vent or main steam line radiation monitors are more appropriate for a given situation.

This change does not affect how the current E-Plan meets the applicable planning standard functions, elements, or site-specific commitments. This change does not require any further evaluation.

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Attachment 6, step 3.b. and preceding note Attachment 6, step 3.b. and preceding note Updated the values for administrative dose guidelines during a declared emergency to NOTE: All site radiologically controlled area NOTE: All site radiologically controlled area align with current DCPP administrative limits.

(RCA) qualified personal are automatically (RCA) qualified personal are automatically This change aligns EP EF-3 with other authorized to receive a dose up to, but not authorized to receive a dose up to, but not EPIPs such as DCPP EPIP EP RB-2, exceeding, the DCPP administrative limits exceeding, the DCPP administrative limits Emergency Exposure Guidelines.

for calendar year exposure (4.5 Rem TEDE) for calendar year exposure (4 rem TEDE) during an ALERT or higher emergency during an ALERT or higher emergency 50.54(q) Effectiveness Evaluation Form classification event, except as may be classification event, except as may be 2022-29, Admin Dose Limit Change limited by lifetime and current year limited by lifetime and current year occupational dose already received or other occupational dose already received or other This change implements 50.54(q) restrictions such as a declared pregnancy. restrictions such as a declared pregnancy. Effectiveness Evaluation Form 2022-29, Admin Dose Limit Change. This change

b. Emergency Exposure Controls b. Emergency Exposure Controls does not affect how the current E-Plan meets the applicable planning standard
1) Ensure proper exposure controls are 1) Ensure proper exposure controls are functions, elements, or site-specific taken for DCPP offsite personnel. taken for DCPP offsite personnel. commitments.
11. 2) IF offsite PG&E emergency workers 2) IF offsite PG&E emergency workers (including onsite and offsite FMTs) are (including onsite and offsite FMTs) are expected to exceed 4.5 REM TEDE annual expected to exceed 4 rem TEDE annual exposure administrative limit, exposure administrative limit, THEN obtain ED authorization per EP RB-2. THEN obtain ED authorization per EP RB-2.

REFER TO Tab 3. REFER TO Tab 3.

3) Ensure personnel who receive more than 3) Ensure personnel who receive more than 5 times any normal occupational limit are 5 times any normal occupational limit are promptly transported to offsite medical promptly transported to offsite medical facilities for evaluation and treatment. facilities for evaluation and treatment.

Attachment 23, Part 1,

  • note Attachment 23, Part 1,
  • note All RCA qualified personnel are All RCA qualified personnel are automatically authorized to receive a dose automatically authorized to receive a dose up to, but not exceeding, the DCPP up to, but not exceeding, the DCPP Administrative Limits for calendar year Administrative Limits for calendar year exposure (4.5 rem TEDE) during an ALERT exposure (4 rem TEDE) during an ALERT or

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 or higher emergency classification event, higher emergency classification event, except as may be limited by lifetime and except as may be limited by lifetime and current year occupational dose already current year occupational dose already received, or other restrictions such as a received, or other restrictions such as a declared pregnancy (EP RB-2). declared pregnancy (EP RB-2).

Attachment 29, step 3, PG&E employees Attachment 29, step 3, PG&E employees without authorized emergency limits without authorized emergency limits TEDE Limit: At ALERT or higher = 4500 - TEDE Limit: At ALERT or higher = 4000 -

YTD TEDE YTD TEDE Thyroid CEDE Limit: 45,000 - YTD TEDE Thyroid CEDE Limit: 40,000 - YTD TEDE Attachment 7, Step 2.g.5) Attachment 7, Step 2.g.5) Restructured the DCPP Specific Source Term Dose Conversion Factors table to Attachment 9, Step 1.w Attachment 9, Step 1.w improve usability. Clarified that the Core, Gap, and Design Bases (DB) Radiological Attachment 9, Step 2.m Attachment 9, Step 2.m Control Standards (RCS) entries are for non-steam generator tube rupture (SGTR)

Attachment 29, Step 8 Attachment 29, Step 8 accidents. Added the narrow range levels associated with each SGTR level category.

Core Non-SGTR Accidents Gap Core This change does not affect how the 12.

DB RCS Gap current E-Plan meets the applicable SGTR Normal (No Fuel Damage) DB RCS planning standard functions, elements, or SGTR Empty (No Fuel Damage) SGTR Accidents - No Fuel Damage site-specific commitments. This change SGTR Flooded (No Fuel Damage) 13%< NR level <96% does not require any further evaluation.

SGTR Normal (Fuel Damage) NR level <13% (Empty)

SGTR Empty (Fuel Damage) NR level >96% (Flooded)

SGTR Flooded (Fuel Damage) SGTR Accidents - With Fuel Damage 13%< NR level <96%

NR level <13% (Empty)

NR level >96% (Flooded)

Attachment 9, Step 1.o Attachment 9, Step 1.o Changed step to clarify that "team members" refers to the Field Monitor Team (FMT)

13. Prepare PEDs to be distributed to team Ensure FMT members are issued members. Changed action verb from members. appropriate dosimetry (PED and TLD). prepare to ensure since DCPP EPIP EP RB-8, Instructions for Field Monitoring

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Teams, directs FMTs to self-issue personal electronic dosimeters (PEDs) as needed so the FMT Coordinator should only prepare and issue PEDs if individuals do not already have a PED. Added thermoluminescent dosimeter (TLD) in addition to the PED as the expected dosimetry for FMT members is both a PED and TLD.

This change does not affect how the current E-Plan meets the applicable planning standard functions, elements, or site-specific commitments. This change does not require any further evaluation.

Attachment 25 Attachment 25 Replaced existing FMT Data Sheet with new format and layout based on feedback from See Appendix C of this Change Table. See Appendix C of this Change Table. incumbent FMT Coordinators. The new data sheet improves readability, increases writing space to record data, and reduces the number of abbreviations.

Added a note that the closed window gamma exposure rate and air sample iodine

14. cartridge results are used by dose assessment personnel to validate the dose assessment model.

This change does not affect how the current E-Plan meets the applicable planning standard functions, elements, or site-specific commitments. This change does not require any further evaluation.

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Appendix A - RMS Power Sources change Revision 49 Battery Monitor Name/Description Bus E Bus F Bus G Bus H Busl Backup PLANT VENT RM-14 (LRP) NR Noble Gas X RM-14 (RDU) X X RM-14R (LRP) RNR Noble Gas X RM-14R (RDU) X X RM-24 (LRP) NR Iodine X RM-24 (RDU) X X RM-24R (LRP) RNR Iodine X RM-24R (RDU) X X RM-28 (LRP) NR Particulate X RM-28 (RDU) X X RM-28R (LRP) RNR Particulate X RM-28R (RDU) X X RM-29 PV Gross Gamma X X RM-34 PV ALARA (PV skid area) X RM-87 (LRP) Extended Range Noble Gas X SECONDARY RM-15 (LRP) Condenser Air Ejector (CAE) X RM-15 (RDU) X X RM-15R (LRP) Redundant CAE X RM-15R (RDU) X X RM-19 Steam Gen Slowdown Sample Line X X RM-23 Steam Generator Slowdown X RM-71 Main Steamline #1 X X RM-72 Main Steamline #2 X X RM-73 Main Steamline #3 X X RM-74 Main Steamline #4 X X CONTAINMENT RM-2 Low Range Area X X RM-7 lncore Seal Table Room X X RM-30 High Range Area X X RM-31 High Range Area X X RM-44A (LRP) Containment Purge Exhaust (CPE) - Trai n 'A' X RM-44A (RDU) X X RM-44S <LRP) Containment Purae Exhaust <CPE) - Trai n 'S' X RM-44S (RDU) X X FUEL HANDLING BUILDING IFHBI RM-58 Spent Fuel Pool Area X X RM-59 New Fuel Pit Area X X (LRP) = Local radiation processor; includes detector and local display (RDU) = Radiation display unit; this is the Control Room display (NR) = Normal range (RNR) = Redundant normal range

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Revision 50 NOTE: T here are no unit differences on this table .

Battery Monitor Name/Description Bus E Bus F BusG Bus H Backup PLANT VENT RM- 14 (*) NR Noble Gas X RM- 14R (*) RNR Noble Gas X RM-24 (*) NR Iodine X RM-24R (*) RNR Iodine X RM-28 (*) NR Particulate X RM-28R (*) RNR Particulate X RM-29 PV Gross Gamma X X RM-34 PV ALARA (PV skid area) X RM-87 (*) Extended Range Noble Gas X SECONDARY RM- 15 (*) Condenser Air Ejector (CAE) X RM- 15R (*) Redundant CAE X RM- 19 Steam Gen Slowdown Sample Li ne X X RM-23 Steam Generator Slowdown X RM-71 Main Steamline #1 X X RM-72 Main Steamline #2 X X RM-73 Main Steamline #3 X X RM-74 Main Steamline #4 X X CONTAINMENT RM-2 Low Range Area X X RM-7 lncore Seal Table Room X X RM-30 Hiqh Ranqe Area X X RM-31 High Range Area X X RM-44A Containment Purge Exhaust (CPE) - Train 'A' X RM-44S Containment Purge Exhaust (CPE) - Train 'B' X FUEL HANDLING BUILDING (FHB)

RM-58 Spent Fuel Pool Area X X RM-59 New Fuel Pit Area X X

(*) = Instrument display in the Control Room is energ ized by a non-vital bus with battery backup (NR) = Normal range (RNR) = Redundant normal range

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Appendix B - Leak Path Flowchart change Revision 49 Single GE/GW GE/GW exhaust Monitor for RM-7X in YES SPING NG YES fans (E-160 or 161) NO Path 9 Rad Release alarm? in alarm? running?

YES NO NO YES NO Path 5 FMT RM-14, Positive or PIC NO 87, 29 in indication of steam

>bkgd? alarm? to atmosphere?

YES YES NO Path 10 RM-44 (or) off scale YES Path 1 Return to unmonitored release high? Beginning open CTMT hatch ISFSI NO GE/GW SPING NG YES Path 2 in alarm?

NO RM-58, Tank Leak RM-13 RM-17A/B NO NO 59, or FHB NO or CVCS Leak NO Path 3 in alarm? in alarm?

AMS-4? in Aux Bldg?

YES YES YES YES Path 4 Path 7 Path 8 Path 6

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Revision 50 E-160&161 005 M onitor for OR YES YES Rad Release Non-vital 480V bu ses deenergized?

(Note 2)

"~

NO NO YES NO NO NO

~ Posit ive indication of stea m YES to atmosphere?

YES Path 10 RM-44 off (or)

YES~ NO unmonitored release open CTMT hatch ISFSI Return to NO Beginning YES~

NO RM-17A/B NO NO~

in alarm?

YES YES YES YES

~ ~ ~ ~

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Appendix C - FMT Data Sheet change Revision 49 FMT Data Sheet Air Sample Air Sample Gamma and Particulate Iodine Location Beta-Gamma Count Rate Smearable Filter Cartridge (Include 3 ft mR/hrl Ground at 3 Feet- Surface Air (net cpm) (net cpm) Reoorted To GPS WC WO Count Rate Skyshine Contamination Sample µCi/cc * µCi/cc ** PG&E County St at e coordinates Volume Sample Date Time if av ailable) Team (net cpm) (net cpm) ( dpm/100cm 2) (113)

Initial Follow-Up Initial Follow-Up Initial Follow-Up Initial Follow-Up Initial Follow-Up Initial Follow-Up Particulate µCi/cc = (1.GOE-10) x (net cpm) / Volume (113)

Iodine µCi/c = (5.GOE-09) x (net cpm) / Volume (113)

Enclosure 3 PG&E Letter DCL-22-077 PG&E Letter DIL-22-011 Revision 50 NOTE: Window closed gamma exposure rate and iodine air sample results (bolded) are used by dose assessors for dose assessment model validation.

Initial Date Survey Time Team Location O Followup Lat:

OR I I RMP: Long:

Gamma Window Beta-Gamma Ground Count Rate Count Rate at 3 feet - Smearable Surface Closed at 3 feet Window Open at 3 Skyshine Contamination feet (mB/h[.) (mB/h[.) (net ~ (net &mn) (m/100cm2 )

Air Sample Air Sample Particulate Filter Air Sample Iodine Cartridge Volume X 1.6E-10 = X 5.6E-09 =

(ft3) (net &mn) Volume (µCi/cc) (net &mn) Volume (µCi/cc)

Results Reported to: _ _ PGE _ _ County State 0 Initial Date Survey Time Team Location 0 Follow up Lat:

OR I I RMP: Long:

Gamma Window Beta-Gamma Ground Count Rate Count Rate at 3 feet - Smearable Surface Closed at 3 feet Window Open at 3 Skyshine Contamination feet (m,8/h[.) (mB/!10 (net CQm) (net CQm) (dgm/ 100cm2 )

Air Sample Air Sample Particulate Filter Air Sample Iodine Cartridge Volume X 1.0E-10 = X G.0E-09 =

(ft3) (net &mn) Volume (µCi/cc) (net &mn) Volume (µCi/cc)

Results Reported to: _ _ PGE _ _ County State

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