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

and Independent Spent Fuel Storage Installation - Emergency Plan Implementing Procedures Updates

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

Text

Pacific Gas and Electric Company"'

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

691.6300 Fax: 605.545.6265 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 November 17, 2016 Page2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Enclosure Title 5 6 7 8 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 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 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 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 Proc. No. OM10.ID1 OM10.DC1 EP G-1 EP G-2* EP G-3* EP G-4* EP G-5 EP OR-3 EP RB-1 EP RB-2 EP RB-3 EP RB-4 EP RB-5 EP RB-8 EP RB-9 EP RB-10 EP RB-11 EP RB-12 EP RB-14 EP RB-14A EP RB-15 EP RB-16 EP R-2 EP R-3 EP R-7 EP EF-1* EP EF-2* EP EF-3* EP EF-4 EP EF-9* EP EF-10 EP EF-11 Enclosure 1 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Rev. 14 8 44 50 59 29 14 10 8 8 7 5 8 27 15 19 14 11 9 2 15 14 33 9 16A 52 39 44 20 12 17 2 Title Maintaining Emergency Preparedness Emergency Preparedness Drills and Exercises Emergency Classification and Emergency Plan Activation Interim Emergency Response Organization Emergency Notification of Off-Site Agencies Assembly and Accountability Evacuation of Non-Essential Site Personnel Emergency Recovery Personnel Dosimetry Emergency Exposure Guides Stable Iodine Thyroid Blocking Access to and Establishment of Controlled Areas Under Emergency Conditions Alternate Personnel Decontamination Facilities Instructions for Field Monitoring Teams Calculation of Release Rate Protective Action Recommendations Emergency Offsite Dose Calculations Plant Vent Iodine and Particulate Sampling During Accident Conditions Core Damage Assessment Procedure Initial Detection of Fuel Cladding Damage Post Accident Sampling System Operating Instructions for the EARS Computer Program Release of Airborne Radioactive Materials Initial Assessment Release of Radioactive Liquids Off-Site Transportation Accidents Activation and Operation of the Technical Support Center Activation and Operation of the Operational Support Center Activation and Operation of the Emergency Operations Facility Activation of the Off-Site Emergency Laboratory Backup Emergency Response Facilities Activation and Operation of the Joint Information Center Alternate Emergency Response Facilities/

Incident Command Post (ICP) *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 Attachment 1 -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. Attachment 1 -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. ' 1 of 31 Original Content Content Change Attachment 1 -step 1.c-1.c.7) Attachment 1 -step 1.b -1.b.4) c. Initiate ERO actions: b. Initiate ERO Actions NOTE: VANS should be activated NOTE:VANS should be activated immediately after an event immediately after an event declaration (Alert or higher). declaration (Alert or higher). 1) Ensure Communicator

1. 2 1) Direct Communicator

1. 2, or other activates VANS per Attachment qualified operator, to activate VANS 3. per Attachment

3. 2) Ensure Communicator

1. 1 2) Direct available operator to make completes the Emergency a Public Address Announcement Notification Form (ENF) for approval per Attachment 2.T 30899 per Attachment

6. 3) Direct available operator to send 3) Direct Shift Phone Talker to a SmartMSG message per make offsite verbal notifications to Attachment 1 o.T 6779 the County and State per Attachment 11.r 04380 4) Update the Control Room (unless time critical actions are being 4) Direct the Work Control Shift performed).

Foreman to initiate Attachment

4. Record Time: 5) Direct a Work Control Lead (WCL), or other licensed ,-operator, to initiate Attachment

5. 6) IF a General Emergency is declared, THEN determine AND approve protective action 2 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #3 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

Added in the phrase "or other qualified operator" for voice activated notification system (VANS) activation to account for situations in which Communicator

1. 2 may not activate VANS. Multiple operators are trained and qualified on the activation of VANS. This change aligns with E-Plan Section 5 and Appendix F for on-shift responsibilities.

The actions to make the PA announcement and send out the SmartMSG were moved up in the sequence of steps as they belong next to the activation of VANS as they are also means by which the ERO are notified .. Revision 49 step 1.c.3) was relocated to step 1.d.3) in Revision 50 based on reformatting of the attachment.

Revision 49 steps 1.c.4) and 1.c.5) were relocated to steps 1.e.1) and 1.e.2) respectively in Revision 50 based on reformatting of the attachment.

Revision 49 step 1.c.6) was relocated to step 1.c.1) in Revision 50 based on reformatting of the attachment.

Revision 49 step 1.c. 7) was relocated to step 1.e.3) in Revision 50 based on reformatting of the attachment.

There is no change of intent as all of the actions are still beina performed.

The relocation of the steps from j Original Content Content Change recommendation (PAR) per EP RB-10. 7) Initiate logging declarations and actions taken. Attachment 1 -step 1.c.6) Attachment 1 -step 1.c -1.c.1 ).a) NIA-new content added c. Emergency Protective Actions [TIME CRITICAL]

6) IF a General Emergency is 1) IF GENERAL EMERGENCY declared, declared, THEN determine THEN determine and approve AND approve protective action protective action recommendation recommendation (PAR) per EP (PAR) per EP RB-10. RB-10. NIA-new content added a) Obtain independent recommendation if time permits. 3 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Revision 49 to Revision 50 is acceptable because the attachment is a guideline and not necessarily a step by step sequence of instructions.

Many of the tasks get implemented in parallel, which is hard to reflect in the 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. Change #4 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

This change includes a new "bin" for PARs. Added in the "[TIME CRITICAL]" phrase to make it clear th_at PARs require a high level of attention.

Added in "Obtain independent recommendation if time permits" to be consistent with other implementing procedures for the TSC and EOF decision/makers.

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.

Original Content Content Change Attachment 1 -steps 1.c.2) and Attachment 1 -step 1.d -1.d.1 ).b) 1.c.3) d. Emergency Notifications

[TIME NIA-new content added CRITICAL]

NIA-new content added 1) Complete offsite notifications within 15 minutes of event declaration per EP G-3. 2) Ensure Communicator

1. 1 completes the Emergency a) Direct Communicator

1. 1 , or other Notification Form (ENF) for qualified operator, to complete the approval per Attachment 2.T 30899 Emergency Notification Form for approval per Attachment

2. 3089 3) Direct Shift Phone Talker to make offsite verbal notifications to b) Direct Shift Phone Talker, or the County and State other qualified operator, to make per Attachment 11.T 04380 offsite verbal notifications to the and State per Attachment 11.T04 80 Attachment 1 -Multiple steps Attachment 1 -step 1.e -1.e.3) NIA-new content added e. Additional Actions: 1.c.4) Direct Work Control Shift 1) Direct Work Control Shift Foreman (WCSFM) to initiate Foreman (WCSFM) to initiate Attachment

4. Attachment

4. 1.c.5) Direct a Work Control Lead 2) Direct Work Control Lead (WGL), (WGL), or other licensed or other licensed operator, to initiate 4 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #5 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

This change includes a new "bin" for emergency notifications.

Added in the phrase "or other qualified operator

for notifications to account for situations in which Communicator

1. 1 may not fill out the ENF. Multiple operators are trained and qualified on filling out the ENF. This change aligns with E-Plan Section 5 and Appendix F for on-shift responsibilities.

Added in the phrase "or other qualified operator" for notifications to account for situations in which Shift Phone Talker may not make the phone calls to the County and 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.

Change #6 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

This change includes a new "bin" for additional actions. Multiple steps were relocated.

There is no change of intent as all of the actions are still being performed.

The relocation of the steps from Revision 49 to Revision 50 is Original Content Content Change operator, to initiate Attachment

5. Attachment

5. 1.c.7) Initiate logging declarations and actions taken 3) Log declarations, decisions, and actions taken. . Attachment 1 -step 1.d -1.d.3) Attachment 1 -step 2.a -2.a.1 ).b) CA.UTION:

Special consideration CAUTION: Special consideration should be given to performing should be given to performing Assembly, Accountability and/or Assembly, Accountability and/or evacuation when the action place evacuation when the action place personnel in danger (security personnel in danger (security event, event, toxic gases, fires, weather toxic gases, fires, weather conditions, etc.). conditions, etc.). d. Inform plant personnel of the a. Assembly and Accountability emergency as follows: 1) IF SAE, GE, security event, or 1) IF SAE, GE, security event, or any other event warranting any other event warranting Assembly and Accountability, Assembly and Accountability as THEN initiate Assembly and determined by SM, Accountability PER EP G-THEN initiate Assembly and 4. T36223ff04336 Accountability PER EP G-4.T 36223 a) Record time of site emergency a) Record time of site emergency signal activation signal activation

2) IF not implementing EP G-4, b) Direct Communicator

1. 2, or other THEN direct an operator to available operator, to complete EP 5 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change acceptable because the attachment is a guideline and not necessarily a step-by-step sequence of instructions.

Many of the tasks getimplemented in parallel, which is hard to reflect in the 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 . Change #7 -Sponsor edit -no change in intent with respect to the E-Plan. The PA message and SmartMSG steps were relocated (see Change #3). Assembly and accountability actions were relocated from initial actions to subsequent actions based on reformatting of the attachment to "bin" like tasks with each other based on user feedback to improve performance.

This change includes a new "bin" for assembly and accountability.

There is no change of intent as all of the actions associated with assembly and accountability are still being performed.

The relocation of the steps from the last step of the initial actions to the first step of subsequent actions is acceptable because the attachment is a guideline and not necessarily a step-by-step sequence of instructions.

The intent of initial actions is to group 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 Original Content initiate Attachment 6, "Public Address Announcement Templates."T 35779 3) Direct an operator to send a pager message to the entire site through the SmartMSG system per Attachment 1 o.T 36779 Attachment 1 -step 2.b N/A-new content added b. Evaluate initiation of an early work release, or site evacuation. (Refer to EP G-5.)T 04336 Content Change G-4 (Form 69-13231), "Accountability Roster." Attachment 1 -step 2.b -2.b.2) b. Early Work Release and Site Evacuation

1) IF at a UE or Alert, THEN evaluate early work release per EP G-5.T04336

2) IF at a SAE or GE, THEN evaluate site evacuation per EP 8_5_T04336

• 6 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change 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 assembly an,d accountability.

This change continues to provide alignment with the content of the current E-Plan. Change #8 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

This change includes a new "bin" for early work release and site evacuation.

/ Added in specific criteria for early work release for the Unusual Event (UE) and Alert levels, which is when an early work release is applicable per EP G-5. Also added 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.

Original Content Attachment 1 -step 2.c N/A-new content added c. Authorize exceeding normal dose limits, if required. (Refer to EP RB-2.)ro4336 Attachment 1 -step 2.d N/A-new content added d. Authorize Kl administration, if reauired. (Refer to EP RB-3.) to4336 Attachment 1 -step 2.e N/A -new content added Content Change Attachment 1 -step 2.c -2.c.1) C. Emergency Exposures

1) Authorize exceeding normal dose limits, if required (PER EP RB 2.)T04336 -step 2.d -2.d.1) d. Administration of Kl 1) Authorize Kl administration, if required (PER EP RB-3.)r 04336 Attachment 1 -step 2.e -2.e.1) e. Control Room Habitability 7 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #9 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

This change includes a new "bin" for emergency 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. Change #10 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

This change includes a new "bin" for administration of 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. Change #11 -Sponsor edit -no change in intent with respect to the E-Plan. ' Reformatted the attachment to "bin" like tasks with each Original Content Content Change e. IF in Mode 3 (Recirc) 1) IF in Mode 3 (Recircj ventilation, ventilation, THEN evaluate need for sampling THEN evaluate need for sampling Control Room air quality for C02 Control Room air quality for Cb 2 build-up.

build-up. (REFER to OP H-5:1V). (REFER to OP H-5:1V). Attachment 1 -step 2.f Attachment 1 -step 2.f-2.f.1) N/A-new content added f. Other Duties f. Authorize overtime and other 1) Authorize overtime and other expenses associated with expenses associated with establishing and maintaining an establishing and maintaining an appropriate site emergency appropriate site emergency organization.

organization. -step 2.h Attachment 1 -step 2.g -2.g.1) N/A content added g. Emergency Termination

h. For termination of an 1) For termination of an UNUSUAL UNUSUAL EVENT, initiate EVENT, initiate Attachment 7 (Form Attachment 7 (Form 69-21273), 69-21273), "Guidelines for "Guidelines for Terminating an Terminating an Unusual Event." Unusual Event" 8 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change other based on user feedback to improve performance.

This change includes a new "bin" for control room habitability.

This change continues to provide alignment with the content of the current E-Plan. Change #12 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

This change includes a new "bin" for other duties. This change continues to provide alignment with the content of the current E-Plan. Change #13 -Sponsor edit-no change in intent with respect to the E-Plan. Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

This change includes a new "bin" for emergency termination.

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.

Original Content Content Change Attachment 1 -step 2.g -2.g.2) Attachment 1 -step 2.h -2.h.1 ).c) NIA -new content added h. Command and Control Turnover g. When ready to turn over 1) WHEN the SEC or ED is ready to Command and* Control of the take command and control, emergency, then perform all of THEN: the following:

a) Use EP EF-1 (Form 69-20437), 1) Use EP EF-1 (Form 69-20437), "Command and Control Turnover "Command and Control Turnover Checklist" to turnover Checklist," to turnover responsibilities responsibilities.

b) Update the CR that you have NIA -new conter:it added turned over command and control and include which duties the CR is responsible for. 2) Ensure that copies of ENFs c) Ensure that copies of ENFs created in the Control Room have created in the Control Room have been provided to the been provided to the TSC and EOF. TSC and EOF. Attachment 1 -step 3.a -3.a.1) Attachment 1 -step 3.a -3.a.2).a)_

& 3.b-3.b.1)

NIA-new content added a. Plant Monitoring and Assessment

a. Continue reviewing EP G-1 1) Continue reviewing EP G-1 EAL EAL criteria.

criteria.

1) Report any potential changes a) Report changes in any of the in event classification to the Site following to the Site Emerqency 9 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #14 -Sponsor edit-no change in intent with respect to the E-Plan. Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

This change includes a new "bin" for command and control turnover.

Step was also relocated from 2.g to 2.h to improve flow. This is a subsequent action that has no time requirement; therefore, there is no impact on relocating it. Added in a new step for the Shift Manager (SM) to update the crew on the transfer of command and control to enhance the guidance for improved recognition of what E-Plan tasks the control room is responsible for after turnover.

This change continues to provide alignment with the content of the current E-Plan. Change #15 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

This change includes a new "bin" for plant monitoring and assessment.

Steps 3.a and 3.b from Revision 49 were combined into *step 3.a in Revision 50. Both of these tasks are ongoing Original Content Emergency Coordinator or Emergency Director (2002 Bridgeline is preferred).

b. Monitor radiological effluent conditions.

1) Report significant changes to the Radiological Advisor in the TSC (2002 Bridgeline is preferred).

Content Change Coordinator or Emergency Director (2002 Bridgeline is,preferred):

• Escalations in event classification

• Concurrent EAL thresholds that are met 2) Continue monitoring radiological effluent conditions.

a) Report significant changes in r(!diological effluent conditions to the Radiological Advisor in the TSC (2002 Bridgeline is preferred). -steps 3.c and 3.d Attachment 1 -step 3.b -3.b.2) N/A-new content added c. Assist the TSC in determining station priorities for repair and mitigation actions onsite (2002 Bridgeline is preferred).

d. Brief the TSC Operations Advisor of significant changes in plant/system/

equipment status and actions being taken in the Control Room. Attachment 1 -step 3.e N/A -new content added b. Plant Priorities

1) Assist the TSC in determining station priorities for repair and mitigation actions onsite (2002 Bridgeline is preferred).

2) Brief the TSC Operations Advisor of significant changes in plant/system/equipment status and actions being taken in the Control Room. Attachment 1 -step 3.c -3.c.1) c. Periodic Briefs 10 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change actions that have no time requirements; therefore, there is no impact on combining them. This change continues to provide alignment with the content of the current E-Plan. Change #16 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

This change includes a new "bin" for plant priorities.

This change continues to provide alignment with the content of the current E-Plan. Change #17 -Sponsor edit -no change in intent with respect to the E-Plan.

Original Content Content Change e. Perform periodic intra-facility

1) Perform periodic intra-facility teleconference I video conference teleconference I video conference tailboards.

Refer to EP EF-3 tailboards.

Refer to EP EF-3 (Form (Form 69-20788), "Emergency 69-20788), "Emergency Response Response Facility Tailboard Facility Tailboard Checklist." Checklist." Attachment 2 -note at top of Attachment 2 -note at top of page 1 page 1 Steps in this checklist may need to N/A-new content added be performed in an order other than listed based on sequence of events. Attachment 2 -step 2.a.5) Attachment 2 -step 2.a.5) Ensure that the Shift Phone Ensure that the Shift Phone Talker Talker completes verbal completes verbal notifications to the notifications to the County and County and State within State within approximately 45 approximately 45 minutes.or less of minutes of the previous verbal the previous verbal notification.

notification.

11 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Reformatted the attachment to "bin" like tasks with each other based on user feedback to improve performance.

This change includes a new "bin" for periodic briefs. This change continues to provide alignment with the content of the current E-Plan. Change #18 -Sponsor edit -no change in intent with respect to the E-Plan. Added in note to be consistent with other implementing 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. Change #19 -Sponsor edit -no change of intent with respect to the E-Plan. Added in the words "or less" to align with the notification procedure EP G-3. 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. -I Original Content Attachment 3 -note at top of page 1 NIA-new content added Attachment 3 -step 1.b.2) IF the initial event classification is an ALERT or higher, THEN activate VANS immediately after time of classification. -step 1.b.3) IF the event classification is an UNUSUAL EVENT, THEN activate VANS as soon as possible.

Content Change Attachment 3 -note at top of page 1 Steps in this checklist may need to be performed in an order other than listed based on sequence of events. Attachment 3 -step 1.b.2) Activate VANS immediately after time of classification for ALERT or higher. Attachment 3 -step 1.b.3) Activate VANS as soon as possible after time of classification for UNUSUAL EVENT. 12 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #20 -Sponsor edit -no change in intent with respect to the E-Plan. Added in note to be consistent with other implementing 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. Change #21 -Sponsor edit -no change in intent with respect to the E-Plan. 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. Change #22 -Sponsor edit -no change in intent with respect to the E-Plan. 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.

Original Content Attachment 3 -step 1.b.6).b)

6) Determine appropriate VANS scenario ID: b) Non-Security Event Scenarios Content Change Attachment 3 -step 1.b.4) -1.b.4).a)

4) Determine appropriate VANS scenario ID: (1) 0112: Non-Security a) NON-SECURITY Event UNUSUAL EVENT with no further Scenarios action required (2) 2012: Non-Security UNUSUAL EVENT with ERO reporting to their emergency response facilities (3) 0113: Non-Security ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY -step 1.b.6).a) a) Security Event Scenarios (1) 1010: Security UNUSUAL EVENT (2) 0114: Security ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY (3) 1012: ERO Notification Homeland Security Elevated Threat Alert

• 0112: Non-Security UNUSUAL EVENT with no further action required

• 2012: Non-Security UNUSUAL EVENT with ERO reporting to emergency response facilities

• 0113: Non-Security ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY -step 1.b.4).b) b) SECURITY Event Scenarios

• 1010: Security UNUSUAL EVENT

• 0114: Security ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY

'-Content relocated (see change# 25) 13 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #23 -Sponsor edit -no change in intent with respect to the E-Plan. 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. Change #24 -Sponsor edit -no change in intent with respect to the E-Plan. . 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. The "ERO Notification Homeland Security Elevated Threat Alert" was moved from the security events heading 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.

• Original Content Content Change Attachment 3 -step 1.b.6).d) -step 1.b.4).d) 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-Emergency Notification Emergency Notification (2) 0555: 12Kv Power Outage

• 0555: 12Kv Power Outage Call Call out out (3) 0777: OCC Call out

• 0777: OCC Call out (4) 0999: DCPP Fire Fighters Call .

• 0999: DCPP Fire Fighters Call out *out (5) 0116: Congregate Care

• 0116: Congregate Care Callout Callout Content relocated (see change #24) (6) 1007: Training Scenario Attachment 3 -step 1.b.4) -1.b.5) 4) Determine appropriate "On the fly Template" to use: a) IF a non-security event, THEN use applicable security event template.

b) IF a security event, THEN use the security event template.

• 1012: ERO Notification Homeland Security Elevated Threat Alert

• 1007: Training Scenario Attachment 3 -step 1.b.5) -1.b.5).a)

5) Determine which "On the fly Template" to use:

• TEMPLATE 1: Non-Security UNUSUAL EVENT

• TEMPLATE 2: Non-Security ALERT or HIGHER.

• TEMPLATE 3: ALL Security Events. 14 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change This change continues to provide alignment with the content of the current E-Plan. Change #25 -Sponsor edit -no change in intent with respect to the E-Plan. 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. Change #26 -Sponsor edit -no change in intent with respect to the E-Plan.

• 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. The different on-the-fly templates were designated as 1-4 to help differentiate them based upon user feedback. I Original Content c) IF event has been terminated, THEN use the event termination template.

5) Obtain enough information from the SM or Communicator

1. 1 to fill out applicable "On the fly Message" template. -Non-Security UNUSUAL EVENT template N/A-new content added Attachment 3 -Non-Security ALERT or HIGHER template N/A-new content added Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Content Change Change Number I Type of Change I Reason for Change

• TEMP LA TE 4: Emergency event termination.

This change continues to provide alignment with the content of the current E-Plan. a) Obtain information from the SM or Communicator

1. 1 to fill out template. -Non-Security UNUSUAL EVENT template Changes made:

• Reformatted template

• Added TEMPLATE 1" Attachment 3 -Non-Security ALERT or HIGHER template Changes made:

• Reformatted template

• Added "TEMPLATE 2" 15 of 31 Change #27 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted template to make the flow better with the performance of the task of activating VANS. 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. Change #28 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted template to make the flow better with the performance of the task of activating VANS. 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.

Original Content Content Change Attachment 3 -Security Event Attachment 3 -Security Event template template N/A -new content added Changes made:

• Reformatted template

• Added "TEMPLATE 3" Attachment 3 -Emergency Event Attachment 3 -Emergency Event Termination template Termination template N/A-new content added Changes made: . . Reformatted template

• Added "TEMPLATE 4" Attachment 3 -step 1.c.1 ).b) Attachment 3 -step 1.c.1. a)* . b) Correct scenario ID determined a) Correct scenario ID determined from step 1.b.6) above: from step 1.b.4) above 16 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #29 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted template to make the flow better with the performance of the task of activating VANS. 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. Change #30 -Sponsor edit -no change in intent with respect to the E-Plan. 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. Change #31 -Sponsor edit -no change in intent with respect to the E-Plan. 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.

Original Content Content Change -Attachment 3 -step 1.c.1) .a) Attachment 3 -step 1.c.1. b) 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 Attachment 3 -step 1.c.6) -Attachment 3 -step 1.c.6) -1.c.6).d) 1.c.6).c)

6) Listen to the prompts. 6) Listen to the prompts. a) Press "2", to record on-the-fly a) Press "2", to record on the fly message. message. b) Wait for prompt. b) When prompted, record message using template.

c) Record message using applicable template c) Then press "#." d) Then press "#." Attachment 3 -new step Attachment 3 -step 1.c. 7) -1.c.7).b).(1)

N/A-new content added 17 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change This change continues to provide alignment with the content of the current E-Plan. Change #32 -Sponsor edit -no change in intent with respect to the E-Plan. 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. Change #33 -Sponsor edit -no change in intent with respect to the E-Plan. 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. Change #34 -Sponsor edit -no change in intent with respect to the E-Plan.

Original Content Attachment 3 -

1 .. IF Assembly and Accountability is initiated, THEN fax the on-shift accountability roster to the DCPP Watch Commander at (x3115) within 15 minutes from the time the site emergency signal was sounded, per EP G-4. Content Change 7) The system should replay the recorded on-the-fly message and ask if it is correct: a) If correct, press "1" for yes. b) If incorrect, press "2" for no. (1) The system will direct you to record the message. Attachment 3 -step 2.a IF Assembly and Accountability is initiated, THEN fax the on-shift accountability roster to the DCPP Watch Commander at (x3115) within 15 minutes from the time the site emergency signal was sounded, per EP G-4. 18 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for ,-Change Added in new step to fix an issue identified by the end user. This prompt exists in the VAN_$_ activation process but it was missing from the procedure.

This change makes the procedurE!

accurate for the task of activating VANS. This change continues to provide alignment with the content of the current E-Plan. Change #35 -Sponsor edit -no change in intent with respect to the E-Plan. Assembly and accountability actions were relocated from the last step of initial actions to the first step of subsequent actions based on reformatting of the attachment There is no change of intent as all of the actions 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 Original Content Content Change Attachment 4 -note at top of Attachment 4 -note at top of page 1 page 1 Steps in this checklist may need to N/A-new content added be performed in an order other than listed based on sequence of events. Attachment 6 -step 1.a Attachment 6 -step 1.a a. For Security events, GO TO a. IF security event, Section 2. THEN GO TO step 2. Attachment 6 -steps 1.b -Attachment 6 -step 1.b -1.d.2).c).

1.b.3).a).(2)

b. Based upon plant conditions, b. Based upon plant use use one of the following one of the. following templates to templates to develop a PA message. T36779 develop and make a PA

• 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 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. Change #36 -Sponsor edit -no change in intent with respect to the E-Plan. Added in note to be consistent with other implementing 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. Change #37 -Sponsor edit -no change in intent with respect to the E-Plan. 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. Change #38 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted steps to clean them up and make them -simpler and more direct to enhance user performance.

The intent of the steps remains unchanged.

The same actions are taken at the same emergency classification levels. ---*-------------

Original Content ALERT: 1) Make a PA announcement using the appropriate template .. 2) Repeat the PA announcement.

CAUTION: Assembly, Accountability and/or evacuation when in a security event or other hazardous condition (i.e., toxic gases, fires or weather conditions) may place personnel in danger. d. When a SITE AREA EMERGENCY or GENERAL EMERGENCY is declared, determine if it is safe to move personnel.

T 35779 1) IF it is NOT safe to move personnel:

a) Make a PA announcement using the "NOT SAFE TO MOVE PERSONNEL" template.

b) Repeat the PA announcement.

2) IF it is safe to move personnel:

a) Make a PA announcement using the "SAFE TO MOVE Content Change TEMPLATE A. 2) ALERT use TEMPLATE B. CAUTION: Assembly, Accountability and/or evacuation when in a security event or other hazardous condition (i.e., toxic gases, fires or weather conditions) may place personnel in danger. 3) SITE AREA EMERGENCY or GENERAL EMERGENCY:

a) Determine if it is safe to move personnel.T3B779 (1) IF NOT safe to move personnel, THEN make a PA announcement using TEMPLATE C. (2) IF safe to move personnel, THEN make a PA announcement using TEMPLATE D, AND sound the site emergency signal for 60 seconds. 20 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change The non-security PA templates were designated as A-D to help differentiate them based upon user feedback.

Relocated "repeat the announcement" from the body of the instruction into the body of the templates to improve usability.

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

Original Content Content Change PERSONNEL" template.

b) Sound the site emergency signal for 60 seconds. c) Repeat the PA announcement. -UNUSUAL Attachment 6 -UNUSUAL EVENT EVENT template template N/A -new content added Changes made:

• Added "TEMPLATE A"

• Added "repeat the announcement"

• Reformatted template Attachment 6 -ALERT template Attachment 6 -ALERT template NIA -new content added Changes made:

• Added "TEMPLATE B"

• Added "repeat the announcement"

• Reformatted template 21 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #39 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted template to make the flow better with the performance of the task of making a public announcement (PA). 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. Change #40 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted template to make the flow better with the performance of the task of making a PA. Relocated "repeat the announcement" from the body of the instruction into the body of the template to improve usability.

Original Content Content Change Attachment 6 -SITE AREA Attachment 6 -SITE AREA EMERGENCY or GENERAL EMERGENCY or GENERAL EMERGENCY

& Not Safe to EMERGENCY

& Not Safe to Move Move Personnel template Personnel template N/A-new content added Changes made:

• Added "TEMPLATE C"

• Added "repeat the announcement"

• Reformatted template Attachment 6-SITE AREA Attachment 6-SITE AREA EMERGENCY or GENERAL EMERGENCY or GENERAL EMERGENCY

& Safe to Move EMERGENCY

& Safe to Move Personnel template Personnel template NIA-new content added Changes made:

• Added "TEMPLATE D"

• Added "repeat the announcement"

• Reformatted template 22 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 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. Change #41 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted template to make the flow better with the performance of the task of making a PA. 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. Change #42 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted template to make the flow better with the performance of the task of making a PA. 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 Original Content Content Change Attachment 6 -step 2.a Attachment 6 -step 2.a 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 M-15A.T 357'1 9 message scripts.r 36779 Attachment 6 -step 2.b -2.d.2).d)

b. For a non-Aircraft based threat, determine if it is safe to move personnel.

T 35779 c. IF NOT safe to move personnel:

1) Develop and make a PA announcement using template A "SECURITY NOT SAFE TO MOVE PERSONNEL".

2) Repeat the PA announcement.

d. IF safe to move personnel:

1) For an UNUSUAL EVENT: Attachment 6 -step 2.b -2.b.2).b).(3)

b. Determine if it is safe to move personnel.r 36779 1) IF NOT safe to move personnel, THEN make PA announcement using TEMP LA TE E. 2) IF safe to move personnel:

a) UNUSUAL EVENT make PA announcement using TEMPLATE F. 23 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 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. Change #43 -Sponsor edit -no change in intent with respect to the E-Plan. 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. Change #44 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted steps to clean them up and make them simpler and more direct to enhance user performance.

The intent of the steps remains unchanged.

The same actions are taken at the same emergency classification levels. The security event PA templates were designated as E-G to help differentiate them based upon user feedback.

Relocated "repeat the announcement" from the body of the instruction into the body of the templates to improve usability.

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

Original Content a) Develop and make a PA announcement using template B "SECURITY UNUSUAL EVENT SAFE TO MOVE PERSONNEL".

b) Repeat the PA announcement.

2) For an ALERT, SITE AREA EMERGENCY or GENERAL EMERGENCY:

a) Develop and make a PA announcement using template C "SECURITY ALERT OR HIGHER SAFE TO MOVE PERSONNEL".

b) Sound the Site Emergency Signal for 60 seconds. c) Repeat the PA announcement.

d) Go to CP M-15A Attachment 20 for subsequent actions. Attachment 6 -Security Event & Not Safe to Move Personnel template N/A -new content added Content Change b) ALERT, SITE AREA EMERGENCY or GENERAL EMERGENCY:

(1) Make PA announcement using TEMPLATE G. (2) Sound the Site Emergency Signal for 60 seconds. (3) GO TO CP M-15A Attachment 20 for subsequent actions. Attachment 6 -Security Event & Not Safe to Move Personnel template Changes made:

• Changed "TEMPLATE A" to "TEMPLATE E"

• Added "repeat the 24 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #45 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted template to make the flow better with the performance of the task of making a PA. Relocated "repeat the announcement" from the body of the instruction into the body of the template to improve Original Content Attachment 6 -Security UNUSUAL EVENT & Safe to Move Personnel template N/A-new content added Attachment 6 -Security ALERT or HIGHER & Safe to Move Personnel template N/A-new content added Content Change announcement"

• Reformatted template Attachment 6 -Security UNUSUAL EVENT & Safe to Move Personnel template Changes made:

• Added*Changed "TEMPLATE B" to "TEMPLATE F"

• Added "repeat the announcement"

• Reformatted template Attachment 6 -Security ALERT or HIGHER & Safe to Move Personnel template Changes made:

• Changed "TEMPLATE C" to "TEMPLATE G"

• Added "repeat the announcement" 25 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change usability.

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. Change #46 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted template to make the flow better with the performance of the task of making a PA. Relocated "repeat the announcement" from the body of the instruction into the body of the template to improve usability.

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. Change #47 -Sponsor edit -no change in intent with respect to the E-Plan. , Reformatted template to make the flow better with performance of the task of making a PA.

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

Original Content Attachment 6 -new step N/A -new content added Attachment 6 -step 2.e e. IF the public address system is unavailable, THEN call the DCPP Security Watch Commander (x3330) and request the following:

Content Change

• Reformatted template Attachment 6 -step 3 PUBLIC ADDRESS SYSTEM UNAVAILABILITY -step 3.a a. IF the public address system is unavailable, THEN use SmartMSG to communicate with plant staff, AND call the DCPP Security Watch Commander (x3330) and request the following:

26 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change 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. Change #48 -Sponsor edit -no change in intent with respect to the E-Plan. 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 the content of the current E-Plan. Change #49 -Sponsor edit -no change in intent with respect to the E-Plan. Added in the use of SmartMSG as another means of communicating with plant staff in the event that the PA system is unavailable.

SmartMSG is an existing communications tool that is available in the Control Room. It uses the pager system to send a message to all personnel onsite with pagers. Operators are trained on the use of this system.

Original Content Attachment 6 -step 2.f -2.f.1) f. IF the public address system AND security are unavailable, THEN email the above PA message to "DCPP *NPG _, Nuclear Power Generation Business Unit" and, 1) Add the PA message to bridge line ext. 2800: Attachment 7 -:-step 2.e e. Notify Senior Plant Management and PG&E External Communications that the event has been terminated by activating VANS per Attachment 8 using SCENARIO ID 0200. Content Change Attachment 6 -step 3.b -3.b.3) b. IF the public address system AND security are unavailable, THEN: 1) Use SmartMSG to communicate with plant staff. 2) Email the content of the applicable PA message to "DCPP *NPG Nuclear Power Generation Business Unit". 3) Add the content of the applicable PA message to bridge line ext. 2800: Attachment 7 -step 2.e e. Notify Senior Plant Management and PG&E External Communications that the event has been terminated by activating VANS using SCENARIO ID 0200. 27 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change This change continues to provide alignment with the content of the current E-Plan. Change #50 -Sponsor edit -no change in intent with respect to the E-Plan .. Reformatted step to clean it up and make it simpler and more direct to enhance user performance.

The intent of the step remains unchanged.

Added in the use of SmartMSG as another means of communicating with plant staff in the event that the PA system is unavailable.

SmartMSG is an existing communications tool that is available in the Control Room. It uses the pager system to send a message to all personnel onsite with pagers. Operators are trained on the use of this system. This change continues to provide alignment with the content of the current E-Plan. Change #51 -Sponsor edit -no change in intent with respect to the E-Plan. Removed the reference to attachment 8 because it is unnecessary.

The personnel that would be tasked with the action to activate VANS are familiar with where the procedure guidance is that provides direction.

The intent of the step remains unchanged.

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

Original Content Attachment 8 -step 1.b.2) -1.b.2).c)

b. Determine appropriate VANS scenario ID: 2) NON-SECURITY Event Scenarios a) 0112: Non-Security UNUSUAL EVENT with no further action required b) 2012: Nori-Security UNUSUAL EVENT with ERO reporting to their normal emergency response facilities c) 0113: Non-Security ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY -step 1.b.1) -1.b.1 ).c) 1) Security Event Scenarios a) 1010: Security UNUSUAL --._ EVENT b) 0114: Security ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY c) 1012: ERO Notification Homeland Security Elevated Threat Alert Content Change Attachment 8 -step 1.b -1.b.1) b. Determine appropriate VANS scenario ID: 1) NON-SECURITY Event Scenarios

• 0112: Non-Security UNUSUAL EVENT with no further action required

• 2012: Non-Security UNUSUAL EVENT with ERO reporting to their normal emergency response facilities

• 0113: Non-Security ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY -step 1.b.2) 2) SECURITY Event Scenarios

• 1010: Security UNUSUAL EVENT

• 0114: Security ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY Content relocated (see change# 54) 28 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #52 -Sponsor edit -no change in intent with respect to the E-Plan. 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. Change #53 -Sponsor edit -no change in intent with respect to the E-Plan. 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. The "ERO Notification Homeland Security Elevated Threat Alert" was moved from the security events heading 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 belonQs Original Content Attachment 8 -step 1.b.4) -1.b.4).f)

Content Change Attachment 8 -step 1.b.4) 4) Non-Emergency Scenarios

4) Nqn-Emergency Scenarios

• 0111: 1 Hr. I 4 Hr. I 8 Hr. Non-a) 0111: 1 Hr. I 4 Hr. I 8 Hr. Non-Emergency Notification Emergency Notification

• 0555: 12Kv Power Outage Call b) 0555: 12Kv Power Outage Call out out

• 0777: OCC Call out c) 0777: OCC Call out

• 0999: DCPP Fire Fighters Call d) 0999: DCPP Fire Fighters Call out out

• 0116: Congregate Care Callout e) 0116: Congregate Care Callout

• 1012: ERO Notification f) 1007: Training Scenario Homeland Security Elevated Threat Alert * .1007: Training Scenario Attachment 8 -step 1.h -1.h.4) Attachment 8 -step 1.h -1.h.3) h. Listen to the prompts. h. Listen to the prompts. Enclosure 2 PG&E Letter DCL-16-120 . PG&E Letter DIL-16-018 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. Change #54 -Sponsor edit -no change in intent with respect to the E-Plan. 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. Change #55 -Sponsor edit -no change in intent with respect to the E-Plan. Reformatted step to clean it up and make it simpler and 1) Press "2", to record on-the-fly message. 1) Press "2", to record on the fly more direct to enhance user The intent of 2) Wait for prompt. 3) Record message using applicable template message. the step remains unchanged.

The step was relocated to make the flow of the procedure line up better with the 2) When prompted, record message performance of the task of activating VANS. using applicable template.

This change continues to provide alignment with the 3) Then press"#." content of the current E-Plan. 29 of 31 Original Content Content Change 4) Then press "#." Attachment 8 -new step Attachment 8 -step 1.i -1.i.2).a)

N/A-new content added i. The system should replay the recorded on-the-fly message and ask if it is correct: 1) If correct, press "1" for yes. 2) If incorrect, press "2" for no. a) The system will direct you to re-record the message. Attachment 11 -note at top of Attachment 11 -note at top of page page 1 1 N/A-new content added Steps in this checklist may need to be performed in an order o.ther than listed based on sequence of events. Attachment 11 -step 2 note Attachment 11 -step 2 note Follow-up notifications per EP G-Follow up notifications per EP G-3 3 (Form 69-21638), "DCPP (Form 69-21638), "DCPP Follow Up Follow-Up Emergency Notification Emergency Notification Form", 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 Change Number I Type of Change I Reason for Change Change #56 -Sponsor edit -no change in intent with respect to the E-Plan. Added in new step to fix an issue identified by the end user. This prompt exists in the VANS activation process but it was missing from the procedure.

This change makes the procedure accurate for the task of activating VANS. This change continues to provide alignment with the content of the current E-Plan. Change #57 -Sponsor edit -no change in intent with respect to the E-Plan. Added in note to be consistent with other implementing 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.*

Change #58 -Sponsor edit -no change of intent with respect to the E-Plan. Added in the words "or less" to align with the notification procedure EP G-3.

Original Content Content Change approximately every 45 minutes. every 45 minutes or less. (Refer to (Refer to EP G-3.) EP G-3.) 31 of 31 Enclosure 2 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change 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.

Summary of the Analysis of Changes to Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 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 Revision 59 Original Content Step 2.1.1.a 1st bullet

• A new emergency classification level Step 2.1.1.a.1.b)

On-Going Event: This is used when tile DCPP Station is already in a declared emergency.

This . gives notice of an upgrade to an emergency classification level on either Unit, or a new PAR. The message number of an On-Going Event is the next sequential number. Step 2.1.1.b 1st paragraph Follow-Up Notifications:

Required to be performed approximately every 45 minutes during an ongoing Content Change Step2.1.1.a 1st bullet

• A new emergency classification level (ECL) Step 2.1.1.a.1.b)

On-Going Event: This is used when the DCPP Station is already in a declared emergency.

This gives notice of an upgrade to a higher emergency classification level or a new PAR. The message number of an On-Going Event is the next sequential number. Step 2.1.1.b 1st paragraph Follow-Up Notifications:

Required to be performed approximately every 45 minutes or less of the previous verbal notification during an ongoing 1of10 Change Number I Type of Change I Reason for Change Change #1 -Sponsor edit -no change in intent with respect to the Emergency Plan (E-Plan).

Added in acronym for emergency classification level for consistency and alignment with writer's guide. Change #2 -Sponsor edit-no change in intent with respect to the E-Plan. Cleaned up the language around upgrading to a higher classification level to remove the term "on either unit" based on user feedback that it is potentially misleading.

For example if U1 was in an alert and then U2 met the conditions for an alert the Revision 58 language infers that upgrade would be required which is incorrect.

Revision 59 fixes the language to be 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. Change #3 -Sponsor edit -no change of intent with respect to the E-Plan. Added in the words "or less of the previous verbal notification" to clarify the time requirements for up notifications.

Feedback from the users of the Original Content Content Change event using Attachment 4 (Form event using Attachment 4 69-21638), (Form 69-21638), "DCPP Follow-Up "DCPP Follow-Up Emergency Emergency Notification Form." Notification Form." Step 2.1.1.b 2no paragraph Step 2.1.1.b 2na paragraph The appropriate notification is a The appropriate notification is a Follow-Up ENF due to a Follow-Up ENF due to a significant significant change in plant change in plant conditions (message conditions (message number 4). number 4). This is an example of This is an example of meeting a meeting a concurrent EAL. secondary EGL. Step 2.1.2 -Step 2.1.2 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 2of10 Enclosure 3 PG&E DGL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change 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. Change #4 -Sponsor edit -no change of intent with respect to the E-Plan. Changed the phrase "secondary ECL" to "concurrent EAL". Feedback from the users of the procedure was that it wasn't specifically clear on what a secondary ECL was. The term concurrent EAL was decided 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. Change #5 -Sponsor edit -no change of intent with respect to the E-Plan. Editorial chanQe to correct lanQuaQe that is not Original Content -Content Change called. The ENF DCPP ENF is not used by the NRC. Form is not used by the NRC. Step 2.1.4 Step 2.1.4 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 be notified within 15 minutes of: notified within 15 minutes of:

• An initial classification of an

• An initial classification of an emergency emergency

• A new PAR

• A new PAR

• Changes to emergency

• Changes to emergency classification levels classification levels

• Changes to PARs

• Changes to PARs

• Corrections for an inaccurate PAR 3of10 Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change technically correct. The Revision 58 language "ENF 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. Change #6 -Sponsor edit -no change of intent with respect to the E-Plan. The last bullet "Corrections for an inaccurate PAR" was removed from this section as it was erroneously added in the previous Revision 57. The intent of the Revision 57 addition was to provide some type of guidance for the ERO on how to handle an inaccurate PAR as nothing existed prior to Revision 57. There is no E-Plan requirement to correct inaccurate PARs within 15 minutes. Feedback from the ERO 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 Original Content Content Change Step 6.1.3 Step 6.1.3 Within 15 minutes of EGL or [TIME CRITICAL]:

Within PAR declaration, SLO County 15 minutes of new EGL or new PAR and the State of declaration, SLO County and the California shall be notified by State of California shall be notified by transmittal of information on an transmittal of information on an approved Form.T 32164 approved Form.T 32164 Step 6.2.3 Step 6.2.3 Perform a follow-up notification Perform follow-up notifications 45 45 minutes or minutes or less. less of the previous verbal notification.

a. Some conditions (not all) that a. Routine Follow-Up notifications may trigger making a follow-up indicate that conditions are stable and notification in have not significantly changed since less than 45 minutes are: the last notification.

1. (Primary Reason) Change in b. Some conditions (not all) that may Radiological Release status trigger making an expedited follow-up (start, or stop) notification in less than 45 minutes 4of10 Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DI L-16-018 Change Number I Type of Change I Reason for Change described in the E-Plan. Change #7 -Sponsor edit -no change of intent with respect to the E-Plan. Added in "[TIME CRITICAL]" to identify the need for urgency on initial notifications as they need to be completed within 15 minutes. 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. Change #8 -Sponsor edit -no change of intent with respect to the E-Plan. Guidance was re-written to provide enhanced details and clearer instructions for when to perform follow-up notifications.

Added in the words "or less of the previous verbal notification" to clarify the time requirements for follow-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.

Original*

Content Content Change are: 2. Change in unit status (mode * (Primary Reason) change in change for affected or unaffected radiological release status (start, unit) or stop)

• Change in unit status (e.g. mode 3. Change in spent fuel pool change for affected or unaffected conditions unit, loss of important plant components or systems) 4. Notification of meeting

• Concurrent EALs met (e.g. Alert additional secondary ECLs declared on Unit 1, then Alert met on Unit 2 would be a concurrent

5. A correction for an inaccurate EAL with no declaration needed PAR 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)

c. Follow-up notifications to an off-site agency may be waiv.ed or extended to intervals greater than 45 minutes if the off-site agency agrees. 5of10 Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Chanae 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. The five examples under the section on when to perform follow-up notifications in less than 45 minutes were enhanced based upon user feedback.

All of the Revision 58 content remains in Revision 59 with the addition of clarifying content. The exceptions being:

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

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

These changes align with the E-Plan Section 4.1.2.3.6 which states that at the Alert level or higher DCPP plant staff will provide, "periodic plant status updates to off-site authorities (approximately every 45 minutes or immediately if situation warrants)." The E-Plan does not specify which conditions would require expedited follow-up notifications.

The examples provided in Revision 59 align with agreed Original Content Content Change Step 6.2.4 Perform the following Step 6.3 Correcting Errors on to correct previously transmitted Previously Transmitted ENFs or ENFs: Follow-Up ENFs a. Provide a verbal 6.3.1 Provide a verbal update/correction to the County, update/correction to the County, State, and NRC State, and NRC b. Create a new ENF to correct 6.3.2 For corrections to an incorrect the issue PAR: 1. Use an initial or follow-up form a. IF the correct PAR is more to correct the issue based on conservative (i.e. includes more PAZs which form contained the original or more protective actions) than the error. previously transmitted incorrect PAR, THEN send an updated initial ENF to correct the issue. 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 Dl°L-16-018 Change Number I Type of Change I Reason for Change upon conditions with the offsite agencies on when expedited follow-ups should be done. Change #9 -Sponsor edit -no change of intent with respect to the E-Plan. This content was added in the previous Revision 57. The intent of the Revision 57 addition was to provide some type of guidance for the ERO on how to handle an inaccurate ENF that had been transmitted to offsite agencies as nothing existed prior to Revision 57 on how to handle that situation.

There is no E-Plan requirement to correct inaccurate notifications.

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 notifications is not described in the E-Plan, nor is it described in any regulatory guidance or requirements. ,

Original Content 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 Follow-up notifications to an off-site agency may be waived or extended to intervals greater than 45 minutes if the off-site agency agrees. Attachment 2 step 1.a Attachment 2 step 1.a a. Follow-Up Notifications are a. Follow-Up Notifications are made made using Form 69-21638 using Form 69-21638 approximately approximately every 45 every 45 minutes or less of the minutes (time may be changed previous verbal notification (time may based upon agreement with be changed based upon agreement offsite agencies)

OR when with offsite agencies)

OR when 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 Change Number I Type of Change I Reason for Change Change #10 -Sponsor edit -no* change of intent with respect to the E-Plan. Step was relocated verbatim.

This* is an editorial change that was done to move the instruction to the applicable section of the procedure.

The relocation does not alter any requirements or timeliness aspects associated with the performance of follow-up notifications.

Change #11 -Sponsor edit -no change of intent with respect to the E-Plan. Refer to Change #8 for details associated with this change. Change #11 is a copy and paste of the Change #8 content for alignment throughout the procedure.

Original Content 1) Change of plant operating mode 2) Change of radiological release status 3) Evacuation of onsite Personnel

4) Call for outside assistance (Fire, Ambulance or Police) 5) Notification of meeting secondary ECLs Attachment 2 block 4 instructions "Change in Plant Status" is used for: Content Change 1) Change in radiological release status (start, or stop) 2) Change in unit status (e.g., mode change for affected or unaffected unit, loss of important plant components or systems) 3) Concurrent EALs met (e.g., Alert declared on Unit 1, theri Alert met on Unit 2 would be a concurrent EAL with no declaration needed but Follow-Up 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)

Attachment 2 block 4 instructions "Change in Plant Status" is used for:

• Change in radioloQical release 8of10 Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #12 -Sponsor edit -no change of intent with respect to the E-Plan. Refer to Change #8 for details associated with this Original Content Content Change

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

• Change in unit status (e.g. mode

• Unit mode change (affected or change for affected or unaffeded unaffected unit) unit, loss of important plant

• 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) Attachment 2 block 7 instructions Attachment 2 block 7 instructions N/A new content added PIC data may be found at:

• httg ://gd nserver/P IC. asgx

• FMT Communicator in the UDAC

• Rad Data Processor in the TSC 9of10 Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change change. Change #12 is a copy and paste of the Change #8 content for alignment throughout the procedure.

,.-Change #13 -Sponsor edit -no change of intent with respect to the E-Plan. Added in instructions on where to obtain pressurized ion chamber (PIC) data based on user feedback.

This change is an enhancement to improve use by the ERO. This chanQe has no impact on the content of Original Content Content Change .. Attachment 5 step 3.d.1 Attachment 5 step 3.d.1 "Routine update" -Used routine "Routine update" -Used for routine updates provided -every 45 updates provided -every 45 minutes minutes. or less of the previous verbal notification.

Attachment 5 step 3.g.1 Attachment 5 step N/A new content added 1) PIC data may be found at:

• htt12://12dnserver/PIC.as12x

• FMT Communicator in the UDAC

• Rad Data Processor in the TSC 10of10 Enclosure 3 PG&E Letter DCL-16-120 PG&E Letter DI L-16-018 Change Number I Type of Change I Reason for Change the current E-Plan . Change #14 -Sponsor edit-no change of intent with respect to the E-Plan. Added in the words "or less of the previous verbal notification" to clarify the time requirements for follow-* 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. Change #15 -Sponsor edit -no change of intent with respect to the E-Plan. Added in instructions on where to obtain PIC data based on user feedback.

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

Summary of the Analysis of Changes to Enclosure 4 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 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 Building 109 and 119, 2nd floor breezeway Evaluation assembly area. 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 Original Content Content Change Title: Assembly and Accountablity Title: Assembly and Accountability Step 2.1.16 Step 2.1.16 If a radiological release is in If a radiological release is in progress, progress, radiological monitors Viewpoint will be used to monitor will be dispatched to the assembly assembly area dose rates, or areas to check dose rates are radiological monitors will be dispatched within acceptable limits. In the to the assembly areas to check dose event dose rates exceed rates, to ensure dose rates are within acceptable limits, personnel will acceptable limits. In the event dose be evacuated as quickly as rates exceed acceptable limits, possible.

personnel will be evacuated as quickly as possible.

2 of 6 Enclosure 4 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #2 -Editorial change with no change of intent. 50846295 -Task 4 -The title of the procedure is spelled wrong. Specifically, the word accountability.

Change #3 -Process change with no change of intent. RDS31, remote radiation monitors, are now installed in the assembly areas. Viewpoint is a software program that allows for remote monitoring of the radiation monitors.

A chemistry and radiation protection (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 monitorinQ of the assembly areas. If they are Original Content Content Change Step 3.7 Step 3.7 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 areas. viewpoint is unavailable.

3.7.3 Performing

air sampling at 3.7.2 Performing general area surveys the onsite assembly areas, as of the on-site assembly areas, as necessary.

necessary.

3.7.3 Performing

air sampling at the onsite assembly areas, as necessary.

3 of 6 Enclosure 4 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 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. Change #4 -Process change with no change of intent. RDS31, remote radiation monitors, are now installed in the assembly areas. Viewpoint is a software program that allows for remote monitoring of the 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.

Original Content Content Change Step 10.1.3.a.1.a Step 10.1.3.a.1.a Dispatch available RP technician Ensure Radiation Protection is following to assembly areas to perform Section 16, "Radiation Protection general area survey using Section Checklist." 16, "Radiation Protection Checklist." 4 of 6 Enclosure 4 PG&E Letter DCL-16-120.

PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #5 -Process change with no change of intent. RDS31, remote radiation monitors, are now installed in the assembly areas. Viewpoint is a software program that allows for remote monitoring of the 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.

'* Original Content Section 16 Radiation Protection Checklist 16.1 Initial Actions 16.1.1 Perform assembly area monitoring:

a. Obtain dose rate instrument.

b. Obtain air sampling equipment.

c. Go to assigned assembly area (Building 109, Building 119 and/or Warehouse B) and perform the following: 1 . Perform a general area dose rate survey to determine background radiological conditions.

2. IF any radiation above normal background detected, THEN recommend restrictions on eating and drinking.

3. IF general area dose rates exceed 3mR/hr,THEN immediately inform the Control Room orTSC. a) Start air sampling of the assembly*area for radioiodine

d. Report assembly area monitoring results to the TSC Radioloqical Advisor or Shift Content Change Section 16 Radiation Protection Checklist 16.1.1 Monitor the assembly area dose rates on Viewpoint.

a. IF the assembly area dose rates are not available on Viewpoint, OR dose rates exceed 3 mR/hr, THEN direct a C&RP tech to the affected assembly areas to perform the following:

1. Obtain dose rate instrument.

2. Obtain air sampling equipment.

3. Go to assigned assembly area (Building 109, Building 119 and/or Warehouse B) and perform the following:

a) Perform a general area dose rate survey to determine background radiological conditions.

b) IF any radiation above normal background detected, THEN recommend restrictions on eating and drinking.

c) IF general dose rates exceed 3mR/hr, THEN immediately notify the Control Room or TSC. 1) Start air sampling of the assembly area for radioiodine

4. Report assembly area monitoring 5 of 6 Enclosure 4 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #6 -Process change with no change of intent. RDS31, remote radiation monitors, are now installed in the assembly areas. Viewpoint is a software program that allows for remote monitoring of the 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.

Original Content Manager. 16.2 Subsequent Actions 16.2.1 Continue Monitoring Assembly Area: a. Inform Assembly Area Leader of survey results. b. For further instructions or resource requests, contact the Control Room or TSC. c. Continue to monitor assembly areas until directed otherwise by the Shift Manager or SEC. N/A Content Change results to the TSC Radiological Advisor or Shift Manager. 16.2 Subsequent Actions 16.2.1 Continue Monitoring Assembly Area on Viewpoint, or locally: a. Notify Assembly Area Leader of local survey results. b. For further instructions or resource requests, contact the Control Room or TSC. c. Continue to monitor assembly area until directed otherwise by the Shift Manager or SEC. Step 1.4 -deleted, not a rewrite revision Section 11.3.2, steps are a, b, c ... not 1, 2, 3 6of6 Enclosure 4 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #7 -Editorial and formatting changes Summary of the Analysis of Changes to Enclosure 5 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 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 Original Content Content Change Change Number I Type of Change I Reason for 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 the TSC staff. the TSC staff. intent. 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 Original Content Content Change Site Emergency Coordinator Site Emergency Coordinator Checklist Checklist

3. Situational Actions 3. Situational Actions a) Risk Significant Actions a) Risk Significant Actions (Classification, Notification, Dose (Classification, Notification, Assessment, PARs) Dose Assessment, PARs)* 1) Classify and declare an 1) Classify and declare an emergency condition within 15 emergency condition within minutes per EP G-1. 15 minutes per EP G-1. REFER TO Tab 12. REFER TO Tab 12. a. Confer with Ops Advisor on EALs. a) If time permits, get at b. If time permits, get at least one 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

2. Ongoing Actions 2. Ongoing Actions b. Assist the SEC with b. Confer with the SEC on evaluating plant evaluating plant conditions conditions against EALs against EALs and upgrade criteria and upgrade criteria as as needed. needed. 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 Change Change #4 -Process change with no change of intent. Change is being made to delineate that an independent peer check is needed, if time permits. The Operations Advisor is not considered a peer as they report to the SEC and are located in the same 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 assignments in accordance with the E-Plan. Change #5 -Process change with no change of intent. Change is being made to delineate that an independent peer check is needed, if time permits. The Operations Advisor is not considered a peer as they report to the SEC and are located in the same 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 in accordance with the E-Plan.

Original Content Site Emergency Coordinator Checklist

2. Ongoing Actions NOTE: Direct the communications advisor to perform routine follow-up offsite notifications to County, State, and NRC officials per EP G-3. REFER TO Tab 10 and 11. TSC Director Checklist

2. Ongoing Actions NOTE:

notifications to the County and State are required to be completed within 15 minutes following the declaration of a new event classification or new PAR at the GE level (notifications to the NRC within one hour). Follow-up notifications should be made approximately every 45 minutes. Communications Advisor -TSC Checklist Content Change Site Emergency Coordinator Checklist

2. Ongoing Actions NOTE: Direct the communications advisor to perform routine and expedited follow-up offsite notifications to County, State, and NRC officials per EP G-3. REFER TO Tab 10 and 11. TSC Director Checklist

2. Ongoing Actions NOTE: DCPP emergency notifications to the County and State are required to be completed within 15 minutes following the declaration of a new event classification or new PAR at the GE level (notifications to the NRG within one hour). Follow-up notifications should be made approximately every 45 minutes or less. Communications Coordinator Checklist

2. Onaoina Actions 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 Change Change #6 -Editorial change with no change of intent. The information pertaining to both routine and expedited notifications exists in EP G-3. This change is being made for consistency between EP G-3 and EP EF-1. Change #7 -Editorial change with no change of intent. The statement "or less" already exists in EP G-3. Adding "or less" in this note brings EP EF-1 in line with EP G-3 to provide better alignment between the procedures. , Change #8 -Editorial change with no change of intent.

Original Content 2. Ongoing Actions b. Until relieved by the EOF, ensure the County and State are notified of new classification levels or new PARS within 15 minutes of declaration (one hour for NRC), and updated on 45 minute intervals.

Agency/ENS Communicator Checklist

1. Initial Actions g. IF requested to assist with off-site agency emergency notifications, THEN complete the notifications per EP G-3, "Emergency Notification of Off-Site Agencies." REFER TO Tabs 2, .3, and 4. 3) Follow-up notifications should be made within approximately 45 minutes. Content Change b. Until relieved by the EOF, ensure the County and State are notified of new classification levels or new PARS within 15 minutes of declaration (one hour for NRC), and updated on 45 minute or less intervals.

Agency/ENS Communicator Checklist

1. Initial Actions g. IF requested to assist with off-site agency emergency notifications, THEN complete the notifications per EP G-3, "Emergency Notification of Off-Site Agencies." REFER TO Tabs 2, 3, and 4. 3) Follow-up notifications should be made within approximately 45 minutes or less. 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 Change The statement "or less" already exists in EP G-3. Adding "or less" in this note brings EP EF-1 in line with EP G-3 to provide better alignment between the procedures.

Change #9 -Editorial change with no change of intent. The statement "or less" already exists in EP G-3. Adding "or less" in this note brings EP EF-1 in line with EP G-3 to provide better alignment between the procedures.

'

Original Content Administrative Advisor Checklist

1. Initial Actions d. Determine clerical staffing needs in each of the following facilities by contacting the appropriate position:

f. Assign clerical personnel to: j. Establish 24-hour shift manning schedules (12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts) for the TSC, OSC, EOF, and JIC. Coordinate with each facility.

REFER TO Tab 2. 1) For the OSC, walk down and work with the OSC clerical staff to develop the list. TSC Clerical Support Position Binder Tab Index EP EF-1, Form 69-21165, "TSC Clerical Support Checklist" Content Change Administrative Advisor Checklist

1. Initial Actions d. Determine administrative staffing needs in each of the following facilities by contacting the appropriate position:

f. Assign administrative personnel to: j. Establish 24-hour shift manning schedules (12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts) for the TSC, OSC, EOF, and JIC. Coordinate with each facility.

REFER TO Tab 2. 1) For the OSC, walk down and work with the OSC administrative staff to develop the list. TSC Administrative Support Position Binder Tab Index EP EF-1, Form 69-21165, "TSC Administrative Support Checklist" 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 Change Change #1 O -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. Change #11 -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 "Cl.erk" with "Admin". Refer to SAPN 50449609, Original Content Content Change 6 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 Change Task 17.

Summary of the Analysis of Changes to Enclosure 6 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 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 Attachment 1 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. Attachment 6 Step 1.e Attachment 6 Step 1.e Change #2 -Process with no change of intent. 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. Attachment 6 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 I I Original Content Attachment 10 Team Return and Debrief 10 Mission Status: ---------11 Return Time: ---Debrief Time: --Debrief By: __ _ NIA Content Change direction.

2) Check that the wind direction indicated on the OSC EPZ map corresponds with the TSC EPZ map. Enclosure 6 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Attachment 10 Change #4 -Administrative with no change of Team Return and Debrief intent. 10 Mission Status: SAPN 50872171 "9/21/16 DR EP EF-2 Debrief Process" recommends that Attachment 10 "Team Pre---11 Return Time: ---12 Debrief With: [ ] l&C/MM/Elect/Chem Coordinator [ ] SRPC (Rad Teams) [ ] Team Coordinator Att 1, position binder: Departure Checklist," be updated to include debriefing the teams with the appropriate coordinators.

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 Original Content Content Change Change Number I Type of Change I Reason for 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 corporate emergency response company emergency operations intent. 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 Original Content Emergency Director Checklist

1. Classify and declare an. emergency condition within 15 minutes per EP G-1. REFER TO Tab 4. a) If time permits, obtain at , least one peer check from EOF Director, SEC, and/or SM on EAL recommendation. , Emergency Director Checklist

6. Direct the following individuals to make announcements:

Emergency Director Checklist 9.) Direct Communications Coordinator to perform routine follow-up offsite notifications to County, State, and NRC officials Content Change Emergency Director Checklist

2. Classify and declare an emergency condition within 15 minutes per EP G-1. REFER TO Tab 4. a. Confer with EOF Director on EALs. b. If time permits, obtain at least one peer check from SEC and/or SM on EAL recommendation.

Emergency Director Checklist

6. Direct the following individuals to make PA announcements:

Emergency Director Checklist 9.) Direct Communications Coordinator to perform routine and expedited

' follow-up offsite notifications to County, State, and NRC officials per EP G-3. 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 Change Change #4 -Administrative change with no change of intent. Change is being made to delineate that an independent peer check is needed, if time permits. The EOF Director is not considered a peer as they report to the ED and are located in the same facility.

The EOF Director 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 EOF Director or the ED with respect to performing their emergency assignments in accordance with the E-Plan. Change #5 -Editorial change with no change of intent. r Editorial change to add PA in front of announcement to be consistent with designation in sections a) and b). Change #6 -Editorial change with no change of intent. The information pertaining to both routine and expedited notifications exists in EP G-3. This change is being Original Content per EP G-3. REFER TO Tab 7. Emergency Director Checklist

b. Other Functions and Responsibilities

1) Personnel Protective Measures a) Authorize emergency exposures as needed per EP RB-2. REFER TO Tab8. b) Authorize administration of potassium iodide (Kl) to PG&E offsite emergency workers per EP RB-3. REFER TO Tab 9. Emergency Director Checklist

b. Other Functions and Responsibilities

2) Site Evacuation .a) lE informed by SEC of pending Site Evacuation of non-essential personnel Content Change REFER TO Tab 7. Emergency Director Checklist

b. Other Functions and Responsibilities

1) Personnel Protective Measures a) Authorize emergency exposures as needed per EP RB-2. REFER TO Tab 8. b) Authorize administration of potassium iodide (Kl) to PG&E offsite emergency workers (including FMTs) per EP RB-3. REFERTO Tab 9. Emergency Director Checklist

b. Other Functions and Responsibilities

2) Early Work Release or Site Evacuation a) lE informed by SEC of 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 Change made for consistency between EP G-3 and EP EF-3. Change #7 -Administrative change with no change of intent. Added FMT's to clarify that they are included as offsite emergency workers. This is a clarification and does not impact the tasks the ED performs.

Change #8 -Editorial change with no change of intent. EP G-5 designates that the ED is provided information on and coordination of both Early Work Release and Site Evacuation.

This change is being made for consistency between EP G-5 and EP EF-3.

Original Content Content Change from DCPP, Site Evacuation of non-essential THEN: personnel from DCPP, (1) Ensure evacuation is THEN: coordinated with County. (1) Ensure Early Work (2) Notify company Release or Site Evacuation is spokesperson of coordinated with County. upcoming site (2) Notify company evacuation.

spokesperson of upcoming Early Work Release or Site Evacuation.

EOF Director Checklist EOF Director Checklist New content g. Assign individuals to maintain facility status boards (e.g. Electrical Bus Loads, Sequence of Events, ENF Tracking, Unit 1 and 2 Plant Status). EOF Director Checklist EOF Director Checklist New content 4) Ensuring all facility status boards are being maintained.

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 Change Change #9 -Administrative change with no change of intent. Added step 1.g to formalize a process already in place. 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.

Change #10 -Administrative change with no change of intent. 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 Original Content Radiological Manager Checklist

f. Check the following staffing positions have been filled (* designates "minimum staffing" position.)

7) UDAC Clerk FMT Coordinator Checklist

i. Establish EOF/EOC radiological protection*.

2) Complete County Exposure Tracking Sheet and submit copy to Emergency Worker Exposure Coordinator (EWEC) via County UDAC -Coordinator.

REFER TO Tab 5. Content Change Radiological Manager Checklist

f. Check the following staffing positions have been filled (* designates "minimum staffing" position.)

7) UDAC Admin Assistant FMT Coordinator Checklist

i. Establish EOF/EOC radiological protection.

2) Complete County Agency Personnel Exposure Log and submit copy to Emergency Worker Exposure Coordinator (EWEC) via County UDAC Coordinator.

REFER TO 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 Change intent within the E-Plan as the responsibilities have not changed. This is an administrative task and does not require any specific qualification.

Change #11 -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. Change #12 -Editorial*change with no change of intent. This is a reference to a San Luis Obispo (SLO) County form. SLO County renamed the form and this change is being made to accurately reflect the new form name.

Original Content FMT Coordinator Checklist

a. Dispatch and coordinate activities of FMTs and offsite emergency lab. 8) Provide copies, or direct UDAC Clerk to provide copies, of FMT Data Sheets to the following individuals: . 9) Maintain, or direct the UDAC Clerk to maintain, FMT and U DAC status boards (team assignment and location).

FMT Coordinator Checklist NOTE:UDAC Clerk may assist with communication requirements for this function.

FMT Coordinator Position Binder Tab Index Form CC-12, "County Exposure Tracking Sheet" (111.06, HP-11) Content Change FMT Coordinator Checklist

a. Dispatsh and coordinate activities of FMTs and offsite emergency lab. 8) Provide copies, or direct UDAC Admin Assistant to provide copies, of F,MT Data Sheets to the following individuals:

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

FMT Coordinator Checklist NOTE:UDAC Admin Assistant may assist with communication requirements for this function.

FMT Coordinator Position Binder Tab Index Form 2, "Agency Personnel Exposure Log" (111.06, HP-11) 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 Change Change #13 -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 "Ad min". Refer to SAPN 50449609, Task 17. Change #14 -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. '* Change #15 -Editorial change with no change of intent. This is a reference to a San Luis Obispo (SLO) County Original Content EOF Security Liaison Checklist New content Communications Coordinator I Checklist

1. Initial Actions d. Obtain all Emergency Notification Forms (ENF) from the ENF software program. 1) Approved ENFs may be obtained by clicking the "View/Edit Archived Notification Form Events" link in the ENF software program. a) Have support staff (clerks) distribute hard copies of all ENFs. Content Change EOF Security Liaison Checklist

b. Coordinate with County for Early Work Release and Site Evacuations.

Communications Coordinator Checklist

1. Initial Actions d. Obtain all Emergency Notification Forms (ENF) from the ENF software program. 1) Approved ENFs may be obtained by clicking the "View/Edit Archived Notification Form Events" link in the ENF software program. a) Have support staff (Admin) distribute hard copies of all ENFs. 2) Notify support staff (Admin) that 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 Change form. SLO County renamed the form and this change is being made to accurately reflect the new form name. Change #16 -Process change with no change of intent. 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. ' Change #17 -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.

/ Original Content 2) Notify support staff (clerks) that you are to immediately receive copies of all emergency notifications received by fax. Communications Coordinator Checklist

2. Ongoing Actions NOTE: Notifications to the County and State are required to be completed within 15 minutes from the time of a new emergency classification or PAR. Follow up notifications should be made within approximately 45 minutes of the last notification.

Communications Coordinator Checklist

2. Ongoing Actions b. Oversee transmittal and distribution of notifications.

3) Provide or direct Offsite Communicator to provide a coov of completed notification Content Change you are to immediately receive copies of all emergency . notifications received by fax. Communications Coordinator Checklist

2. Ongoing Actions NOTE: Notifications to the County and State are required to be completed within 15 minutes from the time of a new classification or PAR. Follow up notifications should be made within approximately 45 minutes or less of the last notification.

Enclosure 7 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #18 -Administrative change with no change of intent. The statement "or less" already exists in EP G-3. Adding "or less" in this note brings EP EF-3 in line with EP G-3 to provide better alignment between the procedures.

Communications Coordinator Checklist Change #19 _Editorial change with no change of 2. Ongoing Actions intent. b. Oversee transmittal and distribution of notifications.

3) Provide or direct Offsite Communicator to provide a copy of completed notification forms to EOF Admin Assistant for 8 of 23 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.

Original Content forms to EOF Clerk for distribution and posting. Communications Coordinator Checklist

2. Ongoing Actions b. Oversee transmittal and distribution of notifications.

,* 4) Ensure follow-up emergency notifications are issued approximately every 45 minutes. Offsite Communicator Checklist

1. Initial Actions f. Coordinate with EOF clerk and UDAC clerk to ensure copies of ENFs are immediately distributed to the EOF staff upon receipt. Offsite Communicator Checklist

2. Ongoing Actions NOTE: Notifications to the County and State are required to be completed within 15 minutes Content Chan*ge distribution and posting. Communications Coordinator Checklist

2. Ongoing Actions b. Oversee transmittal and distribution of notifications.

4) Ensure follow-up emergency notifications are issued approximately every 45 minutes or less. Offsite Communicator Checklist

1. Initial Actions f. Coordinate with EOF Admin Assistant and UDAC Admin Assistant to ensure copies of ENFs are immediately distributed to the EOF staff upon receipt. Offsite Communicator Checklist

2. Ongoing Actions NOTE: Notifications to the County and State are required to be completed 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 Change Change #20 -Editorial change with no change of intent. The statement "or less" already exists in EP G-3. Adding "or less" in this note brings EP EF-3 in line with EP G-3 to provide better alignment between the procedures.

Change #21 -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. Change #22 -Editorial change with no change of intent. The statement "or less" already exists in EP G-3. Adding "or less" in this note brings EP EF-3 in line with Original Content from the time of a new emergency classification or PAR. Follow up notifications should be made within approximately 45 minutes of the last notification.

Offsite Communicator Checklist

2. Ongoing Actions b. Transmit, receive, and document notification information.

8) Assist in completing follow-up emergency notifications to be issued approximately every 45 minutes. Government Relations Coordinator Checklist

1. Initial Actions g. Provide initial notification to company personnel as follows: 2) Initiate videoconference or teleconference contact with government relations Content Change new emergency classification or PAR. Follow up notifications should be made within approximately 45 minutes or less of the last notification

... Offsite Communicator Checklist

2. Ongoing Actions b. Transmit, receive, and document notification information.

8) Assist in completing follow-up emergency notifications to be issued approximately every 45 minutes or less. Government Relations Coordinator Checklist

1. Initial Actions g. Provide initial notification to company personnel as follows: 2) Initiate videoconference or teleconference contact with 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 Change EP G-3 to provide better alignment between the procedures.

Change #23 -Editorial change with no change of intent. The statement "or less" already exists in EP G-3. Adding "or less" in this note brings EP EF-3 in line with EP G-3 to provide better alignment between the procedures.

Change #24 -Administrative change with no change of intent. Reflect specific location in General Office of Emergency Operations Center where videoconference and teleconference capability exists. Videoconference is set up with automatic connection to this location.

This change enhances the capability to effectively communicate with the General office.

Original Content Content 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 Checklist

1. Initial Actions h. Make contact with General Office Technical Liaison (GOTL) and request that they report to PG&E General Office and act as a liaison to company EOC. 1) Maintain contact with GOTL to ensure that they are kept informed of event status. 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 Change Change #25 -Process change with no change of intent Role of GOTL is evolving as the Company Emergency Response Plan (ERP) is developed.

ERP designates point at which the Company EOC will activate in the event of an incident at DCPP. If Company EOC is activated they expect a Nuclear Liaison to respond to the EOC to provide information between the EOF and 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.

Original Content Government Relations Coordinator Checklist

2. Continuing Actions a. Monitor actions and events from EOF to provide information to other government relations representatives, and JIC personnel. . Government Relations Coordinator Checklist

2. Continuing Actions d. Update the Policy Group Chair of designee, and External Communications Content Change Government Relations Coordinator Checklist

2. Continuing Actions a. Monitor actions and events from EOF to provide information to other government relations representatives, GOTL and JIC personnel.

' Government Relations Coordinator Checklist

2. Continuing Actions d. Update the Company EOC Incident Commander or GOTL (if 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 Change Change #26 -Process change with no change of intent Role of GOTL is evolving as the Company Emergency Response Plan (ERP) is developed.

ERP designates point at which the Company EOC will activate in event of an incident at DCPP. If Company EOC 1s activated they expect a Nuclear Liaison to respond to the EOC to provide information between the EOF and 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. Change #27 -Editorial change with no change of intent. Change title of Policy Group Chair to Company EOC Incident Commander and specify GOTL rather than designee to reflect updates in the Company Emergency Original Content and Coordination Center (EXCCC) (if activated) at least every classification change of the following:

e. Obtain information from the Policy Group Chair (or designee) regarding:

Government Relations Coordinator Checklist

2. Continuing Actions f. IF requested by Policy Group Chair (or designee) to provide a liaison at company EOC or PG&E General Office, THEN contact General Office Technical Liaison to report to PG&E General Office. Content Change Communications and Coordination Center (EXCCC) (if activated) at least every classification change of the following:

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

Content moved to section 1.h 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 Change Response Plan. Refer to SAPN 50449609, Task 25. Change #28 -Process change with no change of intent. Content moved to initial actions. The role of the GOTL evolved when the Company Emergency Response Plan (ERP) was modified to comply with the Incident Command System (ICS). The ERP designates point at which the Company EOC will activate in the event of an incident at DCPP. If Company EOC is activated they expect a Nuclear Liaison to respond to the EOC to provide information between the EOF and EOC. This is 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.

Original Content Government Relations Coordinator Checklist

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

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

1. Initial Actions c. Initiate and maintain a position log (use Emergency Log Sheets) to documenting significant actions performed and communications related to your position.

REFER TO Tab 1. EOF Security Checklist

1. Initial Actions e. Setup Content Change Government Relations Coordinator Checklist

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

1) Represent JIG in interactions with EOF and County Public Information Manager (PIM) in EOG. EOF Security Checklist

1. Initial Actions c. Initiate and maintain a position log (use Emergency Log Sheets) to* documentffi§-significant actions performed and communications related to your position.

REFER TO Tab 1. EOF Security Checklist

1. Initial Actions 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 Change Change #29 -Editorial change with no change of intent. This change is correcting a typo which left off a letter. Change #30 -Editorial change with no change of intent. This change is correcting a grammatical error. Change #31 -Administrative change with no change of intent.

Original Content 1) Use Attachment 3, "Emergency Operations Facility Security Set Up," of this procedure as guidance to position access tables and chairs at facility entry point. REFER TO Tab 2. 2) Obtain position vests and ID badges. 3) Locate access lists and EOF ID badges. EOF Security Checklist

2. Ongoing Actions a. Provide building access controls for PG&E and NRC personnel to EOF. 1) Check for proper access identification:

a) PG&E ID badge. b) EOF ID badge. . c) NRC ID badge. d) Name appears on visitor list. 2) Record entry and exit time Content Change 1) Use Attachment 3, "Emergency Operations Facility Security Set Up," of this procedure as guidance to position access tables and chairs at facility entry point. REFER TO Tab 2. 2) Obtain position vests, tables and chairs and ID badges. 31 Locate access list. and EOF ID badges. EOF Security Checklist

2. Ongoing Actions a. Provide building access controls for PG&E and NRC personnel to EOF. 1) Check for proper access identification:

a) PG&E ID badge. b) EOF ID badge. c) NRC ID badge . d) Name appears on visitor list. 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 Change This change is being made as he position vests contain an ID of the position and the need for ID badges is redundant.

In addition, PG&E is no longer responsible for checking in county staff or visitors.

PG&E is only responsible for maintaining a list of PG&E and NRC personnel that are reporting to the EOF. None o_f changes to this checklist change or add respons1b1ht1es and there is no impact on the E-Plan. Refer to SAPNs 50872169 and 5082167. --Change #32 -Process change with change of intent This change is needed to bring the procedure up to date with upgrades that have occurred.

The position vests contain an ID of the position and the reed for ID badges is redundant.

In addition, PG&E is no longer responsible for checking in county staff or visitors.

PG&E is only responsible for maintaining a list of PG&E and NRC personnel that are reporting to the EOF. None of the changes to this checklist change or add responsibilities and there is no impact on the E-Plan. Refer to SAPNs 50872169 and 5082167.

Original Content of individuals entering and exiting EOF 3) Personnel not having approved ID or on access list may be granted access by EOF Director.

EOF Administrative Support Checklist

1. Initial Actions e. Coordinate with other Clerical staff and Emergency Director Administrative Assistant to assume one of the following support roles: 1) EOF Clerk (REFER TO step 2.b) 2) UDAC Clerk (REFER TO steps 1.f and 2.c) f. UDAC Clerk: 1) Report to Radiological Manager and inform him or her that you are performing UDAC Clerk duties. Content Change individuals entering and exiting EOF on access list. a) Do not delay facility activation to record entry times. Allow PG&E badged personnel to bypass, and obtain entry times from EOF sign-in board after facility activation.

EOF Administrative Support Checklist

1. Initial Actions e. Coordinate with other Administrative staff and Emergency Director Administrative Assistant to assume one of the following support roles: 1) EOF Adm in Assistant (REFER TO step 2.b) 2) UDAC Admin Assistant (REFER TO steps 1.f and 2.c) f. UDAC Admin Assistant:

1) Report to Radiological Manager and inform him or her that you are performing UDAC 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 Change Change #33 -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.

Original Content EOF Administrative Support Checklist

2. Ongoing Actions b. EOF Clerk: c. UDAC Clerk: d. Position Relief Turnover 3) Notify the individual specified that you have turned over your ERO responsibilities.

a) EOF Clerk -notify EOF Director b) UDAC Clerk-notify Radiological Manager EOF Clerical Support Position Binder Tab Index EP EF-3, Form 69-21134, "EOF Clerical Support Checklist" -Content Change EOF Administrative Support Checklist

2. Ongoing Actions b. EOF Admin Assistant:

c. UDAC Admin Assistant:

d. Position Relief Turnover 3) Notify the individual specified that you have turned over your ERO responsibilities.

a) EOF Admin Assistant

-notify EOF Director b) UDAC Admin Assistant-notify Radiological Manager EOF Administrative Support Position Binder Tab Index EP EF-3, Form 69-21134, "EOF Administrative Support Checklist" 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 . Change Change #34 -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, Task17. Change #35 -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.

Original Content Emergency Director Admin Assistant Checklist

1. Initial Actions c. Check in with ED and EOF Director.

1) Confirm role expectations for: a) Phone Coverage b) White board communications (Admin. Assistant or EOF Director).

c) Maintaining ED log. Emergency Director Admin Assistant Checklist

1. Initial Actions e. Assign clerical to location/department as needed: g. Contact Administrative Advisor at Tse;. 1) Administrative Advisor may provide: a) Additional clerical Content Change Emergency Director Admin Assistant Checklist

1. Initial Actions c. Check in with ED and EOF Director.

d. Maintain Phone coverage.

e. Verify that the EOF director has assigned individuals to maintain status boards. f. Maintainffi9 ED log. Emergency Director Admin Assistant Checklist

1. Initial Actions e. Assign administrative support to location/department as needed: g. Contact Administrative Advisor at TSC. 1) Administrative Advisor may '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 Change Change #36 -Administrative change with no change of intent Change is being made to align with position expectations and to reorder steps for clarity. This is not a change of intent within the E-Plan as the responsibilities have not changed. The change adds . clarity and alignment.

Change #37 -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.

Original Content support for the EOF. 2. Ongoing Actions b. Ensure EOF clerical staff is adequate to support ERO functions.

General Office Technical Liaison Checklist

1. Initial Actions g. IF requested by Policy Group Chair (or designee) to provide a liaison at company EOD or PG&E General Office, THEN report to PG&E General office. 2. Continuing Actions a. Monitor actions and events from EOF to provide information to corporate response.

personnel.

1) Coordinate with EOF Director and Engineering Liaison to develop Content Change a) Additional administrative support for the EOF. 2. Ongoing Actions b. Ensure EOF administrative support is adequate to support ERO functions.

General Office Technical Liaison Checklist

1. Initial Actions g. IF requested report to Company EOG and act as liaison. h. Upon arrival at Company EOG, establish contact with the following:

1) Incident Commander 2)0perations Section Chief i. Provide event status update to the Company EOG. j. Contact Government Relations Coordinator in EOF to remain current on events and response actions taking 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 Change Change #38 -Process change with no change of intent. The role of the GOTL evolved when the Company Emergency Response Plan (ERP) was modified to comply with the Incident Command System (ICS). ERP designates point at which the Company EOC will activate in the event of an incident at DCPP. If Company EOC is activated they expect a Nuclear Liaison to respond to the EOG to provide information between the EOF and EOC. This is an automatic action and does not need to be requested.

The change adds clarity and alignment with the ERP.

Original Content information about significant emergency events. c. Evaluate and respond to external company issues and inform the ED of corporate status and decisions.

d. Assist the Government Relations Coordinator with updating the Policy Group Chair, or designee, and External Communications and Coordination Center (EXCCC) (if activated) at least every classification change of the following:

e. Position Relief Turnover 3) Notify EOF Director that you have turned over your ERO responsibilities.

Content Change 2. Continuing Actions

• a. Monitor actions and events from EOF to provide information to corporate response personnel.

1) Coordinate with Government Relations.

Coordinator to develop information about significant emergency events. c. Evaluate and respond to external company issues and inform the Government Relations Coordinator of corporate status and decisions.

d. Update the Company EOC Incident Commander, or designee, and External Communications and Coordination Center (EXCCC) (if activated) at least every classification change of the 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

• Change -

Original Content General Office Technical Liaison Checklist

3. Situation Actions a. IF travel to the corporate emergency operations center has been requested, THEN upon arrival at G.O. EOC, establish contact with the following:

b. Corporate Security c. Lead officers in the 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. / Content Change responsibilities.

General Office Technical Liaison Checklist

3. Situation Actions Content relocated to Section 1.g, h, i and j. 21 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 Change Change #39 -Administrative change with no change of intent Content was moved into Sections 1.g, h, I, and j of the checklist as position is expected to travel to Company Emergency Operations Center upon request. Role of GOTL is evolving as the Company Emergency Response Plan (ERP) is developed.

ERP designates point at which the Company EOC will activate in event of an incident at DCPP. If Company EOC 1s activated they expect a Nuclear Liaison to respond to the EOG to provide information between the EOF and EOG. This is now an initial action as opposed to a situational specific.

'

Original Content Attachment 24 FMT Briefing Sheet Part 2 New content / ,' Communications Coordinator Checklist 1.lnitial Actions g. Perform the following bridge line monitoring actions: 2)Monitor or have the Offsite Coordinator monitor bridge line x2002 Content Change Attachment 24 FMT Briefing Sheet Part 2 Verify thateach FMT member completes Record of Distribution of Potassium Iodide (Kl) form 69-9395 and review the Kl Consumer Package Insert. Tell them "Do not ingest Kl until directed".

Gamma instrument exposure rate turn-back values: 20 mr/hr for offsite FMTs unless told otherwise 200 mr/hr for onsite FMTs unless told otherwise Communications Coordinator Checklist 1.lnitial Actions g. Perform the following bridge line monitoring actions: 2)Monitor or have the Offsite Communicator 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 Change Change #40 -Administrative change with no change of intent This change is being made to ensure that Kl Authorization for the PG&E Field Monitoring Teams (FMT) is documented and that FMTs are provided the IOSAT Kl pharmaceutical precautions as directed by 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. There is no effect on the implementation of the E Plan. Change #41 -Editorial Change with no change in intent. Change is being made to correct a typo in a position, title. Refer to SAPN 50449609, Task 27.

Original Content

• Content Change Attachment 30 Dose Assessment Attachment 30 Dose Assessment Data Data Sheet Sheet ESE distribute copies to: Admin Assistant distribute copies to: 3. RESPONSIBILITIES

3. RESPONSIBILITIES 3.1 O EOF security liaison is 3.1 O EOF security liaison is responsible for: responsible for: 3.10.2 This position is not an 3.10.2 Deleted content ERO minimum staff or ERO support staff position.

This position serves an advisory role only and would be called out as needed. 23 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 Change Change #42 -Editorial change with no change in intent. Change is being made to correct an obsolete position title and replace with appropriate position title. Refer to SAPN 50449609, Task 13. Change #43 -Administrative change with no change of intent. This change is being made to align EP EF-3 with Section 5 of the E-Plan step 3.10.2 is no longer necessary as Revision 4.15 to E-Plan Section 5 made the Security Liaison position an ERO support staff position.

Refer to SAPN 50449609, Task 14.

Summary of the Analysis of Changes to Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 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

• Accessibility EP EF-9 should be revised to replace room, and security [ ... ] plan mitigative

• Communication links with other the term with backup so as actions).

facilities (e.g. EOF) control rc;>om, and to reduce confusion between the two. 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 Original Content ERF Prim First Second ERF Function ary Backup Backup Function Facili ty Control Con tr Hot S/D (None) Control Room al Panel Room Rao (SM/SFM);

m TSC (SM, STA, SFM) TSC TSC Control Hot S/D Room Panel_ TSC (Min. (Min.

Staff); Staff.); TM/Trng. EOF Bldg. (Supper (Supp.) t) ) OSC-osc 140' Adminis Command -104' Turbine tration OSC-Center Buttr Building -Building Command ess Northeast Room Center Area Corner 215 OSC-Mai osc 140' Canyon ntenance -104' Turbine Rm/Trn OSC-Mai Assembly Buttr Building -g Bldg ntenance Area ess Northeast Craft Area Corner Assembly Area Content Change Prim First ary Backup Facili ty Con tr SM/SFM -al Hot S/D Rao Panel m SM, STA, SFM-TSC TSC Min. Staff--104' Control Buttr Room ess Support Area Staff -Bldg. 109 osc 140' -104' Turbine Buttr Building -ess Northeast Area Corner osc 140' -104' Turbine . Buttr Building -ess Northeast Area Corner 2 of 8 Second Backup (None) Min. Staff -Hot S/D Panel Support Staff -EOF Adm in is tration Building Room 215 Canyon Rm or Training Bldg. 109 Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change 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 (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. This revision adds the EOF as a designated ERF and identifies the first backup as the EEC, and the second backup as SLO ECCO. This ensures that the commitment in the DCPP. E-Plan is fully implemented.

Note that SAPN 50432078, Task 4, also documents that the EEC should be listed as the first choice for the backup EOF. SAPN 50432078, Task 2, states that TM/Trng Bldg" is vague, and recommends that it should be referred to as "Bldg. 109." This revision also

CR/OSC-Con tr OPs 119' Nuclear cl Ready Turbine Operator Roe Room Building Assembly m Ofc/Cyn Area Rm OSC-85' 140' TSC C&RP Acee Access Lab Technicia SS Control n Contr Assembly cl Area Section 2.4 Control Room Function, TSC Function, & Access Control Function Tables Content Change -------------. ----------CR/OSC-Con tr OPS ---

--Nuclear cl Ready Work Operator Roe Room Control Assembly m Center Area or Canyon Rm OSC-85' 140' TSC C&RP Acee Access Lab Technicia SS Control n Contr Assembly al Area EOF EOF Energy SLO Education ECCO-Center-PG&E Ontario Service Road Center S. Higuera Section 2.4 Control Room Function & TSC Function Tables

• Deleted "Black Net phone" Access Control Function Table 3 of 8 Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change incorporates this enhancement, as well -as-otheLs to clarify locations and increase reaaability.____

--The words "on-site" were removed; as_ -the EOF is not onsite and it is no longer applicable.

These changes are being made to align with the current DCPP E-Plan, or are clearly enhancements for procedure usability; therefore, there is no impact on how the E-Plan meets the planning standards, functions or elements.

Change #4 -Process change with change of intent. SAPN 50432078, Task 5, documents that EP EF-9 should be updated to remove "Black Net phones," that were Original Content Content Change

• Changed "PICs" to "PEDs" ) 4 of 8 Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change 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.

Original Content Content Change Section 4.2 Section 3.2 NIA -New content Added "EOF I Emergency Director" 5 of 8 Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 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. Change #5 -Process change with 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.

Original Content Section 5.1 A backup ERF shall be activated when an ERF is determined uninhabitable or otherwise may not start up or continue operations:

See Section 2.1 above for the recommended succession of ERFs. Section 5.3 5.3.1 Backup Control Room: OP AP-BA 5.3.2 Backup TSC: Attachment 7 .1 5.3.3 Backup OSC: Attachment 7.2 5.3.4 Backup Access Control: Attachment

7.3 Content

Change Section 6.1 A backup ERF shall be activated when a primary ERF is determined uninhabitable or otherwise may not start up or continue operations.

See Section 2.1 above for the recommended succession of ERFs. Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 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.

Change #6 -Editorial change with no change of intent. "Primary" being added for clarification only -no change of intent. Section 6.4 Change #7 -Process change with 6.4.1 Backup Control Room: OP AP-BA change of intent. 6.4.2 Backup TSC: Attachment 1 During the Ocean PAR Root Cause 6.4.3 Backup OSC: Attachment 2 Extent of Condition, it was determined

6.4.4 Backup

Access Control: Attachment 3 6.4.5 Backup EOF: Attachment 5 6 of B 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 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 Original Content Content Change -Section 6, Records Section 7.1 & 7.2, Records Checklists completed due to use of this Documents generated by this procedure procedure in a drill or actual event shall be during drills are non-quality records and are forwarded to the Emergency Planning maintained per emergency preparedness Manager for entry into Records administrative procedures.

Management System. Documents generated by this procedure during actual events are non-quality records 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 accordance with AD1 .101 requirements for new template.

7 of 8 Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 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.

Change #8 -Editorial change with no change of intent. Updated the records section to align with other E-Plan Implementing Procedures and AD10.ID2.

This change aligns the EP EF-9 with the current plant process. Change #9 -Editorial change with no change of intent. Attachments reformatted to comply with AD1 .101 requirements.

Editorial changes were made throughout attachments as well.

Original Content Content Change N/A -New Content Attachment 5 Added new attachment, "Backup EOF Activation" 8 of 8 Enclosure 8 PG&E Letter DCL-16-120 PG&E Letter DIL-16-018 Change Number I Type of Change I Reason for Change Change #10 -Process change with 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 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.