IR 05000275/1996018

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Insp Repts 50-275/96-18 & 50-323/96-18 on 961008-11.No Violations Noted.Major Areas Inspected:Control Room Simulator,Technical Support Center,Operational Support Center & Emergency Operations Facility
ML16342D475
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 11/07/1996
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML16342D474 List:
References
50-275-96-18, 50-323-96-18, NUDOCS 9611130077
Download: ML16342D475 (28)


Text

ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.:

License Nos.:

Report No.:

Licensee:

Facility:

Location:

Dates:

Inspectors:

Approved By:

Attachment:

50-275 50-323 DPR-80 DPR-82 50-275/96-1 8 50-323/96-1 8 Pacific Gas and Electric Company Diablo Canyon Nuclear Power Plant, Units 1 and 2 7 1/2 miles NW of Avila Beach Avila Beach, California October 8-11, 1996 Gail M. Good, Senior Emergency Preparedness Analyst (Team Leader)

Francis L. Brush, Resident Inspector (Callaway)

Robert D. Jickling, Emergency Preparedness Analyst, Rill William A. Maier, Emergency Preparedness Specialist, Office of Nuclear Reactor Regulation Blaine Murray, Chief, Plant Support Branch Supplemental Information 9hiii30077 9hii07 PDR ADOCK 05000275

PDR

EXECUTIVE SUMMARY Diablo Canyon Nuclear Power Plant, Units 1 and 2 NRC Inspection Report 50-275/96-18; 50-323/96-18 Routine, announced inspection of the licensee's performance and capabilities during the full-scale, biennial exercise of the emergency plan and implementing procedures.

The inspection team observed activities in the control room simulator, technical support center, operational support center, and emergency operations facility.

Plant Su ort

~

Overall, performance by the control room staff was very good.

The alert was classified in a timely manner, and offsite agencies were notified within the required time limit. The control room staff exhibited good three-way communications; however, information was not always disseminated to everyone in the control room (Section P4.2).

Overall, the technical support center staff's performance was effective.

The site emergency coordinator exercised good command and control. The site area emergency classification and offsite notifications were proper and timely; however, one notification contained an error concerning release status.

The management team prioritized response actions excellently and provided satisfactory support to the control room.

Communications and radiological assessment were good (Section P4.3).

Overall, the operational support center staff's performance was good.

Facility coordinators provided good oversight and control of operational support center activities, which included informativ'e periodic facility briefings by the emergency maintenance coordinator.

Team dispatch was effective and priorities were continually updated as needed.

The post-accident sampling system team was professional and efficient; however, no extremity dosimetry was used (Section P4.4).

~

Overall, the performance of the emergency operations facility staff was good.

Event classifications, notifications, and protective action recommendations were made within required time limits; however, hardcopy confirmation was delayed on some occasions.

Communications could have been more effective in some instances.

Dose assessment activities and field monitoring team control were good.

Interactions with offsite response teams were very good (Section P4.5).

~

The inspectors determined that the scenario was sufficiently challenging to test emergency response capabilities and demonstrate onsite exercise objectives; however, it could have been more challenging for the control room and operational support center.

The use of additional emergency response personnel detracted from the NRC inspection team's ability to determine emergency plan staffing level adequacy (Section P4.6).

The licensee's self-critique process effectively identified areas for corrective action (Section P4.7).

-3-Re ort Details IV. Plant Su ort P4 Staff Knowledge and Performance in Emergency Preparedness P4.1 Pro ram Areas lns ected 82301 The licensee conducted a full-scale, biennial exercise on October 9, 1996.

The exercise was conducted to test major portions of the onsite (licensee) and offsite emergency response capabilities.

The licensee activated its emergency response organization and all emergency response facilities. The Federal Emergency Management Agency evaluated the offsite response capabilities of the State of California and San Louis Obispo county.

The Federal Emergency Management Agency will issue a separate report.

The exercise scenario was conducted using the control room simulator in a dynamic mode.

The exercise scenario began at 8:00 a.m.

Units 1 and 2 were at 100 percent power. A Unit 1 residual heat removal pump and containment spray pump were out of service for maintenance.

At 8:10 a.m., the second Unit 1 residual heat removal pump became inoperable.

The control room was notified of a steam leak in the auxiliary building penetration area at 8:17 a.m. At 8:25 a.m., the shift supervisor declared an alert because two residual heat removal pumps were inoperable for 15 minutes.

The alert declaration prompted emergency response organization and facility activation.

At 9:06 a.m., the technical support center assumed responsibilities for emergency direction and control functions.

At 9:48 a.m., a steam generator tube rupture occurred.

The site emergency coordinator declared a site area emergency. at 9:50 a.m. At 11:05 a.m., emergency direction and control functions transferred to the emergency operations facility. Following an increase of radiological activity, due to failed fuel, the recovery manager declared a general emergency at 11:49 a.m.

The release was projected to continue until about 4-5:00 p.m.; however, the exercise was terminated at about 3:00 p.m., except for recovery discussions in the emergency operations facility.

P4.2 Control Room a.

Ins ection Sco e 82301-03.02 The inspectors observed and evaluated the control room simulator staff as they performed tasks in response to the exercise scenario conditions.

These tasks included detection and classification of events, analysis of plant conditions, notification of offsite authorities, and adherence to the emergency plan and implementing procedures.

The inspectors reviewed applicable emergency plan

4-implementing procedures, logs, checklists, and notification forms generated during the exercise.

b.

Observations and Findin s The control room staff's response to the simulated plant and equipment failures was very good.

The staff immediately recognized changing plant conditions and took appropriate mitigating actions.

The staff also correctly classified the alert resulting from two inoperable residual heat removal pumps and made timely offsite notifications.

The control room staff exhibited good three-way communications during all phases of the exercise.

Three-way communications involve: information communication by provider, information restatement by receiver, and information confirmation by provider.

However, information was not always disseminated to everyone in the control room.

The inspectors observed two examples:

(1) the shift supervisor and emergency operation coordinator were not always present during various control room briefings conducted by the shift foreman, and (2) the control room staff was not informed of the emergency operations facility activation.

The efficiency of the emergency response and mitigation efforts could be affected by incomplete communications.

Conclusions Overall, performance by the control room staff was very good.

The alert was classified in a timely manner, and offsite agencies were notified within the required time limit. The control room staff exhibited good three-way communications; however, information was not always disseminated to everyone in the control room.

P4.3 Technical Su ort Center Ins ection Sco e 82301-03.03 The inspectors observed and evaluated. the technical support center staff as they performed tasks necessary to respond to the exercise scenario conditions.

These tasks included staffing and activation, facility management and control, accident assessment, classification, dose assessment, protective action decisionmaking, notifications and communications, assistance and support to the control room, evaluation of post-accident sampling results, and dispatch and coordination of monitoring teams.

The inspectors reviewed applicable sections of the emergency plan, emergency plan implementing procedures, logs, checklists, status boards, and computer-generated forms and worksheet Observations and Findin s The technical support center was activated in a timely manner.

Emergency direction and control functions transferred from the interim site emergency coordinator (control room shift supervisor) to the site emergency coordinator (technical support center) 38 minutes after the alert declaration.

The technical support center was activated shortly thereafter.

The site emergency coordinator generally exercised good command and control.

The site emergency coordinator kept the advisory staff informed and ensured that briefings were conducted at half-hourly intervals.

Reautar broadcasts over the plant page system were made to inform plant personnel of the emergency status and existing hazards.

The site emergency coordinator also maintained close oversight of outgoing notifications and protective action recommendations.

The site emergency coordinator's briefings with center management advisors were excessively long following the transfer of.emergency direction and control functions to the recovery manager in the emergency operations facility. During the latter half of the exercise, this practice prevented the advisors from briefing and directing their staffs in a timely manner.

In some cases, the advisors had less than 10 minutes between briefings to communicate with and direct their staffs.

As a result, the radiological advisor's staff was not informed of the core damage until about 30 minutes after it was first announced in the technical support center.

This practice could affect the efficiency of the response effort.

The site area emergency that occurred as a result of the steam generator tube rupture was classified correctly, and offsite agency notifications were timely. All 30-minute updates were made at the proper intervals.

Although protective action recommendations were made in accordance with Emergency Procedure EP RB-10, "Protective Action Recommendations,"

Revision 5, on one occasion, inaccurate and confusing information was provided to offsite authorities.

Specifically, Protective Action Recommendation 4 contained conflicting information concerning release status.

As a result, the county had to call the technical support center to obtain clarification. The need to clarify form entries could delay offsite decisionmaking and protective action implementation.

The management team prioritized actions excellently and provided satisfactory support to the control room.

The assistant site emergency coordinator maintained management focus on the priorities/major tasks list. The list was kept at a manageable length and was frequently reviewed and updated.

Priorities were properly communicated to the control room and operational support center.

Communications between the technical support center and the other emergency response facilities were good.

The site emergency coordinator kept facility counterparts informed of technical support center activitie Radiological assessment in the technical support center was good.

The field teams were effectively directed and protective measures were taken promptly. Team members were authorized to take potassium iodide (thyroid blocking agent) and use respiratory protection as soon as the possibility of a thyroid exposure was identified. The radiological assessment team effectively used the various tools available to them to perform dose assessment.

Conclusions Overall, the technical support center staff's performance was effective. The site emergency coordinator exercised good command and control ~ The site area emergency classification and offsite notifications were proper and timely; however, one notification contained an error concerning release status.

The management team prioritized response actions excellently and provided satisfactory support to the control room.

Communications and radiological assessment were good.

P4.4 0 erational Su ort Center a.

Ins ection Sco e 82301-03.05 The inspectors observed and evaluated the operational support center's staff as they performed tasks in response to the scenario conditions.

These tasks included functional staffing, inplant emergency repair team dispatch and coprdination in support of control room and technical support center requests, and the post-accident sampling system response; The inspectors reviewed applicable emergency plan implementing procedures, logs, checklists, and forms generated during the exercise.

b.

Observations and Findin s

Operational" support center activation was rapid and efficient. The emergency maintenance coordinator declared the facility activated approximately 14 minutes after the alert declaration.

The responding emergency personnel quickly readied the facility and obtained information from the control room simulator concerning teams currently in the plant.

Periodic briefings provided by the emergency maintenance coordinator were informative and concise.

Functional area coordinators provided important input to these briefings.

The operational support center was properly monitored for habitability. Surveys were routinely taken, and the results were discussed with the site radiation protection coordinator.

Increasing dose rates were promptly communicated to facility personne Response teams were briefed and dispatched in a timely manner.

More than 20 teams were dispatched during the exercise.

The teams maintained contact with the operational support center through pagers and telephones.

Plant public address announcements kept the teams informed of emergency status changes.

Prior to dispatch, the post-accident sampling system team received a detailed briefing which included travel routes, samples to obtain, and current radiological conditions in the plant.

When the sample team arrived at the sample station, they efficiently proceeded to draw the requested samples by splitting the work. Both team members paid close attention to the sampling procedures.

The inspectors observed that the post-accident sampling team member, who handled and prepared the reactor coolant system offgas sample, was not wearing extremity dosimetry.

The initial sample contact dose rate was 11 rem per hour, and the technician's hands were within one foot of the sample for more than 3 minutes.

The inspectors concluded that the team was dispatched without proper dosimetry.

Although most teams were dispatched with proper equipment, the response team sent to investigate the residual heat removal pump 1-2 breaker did not acquire a meter or tools to test the breaker or open the cabinet.

When a team member reported initial observations, the operational support center requested the team to open the cubicle and continue investigation of the breaker.

The team acknowledged the operational support center's request, even though they did not have the proper tools to continue the inspection.

While observing this team, the inspectors noted that the plant announcements were distorted and not understandable in the area where the team was working (residual heat removal pump 1-2 breaker).

Conclusions Overall, the operational support center staff's performance was good.

Facility coordinators provided good oversight and control of operational support center activities, which included informative periodic facility briefings by the emergency maintenance coordinator.

Team dispatch was effective and priorities were continually updated as needed.

The post-accident sampling system team was professional and efficient; however, no extremity dosimetry was used.

Emer enc 0 erations Facilit Ins ection Sco e 82301-03.04 The inspectors observed the emergency operations facility's staff as they performed tasks in response to the exercise.

These tasks included facility activation, event classification, notification of state and local response agencies, development and issuance of protective action recommendations, dose assessment and coordination of field monitoring teams, analysis of plant conditions, and direct interactions with offsite agency response team Observations and Findin s Initial emergency operations facility staffing and management began within a reasonable time following the 8:25 a.m. alert declaration.

The advisor to the county, and other facility personnel, began arriving from the plant site at about 9:15 a.m.

Upon arrival, personnel signed-in on the recovery manager sign-in board and promptly established communication links. A utility point of contact was quickly stationed in the county emergency operations center (collocated with the emergency operations facility) to communicate utility event notifications/protective action recommendations, answer any questions, and receive any requests for assistance from the county.

In accordance with the Diablo Canyon Power Plant Emergency Plan, full activation did not occur until the recovery manager arrived from the corporate office in San Francisco, California. The corporate personnel, including the recovery manager, arrived at 10:22 a.m.

The recovery manager assumed overall emergency direction and control functions at 11:05 a.m. (about 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the alert declaration).

The NRC response team arrived at 10:37 a.m.

Briefings and internal/external information flow were generally good; however, the effectiveness of these communications was occasionally challenged.

Several examples were observed.

First, the engineering advisor did not immediately communicate the technical support center's site area emergency declaration to the emergency operations facility staff (prior to the arrival of the recovery manager).

The engineering advisor was informed of the site area emergency at 9:51 a.m., but did not communicate the information to the advisor to the county until 9:56 a.m.

The individual waited until he was called upon during a briefing.

Since the emergency operations facility had the responsibility to notify the county of any protective action recommendations, knowledge of the site area emergency classification level was important.

Second, recovery manager briefings were challenged by the following distractions:

(1) county public address announcements, (2) telephone conversations occurring in the recovery manager's office, and (3) ringing telephones.

Third, the engineering liaison and radiological manager often left before briefings ended.

These individuals may have been needed to dispel inaccurate information discussed after their departure.

Fourth, the transfer of protective action recommendation responsibilities between the technical support center and emergency operations facility could have been more systematic.

During the time that Protective Action Recommendation 6 was being prepared, both the technical support center and unified dose assessment center (located within the emergency operations facility) thought they had the responsibility to formulate protective action recommendations.

This confusion led to a slight delay in dissemination of the recommendatio ~,

-9-Fifth, the status of offsite protective action implementation was not always clearly communicated.

At 10:16 a.m., the advisor to the county was informed that the county was evacuating Protective Action Zones 1 and 2; however, at 10:24 a.m.,

the individual informed the recovery manager that the county was considering the evacuations.

This situation emphasized the value of three-way communications.

The emergency operations facility's general emergency classification was timely, and formal (verbal) notification of event classifications (site area and general emergencies)

and protective action recommendation changes were made within regulatory time limits, via the advisor to the county.

However, dissemination of the hardcopy forms was occasionally delayed while the information was entered into the emergency response notification and information system.

The inspectors observed the following two 'examples.

First, Protective Action Recommendation 7 was signed by the recovery manager at 11:20 a.m.; however, the form was not released for dissemination until 11:34 a.m.

(14 minutes later).

Second, following the general emergency declaration at 11:49 a.m., the hardcopy event notification form and protective action recommendation were not disseminated until 12:06 p.m. (17 minutes later).

Since the hardcopy forms provided confirmation of the verbal notifications, the inspectors concluded that unnecessary delays were inappropriate.

Regarding the protective action recommendation form used by the control room and technical support center (Form 69-13216, from Emergency Procedure EP RB-10,

"Protective Action Recommendations,"

Revision 5), the inspectors noted that the form incorrectly indicated that there could be a site area emergency with site boundary doses greater than, or equal to, 1000 millirem total effective dose equivalent, or 5000 millirem thyroid committed dose equivalent.

Emergency action levels in Emergency Procedure EP G-1, "Emergency Classification and Emergency Plan Activation," Revision 24, identified these conditions as a general emergency.

The inspectors concluded that the two procedures were not consistent.

The licensee acknowledged this finding and indicated that the procedure would be quickly corrected.

Dose assessment activities and field monitoring team control performed by the unified dose assessment center were good.

Dose projections and field monitoring results were used to support protective action recommendations; however, when plant conditions warranted, the recovery manager properly made protective yction recommendations that were independent of those developed by the unified dose assessment center.

Field monitoring team member exposures were properly tracked, and an appropriate decision was made to issue potassium iodide to field team members.

Interactions with offsite response teams (state, county, and NRC site team) were very good.

At one point, the recovery manager, radiological manager, and NRC director of site operations participated in a briefing held in the county emergency

-10-operations center (collocated).

The face-to-face meeting emphasized the integrated nature of the response efforts and provided an opportunity for the offsite authorities to converse with utility and NRC management.

Immediately following exercise termination, the recovery manager and key facility managers conducted reentry and recovery discussions.

The recovery manager properly used Emergency Procedure EP OR-3, "Emergency Recovery," Revision 4, to drive the discussions; however, the discussions were broad and lacked specificity regarding necessary actions and concerns.

Moreover, the inspectors noted that EP OR-3 inappropriately required that events be downgraded to a notification of unusual event before entering the recovery phase.

Under some circumstances,

'atisfying this prerequisite could delay the transition, since it may not be possible to downgrade to the specified classification level.

c.

Conclusions Interactions with offsite respo P4.6 Scenario and Exercise Control Overall, the performance of the emergency operations facility staff was good.

Event classifications, notifications, and protective action recommendations were made within required time limits; however, hardcopy confirmation was delayed on some occasions.

Communications could have been more effective in some instances.

Dose assessment activities and field monitoring team control were good.

nse teams were very good.

a.

Ins ection Sco e 82301 The inspectors made observations during the exercise to assess the challenge and realism of the scenario and to evaluate the control of the exercise.

b.

Observations and Findin s The following observations detracted from the realism and training value of the exercise and were considered areas for,improvement:

~

There were more people used in the emergency response organization than prescribed by the emergency plan in two facilities.

In the technical support center, the radiological advisor called out two additional responders shortly after technical support center staffing began; before there was a demonstrated need for their presence.

One of the additional responders functioned in a leadership role for the radiological assessment team when the radiological advisor was absent.

Similarly, in the emergency operations facility, two additional personnel were used to assist with offsite notifications and interact with the NRC site team.

While valid during an actual event, the use of additional personnel hampered the inspection team's ability to determine emergency plan staffing level adequac The scenario could have been more challenging for the control room and operational support center.

The only event classified by the control room was simplistic and required no assessment.

Except for the post-accident sampling system team, there were no radiological challenges for operational support center response teams.

On one occasion, a controller provided data that had not been earned by a participant.

The controller provided dose rate information that was not consistent with the meter scale.

The correct response would have been that the meter was offscale.

Exercise control for at least two emergency response teams appeared to be lacking.

The residual heat removal pump breaker investigation and repair teams were kept on standby at the breakers with nothing to do (and nowhere to sit) for about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

The inspectors concluded that these activities could have been controlled in a more practical manner, considering participant interest and comfort.

c.

Conclusions The inspectors determined that the scenario was sufficiently challenging to test emergency response capabilities and demonstrate onsite exercise objectives; however, it could have been more challenging for the control room and operational support center.

The use of additional emergency response personnel detracted from the NRC inspection team's ability to'determine emergency plan staffing level adequacy.

P4.7 Licensee Self-Criti ue Ins ection Sco e 82301-03.13 The inspectors observed and evaluated the'licensee's post-exercise facility critiques, and the formal management critique, on October 11, 1996, to determine whether the process would identify and characterize weak or deficient areas in need of corrective action.

b.

Observations and Findin s

The post-exercise facility critiques included input from controllers, evaluators, and participants and were generally thorough, open, and self-critical ~ However, on one occasion, during the emergency operations facility critique, participants dismissed the comments of a controller.

The inspectors concluded that the participants'omments could have had a chilling effect on the critique proces The input for the formal management critique included comments from participants, controllers, and evaluators.

The issues identified by the licensee's team were generally consistent with those identified by the NRC inspection team.

c.

Conclusions The licensee's self-critique process effectively identified areas for corrective action.

P8 IVliscellaneous Emergency Preparedness Issues P8.1 Closed Ins ection Followu Item 50-275 9509-01 and 50-323 9509-01: Out-of-date co ies of the emer enc lan in emer enc res onse facilities. The out-of-date plans were not removed from these areas when they were deleted as controlled copies.

The licensee's corrective actions included revising Procedure AD3.ID5, "Procedure Distribution and Control," to require an annual audit of all controlled copies of the emergency plan.

In addition, Procedure AD3.ID5 was also changed to state that emergency plan controlled copy holders should notify document services when copies of the plan are no longer needed.

Procedure OM10.ID2, "DCPP Emergency Plan Review, Revision and Approval," was revised to require the emergency plan sponsor to give procedure services a distribution list to coordinate plan distribution. The inspectors reviewed the licensee's corrective actions and various controlled copies of the emergency plan and did not note any problems.

P8.2 Closed Violation 50-275 9509-02an 50-323 9509-02: Failure to conduct re uired fire drills. The licensee failed to conduct quarterly fire drills which ensured that all fire brigade members participate in at least two quarterly drills per year.

The inspectors reviewed the licensee's corrective actions which included revising procedure TQ1.DC12, "Fire Brigade Training," to require the appropriate number of drills. Additionally, the licensee revised the lesson guide for fire drills to include information to facilitate writing the critique, such as detailed expected actions.

The inspectors also reviewed the second and third quarter 1996 lesson guides for 10 fire brigade drills and noted only 1 minor discrepancy.

V. Mana ement Meetin s

X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on October 11, 1996.

The licensee acknowledged the findings presented.

No proprietary information was identifie ATTACHMENT PARTIALLIST OF PERSONS CONTACTED Licensee G. Rueger, Senior Vice President and General Manager M. Angus, Manager, Regulatory Services R. Bliss, Emergency Planning Coordinator W. Crockett, Manager, Nuclear Quality Services B. Ellis, Emergency Planning Coordinator S. Fridley, Manager, Outage Services C. Harbor, Supervisor, Regulatory Services M. Hug, Supervisor, Onsite Emergency Planning J. Lewis, Bureau Chief, News Services D. Marsh, Emergency Planning Coordinator T. McKnight, NRC Coordinator, Regulatory Services D. Miklush, Manager, Engineering Services J. Molden, Manager, Operations Services R. Morris, Emergency Planning Coordinator D. Oatley, Manager, Maintenance Services R. Powers, Vice President and Plant Manager M. Somerville, Senior Engineer, Radiation Protection D. Tagart, Director, Nuclear Quality Services R. Todaro, Director, Security E. Waage, Supervisor, Offsite Emergency Planning LIST OF INSPECTION PROCEDURES USED IP 82301 Evaluation of Exercises at Power Reactors IP 92904 Followup - Plant Support LIST OF ITEMS CLOSED Closed 50-275/95009-01 50-323/95009-01 IFI Out-of-date copies of the emergency plan in emergency response facilities (Section PB)

50-275/95009-02 50-323/95009-02 VIO Failure to conduct required fire drills (Section PB)

-2-LIST OF DOCUMENTATIONREVIEWED Emer enc Plan Im lementin Procedures EP G-1 EP G-2 EP G-3 EP G-5 EP OR-3 EP RB-10 EP RB-14 EP RB-15 EP EF-1 EP EF-2 EP EF-3 Emergency Classification and Emergency Plan Activation Activation and Operation of the Interim Site Emergency Organization (Control Room)

Notification of Off-site Agencies and Emergency Response Organization Personnel Evacuation of Nonessential Site Personnel Emergency Recovery Protective Action Recommendations Core Damage Assessment Procedure Post Accident Sampling System Activation and Operation of the Technical Support Center Activation and Operation of the Operational Support Center Activation and Operation of the Emergency Operations Facility Revision 24 Revision 19 Revision 28 Revision 6 Revision 4 Revision 5 Revision 5A Revision 5 Revision 19 Revision 17 Revision 11 Other Procedures Documents AD3.ID5 Procedure Dist OM10.ID2 DCPP Emer en ribution and Control g

cy Plan Review, Revision, and Approval OM10.DC1 Emergency Preparedness Drills and Exercises TQ1.DC12 Fire brigade Training Diablo Canyon Power Plant Emergency Plan Revision 3 Revision 2 Revision 0 Revision 3 Revision 3, Change 15