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Pacific· Gas .and El'ecmc Company;to

July 26, 2016

PG&E Letter DCL-16-076 PG&E Letter DIL-16-011

Michael A. Ginn Manager Emergency Planning

Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424

805.545.6300 Internal: 691 .6300 Fax: 805.545.6265

U.S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001

10 CFR 50.54, 10 CFR 72.32

Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Docket No. 72-26, Materials License No. SNM-2511 Diablo Canyon Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update

Dear Commissioners and Staff:

In accordance with 10 CFR 50.54, and including the requirements of 10 CFR 72.32 for the Independent Spent Fuel Storage Installation, Pacific Gas and Electric Company (PG&E) is providing a summary of the analysis of changes to Emergency Plan (E-Pian) Implementing Procedures EP RB-8, "Instructions for Field Monitoring Teams" and OM1 O.DC1, "Emergency Preparedness Drills and Exercises."

The associated enclosures are listed below:

Enclosure Title 1 Diablo Canyon Power Plant Emergency Plan Implementing

Procedures, Revision Numbers for Emergency Plan Implementing Procedures

2 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure EP RB-8, Revision 27, "Instructions for Field Monitoring Teams"

3 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure OM1 O.DC1, Revision 8, "Emergency Preparedness Drills and Exercises"

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-Pian, and that the E-Pian continues to meet the requirements in Appendix E to 10 CFR 50 and the planning standards of 10 CFR 50.47(b). Therefore, prior NRC approval of the associated changes was not required.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance

Callaway • Diablo Canyon • Palo Verde • Wolf Creek

r .

Document Control Desk July 26, 2016

PG&E Letter DCL-16-076 PG&E Letter DIL-16-011

Enclosure 2 of this update contains privacy/proprietary information that has been bracketed in accordance with NRC Generic Letter 81-27, "Privacy and Proprietary Material in Emergency Plans."

PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.

If there are questions regarding this update, please contact me at (805) 545-3446.

Sincerely,

Emergency Planning Manager

bnsm/4540/50863058/ Enclosures cc/enc: John M. Goshen, P.E., NMSS Project Manager

Kriss M. Kennedy, NRC Region IV Administrator John P. Reynoso, NRC Acting Senior Resident Inspector Balwant K. Singal, NRR Senior Project Manager Senior Emergency Preparedness Inspector (RGN-IV/DR)

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance

Callaway • Diablo Canyon • Palo Verde • Wolf Creek

Enclosure 1 PG&E Letter DCL-16-076 PG&E Letter DIL-16-011

DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES

Revision Numbers for Emergency Plan Implementing Procedures

Proc. No. OM10.1D1 OM10.DC1* EP G-1 EP G-2 EP G-3 EP G-4 EP G-5 EP OR-3 EP RB-1 EP RB-2 EP RB-3 EP RB-4

EP RB-5 EP RB-8* EP RB-9 EP RB-10 EP RB-11 EP RB-12

EP RB-14 EP RB-14A EP RB-15 EP RB-16 EP R-2 EP R-3 EP R-7 EP EF-1 EP EF-2 EP EF-3 EP EF-4 EP EF-9 EP EF-10

EP EF-11


DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES

Rev. Title 13 Maintaining Emergency Preparedness 8 Emergency Preparedness Drills and Exercises

44 Emergency Classification and Emergency Plan Activation 49 Interim Emergency Response Organization 58 Emergency Notification of Off-Site Agencies 28 Assembly and Accountability 14 Evacuation of Non-Essential Site Personnel 10 Emergency Recovery 8 Personnel Dosimetry 8 Emergency Exposure Guides 7 Stable Iodine Thyroid Blocking 5 Access to and Establishment of Controlled Areas Under

Emergency Conditions 8 Alternate Personnel Decontamination Facilities

27 Instructions for Field Monitoring Teams 15 Calculation of Release Rate 19 Protective Action Recommendations 14 Emergency Offsite Dose Calculations 11 Plant Vent Iodine and Particulate Sampling During Accident

Conditions 9 Core Damage Assessment Procedure 2 Initial Detection of Fuel Cladding Damage 15 Post Accident Sampling System 13 Operating Instructions for the EARS Computer Program 33 Release of Airborne Radioactive Materials Initial Assessment 9 Release of Radioactive Liquids

16A Off-Site Transportation Accidents 51 Activation and Operation of the Technical Support Center 37 Activation and Operation of the Operational Support Center 43 Activation and Operation of the Emergency Operations Facility 20 Activation of the Off-Site Emergency Laboratory 11 Backup Emergency Response Facilities 16 Activation and Operation of the Joint Information Center

2 Alternate Emergency Response Facilities I Incident Command Post (ICP)

*Revised Document

Page 1 of 1

.,

Summary of the Analysis of Changes to


Emergency Plan Implementing Procedure OM1 O.DC1, Revision 8

Emergency Preparedness Drills and Exercises

# Revision 7 Content Revision 8 Content

1 Section 4.5.1 Section 4.5.1

Operations and fire protection Fire department management is group are responsible for: responsible for:

Scheduling, developing, and Scheduling, developing, and conducting fire drills to meet conducting fire drills to meet Fire FSAR Appendix 9.5H Protection Program requirements as requirements. defined in OMS, "Fire Protection

Program," and described in TQ1.DC12, "Fire Brigade and Emergency Response Training."

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Reason/Impact of Change

Process change with change of intent.

This change is being made in support of the new fire protection (FP) licensing basis, which complies with the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c) and the guidance in Regulatory Guide 1.205, Revision 1, "Risk-informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants." Federal Regulation 10 CFR 50.48(c) incorporates by reference NFPA 805. On April14, 2016, the NRC issued Amendments No. 225 and No. 227 to transition the Diablo Canyon Power Plant (DCPP) FP Program to a risk informed, performance-based program based on NFPA 805. The NFPA 805-based FP Program will supersede the current FP Program licensing basis which is based on 1 0 CFR 50, Appendix R and Appendix A to Branch Technical Position (APCSB) 9.5-1.

This change updates Plant Procedure OM1 O.DC1 to accurately reference the new FP Program licensing basis and ensure the procedure is technically accurate. Plant Procedure TQ1.DC12 was reviewed against Final Safety Analysis Report (FSAR) Appendix 9.5H and it was determined that fire drill capability will be maintained.

!

# Revision 7 Content

2 Section 5.1.3.a

Conduct offsite emergency response exercises biennially with full participation by California state and San Luis Obispo county. Rotate other organizations' (federal, municipalities, and private) participation over the drill cycle period.

3 Note for Section 5.1.3.b

NOTE: The 16 year requirement for ingestion pathway exercises is based on the requirement for the state to participate in an ingestion pathway exercise once per cycle, and to rotate between ingestion pathway EPZs within the state (California has two such EPZs).

Revision 8 Content

Section 5.1.3.a

Conduct offsite emergency response exercises biennially with full participation by the State of California and San Luis Obispo County. Rotate other organizations' (federal, municipalities, and private) participation over the drill cycle period .

N/A- Content removed.

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Editorial change with no change of intent.

Editorial correction - no change of intent.

Process change with no change of intent.

Note removed as it is no longer applicable. DCPPn is the last operating nuclear power plant in California; therefore, there is only one ingestion pathway emergency planning zone (EPZ) within the state. DCPP will now have an ingestion pathway exercise every cycle (every 8 years).

I

I


4 Section 5.1.3.b

Ingestion pathway exercises should be conducted at least once every 16 years.

5 Section 5.1.3.b.1

The California Emergency Management Agency (CEMA) and the California Department of Public Health should have full participation in these exercises.

Revision 8 Content

Section 5.1.3.b

Ingestion pathway exercises shall be conducted at least once every exercise cycle.

Section 5.1.3.b.1

The California Office of Emergency Services and the California Department of Public Health should have full participation in these exercises.

----

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Enclosure 3 PG&E Letter DCL-16-076 PG&E Letter D I L-16-0 11


Process change with no change of intent.

Revised OM10.DC1 to accurately document that an Ingestion Pathway Zone Exercise (IPX) shall be conducted every exercise cycle. DCPP is the last operating nuclear power plant in California; therefore, there is only one ingestion pathway EPZ within the state. DCPP will now have an ingestion pathway exercise every cycle (every 8 years).


Editorial correction to reference current title. This update ensures procedure remains technically accurate. No change of intent.


6 I Section 5.1.4

NOTE: In addition to communications drills, telecommunications checks among the CR, San Luis Obispo Sheriff's office, and CEMA are conducted weekly per STP 1-29.

• Test communications with San Luis Obispo County Sheriff and CEMA response centers monthly.

7 I Section _5.3.1, Table 1

Augmentation Drill (Off Hours Unannounced) (C)

Emergency Facility Back-up Power Drill

Ingestion Pathway Exercise (2C(3))

Fire DriiiT36232 (4)

(4) Per FSAR A__12_2_endix 9.5H.

Revision 8 Content

Section 5.1.4

NOTE: In addition to communications drills, telecommunications checks among the CR, San Luis Obispo Sheriff's office, and California Office of Emergency Services are conducted weekly per STP 1-29.

• Test communications with San Luis Obispo County Sheriff and California Office of Emergency Services response centers monthly.

Section 5.3.1, Table 1

Augmentation Drill (C) Off Hours Drill (between 1800 - 0400 hours) (C) Unannounced Drill (C) Emergency Power Drill Ingestion Pathway Zone Exercise (IPX) (C(3)) Fire D ri 11 T362321T36ao3 ( 4)

(4) Per Fire Protection Program as defined in OM8 and described in TQ1.DC12.

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Process change with change of intent.

Separated augmentation, off hours, and unannounced drill to more accurately depict drill requirements.

Updated the frequency for ingestion pathway exercises to reflect the current requirement. San Onofre (SONGS) is decommissioning; therefore, DCPP is required to have an IPX every cycle/8 years as opposed to every 2 cycles/16 years.

Revised footnote (4) in support of the new fire


(5) Emergency Facility Back- (5) Emergency power drill where a part up Power Drill is performed of plant safety systems (e.g. Technical under EP MT-29, "Emergency Support Center (TSC)) should provide Operations Facility (EOF)" opportunity for ERO to demonstrate the

tasks needed to be able to use available backup power capabilities (i.e., actions required to transfer power, start diesels, plug in uninterruptible

*Note that only applicable power supplies, etc.) sections of the table are displayed above.

*Note that only applicable sections of the table are displayed above.

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protection (FP) licensing basis, which complies with the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c) and the guidance in Regulatory Guide 1.205, Revision 1, "Risk-informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants." Federal Regulation 10 CFR 50.48(c) incorporates by reference NFPA 805. On April14, 2016, the NRC issued Amendments No. 225 and No. 227 to transition the DCPP FP Program to a risk informed, performance-based program based on NFPA 805. The NFPA 805 based FP Program will supersede the current FP Program licensing basis, which is based on 1 0 CFR 50, Appendix R and Appendix A to Branch Technical Position (APCSB) 9.5-1.

Revised Emergency Facility Back-up Power Drill and corresponding footnote (5) to clarify responsibilities and intent. The emergency facility backup power drill was added to OM10.DC1 in Revision 6, issued June 19, 2012. The emergency facility backup power drill was originally required in response to NRC Inspection Procedure (IP) 82302 6-year drill cycle. It is now part of the IP 71114 8-year cycle, specifically IP71114.08 Element 13. This element is also referenced in NUREG 0737, Supplement 1, 8.2.1. The new


8 Section 5.3.3 (3ra bullet) Section 5.3.3 (3rd bullet)

California Emergency California Office of Emergency Management Agency Services

9 Section 5.4.4, Table 2 Section 5.4.4, Table 2

<1 0 Verify participant lists. <1 0 Ensure participant lists are accurate.

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language clarifies what should be tested to meet the requirements discussed in IP71114.08 and NUREG 0737, Supplement 1. Further information is documented in SAPN 50818611.

This change updates OM1 O.DC1 to accurately reference the current drill requirements. This ensures that the procedure is technically accurate.




Replaced "verify" with "ensure" in alignment with writer's guide requirements.

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