DCL-18-082, Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update

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Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update
ML18288A749
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 10/15/2018
From: Ginn M
Pacific Gas & Electric Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
DCL-18-082, DIL-18-014
Download: ML18288A749 (27)
v • d • e


Text

Pacific Gas and Electric Campany*

Michael A. Ginn Diablo Canyon Power Plant Manager P.O . Box 56 Emergency Planning Avila Beach, CA 93424 805.545.3446 Internal: 691.3446 Fax: 805.545.6265 October 15, 2018 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 U.S. Nuclear Regulatory Commission 10 CFR 50.54, 10 CFR 72.32 ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Docket No. 72-26, Materials License No. SNM-2511 Diablo Canyon Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update

Dear Commissioners and Staff:

In accordance with 10 CFR 50.54(q)(5) 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 Procedure EP RB-3, "Stable Iodine Thyroid Blocking."

The associated enclosures are listed below:

  • Enclosure 1 - Diablo Canyon Power Plant Emergency Plan Implementing Procedures, Revision Numbers for Emergency Plan Implementing P raced u res.
  • Enclosure 2 - Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-3, Revision 8, "Stable Iodine Thyroid Blocking."

PG&E evaluated the changes for a reduction in effectiveness, as defined in 10 CFR 50.54(q), and concluded that the changes do not reduce the effectiveness of the E-Plan. The E-Plan continues to meet the requirements in Appendix E of 10 CFR 50 and the planning standards of 10 CFR 50.47(b). Therefore, prior NRC approval of the associated changes was not required .

A member of the STARS Alliance Callaway* Diablo Canyon* Palo Verde* Wolf Creek

Document Control Desk PG&E Letter DCL-18-082 October 15, 2018 PG&E Letter DIL-18-014 Page 2 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,

~Y-~G-Michael A. Ginn Emergency Planning Manager armb/47 43/50997391 Enclosures cc/enc: William C. Allen, NMSS Project Manager Kriss M. Kennedy, NRC Region IV Administrator Christopher 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-18-082 PG&E Letter DIL-18-014 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Revision Numbers for Emergency Plan Implementing Procedures

Enclosure 1 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Proc. No. Rev. Title OM10.ID1 18 Maintaining Emergency Preparedness OM10.DC1 9 Emergency Preparedness Drills and Exercises EP G-1 45 Emergency Classification and Emergency Plan Activation EP G-2 51 Interim Emergency Response Organization EP G-3 60 Emergency Notification of Off-Site Agencies EP G-4 30 Assembly and Accountability EP G-5 15 Evacuation of Non-Essential Site Personnel EP OR-3 10 Emergency Recovery EP RB-1 8 Personnel Dosimetry EP RB-2 8 Emergency Exposure Guides EP RB-3 8* Stable Iodine Thyroid Blocking EP RB-4 5 Access to and Establishment of Controlled Areas Under Emergency Conditions EP RB-5 9 Alternate Personnel Decontamination Facilities EP RB-8 29 Instructions for Field Monitoring Teams EP RB-10 21 Protective Action Recommendations EP RB-12 12 Plant Vent Iodine and Particulate Sampling During Accident Conditions EP RB-14 10 Core Damage Assessment Procedure EP RB-14A 3 Initial Detection of Fuel Cladding Damage EP RB-15 15 Post Accident Sampling System EP RB-16 16 Operating Instructions for the EARS Computer Program EP RB-17 1 Operating Instructions for QuickDose EP R-2 36 Release of Airborne Radioactive Materials Initial Assessment EP R-3 9 Release of Radioactive Liquids EP R-7 18 Off-Site Transportation Accidents EP EF-1 55 Activation and Operation of the Technical Support Center EP EF-2 40 Activation and Operation of the Operational Support Center EP EF-3 46 Activation and Operation of the Emergency Operations Facility EP EF-4 21 Activation of the Off-Site Emergency Laboratory EP EF-9 12 Backup Emergency Response Facilities EP EF-10 17 Activation and Operation of the Joint Information Center EP EF-11 2 Alternate Emergency Response Facilities/ Incident Command Post (ICP)

  • Revised Document Page 1 of 1

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-3, Revision 8, "Stable Iodine Thyroid Blocking"

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 Chang Original Content (Rev 7) Revised Content (Rev 8) Description of Change e

1 N/A Procedure was converted Added content.

Procedure was converted to meet the current revision of the Nuclear Generation Procedure Writer's Manual.

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

2 Table of Contents Table of Contents Added content.

Section Page Headers Section and Page Headers were deleted Changes were made to Table of Contents .

Scope Scope Responsibilities Discussion This change does not affect how the Instructions Responsibilities current E-Plan meets any planning Records Prerequisites standard functions, elements, or site-Attachments Precautions and Limitations specific commitments. No additional Instructions evaluation required.

Issuance of Kl Authorization of Kl Ingestion Ingestion of Kl County Emergency Workers

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DI L-18-014 Follow-Up Actions Records References 3 5. Attachments Table of Contents Modified content.

5.1 "Form 69-9395, "Record of Attachments Section 5 of Revision 7 of EP RB-3 was Distribution of Potassium Iodide," 1. Kl Process Flowchart moved to the Table of Contents.

03/23/00

2. Form 69-22007, Record of Distribution This change does not affect how the of Potassium Iodine, 08/15/18 current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

4 1. Scope, 1. SCOPE Modified content.

1.1 This procedure provides 1.1 This procedure provides instructions The following, "for Pacific Gas and instructions for the administration of for the issuance, authorization, and Electric (PG&E) emergency personnel",

stable iodine in the form of ingestion of stable iodine in the form of was added to provide clarity that this Potassium Iodide (Kl) under Potassium Iodide (Kl) under emergency procedure is to be used by PG&E emergency conditions for emergency conditions for Pacific Gas and Electric emergency personnel only.

personnel. (PG&E) emergency personnel.

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

5 N/A 1.2 This procedure was rewritten; Added content.

therefore, revision bars are not included .

This step was added to explain that the

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 entire procedure was reformatted to meet the current revision of the Nuclear Generation Procedure Writer's Manual.

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

6 N/A 2. DISCUSSION Added content.

This section was added to meet the current standard.

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

7 N/A 2.1 Kl is a salt of stable iodine that can Added content.

help block radioactive iodine from being absorbed by the thyroid gland in the Added a discussion describing Kl, its unlikely event of a nuclear reactor benefits and potential side effects.

accident, thus reducing radiation exposure. Consumption of Kl can cause This change does not affect how the some side effects which may include current E-Plan meets any planning stomach or gastro-intestinal upset, allergic standard functions, elements, or site-reactions, rashes, and inflammation of the specific commitments. No additional salivary glands. evaluation required.

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 8 N/A 2.2 The county Health Officer controls Added content.

authorization for consumption of Kl for all non-PG&E employees. Added a discussion explaining that the county Health Officer's is responsible for non-PG&E personnel Kl consumption.

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

9 N/A 2.3 Evaluating when to Issue Kl Added content.

2.3.1 Consider issuing Kl to PG&E Added a discussion about evaluating emergency personnel when responding to when to consider issuing Kl as an aid to an event in which any one of the following the Rad Advisor, or Rad manager.

exists:

  • The potential for a radioactive release This change does not affect how the to the environment due to the event. current E-Plan meets any planning
  • There is a radioactive release to the standard functions, elements, or site-environment due to the event. specific commitments. No additional
  • Fuel damage . evaluation required.

10 3.1 Evaluating When to Administer 2.4 Evaluating when to authorize the Modified content.

Kl ingestion of Kl Moved this discussion about evaluating when to authorize the ingestion of (administer) Kl from the Instructions section to the new Discussion section .

This change does not affect how the

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DI L-18-014 current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

11 Note following 3.1.1.b Note before step 2.4.1 Modified content.

If the County Health Officer approves Authorization of Kl ingestion for PG&E The note was rewritten for clarity and Kl administration to the County emergency personnel may be considered moved from the Instructions section to emergency workers, then approving below the 5 rem exposure Protective the beginning of the Discussion section Kl administration for PG&E workers Action Guideline, if the County Health to be more appropriately located.

may be considered below the 25 rem Officer authorizes Kl ingestion for County exposure Protective Action emergency workers. The Protective Action Guideline of Guideline. 25 rem was changed to 5 rem to be in accordance with EPA-400/R-17/001, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents". Five rem is also in accordance with San Luis Obispo County Health Agency SOP (CHO-07).

The change to reduce the exposure limit from 25 rem to 5 rem was fully evaluated under 50.54(q) effectiveness evaluation 2018-59. No additional evaluation required.

12 3.1.1 Kl is most effective when 2.4.1 Kl is most effective when ingested Modified content.

administered immediately prior to immediately prior to exposure to exposure to radioiodine, therefore radioiodine. Therefore, authorization of Kl Moved from the Instructions section to administration of Kl should be ingestion should be considered when any the Discussion section.

considered when: one of the followinq exists:

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

13 N/A 2.4.1 Added content.

  • Core conditions exist where there is Added a step as a bullet item to gap source term with degrading plant consider Kl authorization when there is conditions. core gap source term with degrading plant conditions.

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

14 3.1.1.a. Exposure situations exist 2.4.1. Modified content.

where calculated iodine dose equivalent to the thyroid can be

  • Exposure situations exist where This step was rewritten for clarity and 25 rem or greater. calculated thyroid Committed Dose the exposure limit was changed from Equivalent (Thy COE) of iodine to the 25 rem to 5 rem to be in accordance thyroid may be 5 rem or greater. with EPA-400/R-17/001, which has been added to revision S's References and is now Reference 9.1. Five rem is also in accordance with San Luis Obispo County Health Agency SOP (CH0-07).

The change to reduce the exposure

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 limit from 25 rem to 5 rem was fully evaluated under 50.54(q) effectiveness evaluation 2018-59. No additional evaluation required.

15 Note following 3.1.1 .a N/A Removed content.

Refer to Figure 1 below to determine Note was deleted, since Figure 1 was thyroid dose equivalent as a function deleted.

of the airborne 1-131 concentration.

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

16 3.1.1.b No current air analysis is 2.4.1. Modified content.

available and high levels of radio-iodine release are suspected

  • No current air analysis is available and This step was rewritten for clarity.

prior to undertaking an emergency high levels of radioactive iodine from a response operation. radioactive release are suspected prior This change does not affect how the to entering the impacted area . current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

17 Figure 1 N/A Removed content.

Figure 1 was deleted.

The change to reduce the exposure limit from 25 rem to 5 rem was fully

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DI L-18-014 THYROID DOSE COMMllMENT DUE TO INHALATION OF 1-131 evaluated under 50.54(q) 100,000 10,000

.._ effectiveness evaluation 2018-59. No additional evaluation required.

Child Thyroid 1 ,ooo a: z I

...... ~

Dose EqulvaJent Commitment (Rem) 20 -

100 10

~ i ~-:::.f"""

~........, 1txx.-

26 Rom 0.1 0.01 ~

0.001 1

1S7 ,. ,.

Alrl>ome 1-131 DoN _E<!ulvlllent Concentrallon (UC\lcc) 18 N/A 2.4.2 Kl paperwork and authorization of Kl Added content.

ingestion should be prepared prior to a radiological release with significant This step was added to streamline the amounts of iodine, to ensure prompt process of Kl issuance and ingestion of Kl. authorization.

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

19 3.3.1 Prior to issue of Kl, warn 2.4.3 Anyone ingesting Kl shall be Added content.

personnel of the possible effects to informed of the pharmaceutical personnel with iodine sensitivity. precautions prior to ingesting Kl. This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DI L-18-0 14 20 N/A 2.4.4 The term "offsite PG&E personnel" Added content.

includes both offsite and onsite Field Monitoring Teams (FMTs), as the onsite This step was added to ensure that the FMTs are controlled by, and ED knows that they are responsible for communicated to, from the Unified Dose authorizing the ingestion of Kl to all Assessment Center (UDAC), an offsite FMTs , including the onsite FMT.

emergency response facility.

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

21 N/A 2.5 Definitions Added content.

2.5.1 Issue Kl: The briefing, logging, and The definitions section, and the distribution of Kl to PG&E emergency definitions within this section , was personnel. added to help clarify the difference between issuing, authorizing and 2.5.2 Authorize the Ingestion of Kl (i.e. ingesting Kl.

authorize the administration of Kl):

Permission for PG&E emergency workers This change does not affect how the to ingest Kl. This is a non-delegable task current E-Plan meets any planning for the person in command and control standard functions, elements, or site-(Shift Manager, Site Emergency specific commitments. No additional Coordinator, or Emergency Director), as evaluation required.

described in Section 3.

2.5 .3 Ingest Kl: To take Kl into the body by swallowing it. This may only be done after Kl has been both issued and authorized for inqestion to the PG&E emerqency

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 worker.

22 2. Responsibilities 3. RESPONSIBILITIES Modified content.

The Responsibilities Section was moved from Section 2 to Section 4. The text was not changed.

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

23 N/A Note before 3.1 Added content.

NOTE: The authorization for PG&E This note was added for clarification and personnel to ingest Kl is a non delegable to reiterate the E-Plan requirement that task. authorizing the ingestion of Kl as a non-delegable task.

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

24 2.3 Shift Manager 3.1 Shift Manager (SM) is responsible for Modified content.

authorizing the ingestion of Kl for:

2.3.1 Responsible for authorizing Reworded to clarify that the SM would administration of Kl to on-site and 3.1.1 All onsite PG&E personnel, prior to retain responsibility for onsite personnel off-site PG&E personnel until beinq relieved by the Site Emerqency until relived by the SEC.

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 relieved by the Site Emergency Coordinator (SEC).

Coordinator or the Emergency This change does not affect how the Director. 3.1.2 All offsite PG&E personnel, prior to current E-Plan meets any planning being relieved by the SEC or Emergency standard functions, elements, or site-Director (ED). specific commitments. No additional evaluation required.

25 2.2 Site Emergency Coordinator 3.2 SEC is responsible for authorizing the Modified content.

ingestion of Kl for:

2.2.1 Responsible for authorizing Reformatted to meet the current administration of Kl to on-site 3.2.1 All PG&E personnel (onsite and standard and reworded for clarity.

personnel. offsite) until relieved by the ED.

This change does not affect how the 2.2.2 Responsible for authorizing 3.2.2 Onsite PG&E personnel, when either current E-Plan meets any planning administration of Kl to off-site PG&E the SEC or ED has command and control standard functions, elements, or site-personnel until relieved by the of the event. specific commitments. No additional Emergency Director. evaluation required.

26 2.2.3 Responsible for ensuring N/A Removed content.

on-site personnel are informed of the decision to administer Kl. This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

27 2.5 Emergency Director 3.3 ED is responsible for authorizing the Modified content.

ingestion of Kl to offsite PG&E emergency 2.5.1 Responsible for authorizing personnel, including all FMTs (onsite and Reworded to include all PG&E Field administration of Kl to off-site PG&E offsite) when the ED has command and Monitoring Teams.

personnel. control of the event.

This change does not affect how the

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

28 2.1 Radiological Advisor 3.4 Radiological Advisor (RA) is Modified content.

responsible for:

2.1.1 Responsible for evaluating Reworded to clarify the difference when Kl should be administered. 3.4.1 Evaluating when Kl should be issued between issuing and ingesting Kl. Also, to onsite PG&E personnel, based on reinforces the requirement of obtaining 2.1.2 Responsible for coordinating radiological conditions. SEC authorization prior to ingesting Kl.

the issuance of Kl to on-site personnel. 3.4.2 Coordinating the issuance of Kl to This change does not affect how the onsite PG&E personnel. current E-Plan meets any planning standard functions, elements, or site-3.4.3 Coordinating the ingestion of Kl to specific commitments. No additional onsite PG&E personnel, upon evaluation required.

authorization from the SEC.

29 2.4 Radiological Manager 3.5 Radiological Manager (RM) is Modified content.

responsible for:

2.4.1 Responsible for evaluating Reworded to clarify the difference when Kl should be administered. 3.5.1 Evaluating when Kl should be issued between issuing and ingesting Kl. Also, to offsite PG&E personnel, based on reinforces the requirement of ED 2.4.2 Responsible for advising the radiological conditions. authorization prior to ingesting Kl. Step Emergency Director when the 3.5.3 was added as a reminder that Kl County Health Officer has elected to 3.5.2 Coordinating the issuance of Kl to for the onsite FMTs are controlled by issue Kl to emergency workers. offsite PG&E personnel. the EOF.

2.4.3 Responsible for coordinating 3.5.3 Coordinating the ingestion of Kl to This change does not affect how the the issuance of Kl to off-site PG&E offsite PG&E personnel, including the current E-Plan meets any planning personnel. onsite FMT, upon authorization by the ED standard functions, elements, or site-

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 for Kl ingestion. specific commitments. No additional evaluation required.

3.5.4 Advising the ED when the San Luis Obispo County Health Officer has elected to authorize ingestion of Kl to county emergency workers.

3.5.5 Ensuring the County Health Officer and applicable County Unified Dose Assessment personnel are informed of when and why Kl is issued and is authorized to ingest.

30 N/A 4. PREREQUISITES Added content.

None This section was added to meet the current standard.

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

31 N/A 5. PRECAUTIONS AND LIMITATIONS Added content.

This section was added to meet the current standard.

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

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 specific commitments. No additional evaluation required.

32 Caution before Step 3.3.1 I 5.1 Personnel who are allergic to or have Modified content.

sensitivity to iodine may develop adverse CAUTION: Personnel with sensitivity I symptoms from Kl tablet ingestion. This step was reworded for clarity. The to iodine may develop adverse second part concerning shellfish symptoms from Kl tablet ingestion. A allergies was deleted since it is no history of shellfish allergies may longer thought to be factual.

indicate iodine sensitivity.

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

33 N/A 6. INSTRUCTIONS Added content.

6.1 Issuance of Kl This note clarifies that Kl may be issued prior to authorization to ingest Kl.

NOTE 1: Kl may be issued at any time, with instructions to not ingest Kl until This change does not affect how the authorized. current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

34 6. INSTRUCTIONS Added content.

6.1 Issuance of Kl This note informs the reader of the new flowchart that helps describe the NOTE 2: Attachment 1 provides a process .

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DI L-18-014 flowchart of the Kl issuance, authorization of ingestion, and ingestion process. This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

35 3.3 Administration of Kl 6. INSTRUCTIONS Modified content.

CAUTION: Personnel with sensitivity 6.1 Issuance of Kl Caution was reworded for clarity. The to iodine may develop adverse second part concerning shellfish symptoms from Kl tablet ingestion. A CAUTION: Personnel with sensitivity to allergies was deleted since it is no history of shellfish allergies may iodine may develop adverse symptoms longer thought to be factual.

indicate iodine sensitivity. from Kl ingestion.

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

36 3.3.1 Prior to issue of Kl, warn 6.1.1 lE conditions warrant issuance of Kl, Added content personnel of the possible effects to THEN perform the following:

personnel with iodine sensitivity. These steps were reworded and

a. Ensure PG&E personnel are briefed on condensed to one step.

3.3.2 Instruct personnel to review the the pharmaceutical precautions for Kl instructions for potassium iodide tablets. This change does not affect how the tablets. current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 37 N/A 6.1.1.b. Consider dispatching available Added content C&RP techs to assembly areas and other locations where onsite PG&E personnel These steps were added to aid in the are located to assist in the distribution of distribution of Kl to on-site personnel.

Kl.

This change does not affect how the

1. Kl stockpiles exist in the following onsite current E-Plan meets any planning locations: standard functions, elements, or site-
  • Control room specific commitments. No additional
  • Security building evaluation required.
  • RCA access control
  • Building 113 (Warehouse B) 38 N/A 6.1.1.c. lE someone refuses to take Kl, Added content THEN replace that person with someone who agrees to take Kl on the applicable This change does not affect how the team or activity. current E-Plan meets any planning .

standard functions, elements, or site-specific commitments. No additional evaluation required.

39 6.1.1 lE conditions warrant issuance of Kl, Modified content.

3.3.3 Ensure personnel complete THEN perform the following:

Attachment 5.1, "Record of These steps were rewritten for clarity.

Distribution of Potassium Iodide." d. Ensure personnel complete Attachment 2, "Record of Distribution of Potassium This change does not affect how the 3.3.4 Instruct affected personnel to Iodide." current E-Plan meets any planning take one 130 mg Kl tablet. standard functions, elements, or site-

e. Ensure personnel listed on Attachment specific commitments. No additional 2 understands the following: evaluation required.
1. Dosage is one (1) 130 mg tablet per

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 day.

2. Direction will be given when to ingest the Kl tablet.

40 NIA 6.2 Authorization of Kl Ingestion Added content.

NOTE: Authorization of Kl ingestion This note was added for clarification.

is a non delegable task for the SM/SEC/ED. This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

41 3.2 Approval of Kl Administration 6.2.1 Obtain authorization for the ingestion Modified content.

of Kl.

3.2.1 Radiological Advisor shall These steps were rewritten to specify obtain Site Emergency Coordinator a. RA shall obtain SEC authorization for Kl SEC and ED authorization to ingest Kl authorization prior to administering ingestion prior to telling onsite PG&E for onsite/offsite PG&E personnel.

Kl to on-site personnel. personnel to ingest Kl.

This change does not affect how the 3.2.2 Radiological manager shall b. RM shall obtain ED authorization for Kl current E-Plan meets any planning obtain Emergency Director ingestion prior to telling offsite PG&E standard functions, elements, or site-authorization prior to administering personnel (including all FMTs, onsite and specific commitments. No additional Kl to off-site personnel. offsite) to ingest Kl. evaluation required .

42 N/A 6.2.2 Document the authorization to ingest Added content.

Kl in an ERO position log.

This step was added to align with Emergency Planning expectations.

Enclosure 2 PG&E Letter DC L-18-082 PG&E Letter DIL-18-014 Th is change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

43 N/A 6.3 Ingestion of Kl Added content.

CAUTION: Ensure Kl ingestion has been This revision distinguishes the authorized by the SM/SEC/ED. difference between issuing, authorizing and ingesting Kl. These steps were NOTE: For optimal prophylaxis, Kl is added to instruct how to ingest Kl after dosed daily, until a risk of significant Kl has been issued and authorized.

exposure to radioiodines by either inhalation or ingestion no longer exists. This change does not affect how the current E-Plan meets any planning 6.3.1 Direct applicable PG&E personnel to standard functions, elements, or site-ingest one (1) 130 mg Kl tablet. specific commitments. No additional evaluation required.

44 N/A 6.4 County Emergency Workers Added content.

6.4.1 The RM should ensure the ED These steps were added to ensure the knows when the County Health Officer has Emergency Director and the County issued, and authorized to ingest, Kl to Health Officer are aware of each other's County emergency workers. decisions regarding Kl ingestion.

6.4.2 The RM should ensure the County This change does not affect how the Health Officer and applicable County current E-Plan meets any planning Unified Dose Assessment personnel are standard functions, elements, or site-informed of: specific commitments. No additional evaluation required.

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014

a. When and why Kl is issued to PG&E personnel.
b. When and why Kl is authorized for PG&E personnel to ingest.
c. What radiological conditions will be used to determine when PG&E personnel will be directed to ingest Kl.

45 3.3.5 Tablets should be administered 6.5 Follow-Up Actions Modified content.

for ten days after verified exposure.

Dosage is one tablet, once a day. 6.5.1 Ensure one (1) tablet is ingested The steps have been reworded for daily for up to 10 days after verified clarity and moved to Section 7.

3.3.6 Individuals suspected of exposure.

inhalation of airborne contamination This change does not affect how the should receive thyroid counts on a 6.5.2 Ensure individuals suspected of current E-Plan meets any planning regular basis throughout the Kl inhalation of airborne contamination standard functions, elements, or site-treatment period to verify receive thyroid counts on a regular basis specific commitments. No additional effectiveness of treatment and to throughout the Kl treatment period to evaluation required.

estimate dose commitment. ensure effectiveness of treatment and to estimate dose commitment.

46 4 RECORDS 7 RECORDS Modified content.

4.1 Drills 7.1 Documents generated by this The Records Section was moved from procedure during drills are non-quality Section 4 to Section 8. These steps 4.1.1When used for drills, good business records and are maintained were reworded for clarity.

Attachment 5.1 is a good business per OM1 0.ID1, "Maintaining Emergency record and shall be retained by Preparedness." This change does not affect how the emergency planning for 3 years. current E-Plan meets any planning 7.2 Documents Qenerated by this standard functions, elements, or site-

Enclosure 2 PG&E Letter OCL-18-082 PG&E Letter OIL-18-014 4.2 Emergency procedure during actual events are quality specific commitments. No additional records and are maintained for the life of evaluation required.

4.2.1When used for an actual the plant, per AO10.IO1, "Storage and emergency, Attachment 5.1 shall be Control of Quality Assurance Records."

retained as a quality record in accordance with AO10.IO1.

47 N/A 8. REFERENCES Added content.

8.1 EPA-400/R-17/001, "PAG Manual: New section was added.

Protective Action Guides and Planning Guidance for Radiological Incidents This change does not affect how the current E-Plan meets any planning 8.2 NRC000075, "Guidance Potassium standard functions, elements, or site-Iodide as a Thyroid Blocking Agent in specific commitments. No additional Radiation Emergencies evaluation required.

48 N/A Attachment 1 Added content.

NotifyC.OuntyHealthO'ficerand applk:able County Unified Dose Brief personnel on Assessment(UDAC)pe rsonn\!I Klprecalllions whena ndwtr(Klhasbeenissued to PG&E personnel A flowchart was added as an attachment to aid the procedure user

~----->ict\:e~~:~~~~u::~~~~ to with the process of issuing, authorizing Dorument SM/SEC/ED authorization and ingesting Kl for PG&E emergency to ingest Kl by PG&E personnel workers.

Direct applicable PG&E pmonnelto i-igestone(1)1JOrrgKltablet This change does not affect how the Notify C.Ounty Healh Cff1Cer and a_cpli::al:le County Uni1ed Dose Assessment (UDAC) personnel when and why Kl ingestion has beenauthorizedforPG&Epersonnel current E-Plan meets any planning standard functions, elements, or site-Ensure personnel withverifiedex.p,'.lsurescontinuetoingest Kluntilariskofs'JnificantexposuretoradioiodinestJ)' specific commitments. No additional dherinhalafonoringestionnolongerexists evaluation required.

Ensure indvidualssuspected ofinhalationofai'. txirne contarroiation rec er>'eanalysisoftM ir thyroidonaregular basis throughout the Kl treatment period En~re lheeffectivenessofKltreatmentandestmated thyroiddoseoomrritmenttotheindi.id.Ja l

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014 49 Attachment 5.1 Attachment 2 Modified content.

69-9395 DCP Form 69-22007 Attachments are numbered 1, 2, 3 ... in accordance with the current standard.

1. Fill out time and date Kl is NOTE: Your Name and LAN ID administered. indicate you have read and understand the Columns changes:

pharmaceutical precautions for Kl tablets. - The Date column was replaced by

2. Your initials indicate you have Date Kl Issued and Date Kl Ingested.

been made aware of possible Columns: This was done to distinguish between adverse effects to iodine sensitive PG&E Worker Name the two.

personnel. LANID - The Time column was replaced by Date Kl Issued Time Kl Issued and Time Kl Ingested.

Columns: Time Kl Issued This was done to distinguish between Date Date Kl Ingested the two.

Time Time Kl Ingested - Dosage column was changed to Dosage Dosage per Day (130mg) Dosage per Day with 130mg already Name Kl Ingestion Authorized by entered. This was done to ensure that Initials (SM/SEC/ED Name) both the dosage is recorded and that SSN 130mg/day is used.

Organization - The Name column was changed to Address PG&E Worker Name to ensure that only PG&E personnel are issued or directed to ingest Kl.

- The Initials column was removed as it was unnecessary.

- the SSN column was replaced by LAN ID to remove the risk of having emergency response member's personal information being easily available to personnel who have no ligament reason of having that information.

Enclosure 2 PG&E Letter DCL-18-082 PG&E Letter DIL-18-014

- The Organization column was removed as it was unnecessary.

- The Address column was removed as it was unnecessary and to remove the risk of having emergency response

- member's personal information being easily available to personnel who have no ligament reason of having that information.

- The Kl Ingestion Authorized by (SM/SEC/ED Name) column was added as a result of reviewing the Palo Verde Kl Distribution form.

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

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