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

{{Adams
| number = ML16337A356
| issue date = 11/17/2016
| title = Independent Spent Fuel Storage Installation - Emergency Plan Implementing Procedures Updates
| author name = Ginn M
| author affiliation = Pacific Gas &amp; Electric Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS, NRC/NRR
| docket = 05000275, 05000323, 07200026
| license number = DPR-080, DPR-082, SNM-2511
| contact person = 
| case reference number = DCL-16-120, DIL-16-018
| document type = Emergency Preparedness-Emergency Plan Implementing Procedures, Letter type:DCL
| page count = 97
}}

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

==Dear Commissioners*and Staff:==

In accordance with 10 CFR 50.54 and the requirements of 10 CFR 72.32, Pacific Gas and Electric Company (PG&E) is providing a summary of the analysis of changes to Emergency Plan (E-Plan) Implementing Procedures EP G-2, "Interim Emergency Response Organization," EP G-3, "Emergency Notification of Off-Site Agencies,"
EP G-4, "Assembly and Accountability," EP EF-1, "Activation and Operation of the Technical Support Center," EP EF-2, "Activation and Operation of the Operational Support Center," EP EF-3, "Activation and Operation of the Emergency Operations Facility," and EP EF-9, "Backup Emergency Response Facilities."
The associated enclosures are listed below:
Enclosure                                                 Title 1         Diablo Canyon Power Plant Emergency Plan Implementing Procedures, Revision Numbers for Emergency Plan Implementing Procedures 2         Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-2, Revision 50, "Interim Emergency Response Organization" 3         Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-3, Revision 59, "Emergency Notification of Off-Site Agencies" 4         Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-4, Revision 29, "Assembly and Accountability" A member of the STARS Alliance Callaway
* Diablo Canyon
* Palo Verde
* Wolf Creek

Document Control Desk                                               PG&E Letter DCL-16-120 November 17, 2016                                                    PG&E Letter DIL-16-018 Page2 Enclosure                                              Title 5        Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-1, Revision 52, "Activation and Operation of the Technical Su ort Center''
6        Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-2, Revision 39, "Activation and Operation of the 0 erational Su ort Center''
7        Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-3, Revision 44, "Activation and Operation of the Erner enc Operations Facili 8        Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-9, Revision 12, "Backu Erner enc Res onse Faciliti PG&E evaluated the changes for a reduction in effectiveness, as defined in 10 CFR 50.54(q), and concluded that the changes do not reduce the effectiveness of the E-Plan. The E-Plan continues to meet the requirements in Appendix E to 10 CFR Part 50 and the planning standards of 10 CFR 50.47(b). Therefore, prior NRC approval of the associated changes was not required.
This update does not contain any privacy and proprietary information in accordance with NRC Generic Letter 81-27, "Privacy and Proprietary Material in Emergency Plans."
* PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.
If there are questions regarding this update, please contact me at (805) 545-3446.
Sincerely, Michael A. Ginn Emergency Planning Manager aph8/6470/50876578,50876579,50876502, 50876575,50876501,50876576,50876577 Enclosures cc/enc: John M. Goshen, P.E., NMSS Project Manager Kriss M. Kennedy, NRC Region IV Administrator Qhristopher W. Newport, NRC Senior Resident Inspector Balwant K. Singal, NRC Senior Project Manager Senior Emergency Preparedness Inspector (RGN-IV/DR)
A member of the STARS Alliance Callaway
* Diablo Canyon
* Palo Verde* Wolf Creek

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

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

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

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-2. Revision 50 Original Content                    Content Change                   Change Number I Type of Change I Reason for Change  - Note at top of    Attachment 1 - Note attop of page      Change #1 - Sponsor edit - no change in intent with page 1                           1                                      respect to the Emergency Plan (E-Plan).
NIA- new content added           Steps in this checklist may need to    Added in note to be consistent with other implementing be performed in an order other than    procedures. The note informs the user that steps may listed based on sequence of events. need to be performed in a different order than listed because emergencies vary. Note provides clarity to the user that they do not have to abide by strict place keeping if the sequence of events they are faced with do not line up with the way the procedure is ordered.  - Step 1.a - 1.a-4) Attachment 1 -*Step 1.a - 1.a-1 ).a)   Change #2 - Sponsor edit - no change in intent with respect to the E-Plan.
N/A- new content added           a. Emergency Classification [TIME CRITICAL]                              Reformatted the attachment to "bin" like tasks with each
: a. Classify and declare an                                              other based on user feedback to improve performance.
emergency condition within 15     1) Classify and declare emergency     This change includes a new "bin" for emergency minutes per EP G-1.                  conditions within 15 minutes per   classification.
EP G-1.
: 1) Date/Time of Event:                                                  Added in the "[TIME CRITICAL]" phrase to make it clear a) Document:                           that emergency classification requires a high level of
: 2) Emergency Action Level (EAL):
* Date/Time of Event:             attention.
* Emergency Action Level
: 3) Date/Time of Classification:          (EAL):                         There is no change of intent as the requirements for
* Date/Time   of Classification: emergency classification are not altered in any way. This
: 4) Upgrade Criteria:
* Upgrade Criteria:               change continues to provide alignment with the content of the current E-Plan.
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Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                       Content Change                Change Number I Type of Change I Reason for Change  - step 1.c- 1.c.7)      Attachment 1 - step 1.b - 1.b.4)     Change #3 - Sponsor edit - no change in intent with respect to the E-Plan.
: c. Initiate ERO actions:             b. Initiate ERO Actions Reformatted the attachment to "bin" like tasks with each NOTE: VANS should be activated       NOTE:VANS should be activated        other based on user feedback to improve performance.
immediately after an event           immediately after an event declaration (Alert or higher).       declaration (Alert or higher).       Added in the phrase "or other qualified operator" for voice activated notification system (VANS) activation to account
: 1) Ensure Communicator #2            1) Direct Communicator #2, or other  for situations in which Communicator #2 may not activate activates VANS per Attachment        qualified operator, to activate VANS VANS. Multiple operators are trained and qualified on the
: 3.                                   per Attachment 3.                    activation of VANS. This change aligns with E-Plan Section 5 and Appendix F for on-shift responsibilities.
: 2) Ensure Communicator #1            2) Direct available operator to make completes the Emergency              a Public Address Announcement        The actions to make the PA announcement and send out Notification Form (ENF) for          per Attachment 6.                    the SmartMSG were moved up in the sequence of steps approval per Attachment 2.T30899                                          as they belong next to the activation of VANS as they are
: 3) Direct available operator to send also means by which the ERO are notified ..
: 3) Direct Shift Phone Talker to      a SmartMSG pa~er message per make offsite verbal notifications to Attachment 1o.T 6779                 Revision 49 step 1.c.3) was relocated to step 1.d.3) in the County and State                                                      Revision 50 based on reformatting of the attachment.
per Attachment 11.r04380             4) Update the Control Room (unless time critical actions are being      Revision 49 steps 1.c.4) and 1.c.5) were relocated to
: 4) Direct the Work Control Shift     performed).                          steps 1.e.1) and 1.e.2) respectively in Revision 50 based Foreman to initiate Attachment 4. Record Time:                         on reformatting of the attachment.
: 5) Direct a Work Control Lead                                             Revision 49 step 1.c.6) was relocated to step 1.c.1) in (WCL), or other licensed                                                  Revision 50 based on reformatting of the attachment.
operator, to initiate Attachment 5.
Revision 49 step 1.c. 7) was relocated to step 1.e.3) in
: 6) IF a General Emergency is                                              Revision 50 based on reformatting of the attachment.
: declared, THEN determine                                                            There is no change of intent as all of the actions are still AND approve protective action                                             beina performed. The relocation of the steps from j
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Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                 Content Change                  Change Number I Type of Change I Reason for Change recommendation (PAR) per EP                                           Revision 49 to Revision 50 is acceptable because the RB-10.                                                                attachment is a guideline and not necessarily a step by step sequence of instructions. Many of the tasks get
: 7) Initiate logging declarations                                      implemented in parallel, which is hard to reflect in the and actions taken.                                                    procedure. The time requirements for all of the tasks remain the same. There are no changes to the start or stop times for any task in the attachment.
This change continues to provide alignment with the content of the current E-Plan.  - step 1.c.6)       Attachment 1 - step 1.c - 1.c.1 ).a) Change #4 - Sponsor edit - no change in intent with respect to the E-Plan.
NIA- new content added           c. Emergency Protective Actions
[TIME CRITICAL]                      Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.
: 6) IF a General Emergency is     1) IF GENERAL EMERGENCY              This change includes a new "bin" for PARs.
declared,                        declared, THEN determine                   THEN determine and approve           Added in the "[TIME CRITICAL]" phrase to make it clear AND approve protective action    protective action recommendation     th_at PARs require a high level of attention.
recommendation (PAR) per EP      (PAR) per EP RB-10.
RB-10.                                                                Added in "Obtain independent recommendation if time permits" to be consistent with other implementing NIA- new content added           a) Obtain independent                procedures for the TSC and EOF decision/makers.
recommendation if time permits.
There is no change of intent as the requirements for PARs are not altered in any way. The assignments of responsibilities for PARs are not altered by this change.
This change continues to provide alignment with the content of the current E-Plan.
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Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                       Content Change                    Change Number I Type of Change I Reason for Change  - steps 1.c.2) and      Attachment 1 - step 1.d - 1.d.1 ).b)    Change #5 - Sponsor edit - no change in intent with 1.c.3)                                                                       respect to the E-Plan.
: d. Emergency Notifications [TIME NIA- new content added               CRITICAL]                               Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.
NIA- new content added               1) Complete offsite notifications       This change includes a new "bin" for emergency within 15 minutes of event              notifications.
declaration per EP G-3.
: 2) Ensure Communicator #1                                                    Added in the phrase "or other qualified operator'' for completes the Emergency              a) Direct Communicator #1 , or other    notifications to account for situations in which Notification Form (ENF) for          qualified operator, to complete the     Communicator #1 may not fill out the ENF. Multiple approval per Attachment 2.T30899     Emergency Notification Form ~NFJ        operators are trained and qualified on filling out the ENF.
3089 for approval per Attachment 2.          This change aligns with E-Plan Section 5 and Appendix F
: 3) Direct Shift Phone Talker to                                              for on-shift responsibilities.
make offsite verbal notifications to b) Direct Shift Phone Talker, or the County and State                 other qualified operator, to make       Added in the phrase "or other qualified operator" for per Attachment 11.T04380             offsite verbal notifications to the     notifications to account for situations in which Shift Phone Coun~ and State per Attachment          Talker may not make the phone calls to the County and 11.T04 80                               State. Multiple operators are trained and qualified on making the phone calls to the County and State. This change aligns with E-Plan Section 5 and Appendix F for on-shift responsibilities.  - Multiple steps        Attachment 1 - step 1.e - 1.e.3)        Change #6 - Sponsor edit - no change in intent with respect to the E-Plan.
NIA- new content added               e. Additional Actions:
Reformatted the attachment to "bin" like tasks with each 1.c.4) Direct Work Control Shift     1) Direct Work Control Shift            other based on user feedback to improve performance.
Foreman (WCSFM) to initiate          Foreman (WCSFM) to initiate             This change includes a new "bin" for additional actions. .                        Attachment 4.
Multiple steps were relocated. There is no change of 1.c.5) Direct a Work Control Lead    2) Direct Work Control Lead (WGL),      intent as all of the actions are still being performed. The (WGL), or other licensed             or other licensed operator, to initiate relocation of the steps from Revision 49 to Revision 50 is 4 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                         Content Change                Change Number I Type of Change I Reason for Change operator, to initiate Attachment 5. Attachment 5.                        acceptable because the attachment is a guideline and not necessarily a step-by-step sequence of instructions.
1.c.7) Initiate logging declarations                                      Many of the tasks getimplemented in parallel, which is and actions taken                    3) Log declarations, decisions, and  hard to reflect in the procedure. The time requirements actions taken.                       for all of the tasks remain the same. There are no changes to the start or stop times for any task in the attachment. This change continues to provide alignment with the content of the current E-Plan .
. Attachment 1 - step 1.d - 1.d.3)     Attachment 1 - step 2.a - 2.a.1 ).b) Change #7 - Sponsor edit - no change in intent with respect to the E-Plan.
CA.UTION: Special consideration      CAUTION: Special consideration should be given to performing        should be given to performing        The PA message and SmartMSG steps were relocated Assembly, Accountability and/or      Assembly, Accountability and/or      (see Change #3).
evacuation when the action place     evacuation when the action place personnel in danger (security        personnel in danger (security event, Assembly and accountability actions were relocated from event, toxic gases, fires, weather   toxic gases, fires, weather          initial actions to subsequent actions based on reformatting conditions, etc.).                   conditions, etc.).                   of the attachment to "bin" like tasks with each other based on user feedback to improve performance. This change
: d. Inform plant personnel of the     a. Assembly and Accountability       includes a new "bin" for assembly and accountability.
emergency as follows:
: 1) IF SAE, GE, security event, or    There is no change of intent as all of the actions
: 1) IF SAE, GE, security event, or    any other event warranting           associated with assembly and accountability are still any other event warranting           Assembly and Accountability,         being performed. The relocation of the steps from the last Assembly and Accountability as       THEN initiate Assembly and           step of the initial actions to the first step of subsequent determined by SM,                    Accountability PER EP G-             actions is acceptable because the attachment is a THEN initiate Assembly and           4. T36223ff04336                     guideline and not necessarily a step-by-step sequence of Accountability PER EP G-4.T36223                                          instructions.
a) Record time of site emergency a) Record time of site emergency     signal activation                    The intent of initial actions is to group tasks that need to signal activation                                                         be performed within the first 15 minutes of entering the
: 2) IF not implementing EP G-4,       b) Direct Communicator #2, or other  E-Plan. Assembly and accountability is a task that has a THEN direct an operator to           available operator, to complete EP   30-minute requirement, which is beyond the 15-minute 5 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                    Content Change                Change Number I Type of Change I Reason for Change initiate Attachment 6, "Public     G-4 (Form 69-13231),               initial action threshold.
Address Announcement               "Accountability Roster."
Templates."T35779                                                     The time requirements for assembly and accountability remain the same. There are no changes to the start or
: 3) Direct an operator to send a                                       stop times. This change does not alter any pager message to the entire site                                      responsibilities currently assigned for performing through the SmartMSG system                                           assembly an,d accountability.
per Attachment 1o.T36779 This change continues to provide alignment with the content of the current E-Plan.  - step 2.b            Attachment 1 - step 2.b - 2.b.2)   Change #8 - Sponsor edit - no change in intent with respect to the E-Plan.
N/A- new content added             b. Early Work Release and Site Evacuation                         Reformatted the attachment to "bin" like tasks with each
: b. Evaluate initiation of an early                                    other based on user feedback to improve performance.
work release, or site evacuation. 1) IF at a UE or Alert,            This change includes a new "bin" for early work release (Refer to EP G-5.)T04336           THEN evaluate early work release   and site evacuation.                      /
per EP G-5.T04336 Added in specific criteria for early work release for the
: 2) IF at a SAE or GE,              Unusual Event (UE) and Alert levels, which is when an THEN evaluate site evacuation per  early work release is applicable per EP G-5. Also added EP 8 _5 _T04336
* in specific criteria for site evacuation for the Site Area Emergency (SAE) and General Emergency (GE) levels, which is when a site evacuation is applicable per EP G-5.
This change does not create any new requirements or responsibilities. This change aligns EP G-2 with existing content in EP G-5.
This change continues to provide alignment with the content of the current E-Plan.
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Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                     Content Change              Change Number I Type of Change I Reason for Change  - step 2.c             Attachment 1 - step 2.c -2.c.1)    Change #9 - Sponsor edit - no change in intent with respect to the E-Plan.
N/A- new content added              C. Emergency Exposures Reformatted the attachment to "bin" like tasks with each
: c. Authorize exceeding normal       1) Authorize exceeding normal dose other based on user feedback to improve performance.
dose limits, if required. (Refer to limits, if required (PER EP RB     This change includes a new "bin" for emergency EP RB-2 .)ro4336                    2.)T04336                          exposures.
Made an editorial change: "Refer" changed to "PER" to align with other implementing procedures.
This change continues to provide a!ignment with the content of the current E-Plan.  - step 2.d             Attachment 1 - step 2.d - 2.d.1)   Change #10 - Sponsor edit - no change in intent with respect to the E-Plan.
N/A- new content added              d. Administration of Kl Reformatted the attachment to "bin" like tasks with each
: d. Authorize Kl administration, if  1) Authorize Kl administration, if other based on user feedback to improve performance.
reauired. (Refer to EP RB-          required (PER EP RB-3.)r04336      This change includes a new "bin" for administration of 3.) to4336                                                             potassium iodide (Kl).
Made an editorial change: "Refer" changed to "PER" to align with other implementing procedures.
This change continues to provide alignment with the content of the current E-Plan.  - step 2.e             Attachment 1 - step 2.e - 2.e.1)   Change #11 - Sponsor edit - no change in intent with respect to the E-Plan.      '
N/A - new content added             e. Control Room Habitability Reformatted the attachment to "bin" like tasks with each 7 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                  Content Change                  Change Number I Type of Change I Reason for Change
: e. IF in Mode 3 (Recirc)          1) IF in Mode 3 (Recircj ventilation, other based on user feedback to improve performance.
ventilation,                      THEN evaluate need for sampling       This change includes a new "bin" for control room THEN evaluate need for sampling   Control Room air quality for C02      habitability.
Control Room air quality for Cb 2 build-up.
build-up.                         (REFER to OP H-5:1V).                 This change continues to provide alignment with the (REFER to OP H-5:1V).                                                   content of the current E-Plan.  - step 2.f           Attachment 1 - step 2.f- 2.f.1)       Change #12 - Sponsor edit - no change in intent with respect to the E-Plan.
N/A- new content added            f. Other Duties Reformatted the attachment to "bin" like tasks with each
: f. Authorize overtime and other   1) Authorize overtime and other       other based on user feedback to improve performance.
expenses associated with          expenses associated with              This change includes a new "bin" for other duties. This establishing and maintaining an   establishing and maintaining an       change continues to provide alignment with the content of appropriate site emergency        appropriate site emergency            the current E-Plan.
organization.                     organization.  - step 2.h           Attachment 1 - step 2.g - 2.g.1)      Change #13 - Sponsor edit- no change in intent with respect to the E-Plan.
N/A ~new content added            g. Emergency Termination Reformatted the attachment to "bin" like tasks with each
: h. For termination of an          1) For termination of an UNUSUAL      other based on user feedback to improve performance.
UNUSUAL EVENT, initiate           EVENT, initiate Attachment 7 (Form    This change includes a new "bin" for emergency  (Form 69-21273),     69-21273), "Guidelines for            termination.
"Guidelines for Terminating an    Terminating an Unusual Event."
Unusual Event"                                                          Step was also relocated from 2.h to 2.g to improve flow.
This is a subsequent action that has no time requirement; therefore, there is no impact on relocating it. This change continues to provide alignment with the content of the current E-Plan.
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Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                     Content Change                  Change Number I Type of Change I Reason for Change  - step 2.g - 2.g.2)    Attachment 1 - step 2.h - 2.h.1 ).c)  Change #14 - Sponsor edit- no change in intent with respect to the E-Plan.
NIA - new content added             h. Command and Control Turnover Reformatted the attachment to "bin" like tasks with each
: g. When ready to turn over          1) WHEN the SEC or ED is ready to     other based on user feedback to improve performance.
Command and* Control of the         take command and control,             This change includes a new "bin" for command and emergency, then perform all of      THEN:                                 control turnover.
the following:
a) Use EP EF-1 (Form 69-20437),       Step was also relocated from 2.g to 2.h to improve flow.
: 1) Use EP EF-1 (Form 69-20437),     "Command and Control Turnover         This is a subsequent action that has no time requirement; "Command and Control Turnover       Checklist" to turnover                therefore, there is no impact on relocating it.
Checklist," to turnover             responsibilities responsibilities.                                                         Added in a new step for the Shift Manager (SM) to update b) Update the CR that you have        the crew on the transfer of command and control to NIA - new conter:it added           turned over command and control       enhance the guidance for improved recognition of what E-and include which duties the CR is    Plan tasks the control room is responsible for after responsible for.                      turnover.
: 2) Ensure that copies of ENFs       c) Ensure that copies of ENFs         This change continues to provide alignment with the created in the Control Room have    created in the Control Room have      content of the current E-Plan.
been provided to the                been provided to the TSC and EOF.
TSC and EOF.  - step 3.a - 3.a.1)    Attachment 1 - step 3.a - 3.a.2).a)_  Change #15 - Sponsor edit - no change in intent with
&3.b-3.b.1)                                                               respect to the E-Plan.
NIA- new content added              a. Plant Monitoring and Assessment    Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.
: a. Continue reviewing EP G-1        1) Continue reviewing EP G-1 EAL      This change includes a new "bin" for plant monitoring and EAL criteria.                       criteria.                             assessment.
: 1) Report any potential changes     a) Report changes in any of the       Steps 3.a and 3.b from Revision 49 were combined into in event classification to the Site following to the Site Emerqency      *step 3.a in Revision 50. Both of these tasks are ongoing 9 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                   Content Change                    Change Number I Type of Change I Reason for Change Emergency Coordinator or          Coordinator or Emergency Director        actions that have no time requirements; therefore, there is Emergency Director (2002          (2002 Bridgeline is,preferred):          no impact on combining them.
Bridgeline is preferred).
* Escalations in event classification                   This change continues to provide alignment with the
* Concurrent EAL thresholds          content of the current E-Plan.
: b. Monitor radiological effluent          that are met conditions.
: 2) Continue monitoring radiological effluent conditions.
: 1) Report significant changes to the Radiological Advisor in the   a) Report significant changes in TSC (2002 Bridgeline is           r(!diological effluent conditions to the preferred).                       Radiological Advisor in the TSC (2002 Bridgeline is preferred).  - steps 3.c and 3.d  Attachment 1 - step 3.b - 3.b.2)         Change #16 - Sponsor edit - no change in intent with respect to the E-Plan.
N/A- new content added            b. Plant Priorities Reformatted the attachment to "bin" like tasks with each
: c. Assist the TSC in determining  1) Assist the TSC in determining         other based on user feedback to improve performance.
station priorities for repair and station priorities for repair and        This change includes a new "bin" for plant priorities.
mitigation actions onsite (2002   mitigation actions onsite (2002 Bridgeline is preferred).         Bridgeline is preferred).                This change continues to provide alignment with the content of the current E-Plan.
: d. Brief the TSC Operations       2) Brief the TSC Operations Advisor Advisor of significant changes in of significant changes in plant/system/ equipment status    plant/system/equipment status and and actions being taken in the    actions being taken in the Control Control Room.                     Room.  - step 3.e           Attachment 1 - step 3.c - 3.c.1)         Change #17 - Sponsor edit - no change in intent with respect to the E-Plan.
N/A - new content added           c. Periodic Briefs 10 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                   Content Change                   Change Number I Type of Change I Reason for Change Reformatted the attachment to "bin" like tasks with each
: e. Perform periodic intra-facility 1) Perform periodic intra-facility    other based on user feedback to improve performance.
teleconference I video conference  teleconference I video conference     This change includes a new "bin" for periodic briefs.
tailboards. Refer to EP EF-3       tailboards. Refer to EP EF-3 (Form    This change continues to provide alignment with the (Form 69-20788), "Emergency        69-20788), "Emergency Response        content of the current E-Plan.
Response Facility Tailboard        Facility Tailboard Checklist."
Checklist."  - note at top of      Attachment 2 - note at top of page 1 Change #18 - Sponsor edit - no change in intent with page 1                                                                   respect to the E-Plan.
Steps in this checklist may need to N/A- new content added             be performed in an order other than Added in note to be consistent with other implementing listed based on sequence of events. procedures. The note informs. the user that steps may need to be performed in a different order than listed because emergencies vary. The note provides clarity to the user that they do not have to abide by strict place keeping if the sequence of events they are faced with do not line up with the way the procedure is ordered.  - step 2.a.5)         Attachment 2 - step 2.a.5)            Change #19 - Sponsor edit - no change of intent with respect to the E-Plan.
Ensure that the Shift Phone        Ensure that the Shift Phone Talker Talker completes verbal            completes verbal notifications to the Added in the words "or less" to align with the notification notifications to the County and    County and State within               procedure EP G-3.
State within approximately 45      approximately 45 minutes.or less of minutes of the previous verbal     the previous verbal notification. There is no change of intent as the requirement is not notification.                                                            altered as follow-up notifications.are still required to be completed approximately every 45 minutes. This change continues to provide alignment with the content of the current E-Plan.
11 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                        Content Change                  Change Number I Type of Change I Reason for Change  - note at top of          Attachment 3 - note at top of page 1 Change #20 - Sponsor edit - no change in intent with page 1                                                                      respect to the E-Plan.
Steps in this checklist may need to NIA- new content added                 be performed in an order other than Added in note to be consistent with other implementing listed based on sequence of events. procedures. The note informs the user that steps may need to be performed in a different order than listed because emergencies vary. Note provides clarity to the user that they do not have to abide by strict place keeping if the sequence of events they are faced with do not line up with the way the procedure is ordered.  - step 1.b.2)             Attachment 3 - step 1.b.2)           Change #21 - Sponsor edit - no change in intent with respect to the E-Plan.
IF the initial event classification is Activate VANS immediately after an ALERT or higher,                    time of classification for ALERT or  Reformatted step to clean it up and make it simpler and THEN activate VANS immediately         higher.                              more direct to enhance user performance. The intent of after time of classification.                                               the step remains unchanged.
This change continues to provide alignment with the content of the current E-Plan.  - step 1.b.3)             Attachment 3 - step 1.b.3)           Change #22 - Sponsor edit - no change in intent with respect to the E-Plan.
IF the event classification is an      Activate VANS as soon as possible UNUSUAL EVENT,                         after time of classification for     Reformatted step to clean it up and make it simpler and THEN activate VANS as soon as          UNUSUAL EVENT.                       more direct to enhance user performance. The intent of possible.                                                                   the step remains unchanged.
This change continues to provide alignment with the content of the current E-Plan.
12 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                  Content Change                 Change Number I Type of Change I Reason for Change  - step 1.b.6).b)    Attachment 3 - step 1.b.4) -        Change #23 - Sponsor edit - no change in intent with 1.b.4).a)                           respect to the E-Plan.
: 6) Determine appropriate VANS scenario ID:                     4) Determine appropriate VANS       Reformatted step to clean it up and make it simpler and scenario ID:                        more direct to enhance user performance. The intent of b) Non-Security Event Scenarios                                      the step remains unchanged. The step was relocated to (1) 0112: Non-Security           a) NON-SECURITY Event               make the flow of the procedure line up better with the UNUSUAL EVENT with no further    Scenarios                           performance of the task of activating VANS. This change action required
* 0112: Non-Security UNUSUAL        continues to provide alignment with the content of the (2) 2012: Non-Security               EVENT with no further action    current E-Plan.
UNUSUAL EVENT with ERO               required reporting to their emergency
* 2012: Non-Security UNUSUAL response facilities                  EVENT with ERO reporting to (3) 0113: Non-Security ALERT,        emergency response facilities SITE AREA EMERGENCY, or
* 0113: Non-Security ALERT, GENERAL                              SITE AREA EMERGENCY, or EMERGENCY                            GENERAL EMERGENCY  - step 1.b.6).a)    Attachment 3 - step 1.b.4).b)       Change #24 - Sponsor edit - no change in intent with respect to the E-Plan.
a) Security Event Scenarios      b) SECURITY Event Scenarios (1) 1010: Security UNUSUAL
* 1010: Security UNUSUAL          . Reformatted step to clean it up and make it simpler and EVENT                                EVENT                           more direct to enhance user performance. The intent of (2) 0114: Security ALERT, SITE
* 0114: Security ALERT, SITE        the step remains unchanged. The step was relocated to AREA EMERGENCY, or                   AREA EMERGENCY, or              make the flow of the procedure line up better with the GENERAL                              GENERAL EMERGENCY               performance of the task of activating VANS.
EMERGENCY (3) 1012: ERO Notification      '-Content relocated (see change#     The "ERO Notification Homeland Security Elevated Homeland Security Elevated       25)                                 Threat Alert" was moved from the security events heading Threat Alert                                                         to the non-emergency events heading where it belongs.
An elevated homeland security threat is not a declared emergency by itself and as such the scenario ID belongs under the non-emergency heading.
13 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018
* Original Content                    Content Change               Change Number I Type of Change I Reason for Change This change continues to provide alignment with the content of the current E-Plan.  - step 1.b.6).d)       Attachment 3 - step 1.b.4).d)      Change #25 - Sponsor edit - no change in intent with respect to the E-Plan.
d) Non-Emergency Scenarios          d) Non-Emergency Scenarios (1) 0111: 1 Hr. 14 Hr./ 8 Hr. Non-
* 0111: 1 Hr./ 4 Hr./ 8 Hr. Non- Reformatted step to clean it up and make it simpler and Emergency Notification                  Emergency Notification         more direct to enhance user performance. The intent of (2) 0555: 12Kv Power Outage
* 0555: 12Kv Power Outage Call   the step remains unchanged. The step was relocated to Call out                                out                            make the flow of the procedure line up better with the (3) 0777: OCC Call out
* 0777: OCC Call out             performance of the task of activating VANS.
(4) 0999: DCPP Fire Fighters Call .
* 0999: DCPP Fire Fighters Call out                                    *out                            This change continues to provide alignment with the (5) 0116: Congregate Care
* 0116: Congregate Care Callout  content of the current E-Plan.
Callout
* 1012: ERO Notification Content relocated (see change           Homeland Security Elevated
#24)                                    Threat Alert
* 1007: Training Scenario                                                                  ~ I (6) 1007: Training Scenario  - step 1.b.4) -        Attachment 3 - step 1.b.5) -       Change #26 - Sponsor edit - no change in intent with 1.b.5)                              1.b.5).a)                          respect to the E-Plan.                      *
: 4) Determine appropriate "On the    5) Determine which "On the fly     Reformatted step to clean it up and make it simpler and fly Template" to use:               Template" to use:                  more direct to enhance user performance. The intent of a) IF a non-security event,
* TEMPLATE 1: Non-Security         the step remains unchanged. The step was relocated to THEN use applicable non-                UNUSUAL EVENT                  make the flow of the procedure line up better with the security event template.
* TEMPLATE 2: Non-Security         performance of the task of activating VANS.
b) IF a security event,                 ALERT or HIGHER.
THEN use the security event
* TEMPLATE 3: ALL Security         The different on-the-fly templates were designated as 1-4 template.                               Events.                        to help differentiate them based upon user feedback.
14 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                  Content Change              Change Number I Type of Change I Reason for Change c) IF event has been terminated,
* TEMP LATE 4: Emergency event THEN use the event termination         termination.                  This change continues to provide alignment with the template.                                                            content of the current E-Plan.
a) Obtain information from the SM
: 5) Obtain enough information       or Communicator #1 to fill out from the SM or Communicator #1     template.
to fill out applicable "On the fly Message" template.  - Non-Security        Attachment 3 - Non-Security       Change #27 - Sponsor edit - no change in intent with UNUSUAL EVENT template             UNUSUAL EVENT template            respect to the E-Plan.
N/A- new content added             Changes made:                     Reformatted template to make the flow better with the
* Reformatted template        performance of the task of activating VANS.
* Added ''TEMPLATE 1" The different on-the-fly templates were designated as 1-4 to help differentiate them based upon user feedback.
This change continues to provide alignment with the content of the current E-Plan.  - Non-Security        Attachment 3 - Non-Security       Change #28 - Sponsor edit - no change in intent with ALERT or HIGHER template           ALERT or HIGHER template          respect to the E-Plan.
N/A- new content added             Changes made:                     Reformatted template to make the flow better with the
* Reformatted template        performance of the task of activating VANS.
* Added "TEMPLATE 2" The different on-the-fly templates were designated as 1-4 to help differentiate them based upon user feedback.
This change continues to provide alignment with the content of the current E-Plan.
15 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                   Content Change               Change Number I Type of Change I Reason for Change  - Security Event     Attachment 3 - Security Event     Change #29 - Sponsor edit - no change in intent with template                          template                          respect to the E-Plan.
N/A - new content added           Changes made:                     Reformatted template to make the flow better with the
* Reformatted template       performance of the task of activating VANS.
* Added "TEMPLATE 3" The different on-the-fly templates were designated as 1-4 to help differentiate them based upon user feedback.
This change continues to provide alignment with the content of the current E-Plan.  - Emergency Event    Attachment 3 - Emergency Event    Change #30 - Sponsor edit - no change in intent with Termination template              Termination template              respect to the E-Plan.
N/A- new content added Changes made:
Reformatted template
* Added "TEMPLATE 4" Reformatted template to make the flow better with the performance of the task of activating VANS.
The different on-the-fly template_s were designated as 1-4 to help differentiate them based upon user feedback.
This change continues to provide alignment with the content of the current E-Plan.  - step 1.c.1 ).b)    Attachment 3 - step 1.c.1. a)* . Change #31 - Sponsor edit - no change in intent with respect to the E-Plan.
b) Correct scenario ID determined a) Correct scenario ID determined from step 1.b.6) above:           from step 1.b.4) above            Reformatted step to clean it up and make it simpler and more direct to enhance user performance. The intent of the step remains unchanged. The step was relocated to make the flow of the procedure line up better with the performance of the task of activating VANS.
16 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                    Content Change                 Change Number I Type of Change I Reason for Change
                                           -                             This change continues to provide alignment with the content of the current E-Plan.  - step 1.c.1) .a)     Attachment 3 - step 1.c.1. b)         Change #32 - Sponsor edit - no change in intent with respect to the E-Plan.
a) Correct on-the-fly template     b) Correct on-the-fly template filled filled out from step 1.b.5) above. out from step 1.b.5) above            Reformatted step to clean it up and make it simpler and more direct to enhance user performance. The intent of
                                                                ~
the step remains unchanged. The step was relocated to make the flow of the procedure line up better with the performance of the task of activating VANS.
This change continues to provide alignment with the content of the current E-Plan.  - step 1.c.6) -       Attachment 3 - step 1.c.6) -          Change #33 - Sponsor edit - no change in intent with 1.c.6).d)                          1.c.6).c)                             respect to the E-Plan.
: 6) Listen to the prompts.          6) Listen to the prompts.             Reformatted step to clean it up and make it simpler and more direct to enhance user performance. The intent of a) Press "2", to record on-the-fly a) Press "2", to record on the fly    the step remains unchanged. The step was relocated to message.                           message.                              make the flow of the procedure line up better with the performance of the task of activating VANS.
b) Wait for prompt.                b) When prompted, record message using template.                       This change continues to provide alignment with the c) Record message using                                                  content of the current E-Plan.
applicable template                c) Then press "#."
d) Then press "#."  - new step            Attachment 3 - step 1.c. 7) -         Change #34 - Sponsor edit - no change in intent with 1.c.7).b).(1)                         respect to the E-Plan.
N/A- new content added 17 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                    Content Change                  Change Number I Type of Change I Reason for
                                                                                                  ,-                    Change
: 7) The system should replay the       Added in new step to fix an issue identified by the end recorded on-the-fly message and       user. This prompt exists in the VAN_$_ activation process ask if it is correct:                 but it was missing from the procedure. This change makes the procedurE! accurate for the task of activating a) If correct, press "1" for yes. VANS.
b) If incorrect, press "2" for no. This change continues to provide alignment with the content of the current E-Plan.
(1) The system will direct you to re-record the message.  - st~p 1..~          Attachment 3 - step 2.a               Change #35 - Sponsor edit - no change in intent with respect to the E-Plan.
IF Assembly and Accountability is IF Assembly and Accountability is initiated,                        initiated,                            Assembly and accountability actions were relocated from THEN fax the on-shift             THEN fax the on-shift accountability  the last step of initial actions to the first step of accountability roster to the DCPP roster to the DCPP Watch              subsequent actions based on reformatting of the Watch Commander at (x3115)        Commander at (x3115) within 15        attachment within 15 minutes from the time   minutes from the time the site the site emergency signal was     emergency signal was sounded, per     There is no change of intent as all of the actions sounded, per EP G-4.              EP G-4.                               associated with assembly and accountability are still being performed. The relocation of the steps from initial actions to subsequent actions is acceptable because the intent of initial actions is to group together tasks that need to be performed within the first 15 minutes of entering the E-Plan. Assembly and accountability is a task that has a 30-minute requirement, which is beyond the 15-minute initial action threshold.
The time requirements for assembly and accountability remain the same. There are no changes to the start or stop times. This change does not alter any responsibilities currently assigned for performing 18 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                  Content Change                  Change Number I Type of Change I Reason for Change assembly and accountability.
This change continues to provide alignment with the content of the current E-Plan.  - note at top of   Attachment 4 - note at top of page 1 Change #36 - Sponsor edit - no change in intent with page 1                                                                respect to the E-Plan.
Steps in this checklist may need to N/A- new content added          be performed in an order other than Added in note to be consistent with other implementing listed based on sequence of events. procedures. The note informs the user that steps may need to be performed in a different order than listed because emergencies vary. Note provides clarity to the user that they do not have to abide by strict place keeping if the sequence of events they are faced with do not line up with the way the procedure is ordered.  - step 1.a         Attachment 6 - step 1.a               Change #37 - Sponsor edit - no change in intent with respect to the E-Plan.
: a. For Security events, GO TO   a. IF security event, Section 2.                      THEN GO TO step 2.                    Reformatted step to clean it up and make it simpler and more direct to enhance user performance. The intent of the step remains unchanged. This change continues to
                                               ~
provide alignment with the content of the current E-Plan.  - steps 1.b -      Attachment 6 - step 1.b -             Change #38 - Sponsor edit - no change in intent with 1.d.2).c).                      1.b.3).a).(2)                         respect to the E-Plan.
: b. Based upon plant conditions, b. Based upon plant ~onditions, use Reformatted steps to clean them up and make them use one of the following        one of the. following templates to   -simpler and more direct to enhance user performance.
templates to develop a PA       develop and make a PA                 The intent of the steps remains unchanged. The same message. T36779                 message:r367 ~ 9
* actions are taken at the same emergency classification levels.
: c. For an UNUSUAL EVENT or      1) UNUSUAL EVENT use 19 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                    Content Change                   Change Number I Type of Change I Reason for Change ALERT:                              TEMPLATE A.                            The non-security PA templates were designated as A-D to help differentiate them based upon user feedback.
: 1) Make a PA announcement           2) ALERT use TEMPLATE B.
using the appropriate template ..                                          Relocated "repeat the announcement" from the body of the instruction into the body of the templates to improve
: 2) Repeat the PA announcement.                                             usability.
CAUTION: Assembly,                  CAUTION: Assembly, Accountability      This change continues to provide alignment with the Accountability and/or evacuation    and/or evacuation when in a            content of the current E-Plan.
when in a security event or other   security event or other hazardous hazardous condition (i.e., toxic    condition (i.e., toxic gases, fires or gases, fires or weather             weather conditions) may place conditions) may place personnel     personnel in danger.
in danger.
: 3) SITE AREA EMERGENCY or
: d. When a SITE AREA                 GENERAL EMERGENCY:
EMERGENCY or GENERAL EMERGENCY is declared,              a) Determine if it is safe to move determine if it is safe to move     personnel.T3B779 personnel. T35779 (1) IF NOT safe to move personnel, THEN make a PA announcement
: 1) IF it is NOT safe to move        using TEMPLATE C.
personnel:
a) Make a PA announcement using the "NOT SAFE TO MOVE PERSONNEL" template.                (2) IF safe to move personnel, THEN make a PA announcement b) Repeat the PA announcement.      using TEMPLATE D, AND sound the site emergency             '
: 2) IF it is safe to move personnel: signal for 60 seconds.
a) Make a PA announcement using the "SAFE TO MOVE 20 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content               Content Change             Change Number I Type of Change I Reason for Change PERSONNEL" template.
b) Sound the site emergency signal for 60 seconds.
c) Repeat the PA announcement.  - UNUSUAL         Attachment 6 - UNUSUAL EVENT   Change #39 - Sponsor edit - no change in intent with EVENT template                 template                       respect to the E-Plan.
N/A - new content added        Changes made:                  Reformatted template to make the flow better with the
* Added "TEMPLATE A"       performance of the task of making a public announcement
* Added "repeat the        (PA).
announcement"
* Reformatted template     Relocated "repeat the announcement" from the body of the instruction into the body of the template to improve usability.
The PA templates were designated as A-D to help differentiate them based upon user feedback.
This change continues to provide alignment with the content of the current E-Plan.  - ALERT template  Attachment 6 - ALERT template  Change #40 - Sponsor edit - no change in intent with respect to the E-Plan.
NIA - new content added        Changes made:
* Added "TEMPLATE B"       Reformatted template to make the flow better with the
* Added "repeat the        performance of the task of making a PA.
announcement"
* Reformatted template     Relocated "repeat the announcement" from the body of the instruction into the body of the template to improve usability.
21 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content          Content Change              Change Number I Type of Change I Reason for Change The PA templates were designated as A-D to help differentiate them based upon user feedback.
This change continues to provide alignment with the content of the current E-Plan.  - SITE AREA Attachment 6 - SITE AREA       Change #41 - Sponsor edit - no change in intent with EMERGENCY or GENERAL     EMERGENCY or GENERAL           respect to the E-Plan.
EMERGENCY & Not Safe to  EMERGENCY & Not Safe to Move Move Personnel template  Personnel template             Reformatted template to make the flow better with the performance of the task of making a PA.
N/A- new content added   Changes made:
* Added "TEMPLATE C"       Relocated "repeat the announcement" from the body of
* Added "repeat the        the instruction into the body of the template to improve announcement"            usability.
* Reformatted template The PA templates were designated as A-D to help differentiate them based upon user feedback.
This change continues to provide alignment with the content of the current E-Plan. - SITE AREA  Attachment 6- SITE AREA        Change #42 - Sponsor edit - no change in intent with EMERGENCY or GENERAL     EMERGENCY or GENERAL           respect to the E-Plan.
EMERGENCY & Safe to Move EMERGENCY & Safe to Move Personnel template       Personnel template             Reformatted template to make the flow better with the performance of the task of making a PA.
NIA- new content added   Changes made:
* Added "TEMPLATE D"       Relocated "repeat the announcement" from the body of
* Added "repeat the        the instruction into the body of the template to improve announcement"            usability.
* Reformatted template The PA templates were designated as A-D to help 22 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                      Content Change                 Change Number I Type of Change I Reason for Chanae differentiate them based upon user feedback.
This change continues to provide alignment with the content of the current E-Plan.  - step 2.a             Attachment 6 - step 2.a              Change #43 - Sponsor edit - no change in intent with respect to the E-Plan.
: a. For Aircraft based threats, use  a. IF aircraft based threat,       -
PA messaae scripts located in CP    THEN GO TO CP M-15A for PA           Reformatted step to clean it' up and make it simpler and M-15A.T357'1 9                      message scripts.r36779               more direct to enhance user performance. The intent of the step remains unchanged. This change continues to provide alignment with the content of the current E-Plan.  - step 2.b -           Attachment 6 - step 2.b -            Change #44 - Sponsor edit - no change in intent with 2.d.2).d)                           2.b.2).b).(3)                        respect to the E-Plan.
: b. For a non-Aircraft based threat, b. Determine if it is safe to move   Reformatted steps to clean them up and make them determine if it is safe to move     personnel.r36779                     simpler and more direct to enhance user performance.
personnel. T35779 The intent of the steps remains unchanged. The same
: c. IF NOT safe to move              1) IF NOT safe to move personnel,    actions are taken at the same emergency classification personnel:                          THEN make PA announcement            levels.
: 1) Develop and make a PA            using TEMP LATE E.
announcement using template A                                            The security event PA templates were designated as E-G "SECURITY NOT SAFE                                                       to help differentiate them based upon user feedback.
TO MOVE PERSONNEL".
Relocated "repeat the announcement" from the body of
: 2) Repeat the PA announcement.                                           the instruction into the body of the templates to improve
: 2) IF safe to move personnel:        usability.
: d. IF safe to move personnel:       a) UNUSUAL EVENT make PA             This change continues to provide alignment with the announcement using TEMPLATE F.       content of the current E-Plan.
: 1) For an UNUSUAL EVENT:
23 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                 Content Change             Change Number I Type of Change I Reason for Change a) Develop and make a PA announcement using template B "SECURITY UNUSUAL EVENT SAFE TO MOVE PERSONNEL".                b) ALERT, SITE AREA b) Repeat the PA announcement. EMERGENCY or GENERAL EMERGENCY:
: 2) For an ALERT, SITE AREA EMERGENCY or GENERAL            (1) Make PA announcement using EMERGENCY:                      TEMPLATE G.
a) Develop and make a PA announcement using template C "SECURITY ALERT                 (2) Sound the Site Emergency OR HIGHER SAFE TO MOVE          Signal for 60 seconds.
PERSONNEL".
b) Sound the Site Emergency Signal for 60 seconds.          (3) GO TO CP M-15A Attachment 20 for subsequent actions.
c) Repeat the PA announcement.
d) Go to CP M-15A Attachment 20 for subsequent actions.  - Security Event & Attachment 6 - Security Event & Change #45 - Sponsor edit - no change in intent with Not Safe to Move Personnel      Not Safe to Move Personnel      respect to the E-Plan.
template                        template Reformatted template to make the flow better with the N/A - new content added         Changes made:                   performance of the task of making a PA.
* Changed "TEMPLATE A" to "TEMPLATE E"            Relocated "repeat the announcement" from the body of
* Added "repeat the         the instruction into the body of the template to improve 24 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                Content Change              Change Number I Type of Change I Reason for Change announcement"             usability.
* Reformatted template The security event PA templates were designated as E-G to help differentiate them based upon user feedback.
This change continues to provide alignment with the content of the current E-Plan.  - Security       Attachment 6 - Security UNUSUAL  Change #46 - Sponsor edit - no change in intent with UNUSUAL EVENT & Safe to       EVENT & Safe to Move Personnel   respect to the E-Plan.
Move Personnel template       template Reformatted template to make the flow better with the N/A- new content added        Changes made:                    performance of the task of making a PA.
* Added*Changed "TEMPLATE B" to           Relocated "repeat the announcement" from the body of "TEMPLATE F"              the instruction into the body of the template to improve
* Added "repeat the          usability.
announcement"
* Reformatted template       The security event PA templates were designated as E-G to help differentiate them based upon user feedback.
This change continues to provide alignment with the content of the current E-Plan.  - Security ALERT Attachment 6 - Security ALERT or Change #47 - Sponsor edit - no change in intent with or HIGHER & Safe to Move      HIGHER & Safe to Move Personnel  respect to the E-Plan.                             ,
Personnel template            template Reformatted template to make the flow better with    th~
N/A- new content added        Changes made:                    performance of the task of making a PA.        *
* Changed "TEMPLATE C" to "TEMPLATE G"              Relocated "repeat the announcement" from the body of
* Added "repeat the          the instruction into the body of the template to improve announcement"             usability.
25 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                    Content Change                Change Number I Type of Change I Reason for Change
* Reformatted template The security event PA templates were designated as E-G to help differentiate them based upon user feedback.
This change continues to provide alignment with the content of the current E-Plan.  - new step            Attachment 6 - step 3              Change #48 - Sponsor edit - no change in intent with respect to the E-Plan.
N/A - new content added            PUBLIC ADDRESS SYSTEM UNAVAILABILITY                     Reformatted step to clean it up and make it simpler and more direct to enhance user performance. The intent of the step remains unchanged.
This step did not belong in section 2 which is for security events. This step is generic guidance that is applicable to all situations and as such needed its own section.
This change continues to provide   ~lignmentwith   the content of the current E-Plan.  - step 2.e            Attachment 6 - step 3.a            Change #49 - Sponsor edit - no change in intent with respect to the E-Plan.
: e. IF the public address system is a. IF the public address system is unavailable,                       unavailable,                       Added in the use of SmartMSG as another means of THEN call the DCPP Security        THEN use SmartMSG to               communicating with plant staff in the event that the PA Watch Commander (x3330) and        communicate with plant staff,      system is unavailable. SmartMSG is an existing request the following:             AND call the DCPP Security Watch   communications tool that is available in the Control Room.
Commander (x3330) and request      It uses the pager system to send a message to all the following:                     personnel onsite with pagers.
Operators are trained on the use of this system.
26 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                  Content Change                  Change Number I Type of Change I Reason for Change This change continues to provide alignment with the content of the current E-Plan.  - step 2.f -2.f.1)   Attachment 6 - step 3.b - 3.b.3)     Change #50 - Sponsor edit - no change in intent with respect to the E-Plan ..
: f. IF the public address system   b. IF the public address system AND security are unavailable,     AND security are unavailable,        Reformatted step to clean it up and make it simpler and THEN email the above PA           THEN:                                more direct to enhance user performance. The intent of message to "DCPP *NPG _,                                               the step remains unchanged.
Nuclear Power Generation          1) Use SmartMSG to communicate Business                          with plant staff.                    Added in the use of SmartMSG as another means of Unit" and,                                                             communicating with plant staff in the event that the PA
: 2) Email the content of the          system is unavailable. SmartMSG is an existing
: 1) Add the PA message to bridge   applicable PA message to "DCPP       communications tool that is available in the Control Room.
line ext. 2800:                   *NPG Nuclear Power Generation        It uses the pager system to send a message to all Business Unit".                      personnel onsite with pagers.
: 3) Add the content of the applicable Operators are trained on the use of this system.
PA message to bridge line ext.
2800:                                This change continues to provide alignment with the content of the current E-Plan.  -:- step 2.e         Attachment 7 - step 2.e              Change #51 - Sponsor edit - no change in intent with respect to the E-Plan.
: e. Notify Senior Plant            e. Notify Senior Plant Management Management and PG&E External      and PG&E External                    Removed the reference to attachment 8 because it is Communications that the event     Communications that the event has    unnecessary. The personnel that would be tasked with has been terminated by activating been terminated by activating VANS   the action to activate VANS are familiar with where the VANS per Attachment 8 using       using SCENARIO ID 0200.              procedure guidance is that provides direction. The intent SCENARIO ID 0200.                                                      of the step remains unchanged.
This change continues to provide alignment with the content of the current E-Plan.
27 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                   Content Change             Change Number I Type of Change I Reason for Change  - step 1.b.2) -       Attachment 8 - step 1.b - 1.b.1) Change #52 - Sponsor edit - no change in intent with 1.b.2).c)                                                           respect to the E-Plan.
: b. Determine appropriate VANS
: b. Determine appropriate VANS      scenario ID:                     Reformatted step to clean it up and make it simpler and scenario ID:                                                        more direct to enhance user performance. The intent of
: 1) NON-SECURITY Event            the step remains unchanged. The step was relocated to
: 2) NON-SECURITY Event              Scenarios                        make the flow of the procedure line up better with the Scenarios
* 0112: Non-Security UNUSUAL     performance of the task of activating VANS.
a) 0112: Non-Security UNUSUAL          EVENT with no further action EVENT with no further action           required                     This change continues to provide alignment with the required
* 2012: Non-Security UNUSUAL     content of the current E-Plan.
b) 2012: Nori-Security UNUSUAL         EVENT with ERO reporting to EVENT with ERO reporting to            their normal emergency their normal emergency response        response facilities facilities
* 0113: Non-Security ALERT, c) 0113: Non-Security ALERT,           SITE AREA EMERGENCY, or SITE AREA EMERGENCY, or                GENERAL EMERGENCY GENERAL EMERGENCY  - step 1.b.1) -       Attachment 8 - step 1.b.2)       Change #53 - Sponsor edit - no change in intent with 1.b.1 ).c)                                                          respect to the E-Plan.
: 2) SECURITY Event Scenarios
: 1) Security Event Scenarios                                         Reformatted step to clean it up and make it simpler and
* 1010: Security UNUSUAL       more direct to enhance user performance. The intent of a) 1010: Security UNUSUAL     --._     EVENT                        the step remains unchanged. The step was relocated to EVENT
* 0114: Security ALERT, SITE     make the flow of the procedure line up better with the b) 0114: Security ALERT, SITE          AREA EMERGENCY, or           performance of the task of activating VANS.
AREA EMERGENCY, or                     GENERAL EMERGENCY GENERAL EMERGENCY                  Content relocated (see change#   The "ERO Notification Homeland Security Elevated c) 1012: ERO Notification          54)                              Threat Alert" was moved from the security events heading Homeland Security Elevated                                          to the non-emergency events heading where it belongs.
Threat Alert                                                        An elevated homeland security threat is not a declared emergency by itself and as such the scenario ID belonQs 28 of 31

Enclosure 2 PG&E Letter DCL-16-120
                                                                                                      . PG&E Letter DIL-16-018 Original Content                     Content Change                Change Number I Type of Change I Reason for Change under the non-emergency heading.
This change continues to provide alignment with the content of the current E-Plan.  - step 1.b.4) -        Attachment 8 - step 1.b.4)           Change #54 - Sponsor edit - no change in intent with 1.b.4).f)                                                                respect to the E-Plan.
: 4) Non-Emergency Scenarios
: 4) Nqn-Emergency Scenarios
* 0111: 1 Hr. I 4 Hr. I 8 Hr. Non-   Reformatted step to clean it up and make it simpler and a) 0111: 1 Hr. I 4 Hr. I 8 Hr. Non-     Emergency Notification           more direct to enhance user performance. The intent of Emergency Notification
* 0555: 12Kv Power Outage Call       the step remains unchanged. The step was relocated to b) 0555: 12Kv Power Outage Call         out                              make the flow of the procedure line up better with the out
* 0777: OCC Call out                 performance of the task of activating VANS.
c) 0777: OCC Call out
* 0999: DCPP Fire Fighters Call d) 0999: DCPP Fire Fighters Call        out                              This change continues to provide alignment with the out
* 0116: Congregate Care Callout  ~ content of the current E-Plan.
e) 0116: Congregate Care Callout
* 1012: ERO Notification f) 1007: Training Scenario              Homeland Security Elevated Threat Alert
                                    *  .1007: Training Scenario  - step 1.h - 1.h.4)    Attachment 8 - step 1.h - 1.h.3)     Change #55 - Sponsor edit - no change in intent with respect to the E-Plan.
: h. Listen to the prompts.           h. Listen to the prompts.
Reformatted step to clean it up and make it simpler and
: 1) Press "2", to record on-the-fly  1) Press "2", to record on the fly   more direct to enhance user performance~ The intent of message.                            message.                             the step remains unchanged. The step was relocated to make the flow of the procedure line up better with the
: 2) Wait for prompt.                 2) When prompted, record message     performance of the task of activating VANS.
using applicable template.
: 3) Record message using                                                  This change continues to provide alignment with the applicable template                 3) Then press"#."                    content of the current E-Plan.
29 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                      Content Change                 Change Number I Type of Change I Reason for Change
: 4) Then press "#."  - new step           Attachment 8 - step 1.i - 1.i.2).a)  Change #56 - Sponsor edit - no change in intent with respect to the E-Plan.
N/A- new content added            i. The system should replay the recorded on-the-fly message and      Added in new step to fix an issue identified by the end ask if it is correct:                user. This prompt exists in the VANS activation process but it was missing from the procedure. This change
: 1) If correct, press "1" for yes. makes the procedure accurate for the task of activating VANS.
: 2) If incorrect, press "2" for no.
This change continues to provide alignment with the a) The system will direct you to re- content of the current E-Plan.
record the message. 1 - note at top of    Attachment 11 - note at top of page  Change #57 - Sponsor edit - no change in intent with page 1                            1                                    respect to the E-Plan.
N/A- new content added            Steps in this checklist may need to  Added in note to be consistent with other implementing be performed in an order o.ther than procedures. The note informs the user that steps may listed based on sequence of events. need to be performed in a different order than listed because emergencies vary. Note provides clarity to the user that they do not have to abide by strict place keeping
                                                                       .if the sequence of events they are faced with do not line up with the way the procedure is ordered.* 1 - step 2 note       Attachment 11 - step 2 note          Change #58 - Sponsor edit - no change of intent with respect to the E-Plan.
Follow-up notifications per EP G- Follow up notifications per EP G-3 3 (Form 69-21638), "DCPP          (Form 69-21638), "DCPP Follow Up     Added in the words "or less" to align with the notification Follow-Up Emergency Notification  Emergency Notification Form",         procedure EP G-3.
Form", should be performed        should be performed approximately 30 of 31

Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                Content Change                  Change Number I Type of Change I Reason for Change approximately every 45 minutes. every 45 minutes or less. (Refer to There is no change of intent as the requirement is not (Refer to EP G-3.)              EP G-3.)                            altered as follow-up notifications are still required to be completed approximately every 45 minutes. This change continues to provide alignment with the content of the current E-Plan.
31 of 31

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

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G~3. Revision 59 Content Change               Change Number I Type of Change I Reason for Original Content Change Step 2.1.1.a 1st bullet           Step2.1.1.a 1st bullet                Change #1 - Sponsor edit - no change in intent with respect to the Emergency Plan (E-Plan).
* A new emergency
* A new emergency classification classification level              level (ECL)                       Added in acronym for emergency classification level for consistency and alignment with writer's guide.
Step 2.1.1.a.1.b)                 Step 2.1.1.a.1.b)                     Change #2 - Sponsor edit- no change in intent with respect to the E-Plan.
On-Going Event: This is used      On-Going Event: This is used when when tile DCPP Station is already the DCPP Station is already in a      Cleaned up the language around upgrading to a in a declared emergency. This . declared emergency. This gives        higher classification level to remove the term "on gives notice of an upgrade to an  notice of an upgrade to a higher      either unit" based on user feedback that it is potentially emergency classification level on emergency classification level or a   misleading. For example if U1 was in an alert and either Unit, or a new PAR. The    new PAR. The message number of an     then U2 met the conditions for an alert the Revision 58 message number of an On-Going     On-Going Event is the next sequential language infers that upgrade would be required which Event is the next sequential      number.                               is incorrect. Revision 59 fixes the language to be number.                                                                 consistent with the DCPP classification process, which only escalates to higher levels based on changes in classification level at the site; not on each individual unit.
This change continues to provide alignment with the content of the current E-Plan.
Step 2.1.1.b 1st paragraph        Step 2.1.1.b 1st paragraph            Change #3 - Sponsor edit - no change of intent with respect to the E-Plan.
Follow-Up Notifications:          Follow-Up Notifications: Required to Required to be performed          be performed approximately every      Added in the words "or less of the previous verbal approximately every               45 minutes or less of the previous    notification" to clarify the time requirements for follow-45 minutes during an ongoing      verbal notification during an ongoing up notifications. Feedback from the users of the 1of10

Enclosure 3 PG&E Lette~ DGL-16-120 PG&E Letter DIL-16-018 Content Change                  Change Number I Type of Change I Reason for Original Content Change event using Attachment 4 (Form     event using Attachment 4                procedure was that it wasn't specifically clear on when 69-21638),                         (Form 69-21638), "DCPP Follow-Up        the clock starts for the next follow-up. This change "DCPP Follow-Up Emergency          Emergency Notification Form."           provides enhanced language to clarify the Notification Form."                                                        requirements.
There is no change of intent as the requirement is not altered as follow-up notifications are still required to be completed approximately every 45 minutes. This
                                          ,~*
change continues to provide alignment with the content of the current E-Plan.
Step 2.1.1.b 2no paragraph         Step 2.1.1.b 2na paragraph              Change #4 - Sponsor edit - no change of intent with respect to the E-Plan.
The appropriate notification is a  The appropriate notification is a Follow-Up ENF due to a             Follow-Up ENF due to a significant      Changed the phrase "secondary ECL" to "concurrent significant change in plant        change in plant conditions (message     EAL". Feedback from the users of the procedure was conditions (message number 4). number 4). This is an example of        that it wasn't specifically clear on what a secondary This is an example of meeting a    meeting a concurrent EAL.               ECL was. The term concurrent EAL was decided secondary EGL.                                                             upon as it provides a better description of the condition in which another EAL at the same classification level is met compared to the previous language.
This change is an enhancement to improve use by the ERO. This change has no impact on the E-Plan as the terms *"secondary EGL" and "concurrent EAL" do not appear anywhere in the E-Plan.
Step 2.1.2                        -Step 2.1.2                              Change #5 - Sponsor edit - no change of intent with respect to the E-Plan.
The official notification to the   The official notification to the NRG is NRG is made when the NRG is        made when the NRG is called. The        Editorial chanQe to correct lanQuaQe that is not 2of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018
                                -              Content Change           Change Number I Type of Change I Reason for Original Content Change called. The ENF                    DCPP ENF is not used by the NRC. technically correct. The Revision 58 language "ENF Form is not used by the NRC.                                         form" was repetitive in the ENF stands for emergency notification form, so the rev 58 language read as emergency notification form.
The Revision 59 change corrects the grammatical error.
Step 2.1.4                         Step 2.1.4                        Change #6 - Sponsor edit - no change of intent with respect to the E-Plan.
San Luis Obispo County (SLO)       San Luis Obispo County (SLO) and and the State of California are to the State of California are to be The last bullet "Corrections for an inaccurate PAR" be notified within 15 minutes of:  notified within 15 minutes of:    was removed from this section as it was erroneously
* An initial classification of an
* An initial classification of an added in the previous Revision 57. The intent of the emergency                          emergency                     Revision 57 addition was to provide some type of
* A new PAR
* A new PAR                       guidance for the ERO on how to handle an inaccurate
* Changes to emergency
* Changes to emergency            PAR as nothing existed prior to Revision 57.
classification levels              classification levels
* Changes    to PARs
* Changes    to PARs            There is no E-Plan requirement to correct inaccurate
* Corrections for an inaccurate                                      PARs within 15 minutes. Feedback from the ERO PAR                                                              identified that this 5th bullefwas confusing as they were unsure if they were forced into a 15-minute clock for something that had no defined requirement in the E-Plan.
A concurrent change was made to Section 6.3 under Revision 59 as well to clarify the process for correcting inaccurate PARs.
This change is an enhancement to improve use by the ERO. This change has no impact on the E-Plan as the process for correcting inaccurate PARs is not 3of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DI L-16-018 Content Change                 Change Number I Type of Change I Reason for Original Content Change described in the E-Plan.
Step 6.1.3                        Step 6.1.3                               Change #7 - Sponsor edit - no change of intent with respect to the E-Plan.
Within 15 minutes of EGL or       [TIME CRITICAL]: Within PAR declaration, SLO County       15 minutes of new EGL or new PAR         Added in "[TIME CRITICAL]" to identify the need for and the State of                  declaration, SLO County and the          urgency on initial notifications as they need to be California shall be notified by   State of California shall be notified by completed within 15 minutes.
transmittal of information on an  transmittal of information on an approved Form.T32164              approved Form.T32164                     Added in "new ECL" and "new PAR" to clarify the language and address user feedback that the wording could be enhanced.
This change is an enhancement to improve use by the ERO. This change has no impact on the content of the current E-Plan.
Step 6.2.3                        Step 6.2.3                               Change #8 - Sponsor edit - no change of intent with respect to the E-Plan.
Perform a follow-up notification  Perform follow-up notifications a~~roximatel~ ever~     45        a~~roximatel~ eve~       45 minutes or   Guidance was re-written to provide enhanced details minutes or less.                  less of the previous verbal              and clearer instructions for when to perform follow-up notification.                            notifications.
: a. Some conditions (not all) that a. Routine Follow-Up notifications       Added in the words "or less of the previous verbal may trigger making a follow-up    indicate that conditions are stable and  notification" to clarify the time requirements for follow-notification in                   have not significantly changed since     up notifications. Feedback from the users of the less than 45 minutes are:         the last notification.                   procedure was that it wasn't specifically clear on when the clock starts for the next follow-up. This change
: 1. (Primary Reason) Change in     b. Some conditions (not all) that may    provides enhanced language to clarify the Radiological Release status       trigger making an expedited follow-up    requirements.
(start, or stop)                  notification in less than 45 minutes 4of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Content Change                   Change Number I Type of Change I Reason for Original* Content Chanae are:                                      There is no change of intent as the requirement is not
: 2. Change in unit status (mode      * (Primary Reason) change in              altered as follow-up notifications are still required to be change for affected or unaffected       radiological release status (start,   completed approximately every 45 minutes. This unit)                                   or stop)                              change continues to provide alignment with the
* Change in unit status (e.g. mode        content of the current E-Plan.
: 3. Change in spent fuel pool            change for affected or unaffected conditions                              unit, loss of important plant         The five examples under the section on when to components or systems)                perform follow-up notifications in less than 45 minutes
: 4. Notification of meeting
* Concurrent EALs met (e.g. Alert         were enhanced based upon user feedback. All of the additional secondary ECLs               declared on Unit 1, then Alert met    Revision 58 content remains in Revision 59 with the on Unit 2 would be a concurrent       addition of clarifying content. The exceptions being:
: 5. A correction for an inaccurate       EAL with no declaration needed PAR                                     but Follow-Up ENF needed to
* The removal of the "correction for an inaccurate communicate change to offsite             PAR". Refer to Change #6 for additional details on agencies)                                 this.
* Change in spent fuel pool
* The inclusion of the "Declared Emergency conditions                                Classification Level (ECL) that was not
* Declared Emergency                          communicated due to being immediately Classification Level (ECL) that           surpassed by a higher ECL". This bullet was was not communicated due to               added to provide an additional example of when being immediately surpassed by a          the offsite agencies should be notified sooner than higher ECL (e.g. Alert declared at        the 45 minute requirement.
0815; SAE declared at 0820; only communicated SAE; Follow-Up           These changes align with the E-Plan Section 4.1.2.3.6 ENF needed to convey Alert was        which states that at the Alert level or higher DCPP met and was declared)                 plant staff will provide, "periodic plant status updates to off-site authorities (approximately every 45 minutes
: c. Follow-up notifications to an off-site or immediately if situation warrants)."
agency may be waiv.ed or extended to intervals greater than 45 minutes if      The E-Plan does not specify which conditions would the off-site agency agrees.               require expedited follow-up notifications. The examples provided in Revision 59 align with agreed 5of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter Dl&deg;L-16-018 Content Change               Change Number I Type of Change I Reason for Original Content Change upon conditions with the offsite agencies on when expedited follow-ups should be done.
Step 6.2.4 Perform the following    Step 6.3 Correcting Errors on         Change #9 - Sponsor edit - no change of intent to correct previously transmitted   Previously Transmitted ENFs or        with respect to the E-Plan.
ENFs:                               Follow-Up ENFs This content was added in the previous Revision 57.
: a. Provide a verbal                 6.3.1 Provide a verbal                The intent of the Revision 57 addition was to provide update/correction to the County,    update/correction to the County,      some type of guidance for the ERO on how to handle State, and NRC                      State, and NRC                        an inaccurate ENF that had been transmitted to offsite agencies as nothing existed prior to Revision 57 on
: b. Create a new ENF to correct      6.3.2 For corrections to an incorrect how to handle that situation.
the issue                           PAR:
There is no E-Plan requirement to correct inaccurate
: 1. Use an initial or follow-up form a. IF the correct PAR is more         notifications.
to correct the issue based on       conservative (i.e. includes more PAZs which form contained the original   or more protective actions) than the  This change is an enhancement to improve use by the error.                              previously transmitted incorrect PAR, ERO. This change has no impact on the E-Plan as THEN send an updated initial ENF to   the process for correcting inaccurate notifications is correct the issue.                    not described in the E-Plan, nor is it described in any regulatory guidance or requirements.
: b. lE the correct PAR is less conservative (i.e. includes less PAZs or less protective actions) than the                   ,
previously transmitted incorrect PAR, THEN the previously transmitted PAR should remain on all subsequent ENFs and Follow-Up ENFs.
: 1. The verbal update is the only update allowed, as once a PAR is issued for an area (PAZ or ocean) it 6of10

Enclosure 3 PG&E Letter DCL-16-120
                                                                                                         . PG&E Letter DIL-16-018 Content Change                 Change Number I Type of Change I Reason for Original Content Change stays in effect for the duration of the event..
6.3.3 For all corrections other than PAR corrections, send an initial or follow-up ENF to correct the issue, based on which type of ENF contained the original error.
Step 6.2.5                         Relocated to step 6.2.3.c               Change #10 - Sponsor edit - no* change of intent with respect to the E-Plan.
Follow-up notifications to an off-site agency may be waived or                                               Step was relocated verbatim. This* is an editorial extended to intervals greater than                                         change that was done to move the instruction to the 45 minutes if the off-site agency                                          applicable section of the procedure.
agrees.
The relocation does not alter any requirements or timeliness aspects associated with the performance of follow-up notifications. step 1.a              Attachment 2 step 1.a                   Change #11 - Sponsor edit - no change of intent with respect to the E-Plan.
: a. Follow-Up Notifications are     a. Follow-Up Notifications are made made using Form 69-21638           using Form 69-21638 approximately       Refer to Change #8 for details associated with this approximately every 45             every 45 minutes or less of the         change.
minutes (time may be changed       previous verbal notification (time may based upon agreement with          be changed based upon agreement         Change #11 is a copy and paste of the Change #8 offsite agencies) OR when          with offsite agencies) OR when          content for alignment throughout the procedure.
significant changes to event or    significant changes to event or plant plant status occur. Examples of    status occur. Examples of significant significant changes are:           changes are:
7of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Content Change                Change Number I Type of Change I Reason for Original Content Change
: 1) Change of plant operating      1) Change in radiological release mode                              status (start, or stop)
: 2) Change of radiological release 2) Change in unit status (e.g., mode status                            change for affected or unaffected unit, loss of important plant components or
: 3) Evacuation of onsite Personnel systems)
: 4) Call for outside assistance    3) Concurrent EALs met (e.g., Alert (Fire, Ambulance or Police)       declared on Unit 1, theri Alert met on Unit 2 would be a concurrent EAL with
: 5) Notification of meeting        no declaration needed but Follow-Up secondary ECLs                    ENF needed to communicate change to offsite agencies)
: 4) Change in spent fuel pool condffions                 *
: 5) Declared Emergency Classification Level (ECL) that was not communicated due to being immediately surpassed by a higher ECL (e.g. Alert declared at 0815; SAE declared at 0820; only communicated SAE; Follow-Up ENF needed to convey Alert was met and was declared)  block 4 instructions Attachment 2 block 4 instructions       Change #12 - Sponsor edit - no change of intent with respect to the E-Plan.
"Change in Plant Status" is used  "Change in Plant Status" is used for:
for:
* Change in radioloQical release        Refer to Change #8 for details associated with this 8of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Content Change                Change Number I Type of Change I Reason for Original Content Change
* Change in radiological release        status (start, or stop)            change.
status (start or stop)
* Change in unit status (e.g. mode
* Unit mode change (affected or         change for affected or unaffeded   Change #12 is a copy and paste of the Change #8 unaffected unit)                        unit, loss of important plant      content for alignment throughout the procedure.
* Change in Spent Fuel Pool             components or systems)                                                 ,.-
(SFP) Condition
* Concurrent EALs met (e.g. Alert
* Or significant plant status           declared on Unit 1, then Alert met changes                                 on Unit 2 would be a concurrent EAL with no declaration needed but Follow-Up ENF needed to communicate change to offsite agencies)
* Change in spent fuel pool conditions
* Declared Emergency Classification Level (ECL) that was not communicated due to being immediately surpassed by a higher ECL (e.g. Alert declared at 0815; SAE declared at 0820; only
                                  /
communicated SAE; Follow-Up ENF needed to convey Alert was met and was declared)
                                        ~  block 7 instructions   Attachment 2 block 7 instructions      Change #13 - Sponsor edit - no change of intent with respect to the E-Plan.
N/A new content added               PIC data may be found at:
* httg ://gd nserver/P IC. asgx        Added in instructions on where to obtain pressurized
* FMT Communicator in the UDAC         ion chamber (PIC) data based on user feedback.
* Rad Data Processor in the TSC This change is an enhancement to improve use by the ERO. This chanQe has no impact on the content of 9of10

Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DI L-16-018 Content Change             Change Number I Type of Change I Reason for Original Content Change
                                                    ..              the current E-Plan . step 3.d.1         Attachment 5 step 3.d.1             Change #14 - Sponsor edit- no change of intent with respect to the E-Plan.
"Routine update" - Used routine "Routine update" - Used for routine updates provided - every 45     updates provided - every 45 minutes Added in the words "or less of the previous verbal minutes.                        or less of the previous verbal      notification" to clarify the time requirements for follow-*
notification.                       up notifications. Feedback from the users of the procedure was that it wasn't specifically clear on when the clock starts for the next follow-up. This change provides enhanced language to clarify the requirements.
There is no change of intent as the requirement is not altered as follow-up notifications are still required to be completed approximately every 45 minutes. This change continues to provide alignment with the content of the current E-Plan. step 3.g.1         Attachment 5 step      3.g.~        Change #15 - Sponsor edit - no change of intent with respect to the E-Plan.
N/A new content added           1) PIC data may be found at:
* htt12://12dnserver/PIC.as12x      Added in instructions on where to obtain PIC data
* FMT Communicator in the UDAC      based on user feedback.
* Rad Data Processor in the TSC This change is an enhancement to improve use by the ERO. This change has no impact on the content of the current E-Plan.
10of10

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

Enclosure 4 PG&E Letter DCL-16:-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-4, Revision 29 Original Content                   Content Change                 Change Number I Type of Change I Reason for Change Step 15 Assembly Area Leader    Step 15 Assembly Area Leader           Change #1 - Editorial change with no change of Checklist                       Checklist                              intent.
NIA - New Content               CAUTION: The second floor              SAPN 50846295 - Task 2 - "Insert a caution prior to breezeway, between building 109 and    step 15.1" building 119, should not be used as an assembly area.                         Building 109 and 119, 2nd floor breezeway Evaluation Summary:
In order to be an assembly area the breezeway is required to provide life safety exits, designed for exiting. This breezeway was not designed to as an assembly area. Per guidance from the CBC (California Building Code) in order for using this space as an assembly area we need to meet all the requirements of an assembly area. There heed to be exits that lead you directly away from the building into
                                           ~
a safe haven location.
Since the current door location led you back into a building this does not qualify as an assembly area.
Per code, you are not allow the exit people into buildings as part of the egress pattern. There are no exit signs and the doors swings in the wrong direction.
Also the exit path directing them back into the building is not fire rated. This space does not and was not desioned to be an"assembly area.
1 of 6

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

==Title:==
Assembly and Accountablity

==Title:==
Assembly and Accountability        Change #2 - Editorial change with no change of intent.
50846295 - Task 4 - The title of the procedure is spelled wrong. Specifically, the word accountability.
Step 2.1.16                        Step 2.1.16                               Change #3 - Process change with no change of intent.
If a radiological release is in    If a radiological release is in progress, progress, radiological monitors    Viewpoint will be used to monitor         RDS31, remote radiation monitors, are now installed will be dispatched to the assembly assembly area dose rates, or              in the assembly areas. Viewpoint is a software areas to check dose rates are      radiological monitors will be dispatched  program that allows for remote monitoring of the within acceptable limits. In the   to the assembly areas to check dose       radiation monitors. A chemistry and radiation event dose rates exceed            rates, to ensure dose rates are within    protection (C&RP) technician is not needed at the acceptable limits, personnel will  acceptable limits. In the event dose      assembly areas unless dose rates exceed 3 mR/hr or be evacuated as quickly as         rates exceed acceptable limits,           dose rates are not available on Viewpoint. In these possible.                          personnel will be evacuated as quickly    cases an air sample would need to be performed by.a as possible.                              C&RP technician.
This change enhances an existing process through the use of new technology that is available at the assembly areas. This change does not remove or alter the requirement to monitor the assembly areas, nor does it remove or alter the thresholds at which additional monitoring actions are required at the assembly areas (i.e., above 3mR/hr). If the new monitors are available, they will be used to provide real time monitorinQ of the assembly areas. If they are 2 of 6

Enclosure 4 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                     Content Change                 Change Number I Type of Change I Reason for Change not available, then a radiation protection (RP) technician will be dispatched to the assembly areas to perform general area surveys as they currently do.
Reference SAPN 50452062, Task 16.
Step 3.7                         Step 3.7                                 Change #4 - Process change with no change of intent.
3.7.1 Performing general area    3. 7 .1 Monitoring the assembly area surveys of the on-site assembly  dose rates on Viewpoint, Or locally if   RDS31, remote radiation monitors, are now installed areas.                           viewpoint is unavailable.                in the assembly areas. Viewpoint is a software program that allows for remote monitoring of the 3.7.3 Performing air sampling at 3.7.2 Performing general area surveys    radiation monitors. A C&RP technician is not needed the onsite assembly areas, as    of the on-site assembly areas, as        at the assembly areas unless dose rates exceed necessary.                       necessary.                               3 mR/hr or dose rates are not available on Viewpoint.
In these cases an air sample would need to be 3.7.3 Performing air sampling at the     performed by a C&RP technician.
onsite assembly areas, as necessary.
This change enhances an existing process through the use of new technology that is available at the assembly areas. This change does not remove or
* alter the requirement to monitor the assembly areas, nor does it remove or alter the thresholds at which additional monitoring actions are required at the assembly areas (i.e., above 3mR/hr). If the new monitors are available, they will be used to provide real time monitoring of the assembly areas. If they are not available, then a RP tech will be dispatched to the assembly areas to perform general area surveys as they currently do. Reference SAPN 50452062, Task 16.
3 of 6

Enclosure 4 PG&E Letter DCL-16-120.
PG&E Letter DIL-16-018 Original Content                      Content Change                  Change Number I Type of Change I Reason for Change Step 10.1.3.a.1.a                 Step 10.1.3.a.1.a                        Change #5 - Process change with no change of intent.
Dispatch available RP technician  Ensure Radiation Protection is following to assembly areas to perform      Section 16, "Radiation Protection        RDS31, remote radiation monitors, are now installed general area survey using Section Checklist."                              in the assembly areas. Viewpoint is a software 16, "Radiation Protection                                                  program that allows for remote monitoring of the Checklist."                                                                radiation monitors. A C&RP technician is not needed at the assembly areas unless dose rates exceed 3 mR/hr or dose rates are not available on Viewpoint.
In these cases an air sample would need to be performed by a C&RP technician.
This change enhances an existing process through the use of new technology that is available at the assembly areas. This change does not remove or alter the requirement to monitor the assembly areas, nor does it remove or alter the thresholds at which additional monitoring actions are required at the assembly areas (i.e., above 3mR/hr). If the new monitors are available, they will be used to provide real time monitoring of the assembly areas. If they are not available, then a RP tech will be dispatched to the assembly areas to perform general area surveys as they currently do. Reference SAPN 50452062, Task 16.
4 of 6

Enclosure 4 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                      Content Change               Change Number I Type of Change I Reason for Change Section 16 Radiation Protection    Section 16 Radiation Protection        Change #6 - Process change with no change of Checklist                          Checklist                              intent.
RDS31, remote radiation monitors, are now installed 16.1 Initial Actions               16.1.1 Monitor the assembly area dose  in the assembly areas. Viewpoint is a software 16.1.1 Perform assembly area       rates on Viewpoint.                    program that allows for remote monitoring of the monitoring:                        a. IF the assembly area dose rates are radiation monitors. A C&RP technician is not needed
: a. Obtain dose rate instrument. not available on Viewpoint, OR dose    at the assembly areas unless dose rates exceed
: b. Obtain air sampling equipment. rates exceed 3 mR/hr, THEN direct a    3 mR/hr or dose rates are not available on Viewpoint.
: c. Go to assigned assembly area    C&RP tech to the affected assembly     In these cases an air sample would need to be (Building 109, Building 119 and/or areas to perform the following:        performed by a C&RP technician.
Warehouse                          1. Obtain dose rate instrument.
B) and perform the following:      2. Obtain air sampling equipment.      This change enhances an existing process through
: 1. Perform a general area dose     3. Go to assigned assembly area        the use of new technology that is available at the rate survey to determine           (Building 109, Building 119 and/or     assembly areas. This change does not remove or background radiological            Warehouse B) and perform the           alter the requirement to monitor the assembly areas, conditions.                        following:                             nor does it remove or alter the thresholds at which
: 2. IF any radiation above normal   a) Perform a general area dose rate    additional monitoring actions are required at the background detected,               survey to determine background         assembly areas (i.e., above 3mR/hr). If the new THEN recommend restrictions on     radiological conditions.               monitors are available, they will be used to provide eating and drinking.               b) IF any radiation above normal       real time monitoring of the assembly areas. If they are
: 3. IF general area dose rates      background detected, THEN              not available, then a RP tech will be dispatched to the exceed 3mR/hr,THEN                 recommend restrictions on eating and   assembly areas to perform general area surveys as immediately inform the Control     drinking.                              they currently do. Reference SAPN 50452062, Room orTSC.                        c) IF general ~rea dose rates exceed   Task 16.
a) Start air sampling of the       3mR/hr, THEN immediately notify the assembly*area for radioiodine      Control Room or TSC.
: d. Report assembly area            1) Start air sampling of the assembly monitoring results to the TSC      area for radioiodine Radioloqical Advisor or Shift      4. Report assembly area monitoring 5 of 6

Enclosure 4 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                      Content Change                 Change Number I Type of Change I Reason for Change Manager.                          results to the TSC Radiological Advisor or Shift Manager.
16.2 Subsequent Actions 16.2 Subsequent Actions 16.2.1 Continue Monitoring Assembly Area:                    16.2.1 Continue Monitoring Assembly Area on Viewpoint, or locally:
: a. Inform Assembly Area Leader of survey results.                a. Notify Assembly Area Leader of local survey results.
: b. For further instructions or resource requests, contact the    b. For further instructions or resource Control Room or                   requests, contact the Control Room or TSC.                              TSC.
: c. Continue to monitor assembly   c. Continue to monitor assembly area areas until directed otherwise by until directed otherwise by the Shift Manager or SEC.
the Shift Manager or SEC.
Step 1.4 - deleted, not a rewrite N/A                               revision                                  Change #7 - Editorial and formatting changes Section 11.3.2, steps are a, b, c ... not 1, 2, 3 6of6

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

Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-1, Revision 52 Change Number I Type of Change I Reason for Original Content                      Content Change Change 3.16.2 Directing clerical staff to 3.16.2 Directing clerical administrative requested emergency response       staff to requested emergency response    Change #1 - Editorial change with no change of facilities.                        facilities.                              intent.
Reflect title change made in 2012 for all DCPP IBEW Physical Clerical staff from "Clerical" to "Administrative" and "Clerk" with "Adm in". Refer to SAPN 50449609, Task 17.
3.17 TSC clerical is responsible   3.17 TSC Admin Assistant is responsible Change #2 - Editorial change with no change of for providing clerical support to  for providing administrative support to intent.
the TSC staff.                     the TSC staff.
Reflect title change of Company Emergency Operations Center m*ade in 2014 in the Company Emergency Response Plan. Refer to SAPN 50449609, Task 25.
6.17 TSC Clerical Support          6.17 TSC Administrative Support Change #3 - Editorial change with no change of 6.17.1 Upon declaration of an      6.17.1 Upon declaration of an            intent.
emergency, use Attachment 17,      emergency, use Attachment 17, "TSC "TSC Clerical Support Checklist,"  Administrative Support Checklist," Form  Reflect title change made in 2012 for all DCPP IBEW Form 69 21165, to guide            69 21165, to guide performance of        Physical Clerical staff from "Clerical" to "Administrative" performance of required actions. required actions.                        and "Clerk" with "Admin". Refer to SAPN 50449609, Task 17.
1 of 6

Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                         Content Change Change Site Emergency Coordinator          Site Emergency Coordinator Checklist Change #4 - Process change with no change of Checklist
: 3. Situational Actions                    intent.
: 3. Situational Actions a) Risk Significant Actions Change is being made to delineate that an a) Risk Significant Actions         (Classification, Notification, Dose independent peer check is needed, if time permits.
(Classification, Notification,      Assessment, PARs)
The Operations Advisor is not considered a peer as Dose Assessment, PARs)*
: 1) Classify and declare an           they report to the SEC and are located in the same
: 1) Classify and declare an          emergency condition within 15        facility. The Operations Advisor is properly trained to emergency condition within          minutes per EP G-1.                  perform the task and should be conferred with prior to a 15 minutes per EP G-1.              REFER TO Tab 12.                     declaration being made. This change does not alter REFER TO Tab 12.                                                         the authority or responsibility of the Operations Advisor
: a. Confer with Ops Advisor on EALs.
or the SEC with respect to performing their emergency a) If time permits, get at
: b. If time permits, get at least one assignments in accordance with the E-Plan.
least one peer check from peer check from ED and/or SM on Ops Advisor, ED, and/or SM EAL recommendation.
on EAL recommendation.
Operations Advisor Checklist        Operations Advisor Checklist Change #5 - Process change with no change of
: 2. Ongoing Actions                  2. Ongoing Actions                        intent.
: b. Assist the SEC with              b. Confer with the SEC on Change is being made to delineate that an evaluating plant                    evaluating plant conditions independent peer check is needed, if time permits.
conditions against EALs             against EALs and upgrade criteria The Operations Advisor is not considered a peer as and upgrade criteria as             as needed.
they report to the SEC and are located in the same needed.
facility. The Operations Advisor is properly trained to perform the task and should be conferred with prior to a declaration being made. This change does not alter the authority or responsibility of the Operations Advisor or the SEC with respect to performing their emergency as~ianments in accordance with the E-Plan.
2 of 6

Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                       Content Change Change Site Emergency Coordinator         Site Emergency Coordinator Checklist Change #6 - Editorial change with no change of Checklist
: 2. Ongoing Actions                         intent.
: 2. Ongoing Actions NOTE: Direct the communications The information pertaining to both routine and NOTE: Direct the                   advisor to perform routine and expedited expedited notifications exists in EP G-3. This change communications advisor to          follow-up offsite notifications to County, is being made for consistency between EP G-3 and perform routine follow-up offsite  State, and NRC officials per EP G-3.
EP EF-1.
notifications to County, State,    REFER TO Tab 10 and 11.
and NRC officials per EP G-3.
REFER TO Tab 10 and 11.
TSC Director Checklist             TSC Director Checklist Change #7 - Editorial change with no change of
: 2. Ongoing Actions                 2. Ongoing Actions                         intent.
NOTE: DCPPeme~ency                 NOTE: DCPP emergency notifications The statement "or less" already exists in EP G-3.
notifications to the County and    to the County and State are required to Adding "or less" in this note brings EP EF-1 in line with State are required to be           be completed within 15 minutes following EP G-3 to provide better alignment between the completed within 15 minutes        the declaration of a new event procedures.                   ,
following the declaration of a new classification or new PAR at the GE level event classification or new PAR    (notifications to the NRG within one at the GE level (notifications to  hour). Follow-up notifications should be the NRC within one hour).          made approximately every 45 minutes or Follow-up notifications should be  less.
made approximately every 45 minutes.
Communications Advisor - TSC       Communications Coordinator Checklist       Change #8 - Editorial change with no change of Checklist
: 2. Onaoina Actions                         intent.
3 of 6

Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                        Content Change Change
: 2. Ongoing Actions                      b. Until relieved by the EOF, ensure The statement "or less" already exists in EP G-3.
the County and State are notified of
: b. Until relieved by the EOF,                                              Adding "or less" in this note brings EP EF-1 in line with new classification levels or new ensure the County and State                                                EP G-3 to provide better alignment between the PARS within 15 minutes of are notified of new                                                        procedures.
classification levels or new       declaration (one hour for NRC), and PARS within 15 minutes of          updated on 45 minute or less intervals.
declaration (one hour for NRC), and updated on 45 minute intervals.
Agency/ENS Communicator            Agency/ENS Communicator Checklist Change #9 - Editorial change with no change of Checklist
: 1. Initial Actions                           intent.
: 1. Initial Actions
: g. IF requested to assist with       The statement "or less" already exists in EP G-3.
: g. IF requested to assist          off-site agency emergency Adding "or less" in this note brings EP EF-1 in line with with off-site agency               notifications, EP G-3 to provide better alignment between the emergency notifications,           THEN complete the notifications procedures.
THEN complete the                  per EP G-3, "Emergency notifications per EP G-3,           Notification of Off-Site Agencies."                        '
        "Emergency Notification             REFER TO Tabs 2, 3, and 4.
of Off-Site Agencies."
: 3) Follow-up notifications should REFER TO Tabs 2, .3, be made within approximately and 4.
45 minutes or less.
: 3) Follow-up notifications should be made within approximately 45 minutes.
4 of 6

Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                         Content Change Change Administrative Advisor Checklist    Administrative Advisor Checklist Change #1 O - Editorial change with no change of
: 1. Initial Actions                  1. Initial Actions                            intent.
: d. Determine clerical            d. Determine administrative staffing Reflect title change made in 2012 for all DCPP IBEW staffing needs in each of        needs in each of the following Physical Clerical staff from "Clerical" to "Administrative" the following facilities by      facilities by contacting the and "Clerk" with "Admin". Refer to SAPN 50449609, contacting the appropriate       appropriate position:
Task 17.
position:
: f. Assign administrative personnel to:
: f. Assign clerical
: j. Establish 24-hour shift manning personnel to:
schedules (12 hour shifts) for the
: j. Establish 24-hour shift       TSC, OSC, EOF, and JIC.
manning schedules               Coordinate with each facility.
(12 hour shifts) for the        REFER TO Tab 2.
TSC, OSC, EOF, and JIC.
: 1) For the OSC, walk down and work Coordinate with each with the OSC administrative staff to facility. REFER TO Tab 2.
develop the list.
: 1) For the OSC, walk down and work with the OSC clerical staff to develop the list.
TSC Clerical Support Position       TSC Administrative Support Position Change #11 - Editorial change with no change of Binder Tab Index                    Binder Tab Index intent.
EP EF-1, Form 69-21165, "TSC        EP EF-1, Form 69-21165, "TSC Clerical Support Checklist"         Administrative Support Checklist"             Reflect title change made in 2012 for all DCPP IBEW Physical Clerical staff from "Clerical" to "Administrative" and "Cl.erk" with "Admin". Refer to SAPN 50449609, 5 of 6

Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content Content Change Change Task 17.
6 of 6

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

Enclosure 6 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-2. Revision 39 Original Content                    Content Change                 Change Number I Type of Change I Reason for Change  Step 2.h.4        Attachment 1 Step 2.h.4                 Change #1 - Administrative with no change of intent.
Updated team status            Updated team status and estimated completion time                         SAPN 50872299 recommends including the team estimated completion time Objective 1.5.2 Demonstration Criteria 8 requirement in EP EF-2.
I  Step 1.e          Attachment 6 Step 1.e                   Change #2 - Process with no change of intent.           I New Content                    Update the Emergency Planning Zone      SAPN 50872109 requests that updating 'wind chart be (EPZ) map with the wind direction. Wind added to one of the coordinator's checklists.
direction may be obtained from the PON Server or the Rad Data Processor.
: 1) Check that the wind direction indicated on the OSC EPZ,map corresponds with the TSC EPZ map. Step 2.d          Attachment 6 Step 2.d                   Change #3 - Process with no change of intent.
New Content                    Monitor the wind direction from the PON SAPN 50872109 requests that updating wind chart be Server or the Rad Data Processor.       added to one of the coordinator's checklists.
: 1) Update the EPZ map with the wind 1 of 2

Enclosure 6 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content              Content Change                Change Number I Type of Change I Reason for Change direction.
: 2) Check that the wind direction indicated on the OSC EPZ map corresponds with the TSC EPZ map. 0            Attachment 10                            Change #4 - Administrative with no change of Team Return and Debrief  Team Return and Debrief                  intent.
10 Mission 10 Mission               Status:                                  SAPN 50872171 "9/21/16 DR EP EF-2 Debrief Status:                                                           Process" recommends that Attachment 10 "Team Pre-Departure Checklist," be updated to include debriefing 11 Return Time:- - -     -                                        the teams with the appropriate coordinators.
Debrief Time: - -        11 Return Time:- - -
Debrief By: _ __         12 Debrief With:
[ ] l&C/MM/Elect/Chem Coordinator
[ ] SRPC (Rad Teams)
[ ] Team Coordinator Att 1, position binder:
NIA                      tab #2 - changed title of AD2.ID1 to     Change #5 -Administrative with no change of Procedure and Work Plan Use and          intent.
Adherence tab #9 - changed from Attachment 24 to   Multiple editorial and formatting changes Form 69-21676 Position binder tab 4 - Attachment 12 to form 69-20512 2 of 2

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

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-3, Revision 44 Change Number I Type of Change I Reason for Original Content                    Content Change Change 3.17 EOF clerical support is       3.17 EOF administrative support is responsible for providing          responsible for providing               Change #1 - Editorial change with no change of communications, copying,           communications, copying, distribution,  intent.
distribution, and other            and other administrative support to the administrative support to the EOF  EOF staff as needed.                    Reflect title change made in 2012 for all DCPP IBEW staff as needed.                                                           Physical Clerical staff from "Clerical" to "Administrative" and "Clerk" with "Admin". Refer to SAPN 50449609, Task 17.
3.20.1 Providing a single point of 3:20.1 Providing a single point of Change #2 - Editorial change with no change of contact between the EOF and the    contact between the EOF and the intent.
corporate emergency response       company emergency operations center.                            center.                                 Reflect title change of Company Emergency Operations 3.20.3 Responding to the           3.20.3 Responding to the company        Center made in 2014 in the Company Emergency corporate emergency operations     emergency operations center when        Response Plan. Refer to SAPN 50449609, Task 25.
center when requested or directed  requested or directed to do so.
to do so.
EOF Clerical Support               6.17 EOF Administrative Support Change #3 - Editorial change with no change of intent.
Reflect title change made in 2012 for all DCPP IBEW Physical Clerical staff from "Clerical" to "Administrative" and "Clerk" with "Admin". Refer to SAPN 50449609, Task 17.
1of23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                         Content Change Change Emergency Director Checklist         Emergency Director Checklist Change #4 - Administrative change with no change
: 1. Classify and declare an.        2. Classify and declare an               of intent.
emergency condition within           emergency condition within 15 15 minutes per EP G-1.               minutes per EP G-1.                   Change is being made to delineate that an independent REFER TO Tab 4.                      REFER TO Tab 4.                       peer check is needed, if time permits. The EOF Director is not considered a peer as they report to the ED and a) If time permits, obtain at ,      a. Confer with EOF Director on are located in the same facility. The EOF Director is least one peer check from            EALs.
properly trained to perform the task and should be EOF Director, SEC, and/or
: b. If time permits, obtain at least   conferred with prior to a declaration being made. This SM on EAL recommendation.
one peer check from SEC and/or        change does not alter the authority or responsibility of SM on EAL recommendation.             the EOF Director or the ED with respect to performing their emergency assignments in accordance with the E-Plan.
, Emergency Director Checklist         Emergency Director Checklist Change #5 - Editorial change with no change of
: 6. Direct the following individuals  6. Direct the following individuals to     intent.
to make announcements:               make PA announcements:                                                                     r Editorial change to add PA in front of announcement to be consistent with designation in sections a) and b).
Emergency Director Checklist         Emergency Director Checklist Change #6 - Editorial change with no change of 9.) Direct Communications            9.) Direct Communications Coordinator      intent.
Coordinator to perform routine       to perform routine and expedited         '
follow-up offsite notifications to   follow-up offsite notifications to County, The information pertaining to both routine and expedited County, State, and NRC officials     State, and NRC officials per EP G-3.       notifications exists in EP G-3. This change is being 2 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                     Content Change Change per EP G-3. REFER TO Tab 7.       REFER TO Tab 7.                       made for consistency between EP G-3 and EP EF-3.
Emergency Director Checklist      Emergency Director Checklist Change #7 - Administrative change with no change
: b. Other Functions and            b. Other Functions and                of intent.
Responsibilities                  Responsibilities Added FMT's to clarify that they are included as offsite
: 1)   Personnel Protective       1) Personnel Protective emergency workers. This is a clarification and does not Measures                   Measures impact the tasks the ED performs.
a) Authorize emergency          a) Authorize emergency exposures as needed             exposures as needed per per EP RB-2. REFER TO           EP RB-2. REFER TO Tab 8.
Tab8.
b) Authorize administration of b) Authorize                    potassium iodide (Kl) to PG&E administration of               offsite emergency workers potassium iodide (Kl) to        (including FMTs) per EP RB-3.
PG&E offsite emergency          REFERTO Tab 9.
workers per EP RB-3.
REFER TO Tab 9.
Emergency Director Checklist      Emergency Director Checklist Change #8 - Editorial change with no change of
: b. Other Functions and            b. Other Functions and                intent.
Responsibilities                  Responsibilities EP G-5 designates that the ED is provided information
: 2) Site Evacuation                2) Early Work Release or Site on and coordination of both Early Work Release and Evacuation
      .a) lE informed by SEC of                                         Site Evacuation. This change is being made for pending Site Evacuation of       a) lE informed by SEC of        consistency between EP G-5 and EP EF-3.
non-essential personnel          pending Early Work Release or 3 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                    Content Change Change from DCPP,                        Site Evacuation of non-essential THEN:                             personnel from DCPP, THEN:
(1) Ensure evacuation is coordinated with County.         (1) Ensure Early Work Release or Site Evacuation is (2) Notify company coordinated with County.
spokesperson of upcoming site                    (2) Notify company evacuation.                      spokesperson of upcoming Early Work Release or Site Evacuation.
                                                                                                                                ~
EOF Director Checklist           EOF Director Checklist Change #9 - Administrative change with no change New content                      g. Assign individuals to maintain facility of intent.
status boards (e.g. Electrical Bus Loads, Sequence of Events, ENF             Added step 1.g to formalize a process already in place.
Tracking, Unit 1 and 2 Plant Status).      Change is being made to align with position expectations and for clarity. This is not a change of intent within the E-Plan as the responsibilities have not changed. This is an administrative task and does not require any specific qualification.
EOF Director Checklist           EOF Director Checklist Change #10 - Administrative change with no change New content                      4) Ensuring all facility status boards     of intent.
are being maintained.
Added step 2.d.4 to formalize a process already in place. Change is being made to align with position expectations and for clarity. This is not a cham::ie of 4 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                     Content Change Change intent within the E-Plan as the responsibilities have not changed. This is an administrative task and does not require any specific qualification.
Radiological Manager Checklist      Radiological Manager Checklist Change #11 - Editorial change with no change of
: f. Check the following staffing    f. Check the following staffing   intent.
positions have been filled (*      positions have been filled (*
designates "minimum                designates "minimum staffing"     Reflect title change made in 2012 for all DCPP IBEW staffing" position.)               position.)                        Physical Clerical staff from "Clerical" to "Administrative" and "Clerk" with "Admin". Refer to SAPN 50449609 task
: 7) UDAC Clerk                      7) UDAC Admin Assistant 17.
FMT Coordinator Checklist           FMT Coordinator Checklist Change #12 - Editorial*change with no change of
: i. Establish EOF/EOC               i. Establish EOF/EOC radiological intent.
radiological protection*.          protection.
This is a reference to a San Luis Obispo (SLO) County
: 2)   Complete County                    2) Complete County form. SLO County renamed the form and this change is Exposure Tracking                  Agency Personnel being made to accurately reflect the new form name.
Sheet and submit                   Exposure Log and submit copy to Emergency                  copy to Emergency Worker Exposure                    Worker Exposure Coordinator (EWEC)                 Coordinator (EWEC) via via County UDAC                    County UDAC
             -Coordinator. REFER                 Coordinator. REFER TO TO Tab 5.                          Tab5.
5 of 23

Enclosure 7 PG&E Letter DCL-16-120 .
PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                       Content Change Change FMT Coordinator Checklist            FMT Coordinator Checklist Change #13 - Editorial change with no change of
: a. Dispatch and coordinate           a. Dispatsh and coordinate activities of  intent.
activities of FMTs and offsite       FMTs and offsite emergency lab.
emergency lab.                                                                 Reflect title change made in 2012 for all DCPP IBEW
: 8) Provide copies, or direct UDAC Physical Clerical staff from "Clerical" to "Administrative"
: 8) Provide copies, or direct        Admin Assistant to provide copies, and "Clerk" with "Ad min". Refer to SAPN 50449609, UDAC Clerk to provide               of F,MT Data Sheets to the Task 17.
copies, of FMT Data Sheets          following individuals:
to the following individuals: .
: 9) Maintain, or direct the UDAC
: 9) Maintain, or direct the          Admin Assistant to maintain, FMT UDAC Clerk to maintain, FMT         and UDAC status boards (team and U DAC status boards             assignment and location).
(team assignment and location).
FMT Coordinator Checklist            FMT Coordinator Checklist Change #14 - Editorial change with no change of NOTE:UDAC Clerk may assist           NOTE:UDAC Admin Assistant may             intent.
with communication requirements      assist with communication for this function.                   requirements for this function.           Reflect title change made in 2012 for all DCPP IBEW Physical Clerical staff from "Clerical" to "Administrative"
                                                                              *and "Clerk" with "Admin". Refer to SAPN 50449609, Task 17.
FMT Coordinator Position Binder      FMT Coordinator Position Binder Tab Change #15 - Editorial change with no change of Tab Index                            Index intent.
Form CC-12, "County Exposure         Form 2, "Agency Personnel Exposure Tracking Sheet" (111.06, HP-11)      Log" (111.06, HP-11)                      This is a reference to a San Luis Obispo (SLO) County 6 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                      Content Change Change form. SLO County renamed the form and this change is being made to accurately reflect the new form name.
EOF Security Liaison Checklist     EOF Security Liaison Checklist Change #16 - Process change with no change of New content                        b. Coordinate with County for Early      intent.
Work Release and Site Evacuations.
This change is being made to reflect an enhancement request from the ERO. The security liaison may be available to support coordination of early work release I site evacuation. As such this guidance is being added to the checklist as an option to assist in the process if available. Refer to SAPN 5086829.
Communications Coordinator         Communications Coordinator Checklist     Change #17 - Editorial change with no change of Checklist
: 1. Initial Actions                       intent.
I 1. Initial Actions
: d. Obtain all Emergency Reflect title change made in 2012 for all DCPP IBEW
: d. Obtain all Emergency            Notification Forms (ENF) from the Physical Clerical staff from "Clerical" to "Administrative" Notification Forms (ENF) from      ENF software program.
and "Clerk" with "Admin". Refer to SAPN 50449609, the ENF software program.
: 1) Approved ENFs may be              Task 17.
: 1) Approved ENFs may be            obtained by clicking the "View/Edit obtained by clicking the           Archived Notification Form Events" "View/Edit Archived                link in the ENF software program.
Notification Form Events" link a) Have support staff (Admin) in the ENF software program.
distribute hard copies of all a) Have support staff               ENFs.
(clerks) distribute hard
: 2) Notify support staff (Admin) that copies of all ENFs.
7 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for
       /  Original Content                         Content Change Change you are to immediately receive
: 2) Notify support staff (clerks) copies of all emergency .
that you are to immediately notifications received by fax.
receive copies of all emergency notifications received by fax.
Communications Coordinator            Communications Coordinator Checklist Change #18 - Administrative change with no change Checklist
: 2. Ongoing Actions                      of intent.
: 2. Ongoing Actions NOTE: Notifications to the County and The statement "or less" already exists in EP G-3.
NOTE: Notifications to the            State are required to be completed Adding "or less" in this note brings EP EF-3 in line with County and State are required to      within 15 minutes from the time of a EP G-3 to provide better alignment between the be completed within 15 minutes        new eme~gency classification or PAR.
procedures.
from the time of a new emergency      Follow up notifications should be made classification or PAR. Follow up      within approximately 45 minutes or less notifications should be made          of the last notification.
within approximately 45 minutes of the last notification.
Communications Coordinator            Communications Coordinator Checklist    Change #19 _Editorial change with no change of Checklist
: 2. Ongoing Actions                      intent.
: 2. Ongoing Actions
: b. Oversee transmittal and Reflect title change made in 2012 for all DCPP IBEW
: b. Oversee transmittal and           distribution of notifications.
Physical Clerical staff from "Clerical" to "Administrative" distribution of notifications.
: 3) Provide or direct Offsite       and "Clerk" with "Admin". Refer to SAPN 50449609,
: 3) Provide or direct Offsite         Communicator to provide a copy of  Task 17.
Communicator to provide a            completed notification forms to coov of completed notification       EOF Admin Assistant for 8 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                                                     Change Number I Type of Change I Reason for Content Chan*ge Change forms to EOF Clerk for               distribution and posting.
distribution and posting.
Communications Coordinator          Communications Coordinator Checklist Change #20 - Editorial change with no change of Checklist
: 2. Ongoing Actions                      intent.
: 2. Ongoing Actions
: b. Oversee transmittal and The statement "or less" already exists in EP G-3.
: b. Oversee transmittal and          distribution of notifications.
Adding "or less" in this note brings EP EF-3 in line with distribution of notifications.
                     ,*                  4) Ensure follow-up emergency      EP G-3 to provide better alignment between the
: 4) Ensure follow-up                  notifications are issued           procedures.
emergency notifications are         approximately every 45 minutes or issued approximately every          less.
45 minutes.
Offsite Communicator Checklist      Offsite Communicator Checklist Change #21 - Editorial change with no change of
: 1. Initial Actions                  1. Initial Actions                      intent.
: f. Coordinate with EOF clerk   f. Coordinate with EOF Admin Reflect title change made in 2012 for all DCPP IBEW and UDAC clerk to ensure       Assistant and UDAC Admin Assistant Physical Clerical staff from "Clerical" to "Administrative" copies of ENFs are             to ensure copies of ENFs are and "Clerk" with "Admin". Refer to SAPN 50449609, immediately distributed to the immediately distributed to the EOF Task 17.
EOF staff upon receipt.        staff upon receipt.
Offsite Communicator Checklist      Offsite Communicator Checklist Change #22 - Editorial change with no change of
: 2. Ongoing Actions                  2. Ongoing Actions                      intent.
NOTE: Notifications to the          NOTE: Notifications to the County and The statement "or less" already exists in EP G-3.
County and State are required to    State are required to be completed Adding "or less" in this note brings EP EF-3 in line with be completed within 15 minutes      within 15 minutes from the time of a 9 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                        Content Change Change from the time of a new emergency     new emergency classification or PAR. EP G-3 to provide better alignment between the classification or PAR. Follow up     Follow up notifications should be made  procedures.
notifications should be made         within approximately 45 minutes or less within approximately 45 minutes      of the last notification ...
of the last notification.
Offsite Communicator Checklist       Offsite Communicator Checklist Change #23 - Editorial change with no change of
: 2. Ongoing Actions                   2. Ongoing Actions                      intent.
: b. Transmit, receive, and       b. Transmit, receive, and document The statement "or less" already exists in EP G-3.
document notification           notification information.
Adding "or less" in this note brings EP EF-3 in line with information.
: 8) Assist in completing follow-up       EP G-3 to provide better alignment between the
: 8) Assist in completing         emergency notifications to be issued    procedures.
follow-up emergency             approximately every 45 minutes or notifications to be issued      less.
approximately every 45 minutes.
Government Relations                 Government Relations Coordinator Change #24 - Administrative change with no change Coordinator Checklist                Checklist of intent.
: 1. Initial Actions                   1. Initial Actions Reflect specific location in General Office of Emergency
: g. Provide initial notification      g. Provide initial notification to Operations Center where videoconference and to company personnel as              company personnel as follows:
teleconference capability exists. Videoconference is set follows:
: 2) Initiate videoconference or     up with automatic connection to this location. This
: 2) Initiate videoconference or       teleconference contact with        change enhances the capability to effectively teleconference contact with           government relations         -    communicate with the General office.
government relations                  representatives in Sacramento, 10 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                     Content  Chang~
Change representatives in               Washington, and PG&E General Sacramento, Washington,          Office Emergency Operations and PG&E General Office to       Center (EOC) to provide initial provide initial event status     event status and establish a and establish a schedule for     schedule for communications communications updates.          updates.
New content                     Government Relations Coordinator Change #25 - Process change with no change of Checklist intent
: 1. Initial Actions Role of GOTL is evolving as the Company Emergency
: h. Make contact with General Response Plan (ERP) is developed. ERP designates Office Technical Liaison (GOTL) point at which the Company EOC will activate in the and request that they report to event of an incident at DCPP. If Company EOC is PG&E General Office and act as a activated they expect a Nuclear Liaison to respond to liaison to company EOC.
the EOC to provide information between the EOF and
: 1) Maintain contact with GOTL to   EOC. The GOTL acts as the Nuclear Liaison. The ensure that they are kept informed Government Relations Coordinator provides the link to of event status.                   the GOTL for providing information on the event. Both the Government Relations Coordinator and GOTL checklists are being revised to support this change.
This revision is necessary to clarify information exchange and dissemination between the EOF and the Company EOC.
This is not a change of intent within the E-Plan as the responsibilities have not changed. The change adds clarity and alignment with the ERP.
11 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                     Content Change Change Government Relations              Government Relations Coordinator Change #26 - Process change with no change of Coordinator Checklist             Checklist intent
: 2. Continuing Actions             2. Continuing Actions Role of GOTL is evolving as the Company Emergency
: a. Monitor actions and events a. Monitor actions and events from Response Plan (ERP) is developed. ERP designates from EOF to provide           EOF to provide information to other point at which the Company EOC will activate in ~he information to other          government relations representatives, event of an incident at DCPP. If Company EOC 1s government relations          GOTL and JIC personnel.
activated they expect a Nuclear Liaison to respond to representatives, and JIC the EOC to provide information between the EOF and personnel.
EOC. The GOTL acts as.the Nuclear Liaison. The Government Relations Coordinator provides the link to the GOTL for providing information on the event. Both the Government Relations Coordinator and GOTL checklists are being revised to support this change.
This revision is necessary to clarify information exchange and dissemination between the EOF and the Company EOC.
This is not a change of intent within the E-Plan as the responsibilities have not changed. The change adds clarity and alignment with the ERP.
Government Relations              Government Relations Coordinator Change #27 - Editorial change with no change of Coordinator Checklist             Checklist intent.
: 2. Continuing Actions             2. Continuing Actions Change title of Policy Group Chair to Company EOC
: d. Update the Policy Group         d. Update the Company EOC Incident Commander and specify GOTL rather than Chair of designee, and             Incident Commander or GOTL (if designee to reflect updates in the Company Emergency External Communications            activated), and External 12 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                     Content Change Change and Coordination Center           Communications and Coordination      Response Plan. Refer to SAPN 50449609, Task 25.
(EXCCC) (if activated) at         Center (EXCCC) (if activated) at least every classification        least every classification change of change of the following:          the following:
: e. Obtain information from the    e. Obtain information from the Policy Group Chair (or            Company EOC Incident designee) regarding:              Commander or GOTL (if activated), regarding:
Government Relations               Content moved to section 1.h Change #28 - Process change with no change of Coordinator Checklist intent.
: 2. Continuing Actions Content moved to initial actions. The role of the GOTL
: f. IF requested by Policy evolved when the Company Emergency Response Plan Group Chair (or designee) to (ERP) was modified to comply with the Incident provide a liaison at company Command System (ICS). The ERP designates point at EOC or PG&E General which the Company EOC will activate in the event of an Office, incident at DCPP. If Company EOC is activated they THEN contact General Office expect a Nuclear Liaison to respond to the EOC to Technical Liaison to report to provide information between the EOF and EOC. This is PG&E General Office.
an automatic action and does not need to be requested.
This is not a change of intent within the E-Plan as the responsibilities have not changed. The change adds clarity and alignment with the ERP.
13 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                       Content Change Change Government Relations               Government Relations Coordinator Change #29 - Editorial change with no change of Coordinator Checklist              Checklist intent.
: 2. Continuing Actions              2. Continuing Actions This change is correcting a typo which left off a letter.
: g. Communicate PG&E public          g. Communicate PG&E public information from JIC to             information from JIC to County County EOC and EOF                  EOC and EOF personnel.
personnel.
: 1) Represent JIG in interactions
: 1) Represent JIC in                 with EOF and County Public interactions with EO and            Information Manager (PIM) in County Public Information           EOG.
Manager (PIM) in EOC.
EOF Security Checklist             EOF Security Checklist Change #30 - Editorial change with no change of
: 1. Initial Actions                 1. Initial Actions                      intent.
: c. Initiate and maintain a     c. Initiate and maintain a position log This change is correcting a grammatical error.
position log (use Emergency   (use Emergency Log Sheets) to*
Log Sheets) to documenting    documentffi&sect;-significant actions significant actions performed performed and communications related and communications related    to your position. REFER TO Tab 1.
to your position. REFER TO Tab 1.
EOF Security Checklist             EOF Security Checklist Change #31 - Administrative change with no change
: 1. Initial Actions                 1. Initial Actions                      of intent.
: e. Setup                            e. Setup 14 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                       Content Change Change
: 1) Use Attachment 3,                1) Use Attachment 3, "Emergency This change is being made as he position vests contain "Emergency Operations               Operations Facility Security Set an ID of the position and the need for ID badges is Facility Security Set Up," of       Up," of this procedure as guidance redundant. In addition, PG&E is no longer responsible this procedure as guidance to       to position access tables and for checking in county staff or visitors. PG&E is only position access tables and          chairs at facility entry point.
responsible for maintaining a list of PG&E and NRC chairs at facility entry point. REFER TO Tab 2.
personnel that are reporting to the EOF. None o_f ~~~
REFER TO Tab 2.
: 2) Obtain position vests, tables    changes to this checklist change or add respons1b1ht1es
: 2) Obtain position vests and        and chairs and ID badges.           and there is no impact on the E-Plan. Refer to SAPNs ID badges.                                                             50872169 and 5082167.
31 Locate access list. and EOF ID
: 3) Locate access lists and           badges.
EOF ID badges.
EOF Security Checklist              EOF Security Checklist Change #32 - Process change with change of intent
: 2. Ongoing Actions                  2. Ongoing Actions This change is needed to bring the procedure up to date
: a. Provide building access          a. Provide building access controls with upgrades that have occurred. The position vests controls for PG&E and              for PG&E and NRC personnel contain an ID of the position and the reed for ID badges NRC personnel to EOF.              to EOF.
is redundant. In addition, PG&E is no longer
: 1) Check for proper access          1) Check for proper access          responsible for checking in county staff or visitors.
identification:                     identification:                     PG&E is only responsible for maintaining a list of PG&E a) PG&E ID badge.                   a) PG&E ID badge.         and NRC personnel that are reporting to the EOF.
None of the changes to this checklist change or add b) EOF ID badge.                    b) EOF ID badge.          responsibilities and there is no impact on the E-Plan.
             .c) NRC ID badge.                    c) NRC ID badge .         Refer to SAPNs 50872169 and 5082167.
d) Name appears on                  d) Name appears on visitor list.                       visitor list.
: 2) Record entry and exit time      2) Record entrv and exit time of 15 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                     Content Change Change of individuals entering and        individuals entering and exiting exiting EOF                        EOF on access list.
: 3) Personnel not having            a) Do not delay facility activation to approved ID or on access list      record entry times. Allow PG&E may be granted access by           badged personnel to bypass, and EOF Director.                      obtain entry times from EOF sign-in board after facility activation.
EOF Administrative Support         EOF Administrative Support Checklist Change #33 - Editorial change with no change of Checklist
: 1. Initial Actions                          intent.
: 1. Initial Actions
: e. Coordinate with other Reflect title change made in 2012 for all DCPP IBEW
: e. Coordinate with other           Administrative staff and Physical Clerical staff from "Clerical" to "Administrative" Clerical staff and Emergency       Emergency Director and "Clerk" with "Admin". Refer to SAPN 50449609 Director Administrative            Administrative Assistant to Task 17.
Assistant to assume one of         assume one of the following the following support roles:       support roles:
: 1) EOF Clerk (REFER TO             1) EOF Adm in Assistant (REFER step 2.b)                          TO step 2.b)
: 2) UDAC Clerk (REFER TO            2) UDAC Admin Assistant steps 1.f and 2.c)                 (REFER TO steps 1.f and 2.c)
: f. UDAC Clerk:                     f. UDAC Admin Assistant:
: 1) Report to Radiological          1) Report to Radiological Manager and inform him or          Manager and inform him or her her that you are performing        that you are performing UDAC UDAC Clerk duties.                 Admin Assistant duties.
16 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                     Content Change
                                                                                       .                              Change EOF Administrative Support        EOF Administrative Support Checklist Change #34 - Editorial change with no change of Checklist
: 2. Ongoing Actions                      intent.
: 2. Ongoing Actions
: b. EOF Admin Assistant:
Reflect title change made in 2012 for all DCPP IBEW
: b. EOF Clerk:
: c. UDAC Admin Assistant:          Physical Clerical staff from "Clerical" to "Administrative"
: c. UDAC Clerk:                                                      and "Clerk" with "Admin". Refer to SAPN 50449609,
: d. Position Relief Turnover
: d. Position Relief Turnover                                         Task17.
: 3) Notify the individual specified
: 3) Notify the individual         that you have turned over your specified that you have          ERO responsibilities.
turned over your ERO a) EOF Admin Assistant - notify responsibilities.
EOF Director a) EOF Clerk - notify EOF b) UDAC Admin Assistant-Director notify Radiological Manager b) UDAC Clerk- notify Radiological Manager EOF Clerical Support Position     EOF Administrative Support Position Change #35 - Editorial change with no change of Binder Tab Index                  Binder Tab Index intent.
EP EF-3, Form 69-21134, "EOF      EP EF-3, Form 69-21134, "EOF Clerical Support Checklist"       Administrative Support Checklist"       Reflect title change made in 2012 for all DCPP IBEW Physical Clerical staff from "Clerical" to "Administrative" and "Clerk" with "Admin". Refer to SAPN 50449609, Task 17.
17 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018
                                                                                *Change Number I Type of Change I Reason for Original Content                        Content Change Change Emergency Director Admin            Emergency Director Admin Assistant Change #36 - Administrative change with no change Assistant Checklist                 Checklist of intent
: 1. Initial Actions                  1. Initial Actions Change is being made to align with position
: c. Check in with ED and                c. Check in with ED and EOF expectations and to reorder steps for clarity. This is not EOF Director.                          Director.
a change of intent within the E-Plan as the
: 1) Confirm role expectations          d. Maintain Phone coverage.      responsibilities have not changed. The change adds .
for:                                                                   clarity and alignment.
: e. Verify that the EOF director a) Phone Coverage                  has assigned individuals to b) White board                     maintain status boards.
communications (Admin.             f. Maintainffi9 ED log.
Assistant or EOF Director).
c) Maintaining ED log.
Emergency Director Admin            Emergency Director Admin Assistant Change #37 - Editorial change with no change of Assistant Checklist                 Checklist intent.
: 1. Initial Actions                  1. Initial Actions Reflect title change made in 2012 for all DCPP IBEW
: e. Assign clerical to                 e. Assign administrative support Physical Clerical staff from "Clerical" to "Administrative" location/department as                to location/department as and "Clerk" with "Admin". Refer to SAPN 50449609, needed:                                needed:
Task 17.
: g. Contact Administrative Advisor at Tse;.
: g. Contact Administrative
: 1) Administrative Advisor                   Advisor at TSC.
may provide:
: 1) Administrative Advisor may a) Additional clerical                    'Provide:
18 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                       Content Change Change support for the EOF.
a) Additional
: 2. Ongoing Actions                                 administrative support for
: b. Ensure EOF clerical                    the EOF.
staff is adequate to      2. Ongoing Actions support ERO functions.
: b. Ensure EOF administrative support is adequate to support ERO functions.
General Office Technical Liaison   General Office Technical Liaison Change #38 - Process change with no change of Checklist                          Checklist intent.
: 1. Initial Actions                 1. Initial Actions The role of the GOTL evolved when the Company
: g. IF requested by Policy         g. IF requested report to Emergency Response Plan (ERP) was modified to Group Chair (or designee)         Company EOG and act as comply with the Incident Command System (ICS). T~e to provide a liaison at            liaison.
ERP designates point at which the Company EOC will company EOD or PG&E
: h. Upon arrival at Company         activate in the event of an incident at DCPP. If General Office, EOG, establish contact with the    Company EOC is activated they expect a Nuclear THEN report to PG&E                following:                         Liaison to respond to the EOG to provide information General office.                                                      between the EOF and EOC. This is an automatic action
: 1) Incident Commander
: 2. Continuing Actions                                                         and does not need to be requested.
2)0perations Section Chief
: a. Monitor actions and The change adds clarity and alignment with the ERP.
events from EOF to                 i. Provide event status update to provide information to               the Company EOG.
corporate response.                j. Contact Government personnel.
Relations Coordinator in EOF
: 1) Coordinate with EOF               to remain current on events Director and Engineering             and response actions taking Liaison to develop                   place at site.
19 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                      Content Change
* Change information about
: 2. Continuing Actions
* significant emergency
: a. Monitor actions and events events.
from EOF to provide information to corporate response                                                     -
: c. Evaluate and respond to personnel.
external company issues
: 1) Coordinate with Government and inform the ED of Relations. Coordinator to corporate status and develop information about decisions.
significant emergency events.
: d. Assist the Government
: c. Evaluate and respond to Relations Coordinator with external company issues and updating the Policy Group inform the Government Chair, or designee, and Relations Coordinator of External Communications corporate status and decisions.
and Coordination Center (EXCCC) (if activated) at
: d. Update the Company EOC least every classification Incident Commander, or change of the following:
designee, and External Communications and
: e. Position Relief Turnover Coordination Center (EXCCC)
: 3) Notify EOF Director that (if activated) at least every you have turned over your classification change of the ERO responsibilities.
following:
: e. Position Relief Turnover
: 3) Notify Government Relations Coordinator that you have turned over your ERO 20 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content                        Content Change Change responsibilities.
General Office Technical Liaison      General Office Technical Liaison Change #39 - Administrative change with no change Checklist                             Checklist of intent
: 3. Situation Actions                  3. Situation Actions Content was moved into Sections 1.g, h, I, and j of the
: a. IF travel to the corporate    Content relocated to Section 1.g, h, i checklist as position is expected to travel to Company emergency operations         and j.
Emergency Operations Center upon request. Role of center has been GOTL is evolving as the Company Emergency requested, Response Plan (ERP) is developed. ERP designates THEN upon arrival at G.O.
point at which the Company EOC will activate in ~he EOC, establish contact event of an incident at DCPP. If Company EOC 1s with the following:
activated they expect a Nuclear Liaison to respond to
: b. Corporate Security                                                   the EOG to provide information between the EOF and EOG. This is now an initial action as opposed to a
: c. Lead officers in the situational specific.
Operations group
: d. Officers in the policy group
: e. Provide lead officers status update.
: f. Contact Government Relations Coordinator in                                                    '
EOF to remain current on events and response actions taking place at site.
/
21 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                                                        Change Number I Type of Change I Reason for Content Change Change 4 FMT Briefing         Attachment 24 FMT Briefing Sheet Part Change #40 - Administrative change with no change Sheet Part 2                       2 of intent New content                        Verify thateach FMT member completes Record of Distribution of       This change is being made to ensure that Kl Potassium Iodide (Kl) form 69-9395        Authorization for the PG&E Field Monitoring Teams and review the Kl Consumer Package        (FMT) is documented and that FMTs are provided the Insert. Tell them "Do not ingest Kl until IOSAT Kl pharmaceutical precautions as directed by directed".                                EP RB-3. In addition this change adds in missing language with respect to turn-back values. These changes clarify and align requirements with EP RB-3.
Gamma instrument exposure rate            There is no effect on the implementation of the E Plan.
turn-back values:
20 mr/hr for offsite FMTs unless told otherwise
                       /
                    ,'             200 mr/hr for onsite FMTs unless told otherwise Communications Coordinator         Communications Coordinator Checklist Change #41 - Editorial Change with no change in Checklist 1.lnitial Actions                         intent.
1.lnitial Actions
: g. Perform the following bridge line Change is being made to correct a typo in a position,
: g. Perform the following           monitoring actions:
title. Refer to SAPN 50449609, Task 27.
bridge line monitoring 2)Monitor or have the Offsite actions:
Communicator monitor bridge line 2)Monitor or have the Offsite      x2002 Coordinator monitor bridge line x2002 22 of 23

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Original Content
* Content Change Change 0 Dose Assessment        Attachment 30 Dose Assessment Data Change #42 - Editorial change with no change in Data Sheet                           Sheet intent.
ESE distribute copies to:            Admin Assistant distribute copies to:
Change is being made to correct an obsolete position title and replace with appropriate position title. Refer to SAPN 50449609, Task 13.
: 3. RESPONSIBILITIES                  3. RESPONSIBILITIES Change #43 - Administrative change with no change 3.1 O EOF security liaison is        3.1 O EOF security liaison is         of intent.
responsible for:                     responsible for:
This change is being made to align EP EF-3 with 3.10.2 This position is not an       3.10.2 Deleted content Section 5 of the E-Plan step 3.10.2 is no longer ERO minimum staff or ERO necessary as Revision 4.15 to E-Plan Section 5 made support staff position. This the Security Liaison position an ERO support staff position serves an advisory position. Refer to SAPN 50449609, Task 14.
role only and would be called out as needed.
23 of 23

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

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP EF-9, Revision 12 Original Content                                Content Change                     Change Number I Type of Change          I Reason for Change N/A                                            Procedure converted to new template.              Change #1 - Editorial change with no Editorial changes made throughout                 change of intent.
procedure.                                        Converted procedure to new template and made editorial changes to align with AD1 .ID1 requirements.
Section 2.1                                    Section 2.1                                       Change #2 - Process change with no The characteristics of an alternative facility The characteristics of a backup facility          change of intent.
should include: 1) accessibility, 2)           should include:                                   SAPN 50432078, Task 3, states that communication links with the EOF, control                                                        EP EF-9 should be revised to replace
* Accessibility room, and security [ ... ] plan mitigative                                                       the term ~lternative with backup so as actions).
* Communication links with other              to reduce confusion between the two.
facilities (e.g. EOF) control rc;>om, and security                                  EP Rulemaking established a new definition of alternate facility, and the
                                                   * [ ... ]                                     alternate TSC/OSC is discussed in
* plan mitigative actions) .                  EP EF-11, not EP EF-9. Replacing alternative with backup restores the original intent, which is aligned with the DCPP E-Plan as well as industry guidance.
Section 2.3                                    Section 2.3                                       Change #3 - Process change with Designated on-site ERFs and their backup       Designated ERFs and their backup facilities       change of intent.
facilities include the following:              include the following:                            During the Ocean PAR Root Cause Extent of Condition, it was determined 1 of 8

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                           Content Change                     Change Number I Type of Change          I Reason for Change ERF      Prim       First   Second         ERF     Prim          First   Second    that DCPP was not fully implementing Function    ary     Backup    Backup       Function   ary        Backup    Backup    the commitment in the E-Plan for a Facili                                     Facili                          backup Emergency Operations Facility ty                                        ty                            (EOF). This was documented in SAPN 50627794, tasks 11 and 78, and is now Control   Con tr    Hot S/D    (None)       Control Con tr     SM/SFM -    (None)    being tracked via SAPN DA 50796556.
Room        al      Panel                  Room       al        Hot S/D             Section 7 .1. 7 .2 of the E-Plan (Revision Rao    (SM/SFM);                          Rao          Panel              4.20) states that the Energy Education m      TSC (SM,                            m       SM, STA,              Center (EEC) is the first choice for a STA, SFM)                                       SFM-               backup EOF, and Section 7.1.8.2 states TSC                that the Electrical Control Center TSC      TSC      Control   Hot S/D Room       Panel_       TSC     TSC       Min. Staff-    Min. Operations (ECCO) could be used as a (Min.      (Min.               - 104'       Control    Staff -  backup location for the EOF.
Staff);   Staff.);              Buttr        Room     Hot S/D   This revision adds the EOF as a TM/Trng. EOF                   ess        Support     Panel   designated ERF and identifies the first Bldg.    (Supper                Area         Staff -  Support   backup as the EEC, and the second (Supp.)       t)    )
Bldg. 109    Staff -  backup as SLO ECCO. This ensures EOF     that the commitment in the DCPP.
OSC-      osc        140'    Adminis                                                E-Plan is fully implemented.
Command    - 104'    Turbine    tration      OSC-     osc           140'    Adm in is Note that SAPN 50432078, Task 4, also Center    Buttr   Building - Building    Command   - 104'       Turbine    tration ess                                                                       documents that the EEC should be Northeast    Room        Center   Buttr      Building - Building listed as the first choice for the backup Area      Corner       215                  ess      Northeast    Room EOF.
Area        Corner       215 OSC- Mai   osc         140'    Canyon ntenance   - 104'    Turbine   Rm/Trn      OSC- Mai   osc           140'    Canyon    SAPN 50432078, Task 2, states that Assembly    Buttr   Building -  g Bldg     ntenance  - 104'       Turbine . Rm or    ''TM/Trng Bldg" is vague, and Area     ess     Northeast                 Craft   Buttr      Building - Training  recommends that it should be referred Area     Corner                Assembly    ess      Northeast     Bldg. to as "Bldg. 109." This revision also Area    Area        Corner       109 2 of 8

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original~                                  Content Change                             Change Number I Type of Change         I
                                         ------------------                                                 Reason for Change
                                           ~                         .
CR/OSC-     Con tr     OPs       119'     CR/OSC-      Con tr       OPS
                                                                                - - 19~- --  incorporates this enhancement, as well Nuclear      cl      Ready    Turbine      Nuclear      cl        Ready            Work      -as-otheLs to clarify locations and Operator    Roe       Room    Building    Operator    Roe         Room           Control      increase reaaability.____ --
Assembly      m                Ofc/Cyn    Assembly       m                         Center      The words "on-site" were removed; as_ -
Area                           Rm          Area                                     or       the EOF is not onsite and it is no longer Canyon       applicable.
OSC-        85'       140'     TSC Rm        These changes are being made to align C&RP      Acee      Access     Lab with the current DCPP E-Plan, or are Technicia     SS      Control               OSC-        85'         140'            TSC clearly enhancements for procedure n      Contr                           C&RP       Acee        Access            Lab usability; therefore, there is no impact Assembly       cl                         Technicia      SS        Control on how the E-Plan meets the planning Area                                         n       Contr standards, functions or elements.
Assembly       al Area EOF       EOF         Energy           SLO Education       ECCO-Center-          PG&E Ontario        Service Road           Center S.
Higuera Section 2.4                               Section 2.4                                           Change #4 - Process change with Control Room Function, TSC Function, &    Control Room Function & TSC Function                  change of intent.
Access Control Function Tables            Tables                                                SAPN 50432078, Task 5, documents that EP EF-9 should be updated to
* Deleted "Black Net phone" remove "Black Net phones," that were Access Control Function Table 3 of 8

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content        Content Change        Change Number I Type of Change           I Reason for Change
* Changed "PICs" to "PEDs" removed from the Control Room and have not been in service since 2001.
This is documented in AR A0503950.
     )
The Black Net function provided a direct link between the Control Room and the County and State EOC - this capability remains available today via automatic tie lines (ATL).
Removal of the Black Net phone system was previously evaluated under 10 CFR 50.54q 2015-65. The current E-Plan makes no mention of the Black Net system. The Black Net function provided a direct link between the CR and the County Emergency Operations Center (EOC) and the State EOC. This capability remains available today via dedicated lines; it just isn't called Black Net anymore. The proposed change removes a piece of equipment that has not been used since at least 2001. All other existing phone capabilities will remain available and unchanged.
Therefore, the proposed change continues to provide for the requisite systems for prompt communication to emergency response personnel.
PICs were changed to PEDs as PICs are obsolete.
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Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content             Content Change         Change Number I Type of Change          I Reason fQr Change The proposed change is being made to ensure that the procedure remains technically accurate by removing a piece of equipment that is no longer used.
Section 4.2                  Section 3.2                      Change #5 - Process change with NIA - New content            Added "EOF I Emergency Director" change of intent.
During the Ocean PAR Root Cause Extent of Condition, it was determined that DCPP was not fully implementing the commitment in the E-Plan for a backup Emergency Operations Facility (EOF). This was documented in SAPN 50627794, Tasks 11 and 78, and is now being tracked via SAPN DA 50796556.
Section 7 .1. 7 .2 of the E-Plan (rev 4.20) states that the Energy Education Center (EEC) is the first choice for a backup EOF, and Section 7.1.8.2 states that the Electrical Control Center Operations (ECCO) could be used as a backup location for the EOF.
EP EF-9 is being revised to incorporate the backup EOF. This change is being made to fully implement the backup EOF, and as such, the E-Plan commitment.
5 of 8

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                          Content Change                  Change Number I Type of Change          I Reason for Change There is no impact on how the E-Plan meets the planning standards, functions or elements.
Section 5.1                               Section 6.1                                Change #6 - Editorial change with no A backup ERF shall be activated when an   A backup ERF shall be activated when a     change of intent.
ERF is determined uninhabitable or        primary ERF is determined uninhabitable or "Primary" being added for clarification otherwise may not start up or continue    otherwise may not start up or continue     only - no change of intent.
operations: See Section 2.1 above for the operations. See Section 2.1 above for the recommended succession of ERFs.           recommended succession of ERFs.
Section 5.3                               Section 6.4                                Change #7 - Process change with 5.3.1 Backup Control Room:                6.4.1 Backup Control Room: OP AP-BA    change of intent.
OP AP-BA                                  6.4.2 Backup TSC: Attachment 1         During the Ocean PAR Root Cause 5.3.2 Backup TSC: Attachment 7 .1         6.4.3 Backup OSC: Attachment 2         Extent of Condition, it was determined that DCPP was not fully implementing 5.3.3 Backup OSC: Attachment 7.2          6.4.4 Backup Access Control:           the commitment in the E-Plan for a 5.3.4 Backup Access Control:              Attachment 3                           backup Emergency Operations Facility Attachment 7.3                            6.4.5 Backup EOF: Attachment 5         (EOF). This was documented in SAPN 50627794, Tasks 11 and 7B, and is now being tracked via SAPN 50796556.
Section 7 .1. 7 .2 of the E-Plan (Revision 4.20) states that the Energy Education Center (EEC) is the first choice for a backup EOF, and Section 7.1.B.2 states that the Electrical Control Center Operations (ECCO) could be used as a 6 of B

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content                                Content Change                     Change Number I Type of Change      I Reason for Change backup location for the EOF.
EP EF-9 is being revised to incorporate the backup EOF. This change is being made to fully implement the backup EOF, and as such, the E-Plan commitment.
There is no impact on how the E-Plan meets the planning standards, functions or elements.
Section 6, Records                            Section 7.1 & 7.2, Records                      Change #8 - Editorial change with no Checklists completed due to use of this       Documents generated by this procedure           change of intent.
procedure in a drill or actual event shall be during drills are non-quality records and are   Updated the records section to align forwarded to the Emergency Planning           maintained per emergency preparedness           with other E-Plan Implementing Manager for entry into Records                administrative procedures.                      Procedures and AD10.ID2. This Management System.                            Documents generated by this procedure           change aligns the EP EF-9 with the during actual events are non-quality records    current plant process.
and are maintained for the life of the plant, per AD10.102, "Storage and Control of Non-quality Assurance Records."
Attachments 1, 2, 3, and 4                    Reformatted attachments 1, 2, 3, and 4 in       Change #9 - Editorial change with no accordance with AD1 .101 requirements for       change of intent.
new template.                                   Attachments reformatted to comply with AD1 .101 requirements. Editorial changes were made throughout attachments as well.
7 of 8

Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Original Content              Content Change         Change Number I Type of Change          I Reason for Change N/A - New Content           Attachment 5                      Change #10 - Process change with Added new attachment, "Backup EOF change of intent.
Activation"                       During the Ocean PAR Root Cause Extent of Condition, it was determined that DCPP was not fully implementing the commitment in the E-Plan for a backup Emergency Operations Facility (EOF). This was documented in SAPN 50627794, Tasks 11 and 78, and is now being tracked via SAPN 50796556.
Section 7 .1. 7 .2 of the E-Plan (Revision 4.20) states that the Energy Education Center (EEC) is the first choice for a backup EOF, and Section 7.1.8.2 states that the Electrical Control Center Operations (ECCO) could be used as a backup location for the EOF.
EP EF-9 is being revised to incorporate the backup EOF. This change is being made to fully implement the backup EOF, and as such, the E-Plan commitment.
There is no impact on how the E-Plan meets the planning standards, functions or elements.
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