Text

Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update
	ML18317A387
Person / Time
Site:	Diablo Canyon
Issue date:	11/13/2018
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-18-094, DIL-18-015
	Download: ML18317A387 (65)
	v • d • e

Pacific Gas and Electric Company Michael A. Ginn Uiablo Canyon Power Plant Manager P.O. Box 56 Emergency Planning Avila Beach, CA 93424 805.545.3446 Internal: 691.3446 Fax: 805.545.6265 November 13, 2018 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 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 Procedures EP RB-3, Revision 9, "Stable Iodine Thyroid Blocking" and EP G-5, Revision 16 "Evacuation of Non-Essential Site Personnel."

The associated enclosures are listed below:

Enclosure 1 - Diablo Canyon Power Plant Emergency Plan Implementing Procedures, Revision Numbers for Emergency Plan Implementing Praced ures.

Enclosure 2 - Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-3, Revision 9, "Stable Iodine Thyroid Blocking."

Enclosure 3 - Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-5, Revision 16 "Evacuation of Non-Essential Site Personnel."

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 A member of the STARS Alliance Callaway

Diablo Canyon

Palo Verde

Wolf Creek

Document Control Desk PG&E Letter DCL-18-094 November 13, 2018 PG&E Letter DIL-18-015 Page 2 10 CFR 50 and the planning standards of 10 CFR 50.47(b). Therefore, prior NRC approval of the associated changes was not requ ired .

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 regard ing th is update, please contact me at (805) 545-3446.

Sincerely,

~ _y__ ~ Gs----=-=--

Michael A. Ginn Emergency Planning Manager armb/4743/51000438 & 51003523 Enclosures cc/enc: William C. Allen , NMSS Project Manager Kriss M. Kennedy, NRC Reg ion IV Adm inistrator 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-18-094 PG&E Letter DIL-18-015 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Revision Numbers for Emergency Plan Implementing Procedures

Enclosure 1 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Proc. No. Rev. Title OM10.ID1 18 Maintaining Emergency Preparedness OM10.DC1 10 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 16* 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 9* 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 47 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-18-094 PG&E Letter DIL-18-015 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-3, Revision 9 "Stable Iodine Thyroid Blocking" Page 1 of 1

Enclosure 2 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 8) Revised Content (Revision 9) Description of Change 1 1.2 This procedure was rewritten ; N/A Removed content.

therefore, revision bars are not included. Revision 9 of EP RB-3 is not a rewrite .

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 2.2 The county Health Officer 2.2 The County Health Officer (CHO) Modified content.

controls authorization for controls authorization of Kl for all non-consumption of Kl for all non- PG&E personnel. Step rewritten to emphasize that the PG&E employees. County Health Officer controls authorization of all aspects of Kl issuance, authorization, and ingestion for non-PG&E personnel, not just 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.

Page 1 of 11

Enclosure 2 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 3 2.3 Evaluating when to issue Kl: 2.3 Kl may be issued (handed out) to Modified content.

PG&E personnel at any point during a 2.3.1 Consider issuing Kl to PG&E declared emergency based upon the Removed the list of conditions to emergency personnel when judgement of the Radiological Manager in consider prior to issuing Kl and leaves responding to an event in which the Emergency Operations Facility (EOF) Kl issuance to the discretion of the any one of the following exists: or the Radiological Advisor in the Radiological Manager (RM) and

The potential for a radioactive Technical Support Center (TSC). Radiological Advisor (RA).

release to the environment due to the event. This change does not affect how the

There is a radioactive release to current E-Plan meets any planning the environment due to the event. standard functions, elements, or site-

Fuel damage. specific commitments. No additional evaluation required.

4 2.4 Evaluating when to authorize 2.4 For optimal protection against inhaled Modified content.

the ingestion of Kl radioiodines, Kl should be administered before or immediately coincident with This item was modified in accordance 2.4.1 Kl is most effective when exposure to radioiodine, though Kl may with the December 2001 FDA guidance ingested immediately prior to still have a substantial protective effect on potassium iodide as a thyroid exposure to even if taken 3 or 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after exposure. blocking agent in radiation emergencies.

radioiodine. Therefore, Furthermore, if the release of radioiodines authorization of Kl ingestion into the atmosphere is protracted, then, of This change does not affect how the should be considered course, even delayed administration may current E-Plan meets any planning when any one of the following reap benefits by reducing, if incompletely, standard functions, elements, or site-exists: the total radiation dose to the thyroid. specific commitments. No additional evaluation required.

Page 2 of 11

Enclosure 2 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 5 2.4.1 Kl is most effective when 2.5 Authorization of Kl ingestion should be Modified content.

ingested immediately prior to considered when any one of the following exposure to exists: This change clarifies that Kl radioiodine. Therefore,

Core conditions exist where there is authorization should be considered for authorization of Kl ingestion gap or core source term (significant any significant fuel damage, gap and should be considered iodine consequence) with degrading core, with degrading plant conditions.

when any one of the following plant conditions.

exists: This change does not affect how the

Core conditions exist where current E-Plan meets any planning there is gap source term standard functions, elements, or site-with degrading plant specific commitments. No additional conditions. evaluation required.

6 N/A 2.6 The protective effect of Kl lasts Added content.

approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . For optimal prophylaxis, Kl should therefore be dosed This discussion item was added to daily, until a risk of significant exposure to inform the reader of the importance of radioiodines by either inhalation or taking Kl daily until the radioiodine risk ingestion no longer exists. no longer exists.

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

Page 3 of 11

Enclosure 2 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 7 2.4.2 Kl paperwork and 2.7 Administrative tasks associated with Modified content.

authorization of Kl ingestion the use of Kl (e.g. issuance, briefings, should be prepared prior to a paperwork) should be completed prior to a This discussion item was modified to radiological release with significant radiological release with the potential for focus on the administrative tasks amounts of iodine, to ensure significant amounts of radioiodine, to necessary for Kl ingestion and removes prompt ingestion ensure prompt ingestion of Kl. the authorization reference.

of 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.

8 N/A 2.10.4 Potassium Iodide: A salt of stable, Added content.

non-radioactive iodine in medicine form.

The administration of potassium iodide The definition of potassium iodine was saturates the thyroid with non-radioactive added to provide context and additional iodine, so it does not absorb radioactive information to the reader.

iodine released into the environment from a radiological incident. This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

Page 4 of 11

Enclosure 2 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 9 3.4 Radiological Advisor (RA) is 3.4 Radiological Advisor (RA) is Modified content.

responsible for: responsible for:

Removed conditions to consider prior to 3.4.1 Evaluating when Kl should 3.4.1 Evaluating when Kl should be issued issuing Kl and leaves Kl issuance to the be issued to onsite PG&E to onsite PG&E personnel. RA's discretion .

personnel, based on radiological 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.

10 3.5 Radiological Manager (RM) is 3.5 Radiological Manager (RM) is Modified content.

responsible for: responsible for:

Removed conditions to consider prior to 3.5.1 Evaluating when Kl should 3.5.1 Evaluating when Kl should be issued issuing Kl and leaves Kl issuance to the be issued to offsite PG&E to offsite PG&E personnel. RM's discretion.

personnel , based on radiological 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.

Page 5 of 11

Enclosure 2 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 11 3.5.5 Ensuring the County Health 3.5.5 Ensuring the County Health Officer Modified content.

Officer and applicable County and applicable County Unified Dose Unified Dose Assessment Assessment personnel are informed of: Reworded this responsibility to further personnel are informed of when

When and why Kl is issued to clarify when and how to inform the and why Kl is issued and is PG&E personnel. County of PG&E decisions concerning authorized to ingest.

What conditions will be used to Kl issuance, authorization, and determine when PG&E will seek ingestion.

authorization for PG&E personnel to ingest Kl from the SM/SEC/ED. This change does not affect how the

When and why Kl is authorized for current E-Plan meets any planning PG&E personnel to ingest. standard functions, elements, or site-specific commitments. No additional evaluation required.

12 6.1.1 IF conditions warrant 6.1.1 Perform the following: Modified content.

issuance of Kl, THEN perform the following : Removed conditions to consider prior to issuing Kl and leaves Kl issuance to the RM's and RA's discretion .

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

Page 6 of 11

Enclosure 2 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 13 6.2.1 Obtain authorization for the N/A Removed content.

ingestion of Kl .

This step was removed due to being repetitive.

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 6.2.1.a. RA shall obtain SEC 6.2.1 RA shall obtain SEC authorization for Modified content.

authorization for Kl ingestion prior Kl ingestion immediately prior to telling to telling onsite PG&E personnel onsite PG&E personnel to ingest Kl. Reworded this step to ensure the RA to ingest Kl . obtains authorization for Kl ingestion immediately prior to giving the direction to take 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.

Page 7 of 11

Enclosure 2 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 15 6.2.1.b. RM shall obtain ED 6.2.2 RM shall obtain ED authorization for Modified content.

authorization for Kl ingestion prior Kl ingestion immediately prior to telling to telling offsite PG&E personnel (including all Reworded this step to ensure the RM FMTs, onsite and offsite) to ingest Kl. obtains authorization for Kl ingestion immediately prior to giving the direction to take 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.

16 6.2 .2 Document the authorization 6.2 .3 Authorization to ingest Kl should be Modified content.

to ingest Kl in an ERO position documented in applicable ERO position log. logs. This step was revised for clarity.

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

Page 8 of 11

Enclosure 2 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 17 N/A 6.3 Ingestion of Kl Added content.

6.3.2 IF severe side effects or allergic Added this step to provide instruction in reactions occur, the event that an individual has severe THEN affected individuals should side effects, or an allergic reaction, after immediately stop taking Kl and consult a taking Kl.

physician for further instructions.

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

18 6.5.1 Ensure one (1) tablet is 6.3.3 Ensure one (1) tablet is ingested Modified content.

ingested daily for up to 10 days daily for up to 10 days after verified after verified exposure. exposure. Moved step from 6.5 "Follow-Up Actions" to 6.3 "Ingestion of 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.

Page 9 of 11

Enclosure 2 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 19 6.4 County Emergency Workers 6.4 County Emergency Workers Modified content.

6.4.1 The RM should ensure the 6.4.1 The RM should ensure the ED Revised this step to remove the need to ED knows when the County knows when the County Health Officer has inform the Emergency Director (ED)

Health Officer has issued, and authorized County emergency workers to when the County issues Kl.

authorized to ingest, Kl to County ingest Kl.

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

20 6.4.2 The RM should ensure the 6.4.2 The RM should ensure the County Modified content.

County Health Officer and Health Officer and applicable County applicable County Unified Dose Unified Dose Assessment personnel are Revised this step to clarify that the Assessment personnel are informed of: County Health Officer needs to be kept informed of: aware of the PG&E decision making

a. When and why Kl is issued to PG&E process regarding Kl issuance,

a. When and why Kl is issued to personnel. authorization, and ingestion .

PG&E personnel.

b. What conditions will be used to This change does not affect how the

b. When and why Kl is authorized determine when PG&E will seek current E-Plan meets any planning for PG&E personnel to ingest. authorization for PG&E personnel to ingest standard functions, elements, or site-Kl from the SM/SEC/ED. specific commitments. No additional

c. What radiological conditions evaluation required.

c. When and why Kl is authorized for PG&E personnel to ingest.

Page 10 of 11

Enclosure 2 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 lflimepermits, briefthe 21 FlllOtJt NolilyCounlyHealthOlfcerand applicable County Unified Dose CountyHealthOfK:eron Modified content.

~ Assessment(UOAC)peaonnel cond~ionswhen PG&E will Attachme~ 1 seekauthorizationtoingest whenand'MlyKlhas beenissued to PG&E personnel Kl from the SM/SEC/ED Revised the Kl Process Flowchart to CillainSMISEC/EDautJ-orizalionto inge,Klby~&Epeaomel reflect the changes in this revision and YES Docume~SMISEC/EDautJ-orization YES Obtain SM/SEC/ED authorization for PG&E personn~ to ingest Kl to correct the logic error of not toinge*KlbyPG&Epersonrel Document SM/SEC/ED authorization for PG&E personnel to ingest K!

rechecking conditions after arriving at NO Directapplicableffi&Epersonnelto inge*one(1)130mgKlla~el NO "Ingestion of Kl not required."

DirectapplicablePG&E personnelloingestone(1)130mgKltablel YES NotfyCounfyHealthOlfceran.d app!icableCo1J1fyUnifiedl OoseAssessmert(UDAC)per5onne!whenandwhyKI lngestim has been aulhonzed fOJ PG&Epersonnel N0 YES Notify County Health aficer aoo ap~<able CountyUDAC personnel whenand'M'lyKlingestionhasbeenauthorizedforPG&Epersonnel This change does not affect how the current E-Plan meets any planning EnsurepersoMelwithverifiedexposurescontinuetoingeslKluntila Ens1.1epersonnelwthverftedexpos11escontinuetoinge Klwtilartikofsignificant exposure toradDiodinestJt NO riskofsignificantexposuretoradioiodinesbyettherinhalationor ingestion no longer exists standard functions, elements, or site-eitherimalafunoringesti>nnolongerexists Ensure individuals suspectedofinhalalionofairbomecontamlnation specific commitments. No additional receiveanalysisoftheirthyroidonaregularbasisthroughoutlheKI YES EnsureindNidualssuspectedofinhalationafarbome contaminationreceNeanalysisoftheirlhyroidonaregular treatment period evaluation required.

basisthroughouttheKllreatmentr;eriod YES Ensuretheeffectiveressof Kl treatmentandestimated thyroiddosecommitmeritotheirxlividual Page 11 of 11

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP G-5, Revision 16 "Evacuation of Non-Essential Site Personnel."

Page 1 of 1

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

1. Multiple locations throughout procedure: Multiple locations throughout procedure: Modified content.

DCPP Personnel DCPP Personnel This change aligns the definition of

a. All operations personnel. a. All Operations personnel. essential personnel to match what is in

b. All Industrial Fire Officers (IFOs). b. All Chemistry and Radiation Protection EP G-4.

c. All DCPP maintenance personnel personnel (Mechanical, Electrical and l&C). c. All members of the Emergency This change does not affect how the

d. All DCPP Chemistry and Radiation Response Organization (ERO). current Emergency Plan (E-Plan) meets Protection personnel (RP). d. All security personnel. any planning standard functions,

e. All members of the Emergency e. All Fire Fighters. elements, or site-specific commitments.

Response Organization (ERO). f. All Medical personnel. No additional evaluation required.

f. All security personnel. g. All maintenance personnel

g. Persons designated essential by the (Mechanical, Electrical and l&C).

Shift Manager or Site Emergency h. Personnel identified as essential or Coordinator. performing critical tasks under the direction of the Shift Manager of Site Emergency Coordinator (SEC) .

2. 2.2.3 2.2 .3 Modified content.

Evacuation Coordinator: A member of the Evacuation Coordinator: A member of the This change reorders list to clarify that security force as requested by the Shift security force as requested by the Shift Technical Support Center (TSC)

Manager or Site Emergency Coordinator. Manager or Site Emergency Coordinator. Security Advisor is first option and if

a. This person is assigned by the Diablo a. This may be the TSC Security Advisor, they are not available then DCWC Canyon Watch Commander (DCWC) or a management person, or anyone else if assigns an individual to be the designee. available. Evacuation Coordinator.

b. This may be a management person if b. If TSC Security Advisor is not available security is unable to support the request. this person is assigned by the Diablo This change aligns with the E-Plan.

c. This may be the TSC Security Advisor Canyon Watch Commander (DCWC) or if available. designee. This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required .

Page 1 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

3. 2.2.7 2.2.7 Modified content.

Off-Site Assembly Area: Areas personnel Offsite Assembly Area : Areas personnel This change adds the statement "if relocate to after the decision has been relocate to, if needed, after the decision needed" and "or release" to clarify that it made to evacuate non-essential site has been made to evacuate or release is not always necessary to use offsite personnel. non-essential personnel. assembly areas and that assembly areas may be used during an early work release .

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

4. 2.2.7 2.2.7 Modified content.

a. Areas to the south may include: The a. Areas to the south may include: The This change adds San Luis Service PG&E Energy Education Center (EEC), PG&E Energy Education Center (EEC), Center to the list of areas to the south Ontario Road (frontage road north of the Ontario Road (frontage road north of the that can be used for offsite assembly.

EEC), Port San Luis Parking Lot, or the EEC), San Luis Service Center, Port San This location is listed as available for Avila Beach Post Office Parking Lot. Luis Parking Lot, or the Avila Beach Post use as a back-up offsite assembly area Office Parking Lot. in the E-Plan Section.

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

Page 2 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

5. NA - added new content 2 .2 .9 Added new content.

Site Evacuation: The removal of non- Added definition of site evacuation.

essential personnel from the site to avoid or reduce high-level, short-term This change does not affect how the exposure, usually from the plume or from current E-Plan meets any planning deposited activity. May be a preemptive standard functions, elements, or site-action taken in response the facility specific commitments. No additional conditions rather than an actual release. evaluation required.

6. Multiple locations throughout procedure Multiple locations throughout procedure Modified content.

Areas Outside the Protected Area: Areas Outside the Protected Area: This change adds specific building Training Building (Building 109), Training Building (Bldg 109), number to Warehouse B and makes Maintenance Shop Building (Building Maintenance Shop Building (Bldg 119), editorial changes to other onsite 119), and Warehouse B. and Warehouse B (Bldg 113). assembly area locations for consistency.

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

Page 3 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

7. 3.2 Site Emergency Coordinator (SEC) 3.2 Site Emergency Coordinator (SEC) Modified content.

3.2.1 Determines the need for, and 3.2.1 Determines the need for, and This change reformats multiple makes the decision to, evacuate or makes the decision to, evacuate or embedded responsibilities from one perform an early perform an early work release . statement into multiple statements for work release, chooses the offsite ease of understanding .

assembly areas if applicable), chooses 3.2.2 Determines if pre-evacuation site the evacuation route, assigns the accountability is necessary, if not already Added in the responsibility to Evacuation Coordinator, if not already done. "Determines if pre-evacuation site done so by the SM. accountability is necessary, if not 3.2 .3 Chooses the evacuation route. already done" to align SEC responsibilities with Shift Manager (SM) 3.2.4 Chooses the offsite assembly responsibilities.

areas, if applicable.

This change does not affect how the 3.2.5 Appoints the Evacuation current E-Plan meets any planning Coordinator, if not already done so by the standard functions, elements, or site-SM. specific commitments. No additional evaluation required .

Page 4 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

8. 3.3 Evacuation Coordinator 3.3 Evacuation Coordinator Modified content.

3.3.1 3.3.1 This change separates early work release and site evacuation into two

d. Communicates the evacuation/ early d. Coordinates early work release plan actionable items. It also corrects the work release plan with offsite agencies with the San Luis Obispo County name of the offsite agency to be (California Highway Patrol, Sheriff's Emergency Operations Center (EOC) or coordinated and communicated with.

Department etc.) prior to moving people Sheriff's Department Watch Commander offsite. if EOC is not activated. This change does not affect how the current E-Plan meets any planning

e. Communicates site evacuation plan standard functions, elements, or site-with the San Luis Obispo County EOC or specific commitments. No additional Sheriff's Department Watch Commander evaluation required.

if EOC is not activated prior to moving people offsite.

9. 4. PREREQUISITES 4. PREREQUISITES Modified content.

4.1. The Shift Manager or Site 4.1 The Shift Manager or Site Emergency This change clarifies that it is non-Emergency Coordinator has identified a Coordinator has identified a need to essential site personnel for which this need to relocate site personnel. relocate non-essential site personnel. procedure refers .

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

Page 5 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

10. 7. RECORDS 7. RECORDS Modified Content 7 .1 Forms and attachments completed 7.1 Documents generated by this This change updates the records during a real event are quality related procedure during drills are non-quality retention requirements.

records and shall good business records and are be retained per AD10.I01 . maintained per OM10.I01, "Maintaining This change does not affect how the Emergency Preparedness." current E-Plan meets any planning 7.2 When used during a drill, forms and standard functions, elements, or site-attachments are good business records 7 .2 Documents generated by this specific commitments. No additional and shall be retained by emergency procedure during actual events are non- evaluation required.

planning for 3 years per AD10 .I02. quality records and are maintained for the life of the plant, per AD10 .I02, "Storage and Control of Non-quality Assurance Records."

11. Off-Site Assembly Areas Attachment 1 Off-Site Assembly Areas Attachment 1 Modified content.

SLOECCO San Luis Obispo Electric SLO Service Center This change updates the title of Control Center Operations SLOECCO San Luis Obispo Electric Control Center Operations with San Luis Service Center. These are the same locations but San Luis Service Center is consistent with name used in the E-Plan .

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

Page 6 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

12. Attachment 2 Attachment 2 Modified content.

1. Evacuation 1. Site Evacuation This change adds site in front of evacuation to be consistent with the N/A - added new content. NOTE: The SM/SEC may assign intent of this attachment.

qualified persons to perform tasks in this checklist. The SM/SEC shall retain the The addition of the note clarifies that decision to evacuate site personnel. other qualified individuals may perform tasks in the checklist but reiterates that only the SM/SEC shall make the decision to evacuate site 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.

13. Attachment 2 Attachment 2 Modified content.

1.b.7) The dose expected during 1.b.7) The dose expected during This change is editorial in nature and evacuation shall be weighted against the evacuation shall be weighed against the corrects a grammatical error.

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

Page 7 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

14. Attachment 2 Attachment 2 Modified content.

1.c. Determine the evacuation route using 1.c. Determine the evacuation route. This change is being made to clarify the following criteria : that evacuation routes are chosen by

1) IF ... the SM/SEC, not used. This change is

1) IF .. . THEN choose the southern route . being made throughout the procedure.

THEN use the southern route .

2) IF none of the above conditions exist This change does not affect how the

2) IF none of the above conditions exist OR the southern route is known to be current E-Plan meets any planning OR the southern route is known to be impassable, standard functions, elements, or site-impassable, TH EN choose the northern route. specific commitments . No additional THEN use the northern route. evaluation required.

3) IF the northern route is chosen,

3) IF the northern route is to be used,

15. Attachment 2 Attachment 2 Modified content.

1.c.2)c) 1.c.3)b) This change deleted "is" which was not necessary in the sentence . This IF security is cannot be reached for the IF security cannot be reached for the gate change is editorial only.

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

Page 8 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

16. Attachment 2 Attachment 2 New content.

2) d) Determine the offsite assembly 1.d. Determine if offsite assembly areas Added specific information on how to areas (if applicable) : are needed . determine if offsite assembly areas are needed.

1) IF the southern route is being used, 1) IF a radiological release occurred, or is THEN use the following areas ... .. . .. in progress that may contaminate Additional change is being made to personnel or personnel vehicles, clarify that evacuation routes are

3) IF the northern route is being used THEN offsite assembly areas should be chosen by the SM/SEC, not used .

TEHN use the following area : activated.

This change does not affect how the

2) If the southern route was chosen, current E-Plan meets any planning THEN use the following areas ..... . .. standard functions, elements, or site-specific commitments. No additional

3) IF the northern route was chosen, evaluation required.

THEN use the following area :

17. Attachment 2 - multiple locations Attachment 2 - multiple locations Modified content.

Table of southern offsite assembly areas. Table of southern offsite assembly areas .

This change adds San Luis Service Center to the list of areas to the south Table located at end of this attachment. Table located at end of this attachment. that can be used for offsite assembly.

This location is listed as available for use as a back-up offsite assembly area in the E-Plan.

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

Page 9 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

18. Attachment 2 Attachment 2 Modified content.

1.i. 1.e. This change moved the location of this note earlier in the attachment and NOTE: The SLO County Emergency NOTE: The SLO County EOC should be rewrote it to be specific to site Organization needs to be notified prior to notified prior to starting a site evacuation evacuation. In addition, clarification has evacuation or early work release due to to assess for potential traffic control been provided that SLO County EOC potential; traffic control problems, problems or other impediments to must be notified prior to commencement impediments to evacuation, and/or evacuation. of site evacuation. This is consistent adverse public reaction to the mass traffic with the E-Plan.

from the site.

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

Page 10 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

19. Attachment 2 Attachment 2 Modified content.

1.e. Determine the need for offsite 1.e. Determine the need for offsite This change moves the step up in the assistance: assistance . checklist and reassigns the responsibility for determining offsite

1) Direct the DCPP Watch Commander, 1) Contact the EOF Security Liaison and assistance from the DCWC to the or designee, to interface with local law have them coordinate with the County Emergency Operations Facility (EOF) enforcement to determine the need for EOC to determine the need for: Security Liaison.

offsite assistance. Consider the need for: a) Traffic control assistance along the a) Traffic control assistance along the evacuation route. This change also directs contact with evacuation route. b) Traffic control assistance at the offsite the Security Liaison at the EOF, if b) Traffic control assistance at the offsite assembly areas . available rather than directly with local assembly areas. c) Evacuation route clearing (i .e., law enforcement based on request from c) Evacuation route clearing (i.e., bulldozers to move impediments). SLO County. In addition, these bulldozers to move impediments) . d) Medical resources at the offsite changes include information on the d) Medical resources at the offsite assembly areas. appropriate offsite agency to interface assembly areas. e) Fire resources at the offsite assembly with in the event the EOF Security e) Fire resources at the offsite assembly areas (fire engines may be used for Liaison is not available.

areas (fire engines may be used for vehicle decontamination etc.).

vehicle decontamination etc.). This change does not affect how the

2) IF the EOF is not activated OR the current E-Plan meets any planning EOF Security Liaison is not available, standard functions, elements, or site-THEN contact the SLO County EOC or specific commitments. No additional Sheriff's Watch Commander if County evaluation required.

EOC is not activated.

Page 11 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change 20 . Attachment 2 Attachment 2 Modified content.

1.f. Determine the need for radiological 1.f. Determine the need for personnel Minor word changes were made to the monitoring at the assembly areas: monitoring and decon at offsite assembly step to improve use. Intent of the step areas . remains unchanged.

1) IF there was, or currently is, a release 1) IF there was, or currently is, a release This change does not affect how the of radioactive materials above normal of radioactive materials above normal current E-Plan meets any planning operating operating limits that may result in the standard functions, elements, or site-limits that may result in the spread of spread of contamination, specific commitments . No additional contamination, THEN personnel and vehicle monitoring evaluation required.

THEN personnel and vehicle and decon should be performed at monitoring/decontamination should be designated offsite assembly areas.

performed at the offsite assembly areas.

2) Refer to the tables in step 1.d of this

2) Refer to the tables in step 1.d of this attachment to determine the suggested attachment to determine the suggested number of radiological monitoring number of radiological monitoring resources for each offsite assembly area.

resources for each offsite assembly area.

Page 12 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

21. Attachment 2 Attachment 2 Modified content.

1. i. Ensure the Emergency Director (ED) 1.g. Ensure the Emergency Director (ED) This change moved the location of the at the emergency operations facility at the EOF (if activated) is notified of the: coordination with the EOF earlier in the (EOF) is notified attachment and specifies decision is to of: 1) Decision to perform site evacuation perform site evacuation.

1) The decision to move personnel 2) Evacuation route chosen In addition these changes include offsite. information on the appropriate offsite

3) Designated offsite assembly areas (if agency to notify in the event the EOF is

2) The evacuation route to be used. applicable) not available.

3) The designated offsite assembly 1.h. IF the EOF is not activated, This change does not affect how the areas. THEN notify the SLO County EOC (or current E-Plan meets any planning Sheriff's Watch Commander if County standard functions, elements, or site-a) IF the EOF is not activated OR the ED EOC is not activated) that: specific commitments. No additional is not available, evaluation required.

THEN direct the DCPP Watch 1) Personnel are going to be evacuated Commander to notify the Sheriff's from DCPP Department that personnel are going to be evacuated, the route to be used, and 2) The evacuation route chosen approximate number of people being moved offsite. 3) Approximate number of people being evacuated (1) Additionally, provide details about any offsite assistance that may be necessary 4) Details about offsite assistance as determined in step 1.e. needed (if applicable)

5) Designated offsite assembly areas (if applicable)

Page 13 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

22. Multiple locations throughout procedure: Multiple locations throughout procedure: Modified Content Determine if any additional personnel Determine if any additional personnel Editorial change to replace numbers need to stay due to their specialized skill need to stay due to their specialized skill with bullets.

set. set.

Consider skills such as: Consider skills such as: This change does not affect how the (1) Engineering

Engineering current E-Plan meets any planning (2) Procurement

Procurement standard functions, elements, or site-(3) Telecommunications

Telecommunications specific commitments. No additional evaluation required.

23. Attachment 2 Attachment 2 Modified content.

1.h. Complete the following table to 1.j. Complete the following table to The table in this section is used to document decisions and information for document decisions and information for document site evacuation . Changes to the Evacuation Coordinator. the Evacuation Coordinator. form were made to clarify this use.

Check boxes for EOF and SLO County Site Evacuation [ ] Yes [ ] No [ ] NA SITE EVACUATION notification of site evacuation were Early Work Release [ ] Yes [ ] No [ ] NA Evacuation Route: [ ] Southern [ ] added to make sure that notification is Evacuation Route: [ ] Southern [ ] Northern not missed.

Northern Offsite Assembly Areas:

Assembly Areas [ ] N/A (no radiological release) San Luis Service Center and Montana

[] N/A (early work release/no radiological [ ] PG&E Energy Education Center de Oro State Park Ranger Station were release) (60-70 cars) included in the list of assembly areas.

[ ] PG&E Energy Education Center (60-70 [ ] Frontage Rd north of Energy cars) Education Center (hundreds) Outside has been corrected to read

[ ] Frontage Rd north of Energy Education [ ] San Luis Service Center (125 cars) Offsite and check boxes are being Center (hundreds) [ ] Port San Luis Parking Lot (250 cars) provided to list personnel that may be

[] Port San Luis Parking Lot (250 cars) [ ] Avila Beach Post Office Parking Lot requested to stay onsite for ease of

[ ] Avila Beach Post Office Parking Lot (250 cars) documentation.

(250 cars) [ ] Montana de Oro State Park Ranger Station (200 cars) This change does not affect how the current E-Plan meets any planning Outside assistance requested: [] Yes [] Offsite assistance requested: [] Yes [] standard functions, elements, or site-Page 14 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change No No specific commitments. No additional evaluation required.

Personnel Monitoring and Decon Personnel Monitoring and Decon required: [] Yes [] No required: [] Yes [] No EOF notified of site evacuation: [] Yes []

No County notified of site evacuation: [] Yes Personnel to remain on site: [ ] ERO [ ] [] No Other (list below)

DCPP Personnel to remain onsite:

[] ERO

[ ] All Operations personnel

[] All Chemistry and Radiation Protection personnel

[ ] All security personnel

[ ] All Fire Fighters

[ ] All Medical personnel

[ ] All maintenance personnel (Mechanical, Electrical and l&C)

Date/Time: [ ] Other (list below)

Shift Manager/ Site Emergency Coordinator Initials: Date/Time:

Shift Manager/ Site Emergency Coordinator Initials:

Page 15 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change 24 . Attachment 2 Attachment 2 Modified content.

1.j . Obtain and brief an Evacuation 1.k. Obtain and brief an Evacuation This change reorders list to clarify that Coordinator: Coordinator: TSC Security Advisor is first option and if they are not available then DCWC NIA - added new content. 1) If available, the TSC Security Advisor assigns an individual to be the should be assigned the duties of the Evacuation Coordinator.

Evacuation Coordinator.

This change does not affect how the

1) Contact the DCPP Watch Commander, 2) IF TSC is not activated or Security current E-Plan meets any planning or designee, and request that: Advisor is not available standard functions, elements, or site-THEN contact the DCPP Watch specific commitments . No additional Commander, or designee, and request evaluation required .

that:

a) He/she assign a member of the security force as the Evacuation a) He/she assign a member of the Coordinator. security force as the Evacuation Coordinator.

b) Have the assigned individual call the Shift Manager/ Site Emergency b) Have the assigned individual call the Coordinator. Shift Manager/ Site Emergency Coordinator.

c) IF security is unavailable OR cannot support allocation of a security officer, 3) IF security is unavailable OR cannot THEN contact and assign any available support allocation of a security officer, supervisor or manager to perform THEN contact and assign any available Evacuation Coordinator duties. supervisor or manager to perform d) If available, the TSC Security Advisor Evacuation Coordinator duties.

may be assigned the duties of the Evacuation Coordinator.

Page 16 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

25. Attachment 2 Attachment 2 Modified content.

1.k.1) 1.1.1) This change adds information for SM or SEC to direct someone to make a public Make a Public Address using the script in Direct someone (Control Room operator address (PA).

Attachment 6, "Public Address Script." or TSC Director) to make a Public Address using the script in Attachment 6, This change does not affect how the "Public Address Script." current E-Plan meets any planning standard functions, elements, or site-specific commitments . No additional evaluation required .

26. Attachment 2 Attachment 2 Modified content.

1.k.4)b) 1.l.4)b) This change corrects name of the plant status line and inserts parentheses Add PA message to bridge line extension Add PA message to plant status line around "if activated ." This change is 2800. x2800 . found in multiple locations throughout procedure and is not being added to 1.1.2) change table to reduce redundancy.

1.m.2)

Provide periodic updates to the EOF, if This change does not affect how the activated, about the status of the site Provide periodic updates to the EOF (if current E-Plan meets any planning evacuation . activated) about the status of the site standard functions, elements, or site-evacuation. specific commitments. No additional evaluation required.

Page 17 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change I Original Content (Revision 15) Revised Content (Revision 16) Description of Change

27. I Attachment 2 Attachment 2 Modified content.

2.c. Plant conditions that warrant an early I2.c. Plant conditions that may warrant an This change moves information from a work release may include, but are not early work release: sub-step into a note. In addition, "other limited to: natural event" has been added to clarify

2) Fuel damage resulting in significant that tsunami warning is not the only

2) Fuel damage that is causing significant increases in RCS activity and/or general natural event that may warrant an early increases in RCS activity and/or general area dose rates within the plant. work release.

dose rated within the plant. NOTE: The County of San Luis

3) A tsunami warning that may lead to a Obispo Emergency Operations Center This change does not affect how the stranded plant scenario. may, as a preventative measure, close current E-Plan meets any planning a) The County of San Luis Obispo down Avila Bay Drive during a tsunami standard functions, elements, or site-Emergency Operations Center may, as a warning. It may be a prudent action to specific commitments. No additional preventative measure, close down Avila initiate an early work release prior to the evaluation required.

Bay Drive during a tsunami warning. It road closures.

may be a prudent action to initiate an early work release prior to the road 3) A tsunami warning or other natural closures. event that may lead to a stranded plant scenario.

28. I Attachment 2 Attachment 2 Modified content.

2.d. 2.d. This change deletes term evacuated. In addition, this change adds a

2) Offsite conditions such as weather or 2) Offsite conditions such as weather or consideration to initiating an early work damage due to a natural event which damage due to a natural event which release based on availability of offsite may endanger evacuated personnel (e.g., may endanger personnel (e.g., seismic resources.

seismic event and associated damage, event and associated damage, tsunami tsunami warning and associated warning and associated inundation paths, This change does not affect how the inundation paths, etc.). etc.). current E-Plan meets any planning standard functions, elements, or site-

4) Are offsite resources available to assist I specific commitments. No additional with movement of personnel if evaluation required.

necessary?

Page 18 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DI L-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

29. Attachment 2 Attachment 2 Modified content.

2.e . Determine the egress route, using 2.e. Determine the egress route. This change reformats the step into the following criteria: bullet form and clarifies that egress routes are chosen by the SM/SEC, not

1) IF the southern route is passable AND 1) IF the southern route is passable AND used.

ANY of the following conditions exist: ANY of the following conditions exist:

a) There is NO release in progress that

There is NO release in progress This change does not affect how the has the potential to contaminate that has the potential to current E-Plan meets any planning personnel or personnel vehicles. contaminate personnel or standard functions, elements, or site-b) There is a release that has the personnel vehicles specific commitments . No additional potential to contaminate personnel or

There is a release that has the evaluation required.

personnel vehicles, but the wind is potential to contaminate personnel coming from between 100° and 220°. or personnel vehicles, but the wind c) It is raining. is coming from between 100° and d) The northern route is known to be 220° impassable.

It is raining THEN use the southern route.

The northern route is known to be impassable THEN choose the southern route.

2) IF none of the above condition exist OR the southern route is known to be 2) IF none of the above condition exist impassable, OR the southern route is known to be THEN use the northern route . impassable, THEN choose the northern route.

3) IF the northern route is to be used ...

3) IF the northern route is chosen ...

Page 19 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

30. Attachment 2 Attachment 2 Modified content.

2.f. Determine if offsite assembly areas 2.f. Determine if offsite assembly areas This change added a parenthetical are needed: are needed (typically offsite assembly statement to provide clarity around need areas are not necessary during an early for offsite assembly areas during an work release) . early work release .

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. Attachment 2 Attachment 2 Modified content.

2.f. 2.f. This change is being made to clarify that egress routes are chosen by the

2) IF the southern route is being used ... 2) IF the southern route was chosen ... SM/SEC, not used.

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

Page 20 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change 32 . N/A - added new content. Attachment 2 Added content.

2.g. Note has been added to highlight importance of coordinating with SLO NOTE: The SLO County EOC needs to County EOC prior to starting an early be coordinated with prior to starting an work release .

early work release to assess for potential traffic control problems or other This change does not affect how the impediments. current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required .

Page 21 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

33. Attachment 2 Attachment 2 Modified content.

2.g. Determine the need for offsite 2.g. Determine the need for offsite This change reassigns the responsibility assistance: assistance. for determining offsite assistance from the DCWC to the EOF Security Liaison.

1) Direct the DCPP Watch Commander, 1) Contact the EOF Security Liaison and or designee, to interface with local law have them coordinate with the County This change also directs contact with enforcement to determine the need for EOC to determine the need for: the Security Liaison at the EOF, if offsite assistance. Consider the need for: available rather than directly with local a) Traffic control assistance along the a) Traffic control assistance along the law enforcement based on request from evacuation route. egress route. SLO County. In addition, these b) Traffic control assistance at the offsite b) Traffic control assistance at the offsite changes include information on the assembly areas. assembly areas. appropriate offsite agency to interface c) Evacuation route clearing (i.e., c) Egress route clearing (i.e., bulldozers with in the event the EOF Security bulldozers to move impediments). to move impediments) . Liaison is not available.

d) Medical resources at the offsite d) Medical resources at the offsite assembly areas. assembly areas. This change does not affect how the e) Fire resources at the offsite assembly e) Fire resources at the offsite assembly current E-Plan meets any planning areas (fire engines may be used for areas (fire engines may be used for standard functions, elements, or site-vehicle decontamination etc.) . vehicle decontamination etc.). specific commitments. No additional evaluation required.

2) IF the EOF is not activated OR the EOF Security Liaison is not available, THEN contact the SLO County EOC or Sheriff's Watch Commander if County EOC is not activated .

Page 22 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change 34 . Attachment 2 Attachment 2 Modified content.

2.h. Determine the need for radiological 2.h. Determine the need for radiological This is an editorial change only to monitoring at the assembly areas: monitoring at the assembly areas. remove the slash between "monitoring/decontamination."

1) IF there was, or currently is, a release 1) IF there was, or currently is, a release of radioactive materials above normal of radioactive materials above normal This change does not affect how the operating operating limits that may result in the current E-Plan meets any planning limits that may result in the spread of spread of contamination, standard functions, elements, or site-contamination, THEN personnel and vehicle monitoring specific commitments . No additional THEN personnel and vehicle and decontamination should be evaluation required .

monitoring/decontamination should be performed at designated offsite assembly performed at the offsite assembly areas. areas.

2) Refer to the tables in step 2.f of this 2) Refer to the tables in step 2.f of this attachment to determine the suggested attachment to determine the suggested number of radiological monitoring number of radiological monitoring resources for each offsite assembly area. resources for each offsite assembly area.

Page 23 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

35. Attachment 2 Attachment 2 Modified content.

2.k. 2. i. This change moved the location of the coordination with the EOF earlier in the Ensure the Emergency Director (ED) at Ensure the Emergency Director (ED) at attachment and specifies decision is to the emergency operations facility (EOF) the EOF (if activated) is notified of the: perform early work release versus is notified of: "move personnel offsite."

1) The decision to move personnel 1) Decision to perform early work release In addition, these changes include offsite. information on the appropriate offsite

2) Egress route chosen agency to notify in the event the EOF is

2) The evacuation route to be used. not available.

3) Designated offsite assembly areas (if

3) The designated offsite assembly applicable) This change does not affect how the areas. current E-Plan meets any planning 2.j . IF the EOF is not activated standard functions, elements, or site-THEN notify the SLO County EOC (or specific commitments. No additional a) IF the EOF is not activated OR the ED Sheriff's Watch Commander if County evaluation required.

is not available, EOC is not activated) that:

THEN direct the DCPP Watch Commander to notify the Sheriff's 1) Personnel are going to be leaving Department that personnel are going to DCPP be evacuated, the route to be used, and approximate number of people being 2) The egress route chosen moved offsite.

(1) Additionally, provide details about any 3) Approximate number of people being offsite assistance that may be necessary released offsite as determined in step 2.f

4) Details about offsite assistance needed (if applicable)

5) Designated offsite assembly areas (if applicable)

Page 24 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

36. Attachment 2 Attachment 2 Modified content.

2.j. Complete the following table to 2.1. Complete the following table to The table in this section is to be used to document decisions and information for document decisions and information for document early work release.

the Evacuation Coordinator. the Evacuation Coordinator.

San Luis Service Center and Montana EARLY WORK RELEASE de Oro State Park Ranger Station have Egress Route: [ ] Southern [ ] Northern Egress Route: [ ] Southern [ ] Northern been included in the list of assembly areas.

Assembly Areas Offsite Assembly Areas:

[] NIA (early work release/no radiological [ ] N/A (no radiological release) Outside has been corrected to read release) [ ] PG&E Energy Education Center Offsite.

[] PG&E Energy Education Center (60-70 (60-70 cars) cars) [ ] Frontage Rd north of Energy This change does not affect how the

[ ] Frontage Rd north of Energy Education Education Center (hundreds) current E-Plan meets any planning Center (hundreds) [ ] San Luis Service Center (125 cars) standard functions, elements, or site-

[] Port San Luis Parking Lot (250 cars) [ ] Port San Luis Parking Lot (250 cars) specific commitments. No additional

[ ] Avila Beach Post Office Parking Lot [ ] Avila Beach Post Office Parking Lot evaluation required.

(250 cars) (250 cars)

[ ] Montana de Oro State Park Ranger Station (200 cars)

Outside assistance requested: [] Yes [] Offsite assistance requested: [] Yes []

No No Personnel Monitoring and Decon Personnel Monitoring and Decon required: [] Yes [] No required: [] Yes [] No EOF notified of early work release: [] Yes

[] No County notified of early work release: [ ]

Yes [] No Page 25 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change Personnel to remain on site: [ ] ERO [ ] DCPP Personnel to remain on site:

Other (list below) [] ERO

[ ] All Operations personnel

[] All Chemistry and Radiation Protection personnel

[ ] All security personnel

[ ] All Fire Fighters

[ ] All Medical personnel

[ ] All maintenance personnel (Mechanical, Electrical and l&C)

[ ] Other (list below)

Dateffime: Dateffime:

Shift Manager/ Site Emergency Shift Manager/ Site Emergency Coordinator Initials: Coordinator Initials:

37. Attachment 2 Attachment 2 Modified content.

2.1.2) 2.m. This change moves information from a sub-step into a note.

An Evacuation Coordinator may not be NOTE: An Evacuation Coordinator may necessary if personnel are going to be not be necessary if personnel are going This change does not affect how the sent home without any additional to be sent home without any additional current E-Plan meets any planning restrictions/guidance (i.e., no offsite restrictions/guidance (i.e., no offsite standard functions, elements, or site-assembly areas, no need for personnel assembly areas, no need for personnel specific commitments. No additional monitoring or decon, etc.). monitoring or decon, etc.). evaluation required.

Page 26 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change I Original Content (Revision 15) Revised Content (Revision 16) Description of Change

38. I Attachment 2 Attachment 2 Modified content.

2.n. Follow-up actions: 2.o. Follow-up actions:

Replaced "if established" with "if

1) Maintain communications with the 1) Maintain communications with the I applicable" and added parenthesis Evacuation Coordinator, if established, Evacuation Coordinator (if applicable) for around "if applicable."

for periodic status updates on progress of periodic status updates on progress of the early work release. the early work release. I This change does not affect how the current E-Plan meets any planning

3) Provide periodic updates to the EOF, if 3) Provide periodic updates to the EOF (if standard functions, elements, or site-activated, about the status of the early activated) about the status of the early specific commitments. No additional work release. work release . evaluation required.

39. I Attachment 3 Attachment 3 I Modified content.

1.a. Receive evacuation/early work 1.a. Receive evacuation instructions for release instructions for the Shift The table in this section is used to the Shift Manager/Site Emergency Manager/Site Emergency Coordinator, document both evacuation and early Coordinator, including: including: work release.

Site Evacuation [ ] Yes [ ] No Site Evacuation [ ] Yes [ ] No [ ] NA [ ] NA San Luis Service Center and Montana Early Work Release [ ] Yes [ ] No [ ] NA Early Work Release [ ] Yes [ ] No de Oro State Park Ranger Station have Evacuation Route: [ ] Southern [ ] [ ] NA been included in the list of assembly Northern Evacuation / Egress Route: [ ] Southern areas.

[ ] Northern Offsite Assembly Areas: Outside has been corrected to read Assembly Areas: [ ] N/A (early work release/no radiological Offsite.

[] N/A (early work release/no radiological release) release) [ ] PG&E Energy Education Center (60 Check boxes are being provided to list

[] PG&E Energy Education Center (60-70 70 cars) personnel that may be requested to stay cars) [ ] Frontage Rd north of Energy onsite for ease of documentation.

[] Frontage Rd north of Energy Education Education Center (hundreds)

Center (hundreds) [ ] San Luis Service Center (125 cars) This change does not affect how the

[] Port San Luis Parking Lot (250 cars) [ ] Port San Luis Parking Lot (250 cars) current E-Plan meets any planning

[ ] AvLI~ Beach Post _Office Parking Lot [ ] Avila Beach Post Office Parking Lot standard functions, elements, or site-Page 27 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change (250 cars) (250 cars) specific comm itments . No additional

[ ] Montana de Oro State Park Ranger evaluation required.

Station (200 cars)

Offsite assistance requested :[ ] Yes

[ ] No Outside assistance requested : [] Yes [] Personnel Monitoring and Decon No required: [ ] Yes [ ] No EOF notified of evacuation/early work Personnel Monitoring and/or Decon release : [ ] Yes [ ] No required: [] Yes [] No County notified of evacuation/early work release: [ ] Yes [ ] No DCPP Personnel to remain on site:

[ ] ERO

[ ] All Operations personnel

[ ] All Chemistry and Radiation Protection personnel

[ ] All security personnel Personnel to remain on site: [ ] All Fire Fighters

[] ERO [ ] All Medical personnel

[ ] Other (list below) [ ] All maintenance personnel Date!Time: (Mechanical, Electrical and l&C)

Shift Manager/ Site Emergency [ ] Other (list below)

Coordinator Initials: Date!Time: Shift Manager/ Site EmerQencv Coordinator Initials:

40. Attachment 3 Attachment 3 Modified content.

1.b. Check with the Shift Manager/ Site 1.b. Check with the Shift Manager/ Site These changes correct the offsite Emergency Coordinator that Emergency Coordinator to ensure agency to communicate with and communications with offsite agencies communications with the SLO County include information on early work (California Highway Patrol, Sheriff's EOC or Sheriff's Watch Commander (if release in addition to site evacuation. It Department etc.) have been made prior EOC is not activated) have been made also clarifies that radiological resources to evacuating personnel from the site. prior to evacuating or releasing personnel are personnel and not equipment.

from the site. Additionally, multiple Qrammatical and Page 28 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change editorial errors are corrected.

1.c. Start the evacuation after receiving 1.c. If not already in progress, start the Shift Manager/ Site Emergency site evacuation or early work release after This change does not affect how the Coordinator permission. receiving Shift Manager/ Site Emergency current E-Plan meets any planning Coordinator permission. standard functions, elements, or site-specific commitments. No additional 1.d. IF radiological monitoring and/or 1.d. IF radiological monitoring and decon evaluation required.

decon is required, is required, THEN: THEN:

1) Contact the TSC Radiological Advisor 1) Contact the TSC Radiological Advisor to coordinate the allocation of qualified to coordinate the allocation of qualified radiological monitoring resources. radiological monitoring personnel.

a) At least one qualified monitor per a) At least one person qualified in offsite assembly area is required. radiological monitoring is required per offsite assembly area.

2) IF the TSC is not activated OR the 2) IF the TSC is not activated OR the Radiological Advisor is unavailable, Radiological Advisor is unavailable, THEN contact the EOF Radiological THEN contact the EOF Radiological Manager to coordinate the allocation of Manager to coordinate the allocation of qualified radiological monitoring qualified radiological monitoring resources. personnel.

3) IF both the TSC and EOF are 3) IF both the TSC and EOF are unavailable, unavailable, THEN perform a manual call-out of RP THEN perform a manual call-out of RP management personnel until someone is management personnel until someone is reached who can coordinate the reached who can coordinate the allocation of qualified radiological allocation of qualified radiological monitoring resources. monitoring personnel.

4) Provide the location(s) of the offsite 4) Provide the location(s) of the offsite Page 29 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change I Original Content (Revision 15) Revised Content (Revision 16) Description of Change assembly areas (if applicable) that are assembly areas (if applicable) that are going to be used to the radiological going to be used.

monitoring personnel.

5) Qualified monitoring personnel should 5) Qualified monitoring personnel should accompany, or meet, each evacuation accompany, or meet, each evacuation group to their assembly area. group at their assembly area.

41. I Attachment 3 Attachment 3 Modified content.

1.f. Appoint Evacuation Team Leaders: 1.f. Appoint Evacuation Team Leaders. These changes reorder sentences for clarity and includes additional detail on

1) At each of the onsite assembly areas, 1) Select management personnel to act location of evacuation kits.

as determined from step 1.e, select as Evacuation Team Leaders for each management personnel to act as onsite assembly area. This change does not affect how the Evacuation Team Leaders. current E-Plan meets any planning 1.f.2) standard functions, elements, or site-1.f.2) specific commitments. No additional NOTE: Evacuation kits and a supply of evaluation required.

NOTE: Evacuation kits and a supply of radios are in Warehouse B (Bldg. 113) in radios are in the north east corner of the FLEX storage area. The onsite FMT Warehouse B. The onsite FMT kits are kits are located in the same area. Each located in the same area. Each kit type is kit type is labeled accordingly.

labeled accordingly.

Page 30 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

42. Attachment 3 Attachment 3 Modified content 1.f. 1.f. This change clarifies that radiological resources are personnel and not 2)b) A qualified radiological monitor 2)b) Qualified radiological monitoring equipment, adds specific building (person) personnel number for Warehouse B, and corrects a grammatical error.

3) Either the Evacuation Team Leader or 3) Either the Evacuation Team Leader or a qualified radiological monitor needs a qualified radiological monitoring This change does not affect how the dosimeter to determine evacuation personnel needs a dosimeter to current E-Plan meets any planning doses. determine evacuation doses. standard functions, elements, or site-a) There are 100 PEDs and 100 TLDs a) There are 100 PEDs and 100 TLDs specific commitments. No additional located in Warehouse B in the same area located in Warehouse B (Bldg. 113) in the evaluation required .

where the evacuation kits are located. same area where the evacuation kits are (1) Additional self reading dosimeters located.

may be obtained from RP or the (1) Additional self-reading dosimeters Radiological Advisor in the TSC if may be obtained from RP or the available. Radiological Advisor in the TSC if available.

43. Attachment 3 Attachment 3 Modified content 1.g. Instruction for personnel evacuation: 1.g. Direct all personnel to: Deleted step that titled section and reformatted all proceeding steps. In

1) Direct all personnel to: 1) Retain their security badges for addition, replaced term required with a) Retain their security badges for identification. applicable for consistency.

identification .

b) Proceed in caravan fashion along the 2) Proceed in caravan fashion along the This change does not affect how the designated route to the offsite assembly designated route to the offsite assembly current E-Plan meets any planning area if required. area (if applicable). standard functions, elements, or site-c) Personnel without transportation specific commitments. No additional should carpool with others that are going 3) Personnel without transportation evaluation required.

to the same offsite assembly area. should carpool with others that are going (1) Arrangements to get home should be to the same offsite assembly area.

Page 31 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change made at the offsite assembly area.

d) If required, evacuated personnel 4) Arrangements to get home should be should remain at the offsite assembly made at the offsite assembly area.

area until monitored and cleared for release . 5) Personnel should remain at the offsite assembly area until monitored and cleared for release (if applicable).

1.h. Notify the TSC Communications

2) Notify the TSC Communications Advisor (x3390) of who the Evacuation Advisor (x3390) of who the Evacuation Team Leader is for each offsite assembly Team Leader is for each offsite assembly area.

area.

1.i. Notify Avila Gate of the evacuation.

3) Notify Avila Gate of the evacuation.

1.j . Coordinate with the TSC Security

4) Coordinate with the TSC Security Advisor (x3260) to have Security direct Advisor (x3260) to have Security direct traffic onsite .

traffic onsite.

1.k. Coordinate with the DCPP Watch

5) Coordinate with the DCPP Watch Commander, or designee, all requested Commander, or designee, all requested offsite traffic control.

offsite traffic control .

Page 32 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change 44 . Attachment 3 Attachment 3 Modified content 1.g.6) Dispatch a vehicle to clear the 1.1. Dispatch a vehicle to clear the south This change clarifies that radiological south access road of personnel who may access road of personnel who may be resources are personnel and not be working along the road or working on working along the road or working on the equipment and renumbers steps based the farms. farms. on previous change.

a) IF conditions warrant (a radiological 1) IF conditions warrant (a radiological This change does not affect how the release occurred or is in progress), release occurred or is in progress), current E-Plan meets any planning THEN a qualified monitor should be THEN qualified radiological monitoring standard functions, elements, or site-assigned to this vehicle to monitor these personnel (1) should be assigned to this specific commitments. No additional personnel and their vehicles. vehicle to monitor these personnel and evaluation required their vehicles.

b) This vehicle should proceed to the offsite assembly area for traffic control. a) This vehicle should proceed to the offsite assembly area for traffic control.

1.g.7) Dispatch a vehicle to notify personnel and visitors along the north 1.m. Dispatch a vehicle to notify access road. Their assembly area is the personnel and visitors along the north Montana de Oro State Park Ranger access road . Their assembly area is the Station. Montana de Oro State Park Ranger Station .

a) IF conditions warrant (a radiological release occurred or is in progress), 1) IF conditions warrant (a radiological THEN a qualified monitor should be release occurred or is in progress),

assigned to this vehicle to monitor these THEN qualified radiological monitoring personnel and their vehicles. personnel (1) should be assigned to this vehicle to monitor these personnel and their vehicles.

45. Attachment 3 Attachment 3 Modified content.

1. h. Actions to be taken at the offsite 1. n. Actions to be taken at the offsite This checklist is used to document both assembly area(s) assembly area(s) . evacuation and early work release. In Page 33 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change addition, the information on PG&E

1) Ensure personnel are accounted for 1) Ensure personnel are accounted for authority to detain personnel has been and monitored. and monitored. deleted . Formatting changes have also been made.

2) Direct the radiological monitors to 2) Direct the radiological monitors to begin surveying personnel and vehicles begin surveying personnel and vehicles This change does not affect how the for contamination using Attachment 5. for contamination using Attachment 5. current E-Plan meets any planning standard functions, elements, or site-

3) Provide periodic updates to the Shift 3) Provide periodic updates to the Shift specific commitments. No additional Manager/ Site Emergency Coordinator Manager/ Site Emergency Coordinator evaluation required about: about:

a) Evacuation status a) Evacuation / early work release status b) Offsite assembly area resource needs b) Offsite assembly area resource needs (1) Additional DCPP personnel needed

Additional DCPP personnel needed (2) Additional non-DCPP resources

Additional non-DCPP resources needed (Fire, local law enforcement, needed (Fire, local law enforcement, traffic control, etc.) traffic control, etc.)

c) Radiological monitoring progress (if c) Radiological monitoring progress (if applicable) applicable)

4) IF public parking lots are used as offsite assembly areas and lots cannot be

4) IF public parking lots are used as completely cleared prior to personnel assembly areas and lots cannot be arriving, completely THEN the owners or vehicle license cleared prior to evacuees arriving, numbers of cars still in the lot should be THEN the owners and/or vehicle license recorded and the vehicles surveyed numbers of cars still in the lot should be before being allowed to leave.

recorded and the vehicles surveyed before being allowed to leave. a) Information on vehicles surveyed should be provided to the San Luis a) Local law enforcement officials shall be Obispo County EOC.

relied upon for detaining vehicles . PG&E Page 34 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change has no authority to detain personnel and/or their property.

46. Attachment 3 Attachment 3 Modified content 1.i. 1.o. This change clarifies that assembly areas are offsite and corrects a NOTE: Each assembly is treated NOTE: Each offsite assembly area is grammatical error.

separately to determine when personnel treated separately to determine when are to be released. personnel are to be released. This change does not affect how the current E-Plan meets any planning 1.o. Release of personnel from offsite standard functions, elements, or site-1.i. Release of personnel from offsite assembly areas. specific commitments. No additional assembly areas: evaluation required.

1) WHEN all of the following conditions

1) WHEN all of the following conditions are met, are met, a) A sufficient number of persons and a) A sufficient number of persons and vehicles in the area have been surveyed vehicles in the area have been surveyed to determine contamination is not a to determine contamination is not a factor.

factor. b) Self-reading dosimeter results have b) Self reading dosimeter results have been recorded.

been recorded. c) Permission to release personnel has c) Permission to release personnel has been received from the Shift Manager/

been received from the Shift Manager/ Site Emergency Coordinator.

Site THEN allow personnel to leave the offsite Emergency Coordinator. assembly area.

THEN allow personnel to leave the offsite assembly area.

Page 35 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

47. Attachment 3 Attachment 3 Modified content 1.j. Close out actions: 1.p. Close out actions This change clarifies that radiological resources are personnel and not

1) Have Evacuation Team Leaders and 1) Have Evacuation Team Leaders and equipment, adds specific building radiological monitors: radiological monitoring personnel: number for Warehouse B, and clarifies a) Return equipment to Warehouse B, or a) Return equipment to Warehouse B that assembly areas are offsite.

other designated area if site is (Bldg . 113), or other designated area. Additionally, the specific facility where inaccessible. b) Provide offsite assembly area documentation shall be provided is b) Provide assembly area documentation documentation (survey forms, dosimetry being designated .

(survey forms, dosimetry records, etc.) to records, etc.) to Control Room or TSC.

you. This change does not affect how the

2) Inform the Shift Manager/ Site current E-Plan meets any planning Emergency Coordinator when all actions standard functions, elements, or site-

2) Inform the Shift Manager/ Site are completed. specific commitments . No additional Emergency Coordinator when all actions evaluation required are completed. 3) Forward all documentation to Emergency Planning.

3) Forward all documentation to Emergency Planning.

48. Attachment 4 Attachment 4 Modified content.

1.a. 1.a. This change clarifies that radiological resources are personnel and not NOTE: Evacuation kits and a supply of NOTE: Evacuation kits and a supply of equipment, adds specific building radios are in the north east corner of radios are in Warehouse B (Bldg. 113) in number for Warehouse B, and includes Warehouse B. The onsite FMT kits are the FLEX storage area. The onsite FMT additional detail on location of located in the same area. Each kit type is kits are located in the same area. Each evacuation kits . The detail added on labeled accordingly. kit type is labeled accordingly. access to the FLEX storage area is provided in FLEX Support Guide 5.

1.a. Obtain the following: 1.a. Obtain the following:

This change does not affect how the Page 36 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

1) A qualified radiological monitor (as 1) Qualified radiological monitoring current E-Plan meets any planning determined by the Evacuation personnel (as determined by the standard functions, elements, or site-Coordinator) Evacuation Coordinator) specific commitments. No additional evaluation required.

N/A - added new content. 2) Access to the FLEX storage area in Warehouse B (Bldg. 113):

a) Open the west personnel door using the electronic lock (pass code for the electronic lock is 2701) b) Enter from the fire station side of the building c) Break a window in the west rollup door

2) Dosimetry (north east corner of Warehouse B) 3) Dosimetry from Warehouse B (Bldg .

a) Either the Evacuation Team Leader or 113) a qualified radiological monitor needs a dosimeter to determine evacuation a) Either the Evacuation Team Leader or doses. qualified radiological monitoring personnel needs a dosimeter to

( 1) There are 100 PEDs and 100 TLDs determine evacuation doses.

located in Warehouse B in the same area (1) There are 100 PEDs and 100 TLDs where the evacuation kits are located. located in Warehouse B (Bldg. 113) in the (2) Additional self reading dosimeters same area where the evacuation kits are may be obtained from RP or the located.

Radiological Advisor in the TSC if (2) Additional self-reading dosimeters available. may be obtained from RP or the Radiological Advisor in the TSC if

3) Plant Frequency Portable Radio (north available.

east corner of Warehouse B)

4) Plant Frequency Portable Radio from

4) Evacuation kit (north east corner of Warehouse B (Bldg. 113)

Warehouse B)

5) Evacuation kit from Warehouse B Page 37 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

5) Evacuation route (as determined by (Bldg. 113) the Evacuation Coordinator)

6) Evacuation route (as determined by

6) Assigned offsite assembly area (as the Evacuation Coordinator) determined by the Evacuation Coordinator) 7) Assigned offsite assembly area (as communicated by the Evacuation

4) On-site traffic pattern (as determined Coordinator) by the Evacuation Coordinator)

8) Onsite traffic pattern (as determined by

5) Sequence of evacuation which will the Evacuation Coordinator) generally be:

a) Warehouse B area 9) Sequence of evacuation will generally b) Parking lots be:

c) Training Building/Maintenance Shop a) Warehouse B (Bldg. 113) area Building b) Parking lots d) All other areas (as determined by the c) Training Building (Bldg. 109)

Evacuation Coordinator) d) Maintenance Shop Building (Bldg. 119) e) All other areas (as determined by the Evacuation Coordinator)

49. Attachment 4 Attachment 4 Modified content.

1.b. Actions at the offsite assembly area: 1.b. Actions at the offsite assembly area This change clarifies that radiological resources are personnel and not

1) At the offsite assembly area ensure 1) At the offsite assembly area ensure equipment; that it is personnel, not personnel are accounted for and personnel are accounted for and evacuees; corrects grammar and monitored. monitored . format; and provides direction on where documentation shall be provided.

a) Record the security badge numbers of 2) Record the security badge numbers of all evacuees, noting any evacuees all personnel, noting those suspected of In addition, the information on PG&E suspected of having received doses in having received doses in excess of 100 authority to detain personnel has been excess of 100 mrem TEDE and those mrem TEDE and those requiring deleted.

requiring decontamination . decontamination.

Page 38 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change (1) IF the evacuee does not have a This change does not affect how the security badge, a) IF personnel does not have a security current E-Plan meets any planning THEN obtain their names and addresses. badge, standard functions, elements, or site-THEN obtain their name and address. specific commitments. No additional

2) Direct the radiological monitors (if evaluation required.

required) to begin surveying personnel 3) Direct qualified radiological monitoring and vehicles for contamination using personnel (if required) to begin surveying Attachment 5. personnel and vehicles for contamination using Attachment 5.

3) Provide periodic updates to the 4) Provide periodic updates to the Evacuation Coordinator about: Evacuation Coordinator about:

a) Evacuation status a) Evacuation status b) Off-site assembly area resource needs b) Off-site assembly area resource needs (1) Additional DCPP personnel needed

Additional DCPP personnel needed (2) Additional non-DCPP resources

Additional non-DCPP resources needed (Fire, local law enforcement, needed (Fire, local law enforcement, traffic control, etc.) traffic control, etc.)

c) Radiological monitoring progress (if c) Radiological monitoring progress (if applicable) applicable)

5) IF public parking lots are used as

4) IF public parking lots are used as offsite assembly areas and lots cannot be assembly areas and lots cannot be completely cleared prior to personnel completely arriving, cleared prior to evacuees arriving, THEN the owners or vehicle license THEN the owners and/or vehicle license numbers of cars still in the lot should be numbers of cars still in the lot should be recorded and the vehicles surveyed recorded and the vehicles surveyed before being allowed to leave.

before being allowed to leave.

a) Information on vehicles surveyed a) Local law enforcement officials shall be should be provided to the Evacuation relied upon for detaining vehicles. PG&E Coordinator.

Page 39 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change has no authority to detain personnel and/or their property.

50. Attachment 4 Attachment 4 Modified content.

1.c. Allow personnel to leave the offsite 1.c. Allow personnel to leave the offsite This change reformats one task into assembly area ONLY after: assembly area after all of the following: two, simplifies steps, and rewrites for clarity.

1) They and their vehicle have been 1) They and their vehicle have been surveyed or a sufficient number of surveyed or a sufficient number of This change does not affect how the persons in that area have been surveyed persons in that area have been surveyed current E-Plan meets any planning to determine contamination is not a to determine contamination is not a standard functions, elements, or site-factor. factor. specific commitments. No additional evaluation required.

2) Self reading dosimeter results have 2) Self-reading dosimeter results have been recorded. been recorded .

3) Permission to release the personnel 3) Permission to release the personnel has been received from the Shift has been received from the Shift Manager/ Site Manager/ Site Emergency Coordinator Emergency Coordinator via the via the Evacuation Coordinator.

Evacuation Coordinator.

1.d. Inform the Evacuation Coordinator

4) Inform the Evacuation Coordinator: when:

a) When all personnel have left the 1) All personnel have left the offsite assembly area. assembly area .

b) If there are any radiological issues that 2) There are any radiological issues that need to be addressed. need to be addressed.

(1) This may include the survey and 3) Survey and release of the offsite release of the offsite assembly area itself assembly area itself is complete.

after all personnel have left.

Page 40 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

51. Attachment 4 Attachment 4 Modified content.

1.d. Close out actions: 1.e. Close out actions: This change adds specific building number for Warehouse B and clarifies

1) Return equipment to Warehouse B, or 1) Return equipment to Warehouse B that assembly areas are offsite.

other designated area if site is (Bldg. 113), or other designated area.

inaccessible. This change does not affect how the

2) Provide offsite assembly area current E-Plan meets any planning

2) Provide assembly area documentation documentation (survey forms, dosimetry standard functions, elements, or site-(survey forms, dosimetry records, etc.) to records, etc.) to the Evacuation specific commitments. No additional the Coordinator. evaluation required Evacuation Coordinator.

3) Inform the Evacuation Coordinator

3) Inform the Evacuation Coordinator when all actions are completed.

when all actions are completed.

52. Attachment 5 Attachment 5 Modified content.

1.a. 1.a. This change adds specific building numbers and includes additional detail NOTE: Evacuation kits and a supply of NOTE: Evacuation kits and a supply of on location of evacuation kits . The radios are in the north east corner of radios are in Warehouse B (Bldg. 113) in detail added on access to the FLEX Warehouse B. The onsite FMT kits are the FLEX storage area. The onsite FMT storage area is provided in FLEX located in the same area. Each kit type is kits are located in the same area. Each Support Guide 5. This change also labeled accordingly. kit type is labeled accordingly. includes an editorial change and clarifies that offsite assembly areas are 1.a. Obtain the following: 1.a. Obtain the following: communicated to by the Evacuation Coordinator to the Radiological Monitor.

N/A- added new content. 1) Access to the FLEX storage area in Warehouse B (Bldg. 113): This change does not affect how the a) Open the west personnel door using current E-Plan meets any planning the electronic lock (pass code for the standard functions, elements, or site-electronic lock is 2701) specific commitments. No additional b) Enter from the fire station side of the evaluation required.

Page 41 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change building c) Break a window in the west rollup door

1) Dosimetry (north east corner of Warehouse B) 2) Dosimetry from Warehouse B (Bldg .

a) Either the Evacuation Team Leader or 113) a qualified radiological monitor needs a dosimeter to determine evacuation a) Either the Evacuation Team Leader or doses. qualified radiological monitoring personnel needs a dosimeter to (1) There are 100 PEDs and 100 TLDs determine evacuation doses.

located in Warehouse B in the same area (1) There are 100 PEDs and 100 TLDs where the evacuation kits are located. located in Warehouse B (Bldg . 113) in the (2) Additional self reading dosimeters same area where the evacuation kits are may be obtained from RP or the located.

Radiological Advisor in the TSC if (2) Additional self-reading dosimeters available. may be obtained from RP or the Radiological Advisor in the TSC if

2) Plant Frequency Portable Radio (north available.

east corner of Warehouse B)

3) Plant Frequency Portable Radio from

3) Evacuation kit (north east corner of Warehouse B (Bldg . 113)

Warehouse B)

4) Evacuation route (as determined by 4) Evacuation kit from Warehouse B the Evacuation Coordinator) (Bldg . 113)

5) Evacuation route (as determined by

5) Assigned offsite assembly area (as the Evacuation Coordinator) determined by the Evacuation Coordinator) 6) Assigned offsite assembly area (as communicated by the Evacuation

6) Onsite traffic pattern (as determined by Coordinator) the Evacuation Coordinator)

7) Onsite traffic pattern (as determined by

7) Sequence of evacuation which will the Evacuation Coordinator)

Page 42 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change generally be :

a) Warehouse B area 8) Sequence of evacuation will generally b) Parking lots be:

c) Training Building/Maintenance Shop a) Warehouse B (Bldg . 113) area Building b) Parking lots d) All other areas (as determined by the c) Training Building (Bldg . 109)

Evacuation Coordinator) . d) Maintenance Shop Building (Bldg. 119) e) All other areas (as determined by the Evacuation Coordinator) .

53 . Attachment 5 Attachment 5 Modified Content 1.b. Actions at the offsite assembly area: 1.b. Actions at the offsite assembly area Editorial change to replace numbers with bullets, reorders sentences for

1) Record the names and/or vehicle 1) Record the names and vehicle license readability, and corrects grammar and license numbers of any vehicles in the numbers of any vehicles in the parking lot formatting . This change also clarifies parking lot before evacuee's arrival. before personnel arrival. that it is personnel, not evacuees who are being monitored; and provides

2) IF public parking lots are used as 2) IF public parking lots are used as direction on where documentation shall assembly areas and lots cannot be assembly areas and lots cannot be be provided.

completely completely cleared prior to evacuees cleared prior to evacuees arriving, arriving, In addition, the information on PG&E THEN the owners and/or vehicle license THEN the owners or vehicle license authority to detain personnel has been numbers of cars still in the lot should be numbers of cars still in the lot should be deleted.

recorded and the vehicles surveyed recorded and the vehicles surveyed before being allowed to leave. before being allowed to leave. This change does not affect how the e) Local law enforcement officials shall be a) Information on vehicles surveyed current E-Plan meets any planning relied upon for detaining vehicles. PG&E should be provided to the Evacuation standard functions, elements, or site-has no authority to detain personnel Team Leader. specific commitments . No additional and/or their property. evaluation required.

3) Record the security badge numbers of

3) Record the security badge numbers of all personnel, noting those suspected of all evacuees, noting any evacuees having received doses in excess of 100 suspected of mrem TEDE and those requiring Page 43 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change having received doses in excess of 100 decontamination.

mrem TEDE and those requiring a) IF the evacuee does not have a decontamination. security badge, f) IF the evacuee does not have a THEN obtain their names and addresses.

security badge, THEN obtain their names and addresses.

4) Initiate a personnel and vehicular 4) Initiate a personnel and vehicle contamination survey program. contamination survey program.

a) Record results on the following forms: a) Record results on the following forms:

( 1) Attachment 7, "Post Evacuation ( 1) Attachment 7, "Post Evacuation Vehicle Monitoring Data" Vehicle Monitoring Data" (2) Attachment 8, "Evacuee Monitoring (2) Attachment 8, "Evacuee Monitoring Data" Data" (3) Report survey summary to Evacuation b) Report survey summary to Evacuation Coordinator and/or Evacuation Team Team Leader and/or Evacuation Leader. Coordinator.

5) A representative sample of individuals and vehicles shall be surveyed to c) A representative sample of individuals determine if contamination is a factor. and vehicles should be surveyed to determine if contamination is a factor.

6) IF personnel are found to be contaminated, 5) IF personnel are found to be THEN ensure contaminated personnel contaminated, are taken to a decontamination center THEN ensure contaminated personnel and decontaminated. are taken to a decontamination center a) Decontamination should be performed and decontaminated.

per RCP NISP-RP.06, "Personnel a) Decontamination should be performed Contamination Monitoring." per RCP NISP-RP.06, "Personnel b) Off-site decon facility selection: Contamination Monitoring."

(1) The EnerQy Education Center b) Offsite decon facility selection:

Page 44 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change Decontamination Facility ( 1) The Energy Education (a) This facility is located in a separate Center Decontamination Facility building behind the main information

This facility is located in a separate center building, which is located on the building behind the main building, west frontage road to which is located on the west frontage Highway 101 (Ontario Rd .), just south of road to Highway 101 (Ontario Rd.),

the San Luis Bay Drive turnoff to just south of the San Luis Bay Drive Avila Beach . turnoff to Avila Beach.

(b) This is the only designated offsite

This is the only designated offsite decontamination facility for non-injured decontamination facility for personnel. non-injured personnel.

(c) One shower and one washbasin are

One shower and one washbasin are located in both decontamination rooms in located in both decontamination this facility. rooms in this facility.

(d) This facility is normally stocked with decontamination supplies .

This facility is normally stocked with decontamination supplies .

(e) Supplies from the plant, the emergency kits or other available sources

Supplies from the plant, the emergency kits or other available may augment the stored supplies stored sources may augment the supplies at this facility. stored at this facility.

(2) French Hospital Emergency Room (2) French Hospital Emergency Room (a) This facility is located at French Hospital at 1911 Johnson Avenue in San

This facility is located at French Hospital at 1911 Johnson Avenue in Luis Obispo city. San Luis Obispo city.

(b) This is the only decontamination facility designated for injured personnel

This is the primary decontamination facility designated for injured requiring immediate offsite medical personnel requiring immediate offsite attention . It should only be selected for medical attention. It should only be personnel with serious medical conditions selected for personnel with serious requiring prompt care.

medical conditions requiring prompt care.

Page 45 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

7) IF vehicles are found to be 6) IF vehicles are found to be contaminated, contaminated, THEN coordinate with the Evacuation THEN coordinate with the Evacuation Team Leader and Evacuation Team Leader and Evacuation Coordinator to determine the best course Coordinator to determine the best course of action. of action.

a) PG&E has no authority to detain personnel and/or their property.

8) Provide periodic updates to the 7) Provide periodic updates to the Evacuation Team Leader about: Evacuation T earn Leader about:

a) Offsite assembly area resource needs a) Offsite assembly area resource needs (1) Additional DCPP personnel needed

Additional DCPP personnel (2) Additional non-DCPP resources needed needed (Fire, local law enforcement,

Additional non-DCPP resources traffic control, etc.) needed (Fire, local law enforcement, traffic control, etc.)

b) Radiological monitoring progress (if b) Radiological monitoring progress (if applicable) applicable)

9) Periodically, record all self reading 8) Periodically, record all self-reading dosimeter results. dosimeter results.

Page 46 of 48

Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change 54 . Attachment 5 Attachment 5 Modified content.

1.c. Allow personnel to leave the offsite 1.c. Allow personnel to leave the offsite This change reformats one task into assembly area ONLY after: assembly area after all of the following : two, simplifies steps, and renumbers fo r clarity.

1) They and their vehicle have been 1) They and their vehicle have been surveyed or a sufficient number of surveyed or a sufficient number of This change does not affect how the persons in that area have been surveyed persons in that area have been surveyed current E-Plan meets any planning to determine contamination is not a to determine contamination is not a standard functions, elements, or site-factor. factor. specific commitments. No additional evaluation required.

2) Self reading dosimeter results have 2) Self-reading dosimeter results have been recorded . been recorded.

3) Permission to release the personnel 3) Permission to release personnel has has been received from the Shift been received from the Shift Manager/

Manager/ Site Site Emergency Coordinator via the Emergency Coordinator via the Evacuation Coordinator.

Evacuation Coordinator.

1.d. Inform the Evacuation Team Leader

4) Inform the Evacuation Coordinator and/or Evacuation Coordinator when :

and/or Evacuation Team Leader:

1) All personnel have left the assembly a) When all personnel have left the area.

assembly area.

b) If there are any radiological issues that 2) There are any radiological issues that need to be addressed . need to be addressed.

(1) This may include the survey and 3) Survey and release of the offsite release of the offsite assembly area itself assembly area itself is complete .

after all personnel have left.

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Enclosure 3 PG&E Letter DCL-18-094 PG&E Letter DIL-18-015 Change Original Content (Revision 15) Revised Content (Revision 16) Description of Change

55. Attachment 5 Attachment 5 Modified content.

1.d. Close out actions: 1.e. Close out actions: This change adds specific building number for Warehouse B.

1) Return equipment to Warehouse B, or 1) Return equipment to Warehouse B other designated area if site is (Bldg. 113), or other designated area. This change does not affect how the inaccessible. current E-Plan meets any planning

2) Provide assembly area documentation standard functions, elements, or site-

2) Provide assembly area documentation (survey forms, dosimetry records, etc.) to specific commitments. No additional (survey forms, dosimetry records, etc.) to the Evacuation Coordinator. evaluation required the Evacuation Coordinator. 3) Inform the Evacuation Coordinator when all actions are completed.

3) Inform the Evacuation Coordinator when all actions are completed.

56. Attachment 7 Attachment 7 Modified content.

Post Evacuation Vehicle Monitoring Data Post Evacuation Vehicle Monitoring Data This change is to correct a typographical area.

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

Page 48 of 48

DCL-18-094, Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update

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Dear Commissioners and Staff:

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DCL-18-094, Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update

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Dear Commissioners and Staff:

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