Text

Emergency Plan Update
	ML23348A138
Person / Time
Site:	Diablo Canyon
Issue date:	12/13/2023
From:	Warwick A; Pacific Gas & Electric Co
To:	; Division of Fuel Management, Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
	DCL-23-128, DIL-23-010
	Download: ML23348A138 (1)
	v • d • e

mPacHic Gas and Electric Company*

Andrew M. Warwick Manager Nuclear Emergency Planning Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 805.545.3865 Andrew.Warwick@pge.com PG&E Letter DCL-23-128 PG&E Letter DIL-23-010 U.S. Nuclear Regulatory Commission 10 CFR 50.54 ATTN: Document Control Desk 10 CFR 72.32 Washington, DC 20555-0001 10 CFR 72.44(f)

Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-001 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 Update

Dear Commissioners and Staff:

In accordance with the requirements of 10 CFR 50.54, 10 CFR 72.32, and 10 CFR 72.44(f), Pacific Gas and Electric Company (PG&E) is providing a summary of the analysis of changes to the Diablo Canyon Power Plant Emergency Plan (E- Plan). The E-Plan continues to meet the requirements in Appendix E of 10 CFR 50 and the standards of 10 CFR 50.47(b). This revision makes updates and enhancements as documented in the enclosures listed below:

Enclosure 1 - Diablo Canyon Power Plant Emergency Plan Table of Contents

Enclosure 2 - Summary of the Analysis of Changes in Emergency Plan Appendix E, Revision 5.00, Evacuation Time Estimates

Enclosure 3 - Summary of the Analysis of Emergency Plan Appendix G, Revision 5.00, Protective Action Recommendation (PAR) Strategy Bases

Enclosure 4 - Current revision of Emergency Plan Appendix E, Revision 5.00, Evacuation Time Estimates

Enclosure 5 - Current revision of Emergency Plan Appendix G, Revision 5.00, Protective Action Recommendation (PAR) Strategy Bases

Enclosure 6 - Diablo Canyon Power Plant Emergency Plan Implementing Procedures

Enclosure 7 - Summary of the Analysis of changes in EP G-3 Revision 64 Emergency Notification of Off-Site Agencies.

A member of the STARS Alliance Callaway

Diablo Canyon

Palo Verde

Wolf Creek

Document Control Desk PG&E Letter DCL.:23-128 Page2 PG&E Letter DIL-23-010

Enclosure 8 - Summary of the Analysis of changes in EP RB-10 Revision 22 "Protective Action Recommendations."

This update does not contain any privacy or proprietary information in accordance with NRG 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) 545-3865.

Sincerely, Andrew M. Warwick Date Manager, Nuclear Emergency Planning GJRb/51215083, 51215084, 51215085, 512150836-Enclosures cc/enc: Kristina Banovac, NMSS Project Manager Mahdi 0. Hayes, NRG Senior Resident Inspector Sean D. Hedger, Senior Emergency Preparedness Inspector, NRG Region IV Samson S. Lee, NRG Project Manager John Monninger, NRG Region IV Administrator A member of the STARS Alliance Callaway

Diablo Canyon

Palo Verde

Wolf Creek

Enclosure 1 PG&E Letter DCL-23-128 PG&E Letter DIL-23-010 DIABLO CANYON POWER PLANT EMERGENCY PLAN Table of Contents Doc. No. Rev. Title E-Plan Coversheet 4.01 Emergency Plan E-Plan Table of 4.05 Table of Contents Contents E-Plan Section 1 5.01 Definitions and Acronyms E-Plan Section 2 4.05 Scope and Applicability E-Plan Section 3 4.00 Summary of Emergency Plan E-Plan Section 4 5.01 Emergency Conditions E-Plan Section 5 5.01 Organizational Control of Emergencies E-Plan Section 6 5.00 Emergency Measures E-Plan Section 7 5.03 Emergency Facilities and Equipment E-Plan Section 8 4.17 Maintaining Emergency Preparedness E-Plan Section 9 4.02 Recovery E-Plan Section 10 4.03 References E-Plan Appendix A 4.08 Procedures E-Plan Appendix B 4.02 Offsite Agency Support Documents E-Plan Appendix C 4.00 Non-Applicable NUREG-0654 Standards E-Plan Appendix D 5.04 Emergency Action Level Technical Basis Manual E-Plan Appendix E* 5.00 Evacuation Time Estimates E-Plan Appendix F 5.01 ERO On-Shift Staffing Analysis Report E-Plan Appendix G* 5.00 Protective Action Recommendation (PAR)

Strategy Bases

Revised Document

Enclosure 2 PG&E Letter DCL-23-128 PG&E Letter DIL-23-010 Summary of the Analysis of Changes in Emergency Plan Appendix E, Revision 5.00, Evacuation Time Estimates

2022 ETE Update Change Table - Emergency Plan Appendix E Change Original Content (Rev 4.00) Revised Content (Rev 5.00) Description of Change 1 In order to ensure the safety of the public living In order to ensure the safety of the public living Updated date to align with the latest ETE in the vicinity of nuclear power plants in the in the vicinity of nuclear power plants in the Report.

nation, the U.S. Nuclear Regulatory nation, the U.S. Nuclear Regulatory This change does not affect how the current E-Commission (NRC) requires licensees to Commission (NRC) requires licensees to Plan meets any planning standard functions, develop and update evacuation times develop and update evacuation times elements, or site-specific commitments. No estimates (ETEs) for areas within the estimates (ETEs) for areas within the additional evaluation required emergency planning zone (EPZ). Updates are emergency planning zone (EPZ). Updates are required following the availability of data from required following the availability of data from the decennial census (10 years) or when the the decennial census (10 years) or when the sensitivity factor for changes in population sensitivity factor for changes in population within the EPZ has been exceeded. This within the EPZ has been exceeded. This appendix contains information from the ETE appendix contains information from the ETE update performed in 2012. This update update performed in 2022. This update implements the requirements of the revised implements the requirements of the revised regulations relevant to ETE updates in regulations relevant to ETE updates in accordance with the guidance provided in accordance with the guidance provided in NUREG/CR-7002, Criteria for Development of NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies. Evacuation Time Estimate Studies.

2 Pacific Gas and Electric (PG&E) contracted Pacific Gas and Electric (PG&E) contracted Updated date for the 2020 census data used KLD Engineering, P.C to estimate evacuation KLD Engineering, P.C to estimate evacuation in the 2022 ETE Report.

times for the 20101 populations within the times for the 20201 populations within the plume exposure pathway emergency planning plume exposure pathway emergency planning Updated KLD report ID to align with the 2022 zone (EPZ) (reference Figure E-1) surrounding zone (EPZ) (reference Figure E-1) surrounding ETE Report.

the Diablo Canyon Power Plant (DCPP). This the Diablo Canyon Power Plant (DCPP). This appendix provides a summary of the final appendix provides a summary of the final Editorial change to the footnote page report describing the methods used to obtain report describing the methods used to obtain reference.

population data and estimated population population data and estimated population This change does not affect how the current E-figures, evacuation road network information, figures, evacuation road network information, Plan meets any planning standard functions, and ETEs. and ETEs. elements, or site-specific commitments. No additional evaluation required Footnote 1: KLD report TR-498, pages 1-9 and Footnote 1: KLD report TR-1235, pages 1-10 10 contain the population figures provided on contain the population figures provided on this this page. page.

Page 1 of 14 Internal

2022 ETE Update Change Table - Emergency Plan Appendix E Change Original Content (Rev 4.00) Revised Content (Rev 5.00) Description of Change 3 The report provides a breakdown of the The report provides a breakdown of the Updated date for the 2020 census data used population by geographic areas and protective population by geographic areas and protective in the 2022 ETE Report.

action zones (PAZ). Five categories of action zones (PAZ). Five categories of population are identified in the report: population are identified in the report: Updated population estimate to align with the

Permanent residents

Permanent residents 2022 ETE Report.

Transient population

Transient population Refer to 10 CFR 50.54(q) effectiveness

Transit dependent permanent residents

Transit dependent permanent residents evaluation 2023-14 for evaluation of the 2022

Special facility residents

Special facility residents ETE report

Schools

Schools The permanent resident population is made up The permanent resident population is made up of individuals residing in the EPZ. The total of individuals residing in the EPZ. The total year 2010 permanent resident populations year 2020 permanent resident populations within the EPZ for DCPP are estimated to be within the EPZ for DCPP are estimated to be 147,221 (reference Table E-1). 152,149 (reference Table E-1).

4 The transient population consists of workers The transient population consists of workers Updated population estimates to align with the employed within the area, recreational employed within the area, recreational 2022 ETE Report.

sportsmen, and visitors. The total peak sportsmen, and visitors. The total peak transient population within the EPZ is transient population within the EPZ is Updated number of schools to align with the estimated to be 30,935. Sixty-five schools estimated to be 41,056. Sixty-one schools 2022 ETE Report.

were identified in the DCPP EPZ. KLD were identified in the DCPP EPZ. KLD Refer to 10 CFR 50.54(q) effectiveness Engineering, P.C. contacted the schools to Engineering, P.C. contacted the schools to evaluation 2023-14 for evaluation of the 2022 collect current enrollment, staff figures, and collect current enrollment, staff figures, and ETE report the evacuation plan. The total peak population the evacuation plan. The total peak population for the schools in the EPZ is estimated to be for the schools in the EPZ is estimated to be 50,863. 52,804.

5 Transit dependent permanent residents in the Transit dependent permanent residents in the Updated population estimates to align with the EPZ are estimated to be 3,402. This study EPZ are estimated to be 1,512. This study 2022 ETE Report.

also considered the voluntary evacuees, who also considered the voluntary evacuees, who are also known as shadow evacuees that are also known as shadow evacuees that Updated date for the 2020 census data used reside within approximately 20 miles from reside within approximately 20 miles from in the 2022 ETE Report.

DCPP. KLD Engineering, P.C. used a DCPP. KLD Engineering, P.C. used a computer traffic simulation model, DYNEV II, computer traffic simulation model, DYNEV II, Updated number of scenarios to align with the to perform the ETE analyses. For the to perform the ETE analyses. For the latest ETE Report.

analyses, the plume exposure pathway EPZ analyses, the plume exposure pathway EPZ Refer to 10 CFR 50.54(q) effectiveness was divided into 12 zones with unique was divided into 12 zones with unique evaluation 2023-14 for evaluation of the 2022 geographic areas including two-mile, six-mile, geographic areas including two-mile, six-mile, ETE report and the EPZ radius rings, as well as staged and the EPZ radius rings, as well as staged evacuation logic. In order to represent the evacuation logic. In order to represent the most realistic emergency scenarios, most realistic emergency scenarios, evacuations for the 12 geographic PAZs were evacuations for the 12 geographic PAZs were Page 2 of 14 Internal

2022 ETE Update Change Table - Emergency Plan Appendix E Change Original Content (Rev 4.00) Revised Content (Rev 5.00) Description of Change modeled individually for the midweek daytime, modeled individually for the midweek daytime, midweek - weekend evening, and weekend midweek - weekend evening, and weekend daytime scenarios. Each of these scenarios daytime scenarios. Each of these scenarios was then considered under both normal and was then considered under both normal and adverse weather conditions using the 2010 adverse weather conditions using the 2020 population estimates. A total of 312 evacuation population estimates. A total of 300 evacuation scenarios were considered as part of this scenarios were considered as part of this study to represent different time of day, staged study to represent different time of day, staged evacuation, temporal, seasonal and weather evacuation, temporal, seasonal and weather conditions (reference Table E-2). conditions (reference Table E-2).

6 Both 100% (Reference Table E-4) and 90% Both 100% (Reference Table E-4) and 90% Removed wording that simply repeated (Reference Table E-3) ETEs for each scenario (Reference Table E-3) ETEs for each scenario information provided in tables E-3 and E-4.

were collected. The 100% ETEs for the were collected. Table E-5 defines each of the The description does not provide any evacuation areas ranged from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 10 25 Evacuation Regions in terms of their additional information or analysis of the data hours and 15 minutes for the normal scenarios respective groups of PAZ and wind direction, that is not available in the tables. The of the 2-mile radius evacuation to full EPZ as applicable. summarization provided in this section is not evacuation and from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months and needed to establish the results of the ETE 35 minutes (same range of scenarios) for Report.

those occurring in adverse weather. The 90%

ETEs for the evacuation areas ranged from 1 Added reference to new Table E-5 which hour to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and 5 minutes of the 2-mile defines each of the 25 Evacuation Regions.

radius evacuation to full EPZ evacuation for Table E-5 provides wind direction information the normal scenarios, and from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 9 and evacuation region descriptions previously hours and 10 minutes (same range of provided in Tables E-3 and E-4. Table E-5 scenarios) for those occurring in adverse also provides detail on the ordering and types weather. of evacuations used in each evacuation region.

Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-14 for evaluation of the 2022 ETE report 7 Based on the data gathered and the results of Based on the data gathered and the results of Updated date to align with the 2022 ETE the evacuation simulations, the existing the evacuation simulations, the existing Report.

evacuation strategy was determined to be evacuation strategy was determined to be This change does not affect how the current E-functional for the 2012 conditions. functional for the 2022 conditions. Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required 8 Figure E-1: DCPP EPZ PAZs Figure E-1: DCPP EPZ PAZs Updated EPZ map as provided in the 2022 ETE Report. New image is in color and higher resolution. The image provides the same Page 3 of 14 Internal

2022 ETE Update Change Table - Emergency Plan Appendix E Change Original Content (Rev 4.00) Revised Content (Rev 5.00) Description of Change information and level of detail as the original image.

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

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9 Table E 1. EPZ Permanent Resident Table E 1. EPZ Permanent Resident Updated table to provide results from the Population Population updated ETE Report. 2020 census data is now compared to 2010 data as those are the two most recent decennial census years.

Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-14 for evaluation of the 2022 ETE report Page 4 of 14 Internal

2022 ETE Update Change Table - Emergency Plan Appendix E Change Original Content (Rev 4.00) Revised Content (Rev 5.00) Description of Change 2000 2010 PAZ 2010 2020 PAZ Pooulation Pooulation Pooulation Pooulation 1 2 0 1 0 0 2 168 168 2 168 160 3 2,069 273,6 3 2,736 2,846 4 637 713 4 713 521 5 14,661 14 217 5 14,217 14,485, 6 7,760 6,562 6 6,562 7,1 70 1 56 28 1 1 28 1 85 8 57,320 60,962 8 60,962 63,286 9 13,502 13 126 9 13,126 13,733 10 36,060 37,476 10 37,476 38,380 111 3,481 4 205 11 4,205 4,454 12 4,94l1 6,775 12 6,775 7,029 TOTAL 1140657 147 221 TOTAL 1147,221 152,149 EPZ Population Growtlil: 4 ..67% EPZ Pooulation Growth : 3..35,%

10 Table E-2. Evacuation Scenario Definitions, Table E-2. Evacuation Scenario Definitions, Updated table and added footnote 3 to align Scenario 12 Scenario 12 with the 2022 ETE Report.

This change does not affect how the current E-Firework Shows at Avila Beach, Pismo Beach, Firework Shows at Avila Beach3, Pismo Plan meets any planning standard functions, and Morro Bay Harbor Beach, and Morro Bay Harbor elements, or site-specific commitments. No additional evaluation required 3 Transients present at Avila Beach to observe the fireworks show at Pismo Beach 11 Table E-3. Time to Clear the Indicated Area of Table E-3. Time to Clear the Indicated Area of Updated table to provide results from the 90 Percent of the Affected Population 90 Percent of the Affected Population updated ETEs provided in the 2022 ETE Report. The updated report uses the same 12 See Addendum A See Addendum A scenarios however the evacuation regions are modified with different numbering as well as some additional regions. The "Description or Wind Direction From" column has been removed and the information is now located in Table E-5 (see change 13).

Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-14 for evaluation of the 2022 ETE report Page 5 of 14 Internal

2022 ETE Update Change Table - Emergency Plan Appendix E Change Original Content (Rev 4.00) Revised Content (Rev 5.00) Description of Change 12 Table E-4. Time to Clear the Indicated Area of Table E-4. Time to Clear the Indicated Area of The "Description or Wind Direction From" 100 Percent of the Affected Population 100 Percent of the Affected Population column has been removed and the information is now located in Table E-5 (see change 13).

See Addendum A See Addendum A Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-14 for evaluation of the 2022 ETE report 13 N/A, added content Table E-5: Description of Evacuation Regions Added Table E-5 which defines each of the 25 Evacuation Regions. Table E-5 provides wind See Addendum A direction information previously provided in Tables E-3 and E-4 along with additional evacuation region detail.

Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-14 for evaluation of the 2022 ETE report Page 6 of 14 Internal

2022 ETE Update Change Table - Emergency Plan Appendix E Addendum A Change 11 - Original Content - Table E-3 Table E-,3. lime to Ctear the Indicated Area of ill. Peroent of the Affected Po:pulatlon Summ@il' Summer Summer Winter Winter Winter Summer Summer Midweek Midweek Midweek IMldweei Weekend MTdwee~ wee~encl Midweek Weekend We-e~end Weekend Scenario: (1) 12) (3) (41 fS) (6) (7) (81 (9) (10) (11) (12)

Description Midday !Midday Evening Midday Midday Evening EveninR Mid'day or Wind Direction Region Good Ra in, Good Rain Good Good Rain, Good Rain Geod Spedal Roadwav wea,ther Weather Weathe:r Weather weather Weather Event lmpar:t From:

ROI z~Mrte Ring (PAZ 1)1 1:00 1.:00 1:.0 0 il0O 1:00 :00 1:00 l:-00 1:00 :l!.:00 1:00 1:00 R02

&-<Mile Ring 1:10 1:10 1:10 1:10 1:1s 1:10 1:10 l:15 1:15 1:20 1:15 1:10 (PAZ 1, 2)

ROS i!::55 3:1:0 2:50 3:05 2:45 2:SS I 3::1!.0 2:4:S 3:0S 2:45 2:45 2:SO

{PAZ 1,2, 5)

SSE,S R09 4:05 4:25 4:0'5 4:15 3:40 3:55 4:15 3:45 3::SS 3:'30 4:35 4:15

,(PAZ 1, 2, 5,. 91 R06 I I 2::SS 3:1S 2:SS 3:10 2:50 2:SS 3:10 2:50 3:05 2:50 2:45 2:55

{PAZ 1, 2, 4,. SI, SSE, SW IRlO (PAZ ll, 2, 4, .S, 5:55 6:10 5:25 S:30 5:05 ' 5:40 6:00 4:55 5:2*0 4:50 5:35 6:30 I

8,9),

IR03 (PAZ ll, 2, 3, 4, 2:45 3:00 2:45 3:00 2:50 2:SO 3:05 .2:45 2:55 2:45 6'.15 3:.45 SJ, R11 WSW (?AZ 1, 2, 3, 4, 6:05 6:55 5:25 6:10 4:55 6:15 6:25 5:00 S:45 4:55 7:05 7:30 s, 1 8. 9}

R1*4 (PAZ 1, 2., 3, 4,. 6:25 7:00 5 :45 6:00 5:10 6:25 6:55 5:30 6:05 S:00 7:05 7:9:5 I s, 1, .a, 9, 10 R201 w (PAZ 1, i, 4. 8) 4:40 5:05 3:55 4 :30 3:40 4:30 4:55 3:40 4: 0 3:40 4:-50 6:.00 Note: The R des:ig;nutfons in the second column are references used withir1 the KlO re,port and provid,ed for ease of cross-refernrn:e.

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2022 ETE Update Change Table - Emergency Plan Appendix E Table E-3. Time to Clear the Indicated Area of 90 Percent of the Affected Population (continued)

R07 1:25 1:40 1:40 6:40 2:45 1:35 1:45 1:25 1:40 1:35 1:35 1:40 (PAZ 1, 2, 3, 4)

R12 (PAZ 1, 2, 3, 4, 5:35 6:00 4:45 5:20 4:10 5:25 5:55 4:25 4:55 4:05 10:55 7:15 6, 7, 8)

RlS W,WNW 8:10 6:30 7:00 5:45 11:15 9:45 (PAZ 1, 2, 3, 4, 7:45 8:20 6:55 7:25 6:00 7:25 6, 7, 8, 10, 11)

R17 (PAZ 1, 2, 3, 4, 7:25 6:10 11:20 10:30 8:00 8:45 7:25 8:00 6:20 7:50 8:35 6:50 6, 7, 8, 10, 11, 12)

R18 NW (PAZ 1, 2, 3, 6, 6:20 7:00 6:30 6:40 5:30 6:10 6:45 5:40 6:15 5:20 9:45 8:35 7, 10, 11, 12)

ROS 1:35 6:35 2:50 1:40 1:45 1:25 1:35 1:30 1:35 1:40 1:25 1:30 (PAZ 1, 2, 3)

R13 (PAZ 1, 2, 3, 6, 2:35 2:55 2:25 2:35 2:05 2:25 2:35 2:15 2:25 2:00 9:50 3:55 NW, NNW 7)

R16 (PAZ 1, 2, 3, 6, 5:55 6:20 5:40 6:15 5:00 5:25 6:00 5:10 5:35 4:50 9:40 7:45 7, 10, 11)

NNW, N, NNE, R19 3:05 3:55 NE, ENE, E, 2:45 3:05 2:35 2:50 , 2:20 2:40 3:00 2:30 2:45 2:20 (PAZ 1, 2, 12)

ESE, SE R04 (PAZ 1, 2, 3, 4, 11:40 10:25 Full EPZ 8:20 9:10 7:30 8:15 6:45 8:05 8 :50 7:05 7:45 6:30 5, 6, 7, 8, 9, 10, 11, 12)

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2022 ETE Update Change Table - Emergency Plan Appendix E Change 11 - Revised Content - Table E-3 Table E-3. Time to Clear the Indicated Area of 90 Percent of the Affected Population Summer Summer Summer Winter Winter Winter Summer Summer Midweek Midweek M idweek Midweek Weekend Midweek Weekend Midweek Weekend Weekend Weekend Scenario: {1} (2) (3) (4) (5) (6) (7) (8) (9) (10} (11) (12)

Midday Midday Evening Midday Midday Evening Evening Midday Region Good Good Good Good Good Good Special Roadway Rain Rain Rain Rain Weather Weather Weather Weather Weather Weather Event Impact Entire 2-Mile Region, 6-Mile Region, FEMA EPZ and Full EPZ R01(PAZ1) 1: 00 1:0 0 1 :00 1 :00 1 :00 1:0 0 1:0 0 1:00 1:00 1 :00 1 :00 1:00 R02 (PAZ 1, 2) 1:15 1 :15 1:30 1:30 1 :25 1 :15 1:15 1:45 1:45 1 :30 1:25 1:15 R03 (PAZ 1, 2, 3, 4, 5) 3:00 3 :15 2 :50 3:00 3:00 3 :00 3:10 2:45 3 :00 2:55 3:15 3:35 R04 (PAZ 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12) 8:40 9:35 8:15 9:05 8:20 9:10 10:05 7:55 8:4 5 8:10 14:30 11:05 6-Mile Riing and Keyhole to FEMA EPZ ROS (PAZ 1, 2, 5) 3:05 3:20 3 :00 3:25 3:05 3 :10 3:20 3:0 0 3 :25 3:00 3:05 3:05 R06 (PAZ 1, 2, 4, 5) 3:10 3:30 3 :05 3:20 3:10 3 :10 3:25 3:05 3 :20 3:05 3:15 3:30 R07 (PAZ 1, 2, 3, 4) 2:00 2:05 1 :45 1 :55 1 :55 1 :55 2:05 1:50 2 :00 2:05 3:05 3:40 R08 (PAZ 1, 2, 3) 1:55 2:05 1:4 5 1 :55 1 :45 2:0 0 2:05 1:45 1:55 1 :55 3:05 3:35 Evacuate 6-Mile Radius and Downwind to Full EPZ Boundary R09 (PAZ 1, 2, 5, 9) 4: 15 4:20 4:0 5 4 :20 4:00 4:0 5 4:25 3:50 4:10 4:00 5:55 4:15 R10 (PAZ 1, 2, 4, 5, 8, 9) 5:30 6 :15 4 :40 5:35 5:00 6 :05 6:50 4:50 5 :20 4:50 7:15 7:00 R11 (PAZ 1, 2, 3, 4, 5, 8, 9) 5:20 6 :05 4 :50 5:15 4:35 6 :10 6:55 4:45 5:15 4:35 7:30 7:00 R12 (PAZ 1, 2, 3, 4, 5, 7, 8, 9,. 11} 5:35 6 :00 4:55 5:30 4:40 6 :15 7:05 5:00 5 :40 4:40 7:30 7:00 R13 (PAZ 1, 2, 3, 4, 6, 7, 8, 10, 11, 12) 8:40 9 :20 8:0 5 9 :15 8:40 8 :25 9:20 7:40 8 :25 8:00 13:50 12:00 R14 (PAZ 1, 2, 3, 6, 7, 10, 11, 12) 6:40 7:25 7 :00 7:40 7:10 6:4 5 7:35 6:20 7:10 6:30 12:45 10:15 R15 (PAZ 1, 2, 3, 10, 12) 5:55 6 :40 5 :50 6:35 6:20 5 :35 6:40 5:30 6 :10 5:35 7:25 9:00 Site Specific Regions R16 (PAZ 1, 2, 4) 1:50 1 :50 2 :10 2:10 2:15 1:50 1:50 2:25 2:25 2:20 2:15 1:50 R17 (PAZ 1, 2, 3, 6) 2:55 3:10 2 :55 3:15 2:45 2 :45 3:05 2:40 2 :55 2:25 9:20 5:10 IR18 (PAZ 3, 4) 1:55 2:05 1 :45 1 :55 1 :55 2 :00 2:05 1 :45 1 :55 2:05 3:05 3:45 R19 (PAZ 4, 5) 3:10 3:25 3:0 0 3:20 3:05 3:15 3:25 3:0 0 3:20 3:00 3:05 3:15 Sta~ed Evacuation Mile Radius Evacuates, then Evacuate Downwind to 6 Miles IR20 (PAZ 1, 2) 1:15 1 :15 1 :30 1 :30 1 :30 1 :15 1:15 1 :45 1 :45 1:30 1 :30 1:15 Staged Evacuation Mile Radius Evacuates, then Evacuate Downwind to FEMA EPZ R21 (PAZ 1, 2, 5) 3:40 4 :10 3 :35 3:50 3:35 3 :40 4:00 3:35 3 :55 3:35 3:40 3:45 R22 (PAZ 1, 2, 4, 5) 3:45 4 :00 3 :40 3:55 3:40 3 :45 4:05 3:40 4:05 3:40 3:40 3:45 R23 (PAZ 1, 2, 3, 4, 5) 3:25 3:40 3:25 3:35 3:30 3:30 3:40 3:25 3 :40 3:30 3:30 4:00 R24 (PAZ 1, 2, 3, 4) 2:05 2:10 1:55 2:00 2:05 2:0 5 2:05 2:00 2 :00 2:10 3:05 3:35 R25 (PAZ 1, 2, 3) 2:00 2:05 1 :55 2:00 2:00 2 :00 2:05 2:0 0 2 :00 2:05 3:10 3:35 Page 9 of 14 Internal

2022 ETE Update Change Table - Emergency Plan Appendix E Change 12 - Original Content - Table E-4 Table E-4. Time to Clear the Indicated Area of 100 Percent of the Affected Population Summer Summer Summer Winter Winter Winter Summer Summer Midweek Midweek Midweek Midweek Weekend Midweek Weekend Midweek Weekend Weekend Weekend Scenario: (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12)

Description Midday Midday Evening Midday Midday Evening Evening Midday or Wind Good Good Special Roadway Region Good Good Good Good Direction Rain Rain Rain Rain Weather Weather Weather Weather Weather Weather Event Impact From:

ROl 2:00 2:00 2:00 2:00 2:00 2:00 2:00 2-Mile Ring 2:00 2:00 2:00 2:00 2:00 (PAZ 1)

R02 4:35 4:35 4:35 4:35 4:35 6-Mile Ring 4:35 4:35 4:35 4:35 4:35 4:35 4:35 (PAZ 1, 2)

ROS 4:40 4:40 4:40 4:40 4:40 4:40 4:40 4:40 4:40 4:40 4:40 4:40 (PAZ 1, 2, 5)

SSE, S R09 5:30 4:50 5:05 4:45 5:35 5:25 5:15 5:45 5:10 5:30 4:45 5:05 (PAZ 1, 2, 5, 9)

R06 4:40 4:40 4:40 4:40 4:40 4:40 4:40 4:.40 4:40 4:40 4:40 4:40 (PAZ 1, 2, 4, 5)

SSE,SW RlO (PAZ 1, 2, 4, 5, 8:00 8:25 7:25 7:45 6:45 7:45 8:25 6:50 7:25 6:40 7:35 8 :15 8, 9) .

R03 (PAZ 1, 2, 3, 4, 4:40 4:40 4:40 4:40 4:40 4:40 4:40 4:40 4:40 4:40 9:20 5:00 5)

Rll WSW (PAZ 1, 2, 3, 4, 8:00 8:40 7:20 7:55 6:50 7:45 8:20 7:00 7:35 6:45 13:20 9:00 5, 7, 8, 9)

R14 (PAZ 1, 2, 3, 4, 8:00 8:45 7:15 7:40 6:55 7:55 8:40 7:00 7:30 6:50 12:55 9:15 5, 7, 8, 9, 11)

R20 5:55 5:00 6:15 7:45 w (PAZ 1, 2, 4, 8) 6:35 7:10 5:20 6:10 5:05 6:25 7:00 5:10 Note: The R designations in the second column are references used within the KLD report and provided for ease of cross-reference.

Page 10 of 14 Internal

2022 ETE Update Change Table - Emergency Plan Appendix E Table E-4. Time to Clear the Indicated Area of 100 Percent of the Affected Population (continued)

R07 4:40 4:40 4:40 4:40 9:20 4:40 4:40 4:40 4:40 4:40 4:40 4:40 (PAZ 1, 2, 3, 4)

R12 (PAZ 1, 2, 3, 4, 7:25 7:50 6:15 6:55 5:35 7:15 7:55 5:55 6:35 5:30 16:35 8 :40 6, 7, 8)

RlS W,WNW 9:35 10:25 8 :55 9:30 8:20 17:45 12:45 (PAZ 1, 2, 3, 4, 9':40 10:25 9:50 10:45 8:30 6, 7, 8, 10, 11)

R17 (PAZ 1, 2, 3, 4, 9:35 10:15 9:00 18:30 13:20 10:15 11:00 10:15 11:25 9 :10 10:05 10:45 6, 7, 8, 10, 11, 12)

R18 NW (PAZ 1, 2, 3, 6,

9:40 10:30 9:45 10:35 8:20 9:05 9:45 8:35 9:30 7:50 16:25 11:00 7, 10, 11, 12)

ROS 4:40 4:40 4:40 4:40 4:40 8:25 4:40 4:40 4:40 4:40 4:40 4:40 (PAZ 1, 2, 3)

R13 (PAZ 1, 2, 3, 6, 4:45 4:45 4 :45 4:45 4:45 4:45 4:45 4:45 4:45 4:45 15:55 5:15 NW,NNW 7}

R16 (PAZ 1, 2, 3, 6, 8:55 10:00 9:00 9:50 7:35 7:55 8:30 8:05 8:30 7:00 16:05 10:10 7, 10, 11)

NNW, N, NNE, NE, R19 4:50 4:50 4:50 4:50 4:50 4 :50 4:50 4:50 4:50 4:50 4:50 4:50 ENE, E, ESE, (PAZ 1, 2, 12)

SE R04 (PAZ 1, 2, 3, 4, 9:40 10:20 9:10 19:05 13:30 Full EPZ 10:15 11:20 10:15 11 :35 9:35 10:15 10:50 5, 6, 7, 8, 9, 10, 11, 12}

Page 11 of 14 Internal

2022 ETE Update Change Table - Emergency Plan Appendix E Change 12 - Revised Content - Table E-4 Table E-4. Time to Clear the Ind icated Area of 100 Perce nt of the Affected Po,p ulation Summer Summer Summer Winter Winter Winter Summer Summer Midweek Midweek Midweek Midweek Weelk end Midweek Weekend Midweek Weekend Weekend Weekend Scenario: (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12)

Midday Midday Even ing Midday Midday Evening Even ing Midday Region Good Good Good Good Good Good Special Roadway Rain Rain Rain Rain Weather Weather Weather Weather Weather Weather Event llr npact Entire 2-Mile Region, 6-Mile Region, FEMA EPZ and Fu ll EPZ R01 (PAZ 1) 1:35 1 :35 1 :30 1 :30 1 :30 1 :35 1 :35 1:3 0 1 :30 1 :30 1 :30 1:35 R02 (PAZ 1, 2) 4 :50 4:50 4:50 4 :50 4 :50 4:50 4:50 4:50 4:50 4 :50 4 :50 4:50 R03 (PAZ 1, 2, 3, 4, 5) 4 :55 4:55 4 :5 5 4 :55 4:55 4 :5 5 4 :55 4:55 4:55 4 :55 4:55 4:55 R04 (PAZ 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12) 10:50 12:10 10:50 11:55 11:45 11:05 12: 10 10:05 10:50 10:35 20: 10 15:00 6-Mile Ring and Keyhole to FIEMA EPZ ROS (PAZ 1, 2, 5) 4 :55 4:55 4 :5 5 4:55 4:55 4 :5 5 4 :55 4:55 4:55 4:55 4:55 4:55 R06 (PAZ 1, 2, 4, 5) 4 :55 4:55 4:55 4 :55 4:55 4:55 4 :55 4:55 4:55 4 :55 4:55 4:55 R07 (PAZ 1, 2, 3, 4) 4 :55 4:55 4:5 5 4 :5 5 4:55 4:5 5 4:55 4:55 4:55 4:55 4:55 4 :55 R08 (PAZ 1, 2, 3) 4 :55 4:55 4:5 5 4 :5 5 4 :55 4:5 5 4:55 4:55 4 :55 4 :55 4 :55 4:55 Evacuate 6 -Mile Radius and Downwind to Full IEPZ Boundary R09 (PAZ 1, 2, 5, 9) 5:10 5:35 5:15 5 :40 5:10 5:10 5:45 5:00 5:10 5:10 7:00 5:15 R10 (PAZ 1, 2, 4, 5, 8, 9,) 8:10 9:l!O 7:05 8 :20 7:10 9:00 10:10 7:15 8:00 7: 10 9:40 9:25 RU (PAZ 1, 2, 3, 4, 5, 8, 9) 8 :30 9:20 8:50 9 :30 9:05 7:50 8:50 7:45 8:25 8 :10 10 :10 11:00 R12 (PAZ 1, 2, 3, 4, 5, 7, 8, 9, 11} 8:25 9:15 7:45 8 :25 7:20 9:20 10: 35 7:50 8:25 7:25 10:05 9:20 R13 (PAZ 1, 2, 3, 4, 6, 7, 8, 10, 1 1, 12) 10:50 11:45 10:35 11:50 11:20 10:20 11:30 9:20 10:05 9:50 18 :55 15:15 R14 (PAZ 1, 2, 3, 6, 7, 10, 11, 12} 9:00 9:55 9:40 10:05 9:45 8:45 9:35 8:15 9:l!O 8:55 18:35 12:40 R15 (PAZ 1, 2, 3, 10, 12) 8 :15 9:10 7:35 8 :05 7:10 9: 15 10: 05 7:25 8:05 7 :05 12:30 9:20 Site Specific Regions R16 (PAZ 1, 2, 4) 4 :55 4:55 4:55 4 :5 5 4:55 4:55 4:55 4:55 4:55 4:55 4:55 4 :55 RU (PAZ 1, 2, 3, 6) 5:00 5:0 0 5:0 0 5:00 5:00 5:0 0 5:00 5:00 5:00 5:00 13:40 6:15 R18 (PAZ 3, 4) 4 :55 4:55 4 :55 4 :5 5 4 :55 4 :55 4 :5 5 4 :55 4:55 4 :55 4 :55 4:55 R19 (PAZ 4, 5) 4 :55 4:55 4:5 5 4 :5 5 4 :55 4:5 5 4 :55 4:55 4:55 4:55 4 :55 4 :55 Stae:ed Evacuation Mile Radius Evacuates, then Evacuate Downwind to 6 Miles R20 (PAZ 1, 2) 4 :50 4:50 4 :50 4 :50 4:50 4 :50 4 :50 4:50 4:50 4 :50 4 :50 4:50 Staged Evacuation Mile Radius Evacuates, then Evacuate Downwind to FEMA EPZ R21 (PAZ 1, 2, 5) 4 :55 4:55 4:55 4 :5 5 4 :55 4:55 4 :55 4:55 4:55 4 :55 4 :55 4:55 R22 (PAZ 1, 2, 4, 5) 4 :55 4:55 4:55 4 :55 4:55 4:55 4:55 4:55 4:55 4 :55 4:55 4:55 R23 (PAZ 1, 2, 3, 4, 5) 4 :55 4:55 4:55 4 :5 5 4 :55 4:55 4 :55 4:55 4:55 4:55 4 :55 4 :55 R24 (PAZ 1, 2, 3, 4) 4 :55 4:55 4:5 5 4 :5 5 4:55 4:5 5 4 :55 4:55 4:55 4:55 4:55 4:55 R25 (PAZ 1, 2, 3) 4 :55 4 :55 4:55 4 :5 5 4 :55 4:55 4 :55 4 :55 4:55 4 :55 4 :55 4:55 Page 12 of 14 Internal

2022 ETE Update Change Table - Emergency Plan Appendix E Change 13 - New Content - Table E-5 T able E-5 : Descriptiion of Evacuation Regions Region Description R01 2-Mrle 1RingI 6-Mrle 1RingI R02 lsimilar to the FEMA 5-mile ring)

R03 FEMA EIPZ R04 Fu ll EPZ Evacuate 2-Mile Radius and Downwind to 6 Miles Wind Direction PAZ RegIion From: 11 2 3 45678 9 110 1 12 IESIE, SE, SS E, S, SSW, SW, IR efer to Region R02 WSW, W, WNW, NW, NNW N, NN E, NE, ENE,. E IRefer to Reg1fon R01 Evacuate 6-Mile Radius and Do111111wind to 10 miles Wind Direction PAZ Region From: 6 7 8 9 110 R05 SE, SSE, S R06 SSW SW,WSW W,WNW ROB NW, N W N, NNE, NE, EN E, E, ESE IRefer to Region R02 Evacuate 6-Mile Radius and Downwind to EPZ Boundary Wind Direction PAZ Region From:

R09 SE, SSE, S R10 SSW R11 SW R12 WSW R13 W, WNW R14 NW R15 NNW N, NNE, NE, EN E, E, ESE Page 13 of 14 Internal

2022 ETE Update Change Table - Emergency Plan Appendix E Table* E-5: Description of Evacua.tiio11 Re,gi:ons ,(co11ti11ued)

Site Specific Regions IPAZ Wind Direction Region1 From: 16 ] ,8 ,g 1101 11 2 R.1 6 R17 R.1 9 Advanced Emergency aassification, 100% of the PAZ(s) alrea evaruated Staged Evacuation Mile Radius Evacuates, then Evacuate Downwind to 6 Miles Wind Direction IPAZ Regiolill From:

3 4 5, 16 ] ,8 ,g 101 11 12 IESE, SE, SSE, S, SSW, SW, R21!li WSW, W, WNW, NW, NNW N, NINE, NE, ENE, IE Rieferto Region R01 PAZ(s) Monitor .andl Plre are Staged Evacuation Mile Radius Evacuates, then Evacuate Downwind to 10 Wind Direction IPAZ Regiolill From: 1101 11 2 R21 SE, SSE, S R22 SSW R2l SW, WSW (& FHl,\'IA EPZ)

R24 W,WNW R25 NiW, NNW Page 14 of 14 Internal

Enclosure 3 PG&E Letter DCL-23-128 PG&E Letter DIL-23-010 Summary of the Analysis of Emergency Plan Appendix G, Revision 5.00, Protective Action Recommendation (PAR) Strategy Bases

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change 1 Section 1 Section 1 Updated section reference to align with current appendix section numbering.

Section 4 of this appendix contains the site Section 5 of this appendix contains the site specific protective action methodology specific protective action methodology Replaced in accordance with with per to be flowchart developed in accordance with the flowchart developed per the guidance of consistent with other documentation.

guidance of Supplement 3 and modified to Supplement 3 and modified to support the support the unique characteristics of the local unique characteristics of the local DCPP EPZ This change does not affect how the DCPP EPZ geography, EPZ population, State geography, EPZ population, State regulations current E-Plan meets any planning standard regulations and ORO commitments. Section 4 and ORO commitments. Section 5 also functions, elements, or site-specific also provides a correlation between the provides a correlation between the Supplement commitments. No additional evaluation Supplement 3 flowchart blocks (as indexed in 3 flowchart blocks (as indexed in NEI 12-10) required.

NEI 12-10) with the site specific PAR with the site specific PAR development bases development bases for DCPP. for DCPP.

2 Section 2.2.2c Section 2.2.2c. Updated section reference to align with current appendix section numbering.

The SER approved DCPP Emergency Plan is The SER approved DCPP Emergency Plan is Revision 3, Change 3 dated 03/31/83. Revision 3, Change 3 dated 03/31/83. This change does not affect how the Section 3 of this appendix provides the Section 4 of this appendix provides the current E-Plan meets any planning standard approved DCPP PAR determination approved DCPP PAR determination functions, elements, or site-specific methodology that included the concepts of methodology that included the concepts of commitments. No additional evaluation plant-based and dose-based PARs. plant-based and dose-based PARs. required.

3 Section 2.4.2a. Section 2.4.2a. Changed transient to transients to correct a grammatical error.

For areas beyond the LPZ, directing transient For areas beyond the LPZ, directing transients to return to their homes, sheltering of to return to their homes, sheltering of This change does not affect how the permanent residents, and deployment of law permanent residents, and deployment of law current E-Plan meets any planning standard enforcement agencies in preparation for enforcement agencies in preparation for functions, elements, or site-specific possible evacuation are the appropriate possible evacuation are the appropriate commitments. No additional evaluation responses while actual conditions are responses while actual conditions are required.

assessed. assessed.

4 Section 2.5.2a. Section 2.5.2a. Added in the and removed a comma to address grammatical errors.

Although a wind persistence study for the Although a wind persistence study for the DCPP EPZ was done, this is not applicable for DCPP EPZ was done, this is not applicable for Updated KLD report ID to align with the 2022 use in PAR methodology described in this use in the PAR methodology described in this ETE Report.

appendix. DCPP does not use map sectors to appendix. DCPP does not use map sectors to make PARs, but uses PAZs. make PARs but uses PAZs. Updated scenario conditions to align with the 2022 ETE Report.

ETE values are taken from KLD TR-498 ETE values are taken from KLD TR-1235 Updated ETE times to align with the 2022 ETE Page 1 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change Table 7.1, Time to Clear the Indicated Area of Table 7.1, Time to Clear the Indicated Area of Report.

90 Percent of the Affected Population. In 90 Percent of the Affected Population. Per accordance with Supplement 3, ETE values for Supplement 3, ETE values for special events Updated population values to align with the special events and roadway impact are not and roadway impact are not included. The 2022 ETE Report.

included. The longest ETE for PAZs 1 and 2 longest ETE for PAZs 1 and 2 (90% population (90% population scenario 10: Winter, All Week, scenarios 8 and 9: Winter, Weekend, Midday, Replaced in accordance with with per to be Evening, Good Weather) is 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 20 minutes. Good Weather and Rain) is 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 45 minutes. consistent with other documentation.

Using a maximum wind persistence Using a maximum wind persistence assumption of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and the longest ETE for assumption of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and the longest ETE for Updated reference number to align with current the combination of PAZ 1 and PAZ 2 of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months the combination of PAZ 1 and PAZ 2 of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months appendix section numbering.

20 minutes, a modification to the protective 45 minutes, a modification to the protective action strategy to include additional downwind action strategy to include additional downwind Refer to 10 CFR 50.54(q) effectiveness PAZs in an expanded evacuation would not be PAZs in an expanded evacuation would not be evaluation 2023-14 for evaluation of the warranted for DCPP. warranted for DCPP. 2022 ETE report.

PAZ 1 permanent and transient populations PAZ 1 permanent and transient populations are 0. PAZ 2 permanent population is 168 and are 0. PAZ 2 permanent population is 160 and the transient population is 333 (ETE Report the transient population is 870 (ETE Report Tables 3.1 and 3.4 - reference 6.7). Based on Tables 3.1 and 3.4 - reference 7.7). Based on the remote geography and limited population of the remote geography and limited population of PAZs 1 and 2, these areas are always PAZs 1 and 2, these areas are always recommended to evacuate or shelter recommended to evacuate or shelter simultaneously. Even if the ETE were to simultaneously. Even if the ETE were to exceed the maximum wind persistence exceed the maximum wind persistence assumption of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months the DCPP site specific assumption of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months the DCPP site specific PAZ equivalent to the 2-5 mile area (PAZ 2) is PAZ equivalent to the 2-5 mile area (PAZ 2) is not divided into multiple geographic areas, not divided into multiple geographic areas, therefore wind persistence is not applicable in therefore wind persistence is not applicable in the 2-5 mile area for DCPP. the 2-5 mile area for DCPP.

5 Section 2.6.2b. Section 2.6.2b. Changed field results to field survey results for consistency throughout the appendix. Field The need to make or expand a PAR for a The need to make or expand a PAR for a survey is the common terminology used at particular PAZ based on dose assessment or particular PAZ based on dose assessment or DCPP for sampling activities performed by the field results indicating a PAG could be field survey results indicating a PAG could be field monitoring teams. Field survey results is exceeded is part of the DCPP site specific PAR exceeded is part of the DCPP site specific PAR also the terminology used in the DCPP EAL methodology. methodology. scheme.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation Page 2 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change required.

6 Section 2.6.2f. Section 2.6.2f. Clarified that upgrade PARs are made on dose assessment and field survey results, not on Only when plant condition or dose assessment Only when dose assessment results or field plant conditions. This change aligns section thresholds indicate the potential for exceeding survey results indicate the potential for 2.6.2f. with 2.6.2b. Also added in areas over an EPA PAG in a new PAZ is an expansion of exceeding an EPA PAG in a new PAZ or area the ocean as upgrade PARs are made for the PARs considered. over the Ocean is an expansion of PARs Ocean and not just the land based PAZs.

considered.

This change doesnt introduce any new logic or alter any decision making within the PAR strategy. This change aligns the content of this section of Appendix G with the current approved method of determining the need for upgrade PARs.

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

7 Section 2.7.2a. Section 2.7.2a. Updated KLD report ID to align with the 2022 ETE Report.

ETE values are taken from KLD TR-498 ETE values are taken from KLD TR-1235 Table 7.1, Time to Clear the Indicated Area of Table 7.1, Time to Clear the Indicated Area of Updated ETE times to align with the 2022 ETE 90 Percent of the Affected Population. In 90 Percent of the Affected Population. Per Report.

accordance with Supplement 3, ETE values for Supplement 3, ETE values for special events special events and roadway impact are not and roadway impact are not included. Updated number of scenario occurrences to included. align with the 2022 ETE Report.

1. The longest 90% ETE for evacuation of the

1. The longest 90% ETE for evacuation of the Basic EPZ (PAZs 1 - 5), which is the area Replaced in accordance with with per to be Basic EPZ (PAZs 1 - 5), which is the area out to approximately 10 miles, is 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months consistent with other documentation.

out to approximately 10 miles, is 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 15 minutes.

05 minutes. The longest 90% ETE for evacuation of the Refer to 10 CFR 50.54(q) effectiveness The longest 90% ETE for evacuation of the entire EPZ (PAZs 1 - 12), which is the area evaluation 2023-14 for evaluation of the entire EPZ (PAZs 1 - 12), which is the area out to approximately 22 miles, is 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months 2022 ETE report.

out to approximately 22 miles, is 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months 05 minutes.

10 minutes.

The Basic EPZ (PAZs 1-5) is very close to the The Basic EPZ (PAZs 1-5) is very close to the 3-hour guidance with a worst case time of 3-hour guidance with a worst case time of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 05 minutes. Nine out of the ten 90% 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 15 minutes. Eight out of the ten 90%

Page 3 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change ETE scenario times shown in the tables below ETE scenario times shown in the tables below for the Basic EPZ are 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months or less. for the Basic EPZ are 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months or less.

Therefore, evacuation is selected as the more Therefore, evacuation is selected as the more appropriate protective action for a rapidly appropriate protective action for a rapidly progressing scenario. progressing scenario.

8 Section 2.7.2a.2 Section 2.7.2a.2 Updated ETE times to align with the 2022 ETE Report.

2 to 5 mile Zone 2 to 5 mile Zone Refer to 10 CFR 50.54(q) effectiveness The longest 90% ETE for PAZs 1 and 2 is 1 The longest 90% ETE for PAZs 1 and 2 is 1 evaluation 2023-14 for evaluation of the hour 20 minutes. hour 45 minutes. 2022 ETE report.

5 to 10 mile Zone 5 to 10 mile Zone Thus, the benefits of the Supplement 3 Thus, the benefits of the Supplement 3 guidance to SIP the downwind PAZs in the 6 to guidance to SIP the downwind PAZs in the 6 to 10 mile area prior to a staged evacuation are 10 mile area prior to a staged evacuation are not greater than the plant uncertainties for such not greater than the plant uncertainties for such an event, the complication of implementing the an event, the complication of implementing the action for the public or the potential dose action for the public or the potential dose avoided. The appropriate DCPP site specific avoided. The appropriate DCPP site specific PAR in this case is to evacuate the downwind PAR in this case is to evacuate the downwind PAZs in the 6 to 10 mile area. This is PAZs in the 6 to 10 mile area. This is supported by the 90% ETE with a "worst case" supported by the 90% ETE with a "worst case" evacuation time of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and 10 minutes. evacuation time of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and 15 minutes.

9 Section 2.7.2a.2 Staged Evacuation Section 2.7.2a.2 Staged Evacuation Updated ETE scenario comparison times to Comparison Tables Comparison Tables align with the 2022 ETE Report. Changes include ETE times and renumbering of the See Addendum B See Addendum B evacuation regions. The updated tables continue to support the strategy of evacuating all affected PAZs simultaneously rather than staged evacuation of PAZs based on distance.

Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-14 for evaluation of the 2022 ETE report.

10 Section 2.7.2a.2, Ocean Section 2.7.2a.2, Ocean Altered the basis for determining the 5 to 10 NM ocean protective action recommendation Due to the potential radiological consequences Due to the potential radiological consequences (PAR) in the rapidly progressing severe of the rapidly progressing scenario, the of the rapidly progressing scenario, the accident (RPSA) scenario.

Page 4 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change uncertainty for further degradation of plant uncertainty for further degradation of plant conditions and the urgency of the incident, the conditions and the urgency of the incident, the Refer to 10 CFR 50.54(q) effectiveness evacuation of watercraft and people from the evacuation of watercraft and people from the evaluation 2023-17 for evaluation of the ocean is recommended to the distance of 5 or ocean is recommended to the distance of 5 or change to the RPSA Ocean PAR strategy.

10 nautical miles depending on wind direction. 10 nautical miles depending on wind direction.

For wind directions where the affected sector or adjacent sectors contain areas of the ocean or a protective action zone with an ocean harbor, the recommended action is to evacuate to the distance of 10 nautical miles.

11 Section 2.7.2b Section 2.7.2b Updated title of the excluded scenarios to match the titles listed in the ETE report for The ETEs used in the development of the The ETEs used in the development of the consistency per KLD TR-1235 Table 7.1.

DCPP site specific PAR methodology are DCPP site specific PAR methodology are based on the 90% population values, excluding based on the 90% population values, excluding This change does not affect how the the infrequent special event and US-101 road the special event and roadway impact current E-Plan meets any planning standard closure scenarios. scenarios. functions, elements, or site-specific commitments. No additional evaluation required.

12 Section 3 Section 3 Updated the date of the State of California Nuclear Power Plant Emergency Response The current State of California Nuclear Power The current State of California Nuclear Power Plan to the current revision.

Plant Emergency Response Plan (dated 2008) Plant Emergency Response Plan (dated 2019) provides the following basis for the DCPP EPZ provides the following basis for the DCPP EPZ This change does not affect how the and PAZ boundaries: and PAZ boundaries: current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

13 Section 3 Section 3 Removed reference to Figure 2-3 as the map shown does not contain a Figure number. This The current plume exposure EPZ boundary for The current plume exposure EPZ boundary for is consistent with other sections of the DCPP provided in the State of California DCPP provided in the State of California Appendix. The figure reference is not required Nuclear Power Plant Emergency Response Nuclear Power Plant Emergency Response since the figure being referenced is clear Page 5 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change Plan (Figure 1.4.2) is shown as Figure 2-3 Plan (Figure 1.4.2) is shown below. based on the layout of the section.

below.

Additionally, the image of the referenced map was replaced with a higher resolution image.

This is an editorial change to improve the legibility of the map.

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 Section 3 Section 3 Updated the date of the SLO County/Cities Nuclear Power Plant Emergency Response Section 3.1 of the current SLO County/Cities Section 3.1 of the current SLO County/Cities Plan to the current revision.

Nuclear Power Plant Emergency Response Nuclear Power Plant Emergency Response Plan (2014) provides the following basis for the Plan (2022) provides the following basis for the This change does not affect how the DCPP EPZ and PAZ boundaries: DCPP EPZ and PAZ boundaries: current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

15 Section 3, NRC-defined plume exposure EPZ Section 3, NRC-defined plume exposure EPZ Removed reference to Figure 3.1-1 as that map caption map caption figure number refers to the section and figure located in the SLO County Emergency Figure 3.1-1, Current SLO OES NRC Current SLO OES NRC Equivalent Plume Response Plan. The figure 3.1.1 reference is Equivalent Plume Exposure EPZ for DCPP Exposure EPZ for DCPP provided in the sentence immediately preceding the map.

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 Section 3 Section 3 The images of all maps were replaced with the current revision of the respective maps from Current Cal OES Plume Exposure EPZ for Current Cal OES Plume Exposure EPZ for the State of California and SLO County/Cities DCPP DCPP Nuclear Power Plant Emergency Response Plans.

Current SLO OES NRC Equivalent Plume Current SLO OES NRC Equivalent Plume Page 6 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change Exposure EPZ for DCPP Exposure EPZ for DCPP This change does not affect how the current E-Plan meets any planning standard Current SLO OES Plume Exposure EPZ for Current SLO OES Plume Exposure EPZ for functions, elements, or site-specific DCPP DCPP commitments. No additional evaluation required.

See Addendum B See Addendum B 17 Section 5.1 Section 5.1 The image of the referenced flowchart was replaced with a higher resolution image. This is NUREG-0654 Supplement 3 / NEI 12-10 PAR NUREG-0654 Supplement 3 / NEI 12-10 PAR an editorial change to improve the legibility of Methodology Flowchart Block Key Methodology Flowchart Block Key the flowchart.

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

18 Section 5.1.2b.1. Section 5.1.2b.1. Refactored the definition for RPSA to improve usability and incorporate feedback from the N/A - added new content A Rapidly Progressing Severe Accident is ERO.

occurring if ALL the following are present:

Added in the lead sentence to establish that A General Emergency has been declared and A General Emergency was declared RPSA criteria requires all the following it is the initial PAR with: conditions, which was inferred in the existing AND content, but not explicitly stated.

Any Containment Loss EAL Initial PAR Removed bullets and indented the "ANDs" to AND better align with the EAL wallcharts and plant AND procedures.

Radiation Monitor 30/31 > 5000 R/Hour Any EAL Table F-1 Containment Barrier Loss Replaced containment loss EAL with EAL OR Table F-1 Containment Barrier Loss based on AND ERO feedback that the containment loss EAL

EAL RG.1.1 met for any Table R-1 GE was not as clear as referring to the fission value ANY of the following: product barrier matrix table loss criteria.

Radiation Monitor 30/31 > 5000 R/Hour

EAL RG1.1 met for RM-87 > 1.9E-10 Refactored the final bulleted item from a amps compound OR to a multiple ANY to list the

EAL RG1.1 met for RM-87 > 3.2E-1 Table R-1 values. Substituted the EAL RG1.1

µCi/cc met for any Table R-1 GE value with the actual Table R-1 GE values. This does not change the intent or interpretation of the RPSA criteria Page 7 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change but is rather relocating information from Table R-1 in place of a reference to Table R-1.

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

19 Section 5.1.3b. DCPP Site Specific Bases Section 5.1.3b. DCPP Site Specific Bases Altered the basis for determining the 5 to 10 NM ocean PAR in the RPSA scenario.

The DCPP site specific PAR for Block G is to: The DCPP site specific PAR for Block G is to: Removed reference to wind table as the ocean

Evacuate PAZs 1 and 2 and all

Evacuate PAZs 1 and 2 and all is evacuated to 10 NM for all wind directions downwind PAZs to 10 miles downwind PAZs to 10 miles during an RPSA.

Administer KI per SLO County Plan

Administer KI per SLO County Plan

Evacuate the Ocean to 5 or 10 nautical

Evacuate the Ocean to 10 nautical Refer to 10 CFR 50.54(q) effectiveness miles depending on direction of the miles evaluation 2023-17 for evaluation of the wind (Per Wind Table)

All other PAZs monitor and prepare. change to the RPSA Ocean PAR strategy.

All other PAZs monitor and prepare.

Updated reference to section 5.2 to align with See discussion in Section 4.2 of this appendix See discussion in Section 5.2 of this appendix current appendix section numbering.

for more information about Ocean PARs. for more information about Ocean PARs.

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 Section 5.1.3b.4 Section 5.1.3b.4 Updated ETE times to align with the 2022 ETE Report. The conclusion regarding Analysis of the DCPP ETE's indicates it is Analysis of the DCPP ETE's indicates it is simultaneous vs staged evacuation remains faster to simultaneously evacuate PAZs 1 faster to simultaneously evacuate PAZs 1 valid as the new ETE studies found only a 5 through 5 than to implement a staged through 5 than to implement a staged minute difference compared to the original evacuation. In the majority of the ETE evacuation. In the majority of the ETE basis for the PAR strategy.

scenarios, the simultaneous evacuation times scenarios, the simultaneous evacuation times did not exceed 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . The worst case did not exceed 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . The worst case Refer to 10 CFR 50.54(q) effectiveness scenarios for a simultaneous evacuation scenarios for a simultaneous evacuation of evaluation 2023-14 for evaluation of the resulted in an ETE of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and 10 minutes. PAZs 1 through 5 resulted in an ETE of 3 2022 ETE report.

This time difference of approximately 10 hours and 15 minutes. This time difference of minutes (3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months versus 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 10 minutes) approximately 15 minutes (3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months versus 3 does not warrant the additional complication hours 15 minutes) does not warrant the involved in a staged evacuation for a rapidly additional complication involved in a staged Page 8 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change progressing severe accident scenario. Thus, evacuation for a rapidly progressing severe the appropriate DCPP site specific PAR in this accident scenario. Thus, the appropriate DCPP event is to evacuate the downwind PAZs in the site specific PAR in this event is to evacuate 6 to 10 mile area (Refer to Section 2.7.2). the downwind PAZs in the 6 to 10 mile area (Refer to Section 2.7.2).

21 Section 5.1.3b.6 Section 5.1.3b.6 Updated KLD report ID to align with the 2022 ETE Report.

The ETE values used to determine the The ETE values used to determine the appropriate actions for a rapidly progressing appropriate actions for a rapidly progressing Refer to 10 CFR 50.54(q) effectiveness severe accident scenario were taken from KLD severe accident scenario were taken from KLD evaluation 2023-14 for evaluation of the TR-498 Table 7.1, Time to Clear the Indicated TR-1235 Table 7.1, Time to Clear the Indicated 2022 ETE report.

Area of 90 Percent of the Affected Population. Area of 90 Percent of the Affected Population.

ETE values for special events and roadway ETE values for special events and roadway impacts are not included (Refer to Section impacts are not included (Refer to Section 2.7.2). 2.7.2).

22 Section 5.1.3b.8 Section 5.1.3b.8 Altered the basis for determining the 5 to 10 NM ocean PAR in the RPSA scenario.

Ocean PARs are dependent upon wind Since all potential wind directions and their direction. The 5 nautical mile (NM) PAR is respective downwind and adjacent sectors Changed the combination of PAZs for a given based upon wind that is from the ocean and contain either the ocean or a PAZ containing wind direction based on elimination of sliver directed in land. Extending the PAR further into an ocean harbor, an Ocean PAR distance of consideration.

the ocean under these conditions is not 10 nautical miles is established for all rapidly required. The PAR distance of 10 NM is progressing severe accident scenarios. Replaced Wind From (Sector) column with established in cases where wind direction Affected Sectors column. Wind from sector is would be sending the plume out to sea. inherent to wind from degrees (provides no additional information). Affected sectors data Refer to Addendum B for table Refer to Addendum B for table provides information consistent with method used to determine affected PAZs.

Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-14 for evaluation of the 2022 ETE report.

Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-17 for evaluation of the change to the RPSA Ocean PAR strategy.

23 Section 5.1.5b.1 Section 5.1.5b.1 Updated ETE times to align with the 2022 ETE Report.

DCPP has a low population density within DCPP has a low population density within PAZs 1 and 2 (6 miles) which results in PAZs 1 and 2 (6 miles) which results in Refer to 10 CFR 50.54(q) effectiveness favorable evacuation times. The longest 90% favorable evacuation times. The longest 90% evaluation 2023-14 for evaluation of the Page 9 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change ETE for PAZs 1 and 2 is only 80 minutes. The ETE for PAZs 1 and 2 is only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 45 2022 ETE report.

DCPP site specific PAR methodology does not minutes. The DCPP site specific PAR take impediments into consideration. This methodology does not take impediments into evaluation is performed by the County as consideration. This evaluation is performed by agreed upon with County officials during the the County as agreed upon with County development of this appendix. officials during the development of this appendix.

24 Section 5.1.5b.2 Section 5.1.5b.2 Updated ETE times to align with the 2022 ETE Report.

DCPP has a low population density within DCPP has a low population density within PAZs 1 and 2 (6 miles) which results in PAZs 1 and 2 (6 miles) which results in Added a comma after Therefore to fix a favorable evacuation times. The longest 90% favorable evacuation times. The longest 90% grammatical error.

ETE for PAZs 1 and 2 is only 80 minutes. ETE for PAZs 1 and 2 is only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 45 Therefore the PAR to evacuate PAZs 1 and 2 minutes. Therefore, the PAR to evacuate PAZs Refer to 10 CFR 50.54(q) effectiveness rather than shelter in place (SIP) was 1 and 2 rather than shelter in place (SIP) was evaluation 2023-14 for evaluation of the determined to be the preferred path for a determined to be the preferred path for a 2022 ETE report.

hostile action event. This basis was agreed to hostile action event. This basis was agreed to by the responsible OROs. by the responsible OROs.

25 Section 5.1.8b Section 5.1.8b Capitalized Ocean to be consistent with other documentation. Changed "in accordance with The DCPP site specific PAR for Block H is to: The DCPP site specific PAR for Block H is to: the" to "per" to be consistent with other

Evacuate PAZs 1 and 2

Evacuate PAZs 1 and 2 documentation.

Evacuate the ocean to 5 nautical miles

Evacuate the Ocean to 5 nautical miles

Administer KI in accordance with the

Administer KI per SLO County plan Reworded qualitative evaluation to reflect the SLO County plan

All other PAZs monitor and prepare updated values in the 2022 ETE Report.

All other PAZs monitor and prepare Refer to 10 CFR 50.54(q) effectiveness Section 5.1.8b.1 Section 5.1.8b.1 evaluation 2023-14 for evaluation of the 2022 ETE report.

The PAZ 1 and PAZ 2 permanent and transient The PAZ 1 and PAZ 2 permanent and transient populations are very small in number (Refer to populations are very small in number (Refer to ETE Report Tables 3 1 and 3 4). Staged ETE Report Tables 3 1 and 3 4). Staged evacuation of PAZs 1 and 2 takes longer than evacuation of PAZs 1 and 2 takes a simultaneous evacuation of PAZs 1 and 2 for approximately the same time as a the 90% population in each of the applicable simultaneous evacuation of PAZs 1 and 2 for scenarios (refer to ETE report Table 7.1). the 90% population in each of the applicable scenarios (refer to ETE report Table 7.1).

26 Section 5.1.8b.1, PAZ 1 & 2 Staged Section 5.1.8b.1, PAZ 1 & 2 Staged Updated ETE times to align with the 2022 ETE Evacuation Comparison Table Evacuation Comparison Table Report.

Page 10 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change See Addendum B See Addendum B Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-14 for evaluation of the 2022 ETE report.

27 Section 5.1.8b.5 Section 5.1.8b.5 Replaced in accordance with with per to be consistent with other documentation.

An addition to the DCPP PAR methodology is An addition to the DCPP PAR methodology is the administration of KI for the general public in the administration of KI for the general public This change does not affect how the accordance with the SLO County Emergency per the SLO County Emergency Response current E-Plan meets any planning standard Response Plan. Plan. functions, elements, or site-specific commitments. No additional evaluation required.

28 Section 5.1.9b.2, 22-Mile EPZ Keyhole Section 5.1.9b.2, 22-Mile EPZ Keyhole Changed the combination of PAZs for a given Evacuation Comparison Table Evacuation Comparison Table wind direction based on elimination of "sliver" consideration.

See Addendum B See Addendum B Corrected PAZ 10 not being included as an affected PAZ for the NNW sector (wind from 327° to <349°).

Replaced Wind From (Sector) column with Affected Sectors column. Wind from sector is inherent to wind from degrees and provides no additional information. Affected sectors data provides information consistent with the method used to determine affected PAZs.

Removed ocean PAR column. Section 5.1.9b.2 is specific to land PAZs. Ocean discussion is provided in 5.1.9b.3. No content is being removed as this information is duplicative of the information in 5.1.9b.3.

Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-14 for evaluation of the 2022 ETE report. Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-17 for evaluation of the change to the RPSA Ocean PAR strategy.

Page 11 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change 29 Section 5.1.9b.3 Section 5.1.9b.3 Clarified under what conditions ocean PAR expansion occurs. Initial plant-based PAR for Ocean PARs are expanded from 5 nautical Ocean PARs are expanded from 5 nautical non-RPSA scenarios include PAR to evacuate miles to 10 nautical miles in cases where wind miles to 10 nautical miles based on dose ocean to 5 NM only. The only PAR changes direction is from the land towards the ocean. assessment results that show areas over the following that are a result of exceeding PAGs Ocean PAR expansion is also based on dose ocean that could exceed EPA-400 PAGs. This based on dose assessment or field survey assessment results that show areas over the expansion completes the radial evacuation for results. Wind direction is only a consideration ocean that could exceed EPA-400 PAGs. This areas comparable to the land areas that would for RPSA scenarios and as an input to dose expansion completes the radial evacuation for be evacuated based upon wind direction. assessment.

areas comparable to the land areas that would be evacuated based upon wind direction. Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-17 for evaluation of the change to the RPSA Ocean PAR strategy.

30 Section 5.1.9b.5 Section 5.1.9b.5 Replaced in accordance with with per to be consistent with other documentation.

An addition to the DCPP PAR methodology is An addition to the DCPP PAR methodology is the administration of KI for the general public in the administration of KI for the general public This change does not affect how the accordance with the SLO County Emergency per the SLO County Emergency Response current E-Plan meets any planning standard Response Plan Plan. functions, elements, or site-specific commitments. No additional evaluation required.

31 Section 5.2 Additional Protective Action Section 5.2 Additional Protective Action Clarified under what conditions ocean PAR Recommendation 1: Ocean PAR Recommendation 1: Ocean PAR expansion occurs. Initial plant-based PAR for 5.2.1 DCPP Site Specific Bases 5.2.1 DCPP Site Specific Bases non-RPSA scenarios include PAR to evacuate ocean to 5 NM only. The only PAR changes The DCPP site specific PAR flowchart includes The DCPP site specific PAR flowchart includes following that are a result of exceeding PAGs ocean evacuation recommendations for 5 ocean evacuation recommendations for 5 based on dose assessment or field survey nautical miles or 10 nautical miles depending nautical miles or 10 nautical miles depending results. Wind direction is only a consideration upon prevailing wind conditions and/or dose upon plant conditions and/or dose assessment for RPSA scenarios and as an input to dose assessment results that indicate EPA-400 results that indicate EPA-400 PAGs could be assessment.

PAGs could be exceeded on areas over the exceeded on areas over the ocean ocean Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-17 for evaluation of the change to the RPSA Ocean PAR strategy.

32 Section 5.4 Additional Protective Action Section 5.4 Additional Protective Action Changed "has" to "have" to correct Recommendation 3 Recommendation 3 grammatical error.

Page 12 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change Licensees are required to provide a Licensees are required to provide a This change does not affect how the recommendation if the respective jurisdictions recommendation if the respective jurisdictions current E-Plan meets any planning standard in the EPZ has elected to include distribution of in the EPZ have elected to include distribution functions, elements, or site-specific KI to the general public. of KI to the general public. commitments. No additional evaluation required.

33 Section 6, DCPP Site Specific PAR Flowchart Section 6, DCPP Site Specific PAR Flowchart Changed formatting, punctuation, and capitalization throughout to improve readability Refer to Addendum B for full chart Refer to Addendum B for full chart based on user feedback.

Recommend ALL of the fo ll ow ing PARs: Changed PAR boxes to include a statement to

Evacu ate PAZ 1 and 2 "Recommend ALL of the following PARs:".

Eva cu ate PAZ(s) 3, 4, 5 per RPSA W ind Directio n Table

Eva cu ate Ocea n to 10 nauti cal mil es Changed the bulleted items to arrows as

ALL OTHER PAZs - MOOTTOR ANO PR ARE FOR POSSIBLE Ad minister Kl per SLO Co un ty Plan bullets are primarily used in other plant PflOTECTIVE ACTIONS All oth er PAZs M on itor and Prepare procedures to indicate a choice rather than a

requirement to perform all.

THEN GO TO BLOCK A t o conti nue assessment Spelled out nautical miles to replace the NM acronym throughout.

Recommend A L of t he fo llowin g PAIRs:

Shelte r PAZ 1 and 2 Eva cuate Ocean t o 5 naut ical m iles Ad ministe r KIi per SLO Co unty Plan

All other PAZs M onito r and Prepa re Reworded "ALL OTHER PAZs - MONITOR AND PREPARE FOR POSSIBLE PROTECTIVE ACTIONS" to "All other PAZs

Monitor and Prepare". This is consistent with the language used in the body of Appendix G

Recommend ALL of the following PARs : and on the Emergency Notification Form used

Evacuate PAZ 1 and 2 to transmit the PAR.

OR Evacuate Ocean to 5 nautica l miles Moved the "continue assessment" step out of Admini ster Kl per SLO County Plan the list since it is not a PAR itself. Reworded

All other PAZs Monitor and Prepare "continue assessment" to "THEN GO TO BLOCK A to continue assessment" or "THEN continue assessment below", as applicable, to THEN continue assessment below clarify how the user should continue the PAR assessment.

BLQO( ,A IBLOCK A Page 13 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change 5 ELD SUL WH IE N Dose Assess m e nt o r f ie ld Surve y Changed the format of BLOCK A to be R oe

A res ults a re ava ilab le, consistent in all locations.

T f-l lEN GO 1 0 DtOOK .A Changed the statement "WHEN DOSE ASSESSMENT OR FIELD RESULTS

IRe,co mm end ALL of the following PAIRs: AVAILABLE RETURN / GO TO" to "WHEN Evacuate applicable PAZ(s) not already Dose Assessment or Field Survey results are

designated fo r evacuation available, THEN GO TO". Adding the word Survey is consistent with all other instances in Administ er :K l per SILO County Plan Appendix G. "Return" is not commonly used in DCPP procedures. "GO TO" is the common wording to direct the user to BLOCK A I. V CllA I ltl OC N O

0 Recomm end AILL of th e fo llow ing PAR:s: regardless if they have been there in the

!Evacuate th e Ocean t o 10 nautical miles process previously or not.

Ad minister Kl per SLO Co unt y Plan Reworded "EVACUATE APPLICABLE PAZ(s)

NOT ALREADY EVACUATED" to "Evacuate Recommend ALL of t he fo ll ow i ng PARs: applicable PAZ(s) not already designated for Evacu at e affected sect or A D adj acent evacuation" to align the PAR wording with the sectors in 2 mi le increm ents t o th e decision making wording.

d ist ance at wh ich eva ouatio n t hresh old is no l onger exceede d Reworded "ADMINISTER KI PER SLO Administ er :Kl per SLO Co unt y Plan COUNTY PLAN IN APPLICABLE PAZ(s)" to "Administer KI per SLO County Plan." This is consistent with the body of Appendix G and the THE GO 10 BLOCK A t o continue assessm ent Emergency Notification Form. There is no method on the form to differentiate where the Administer KI PAR is made, and the box remains checked as long as any PAR has 1E.i NY OF !EANY of the following occurs, TH EN GO TO BLOCK A to reassess PARs:

been made.

DiWGO ,....,......,~ *

Radiological co nditions chan ge.

RADI *

Wind direction changes such t hat an other PAZ may be affected.

After 60 minutes when a sheltering PAR has been made to chec k if the radiolog ica l release has stopped.

R

Dose Assessm ent or Field Survey resu lts beco me available. Removed the BLOCK B header from the last RADI D. block in the flowchart. Block B is not

DOSE referenced in any other part of the chart nor anywhere in Appendix G or EP RB-10.

Added the availability of Field Survey results Page 14 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change RPSA Wind Direction Table as a trigger for when PARs should be reassessed.

Wi nd Di rect ion Evacuat e Evacuate (fro m) PAZ Ocea n o* t o< 124* 1, 2 10 naut ica l mil es Changed the combination of PAZs for a given wind direction based on elimination of sliver 124" t o < 192" 1, 2,. 5 10 naut ica l mil es consideration. Changed the Evacuate Ocean 192" t o< 214" 1,2, 4, 5 10 naut ica l mil es PAR for the RPSA scenario to 10 nautical miles for all wind directions to implement the 214" t o < 259" 1, 2, 3, 4, 5 10 naut ica l mil es changes to Appendix G described above.

259" to< 304" 1, 2, 3,4 10 naut ica l mil es Refer to 10 CFR 50.54(q) effectiveness 304" to < 349* 1, 2,. 3 10 nau t ica l mil es evaluation 2023-14 for evaluation of the 349* t o 360" 1, 2 10 naut ica l mil es 2022 ETE report.

Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-17 for evaluation of the change to the RPSA Ocean PAR strategy.

Removed Wind Sector column as that information is not useful to the decision maker based on the DCPP site-specific PAR strategy.

Since the PAZs have been preassigned for each range of wind directions, providing the "from" sector will not aid the decision maker in determining the correct PAR. The wind direction provided by the ERO Meteorologist, plant data computers, and electronic notification form is provided in degrees from, rather than wind sector.

Table title change to clarify that the table is only used for rapidly progressing severe accidents.

Spelled out "nautical miles" and "evacuate" to improve the readability of the chart.

Reformatted Note 2 by removing bullets and indenting the "ANDs" to better align with the EAL wallcharts and plant procedures.

Refactored the final bulleted item from a Page 15 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change Original Content (Rev 4.02) Revised Content (Rev 5.00) Description of Change

2. A Rapldly Progressing S vcr Accidc Is 2. A Rapidly Progress ing Severe Accident is compound OR to a multiple ANY to list the oc-corr ng f & .or t e f ollowlng ar pres.en t: occurring if ALL of the follow ing are present : Table R-1 values to better align with the EAL

A G n ral Em g ncv was declared A General Emergency was declared wallcharts and plant procedures.

AND AND

lni ial ?AR In itial PAR Substituted the EAL RG1.1 met for any Table AND R-1 GE value with the actual Table R-1 GE Mm values. This does not change the intent or Any EAL Tab le F-1 Conta inment Barrier Loss

Any Contain 1ent loss. EAL applicable interpretation of the RPSA criteria but is rather AND ANY of the fo llowi ng : relocating information from Table R-1 in place

RM 30/3 > 5000 R/h r OR - AL RG 1.1 m~t

RM-30/31 > 5000 R/hr of a reference to Table R-1.

for any ble R-1 GE valu .

EAL RGl.1 met for RM-87 > 1.9E-10 amps

EAL RGl.1 met for RM-87 > 3.2E-1 µCi/cc Changed "field team results" to "field survey results" to be consistent with other references to field surveys on the wall chart.

3. Evacuation thresholds are based on dose

3. EVA CUAT IO N thresholds are based on dose assessment OR fie ld survey resu lts that are assessment .o.B fie ld team resu lts that are eithe r:

e ith e r:

GREATER THAN 1000 mrem TEDE

GREATER THAN 1000 mrem TEDE OR

.o.B

GREATER THAN 5000 mrem Thyroid CDE

GREATER THAN 5000 mrem Thyroid CDE 34 Section 7, References Section 7, References Updated KLD report reference to align with the 2022 ETE Report.

7.7 KLD TR-498, Diablo Canyon Power Plant 7.7 KLD TR-1235, Diablo Canyon Power Development of Evacuation Time Estimates, Plant Development of Evacuation Time Updated date reference to state and county Revision 1 Estimates, Revision 0 plans.

7.8 State of California Nuclear Power Plant 7.8 State of California Nuclear Power Plant Refer to 10 CFR 50.54(q) effectiveness Emergency Response Plan (2008) Emergency Response Plan (2019) evaluation 2023-14 for evaluation of the 2022 ETE report.

7.9 San Luis Obispo County/Cities Nuclear 7.9 San Luis Obispo County/Cities Nuclear Power Plant Emergency Response Plan (2014) Power Plant Emergency Response Plan (2022)

Page 16 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Addendum B Change 9 - Original Content - Staged Evacuation Comparison Tables Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R05 2:55 3:10 2:50 3:05 2:45 2:55 3:10 2:45 3:05 2:45 R22 3:20 3:55 3:20 3:35 3:20 3:20 3:35 3:20 3:35 3:20 Difference 0:25 0:45 0:30 0:30 0:35 0:25 0:25 0:35 0:30 0:35 Average 0:31 R05 represents the simultaneous evacuation of PAZ 1, 2, 5 R22 represents the staged evacuation of PAZ 1 & 2 first followed by 5 Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R06 2:55 3:15 2:55 3:10 2:50 2:55 3:10 2:50 3:05 2:50 R23 3:20 3:35 3:25 3:40 3:25 3:20 3:40 3:20 3:35 3:20 Difference 0:25 0:20 0:30 0:30 0:35 0:25 0:30 0:30 0:30 0:30 Average 0:28 R06 represents the simultaneous evacuation of PAZ 1, 2, 4, 5 R23 represents the staged evacuation of PAZ 1 & 2 first followed by 4 & 5 Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R03 2:45 3:00 2:45 3:00 2:50 2:50 3:05 2:45 2:55 2:45 R24 3:15 3:30 3:15 3:30 3:20 3:20 3:30 3:15 3:30 3:20 Difference 0:30 0:30 0:30 0:30 0:30 0:30 0:25 0:30 0:35 0:35 Average 0:30 R03 represents the simultaneous evacuation of PAZ 1, 2, 3, 4, 5 R24 represents the staged evacuation of PAZ 1 & 2 first followed by 3, 4 & 5 Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R07 1:35 1:45 1:25 1:40 1:35 1:35 1:40 1:25 1:40 1:40 R25 1:50 1:55 1:50 1:55 2:15 1:55 1:55 1:55 1:55 2:15 Difference 0:15 0:10 0:25 0:15 0:40 0:20 0:15 0:30 0:15 0:35 Average 0:22 R07 represents the simultaneous evacuation of PAZ 1, 2, 3, 4 R25 represents the staged evacuation of PAZ 1 & 2 first followed by 3 & 4 Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R08 1:40 1:45 1:25 1:35 1:30 1:35 1:40 1:25 1:30 1:35 R26 1:45 1:55 1:50 1:50 2:10 1:45 1:45 1:50 1:50 2:10 Difference 0:05 0:10 0:25 0:15 0:40 0:10 0:05 0:25 0:20 0:35 Average 0:19 R08 represents the simultaneous evacuation of PAZ 1, 2, 3 R26 represents the staged evacuation of PAZ 1 & 2 first followed by 3 Page 17 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change 9 - Revised Content - Staged Evacuation Comparison Tables Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R03 3:00 3:15 2:50 3:00 3:00 3:00 3:10 2:45 3:00 2:55 R23 3:25 3:40 3:25 3:35 3:30 3:30 3:40 3:25 3:40 3:30 Difference 0:25 0:25 0:35 0:35 0:30 0:30 0:30 0:40 0:40 0:35 Average 0:32 R03 represents the simultaneous evacuation of PAZ 1, 2, 3, 4, 5 R23 represents the staged evacuation of PAZ 1 & 2 first followed by 3, 4, & 5 Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R05 3:05 3:20 3:00 3:25 3:05 3:10 3:20 3:00 3:25 3:00 R21 3:40 4:10 3:35 3:50 3:35 3:40 4:00 3:35 3:55 3:35 Difference 0:35 0:50 0:35 0:25 0:30 0:30 0:40 0:35 0:30 0:35 Average 0:34 R05 represents the simultaneous evacuation of PAZ 1, 2, 5 R21 represents the staged evacuation of PAZ 1 & 2 first followed by 5 Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R06 3:10 3:30 3:05 3:20 3:10 3:10 3:25 3:05 3:20 3:05 R22 3:45 4:00 3:40 3:55 3:40 3:45 4:05 3:40 4:05 3:40 Difference 0:35 0:30 0:35 0:35 0:30 0:35 0:40 0:35 0:45 0:35 Average 0:35 R06 represents the simultaneous evacuation of PAZ 1, 2, 4, 5 R22 represents the staged evacuation of PAZ 1 & 2 first followed by 4 & 5 Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R07 2:00 2:05 1:45 1:55 1:55 1:55 2:05 1:50 2:00 2:05 R24 2:05 2:10 1:55 2:00 2:05 2:05 2:05 2:00 2:00 2:10 Difference 0:05 0:05 0:10 0:05 0:10 0:10 0:00 0:10 0:00 0:05 Average 0:06 R07 represents the simultaneous evacuation of PAZ 1, 2, 3, 4 R24 represents the staged evacuation of PAZ 1 & 2 first followed by 3 & 4 Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R08 1:55 2:05 1:45 1:55 1:45 2:00 2:05 1:45 1:55 1:55 R25 2:00 2:05 1:55 2:00 2:00 2:00 2:05 2:00 2:00 2:05 Difference 0:05 0:00 0:10 0:05 0:15 0:00 0:00 0:15 0:05 0:10 Average 0:06 R08 represents the simultaneous evacuation of PAZ 1, 2, 3 R25 represents the staged evacuation of PAZ 1 & 2 first followed by 3 Page 18 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change 15 & 16 - Original Content - EPZ Maps Page 19 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Page 20 of 31 Internal

Emergency Plan Appendix G Revision 5.00 EMERGENCY PLANNING ZONE Protective Action Zone (PAZ) 1-12, Public Education Zone (PEZ) 13-15 Monitoring, Decontamination and Recep~on Centers & Public School Relocation Centers Siren To Paso Robles, Paso Robles Event Center

_ _ _ _ _ _ _ _ _ _ _ (Mid-State Fairgrounds) & Camp Roberts Info SAN LUIS OBISPO BAY PACIFIC OCEAN San Luis Coastal Students Lucia Mar Students Cayucos Elementary Student, Page 21 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change 15 & 16 - Revised Content - EPZ Maps NW

/

WSW

~~

I \

/

I \ ,

1 ~

SW SE I \

SA¥ LlllS oe1SPO C0~

0Ff1CE OF EMERGENCY H.RVICES Or BlO CANYON POWER PLANT

\

STANDARD PROTECTIVE ACTION ZONE (PAZ} P l..oouceo BY THE SAN LUIS 084SPO COUN AGRICULTURE f EPAA.TNENT GIS TEAM Page 22 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Bayw Losloso Diablo Canyan Power Plant Avlia~

Shell~Beach PACIFIC San Luis Obispo ~ ~ each OCEAN Bay GrovJr\ B'each

\\ ) firoyo Grande Oceano 101 Page 23 of 31 Internal

Emergency Plan Appendix G Revision 5.00 EMERGENCY PLANNING ZONE MAP PROTECTIVE ACTION ZONES (PAZ) 1-12 , PUBLIC EDUCATION ZONES IPEZI 13-15 AND PUBLIC SCHOOL RELOCATION cmm

/

I I

DIABLO

\ CANYON POWER PLANT

\

PACIFIC N LUIS OBISPO BA Y

/

I B

+ -- - -

0 CE AN N

\I' "EVACUATION ROUTES

., PROTECIM ACTION ZONES IPAZ) 1*12

~ MllC EDUCAOON ZONES (PEZ) 13-15

- - ., FM NAUTlCAI.MllE SAFID ZONE

- - ., TEN NAUTlCAL MIi£ SAFETY ZONE Page 24 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change 17 - Original Content - NEI 12-10 PAR Methodology Flowchart Block Key General Emergency Declared (A) l Continue assessment Rapidly progressing maintain PAR (C) severe accident? (1}(B)

~

0 No

~

SIP (3) 2-mile radius /~

Do impediments fo . ._

evacuation ex ist(2} ' - Yes1 and 5 miles downwind ""'-

/ Im pediments "

(D)

(4 ), all others monitor rem oved?

and pr,epare (5) (E) (8} 1(F)

Yes No Yes 1 l l'

PA!R for 2-mile radius and Evacuate 2 mile radius 2-5 mile downwind,,

and SIP (3) 5 mil es depends on ETE (9), SIP GE cond itions downwind (4 ), all 1 4 - - - - - -Ye- - - - - -

5- 1o mi e downwind (4),, remain? (6) (I) all ollilers monitorand others monitor and prepare (5) (G) prepare (5) (H)

I When safer to do so, begin staged GE conditions

- - - - - - No- - - - - - " 1

,evacuation of all remain? (6) (K) affected areas (10) (J) Expand PAR only to areas wher,e PAGs could be exceeded (L)

After 2-mile ETE (7) evacuate 2-5 mifes downwind (4), all others monitor and prepare (5 ) {M)

L __ _ _ _ _ _ _"'l_ Continue assess ment (1 1) {N)

Page 25 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change 17 - Revised Content - NEI 12-10 PAR Methodology Flowchart Block Key General Emergen cy Declared (A)

Continue assessment mainrai n PA:R (C)

No SIP (3) 2-mile rad ius and 5 mi les downwind (4), all others monitor and prepare (5) (E}

Yes Yes PAR for 2-mile radius and Evacuate 2 mile rad ius 2-5 mile downwind, and SIP (3} 5 miles depends on ETIE (9), SIP downwind (4), all i . - - - - -Y11s~ , -------<..

5-10 mile downwirnd (4),

all olhers monitor arnd others mon itor and prepare (5) (G) prepare (5) ( H)

No, When safer to do so, beg in staged

>-- - - - -N10--- - - ---i 1

evacuation of all affected areas (10) (J) Expand PAR only ro areas where PAGs could be exceeded (L)

Yes I

After 2~m ile ETE (7) evacuate 2-5 miles downwind (4), all others monitor and prepare (5) (M)

Continue assessment

~ - - - - -~ (11}(N}

Change 22 - Original Content Mile EPZ Keyhole Evacuation Comparison Table Page 26 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Wind From Wind From (Sector) Ocean 0-6 Mile 6-10 Mile (Degrees) PAR PAZs PAZs 349° - 146° N, NNE, NE, ENE, E, ESE, SE 10 NM 1, 2 N/A 146° - 191° SSE, S 10 NM 1, 2 5 191° - 214° SSW 5 NM 1, 2 4, 5 214° - 236° SW 5 NM 1, 2 4, 5 236° - 259° WSW 5 NM 1, 2 3, 4, 5 259° - 281° W 5 NM 1, 2 3, 4 281° - 304° WNW 10 NM 1, 2 3, 4 304° - 349° NW, NNW 10 NM 1, 2 3 Change 22 - Revised Content Mile EPZ Keyhole Evacuation Comparison Table Wind From 0-6 Mile 6-10 Mile Ocean Affected Sectors (Degrees) PAZs PAZs PAR 349° to < 012° SSW S SSE 1, 2 N/A 10 NM 012° to < 034° SW SSW S 1, 2 N/A 10 NM 034° to < 057° WSW SW SSW 1, 2 N/A 10 NM 057° to < 079° W WSW SW 1, 2 N/A 10 NM 079° to < 102° WNW W WSW 1, 2 N/A 10 NM 102° to < 124° NW WNW W 1, 2 N/A 10 NM 124° to < 147° NNW NW WNW 1, 2 5 10 NM 147° to < 169° N NNW NW 1, 2 5 10 NM 169° to < 192° NNE N NNW 1, 2 5 10 NM 192° to < 214° NE NNE N 1, 2 4, 5 10 NM 214° to < 237° ENE NE NNE 1, 2 3, 4, 5 10 NM 237° to < 259° E ENE NE 1, 2 3, 4, 5 10 NM 259° to < 282° ESE E ENE 1, 2 3, 4 10 NM 282° to < 304° SE ESE E 1, 2 3, 4 10 NM 304° to < 327° SSE SE ESE 1, 2 3 10 NM 327° to < 349° S SSE SE 1, 2 3 10 NM Page 27 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change 26 - Original Content - PAZ 1 & 2 Staged Evacuation Comparison Table Scenario (1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

/ Region R02 1:10 1:10 1:10 1:10 1:15 1:10 1:10 1:15 1:15 1:20 R21 1:15 1:15 1:35 1:35 1:45 1:15 1:20 1:45 1:45 1:50 Difference 0:05 0:05 0:25 0:25 0:30 0:05 0:10 0:30 0:30 0:30 Average: 0:19 R02 represents the simultaneous evacuation of PAZ 1 & 2 R21 represents the staged evacuation of PAZ 1 & 2 Change 26 - Revised Content - PAZ 1 & 2 Staged Evacuation Comparison Table Scenario (1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

/ Region R02 1:15 1:15 1:30 1:30 1:25 1:15 1:15 1:45 1:45 1:30 R20 1:15 1:15 1:30 1:30 1:30 1:15 1:15 1:45 1:45 1:30 Difference 0:00 0:00 0:00 0:00 0:05 0:00 0:00 0:00 0:00 0:00 Average: 0:00 R02 represents the simultaneous evacuation of PAZ 1 & 2 R20 represents the staged evacuation of PAZ 1 first followed by 2 Page 28 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change 28 - Original Content Mile EPZ Keyhole Evacuation Comparison Table Wind From Wind From (Sector) Ocean 0-6 Mile 6-10 Mile 10-22 Mile PAZs (Degrees) PAR PAZs PAZs 326° - 146° NNW, N, NNE, NE, ENE, E, ESE, SE 10 NM 1, 2 12 146° - 191° SSE, S 10 NM 1, 2 5 9 191° - 214° SSW 5 NM 1, 2 4, 5 8, 9 214° - 236° SW 5 NM 1, 2 4, 5 8, 9 236° - 259° WSW 5 NM 1, 2 3, 4, 5 7, 8, 9, 11 259° - 281° W 5 NM 1, 2 3, 4 6, 7, 8, 10, 11, 12 281° - 304° WNW 10 NM 1, 2 3, 4 6, 7, 8, 10, 11, 12 304° - 326° NW 10 NM 1, 2 3 6, 7, 10, 11, 12 Change 28 - Revised Content Mile EPZ Keyhole Evacuation Comparison Table Wind From 0-6 Mile 6-10 Mile 10-22 Mile Affected Sectors (Degrees) PAZs PAZs PAZs 349° to < 012° SSW S SSE 1, 2 N/A N/A 012° to < 034° SW SSW S 1, 2 N/A N/A 034° to < 057° WSW SW SSW 1, 2 N/A N/A 057° to < 079° W WSW SW 1, 2 N/A N/A 079° to < 102° WNW W WSW 1, 2 N/A N/A 102° to < 124° NW WNW W 1, 2 N/A N/A 124° to < 147° NNW NW WNW 1, 2 5 9 147° to < 169° N NNW NW 1, 2 5 9 169° to < 192° NNE N NNW 1, 2 5 9 192° to < 214° NE NNE N 1, 2 4, 5 8, 9 214° to < 237° ENE NE NNE 1, 2 3, 4, 5 8, 9 237° to < 259° E ENE NE 1, 2 3, 4, 5 7, 8, 9, 11 259° to < 282° ESE E ENE 1, 2 3, 4 6, 7, 8, 10, 11, 12 282° to < 304° SE ESE E 1, 2 3, 4 6, 7, 8, 10, 11, 12 304° to < 327° SSE SE ESE 1, 2 3 6, 7, 10, 11, 12 327° to < 349° S SSE SE 1, 2 3 10, 12 Page 29 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change 33 - Original Content - DCPP Site Specific PAR Flowchart

IVAQJATf PA21 MID}

TUAZ.113, 5 FIER Ii*

.., n O<lNi 5

- U!. MSU.V.,EHl' ELTlR PAZ l Alfll l CVAWATI AOfwl iS.lU I I' \LO C<M.JPHY p

MLOJl-iEi MZi

M 0A 11110 Ii lllil Cl~ P<KSIII IIII01ICTI\IE A.CTllff5

. OTES If.fl 11n k m*-1.1..1~ ~ " 0-,

, W. U"'T APfUC.- LIE Pi\llsl OJ A. Ra Ing$~ c den I~

All!AD'I' !\IA.QJATl!O ti\ 'fo,11:owl n rt' preSi!llt:

merg1mcy was dll!c:Jarl!d NO

Any C.ont inm nt lQS'S l ppr I,

RM 30/31 > S000 R/hr I. RG U met FO!I' anv a11)1e R*l GE var~.

3. EVACUATION lhresh ds are base o dos,~

assessment gB, 'fle<ld tum ruults lih t are llhtt:

GR.

OR

r.vMlJAT! AJJE:ClliDSl!CIDR "troid CDE JAC[ NT SlCTOIIS I .! 4 iti1m~ h r;;;iu ma.ling rfflQred. ooo

egr ity rfflQfeG, tc.),

JJE;tW e11pa e PAR~ ,Wll be SWCOUrm'l"lAN a propriate.

5--. F *

ri5k to the ~

Ion~ ~r IIH;Jt C i,AR, slioll!'ld b d.

1ml tee! 'IO S 0*COUllt:y,

-t y n - ~ for ' ew ntdu

.l!Qti.m is~ a, SH LU il PAR Fata PAZ '

wa~ p;rewiously i!ls d ii* EV CiUATIO PA R.

8. Dose ass.essmerrt re5111 It$.are required orxe a1 r ~est,nt~ and continu 11ntil e*

eme!)!enr;:y ,e vent

r *n.-ted.

Page 30 of 31 Internal

Emergency Plan Appendix G Revision 5.00 Change 33 - Revised Content - DCPP Site Specific PAR Flowchart General Emergency Declared Recommend ALL of the following PARs:

Evacuate PAZ 1 and 2 Evacuate PAZ(s) 3, 4, 5 per RPSA Wind Direction Table Event is a Rapidly Progressing Severe Initial PAR Evacuate Ocean to 10 nautical miles YES YES Accident? assessment? Administer KI per SLO County Plan (Note 2) All other PAZs Monitor and Prepare NO THEN GO TO BLOCK A to continue assessment NO Recommend ALL of the following PARs:

Is this a Controlled Shelter PAZ 1 and 2 RPSA Wind Direction Table Short Term Release YES Evacuate Ocean to 5 nautical miles Wind Direction Evacuate Evacuate T < 60 minutes? Administer KI per SLO County Plan (from) PAZ Ocean All other PAZs Monitor and Prepare NO 0° to < 124° 1, 2 10 nautical miles THEN GO TO BLOCK A to continue assessment 124° to < 192° 1, 2, 5 10 nautical miles Recommend ALL of the following PARs:

Evacuate PAZ 1 and 2 192° to < 214° 1, 2, 4, 5 10 nautical miles Evacuate Ocean to 5 nautical miles 214° to < 259° 1, 2, 3, 4, 5 10 nautical miles Administer KI per SLO County Plan All other PAZs Monitor and Prepare BLOCK A 259° to < 304° 1, 2, 3, 4 10 nautical miles 304° to < 349° 1, 2, 3 10 nautical miles THEN continue assessment below 349° to 360° 1, 2 10 nautical miles NOTES Dose Assessment or Field Survey results available?

YES NO

,= WHEN Dose Assessment or Field Survey results are available, THEN GO TO -BLOCK A I

1. -IF flowchart decision block conditions are unknown, -THEN answer "NO".

2. A Rapidly Progressing Severe Accident is occurring if ALL of the following are present:

A General Emergency was declared AND Evacuation Recommend ALL of the following PARs: Initial PAR threshold exceeded in Evacuate applicable PAZ(s) not already AND ANY PAZ NOT previously YES designated for Evacuation? designated for evacuation Any EAL Table F-1 Containment Barrier Loss Administer KI per SLO County Plan AND ANY of the following:

RM-30/31 > 5000 R/hr NO I

EAL RG1.1 met for RM-87 > 1.9E-10 amps

EAL RG1.1 met for RM-87 > 3.2E-1 µCi/cc Evacuation Recommend ALL of the following PARs: 3. Evacuation thresholds are based on dose threshold exceeded in assessment OR field survey results that are Ocean beyond 5 miles? YES---+ Evacuate the Ocean to 10 nautical miles Administer KI per SLO County Plan either:

GREATER THAN 1000 mrem TEDE OR NO I

GREATER THAN 5000 mrem Thyroid CDE

4. -IF the plant has mitigated the conditions that Recommend ALL of the following PARs:

caused the GE declaration (i.e., core cooling Evacuation threshold exceeded Evacuate affected sector AND adjacent restored, containment integrity restored, etc.),

beyond PAZ 8, 9, 11 or 12 YES ---+

OR Ocean beyond 10 sectors in 2 mile increments to the

-THEN expanding the PAR - MAY -NOT be distance at which evacuation threshold is miles?

no longer exceeded appropriate.

Administer KI per SLO County Plan 5. -IF there is no longer a risk to the public because NO the GE conditions are not currently present, THEN GO TO -BLOCK A to continue assessment -THEN no new PAR should be issued.

6. Once a PAR is communicated to SLO County, the PAR stays in effect for the event duration.

IF ANY of the following occurs, THEN GO TO BLOCK A to reassess PARs: 7. Do NOT issue a SHELTER PAR for a PAZ that was

Radiological conditions change. previously issued an EVACUATION PAR.

Wind direction changes such that another PAZ may be affected. 8. Dose assessment results are required once a

After 60 minutes when a sheltering PAR has been made to check if the radiological release has stopped. release starts and continue until the emergency

Dose Assessment or Field Survey results become available. event is terminated.

Page 31 of 31 Internal

Enclosure 4 PG&E Letter DCL-23-128 PG&E Letter DIL-23-010 Current revision of Emergency Plan Appendix E, Revision 5.00, Evacuation Time Estimates

E-Plan Appendix E - Diablo Canyon Power Plant Emergency Plan Page 1 of 9 Evacuation Time Estimates In order to ensure the safety of the public living in the vicinity of nuclear power plants in the nation, the U.S. Nuclear Regulatory Commission (NRC) requires licensees to develop and update evacuation times estimates (ETEs) for areas within the emergency planning zone (EPZ). Updates are required following the availability of data from the decennial census (10 years) or when the sensitivity factor for changes in population within the EPZ has been exceeded. This appendix contains information from the ETE update performed in 2022. This update implements the requirements of the revised regulations relevant to ETE updates in accordance with the guidance provided in NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies.

Pacific Gas and Electric (PG&E) contracted KLD Engineering, P.C to estimate evacuation times for the 20201 populations within the plume exposure pathway emergency planning zone (EPZ)

(reference Figure E-1) surrounding the Diablo Canyon Power Plant (DCPP). This appendix provides a summary of the final report describing the methods used to obtain population data and estimated population figures, evacuation road network information, and ETEs.

The report provides a breakdown of the population by geographic areas and protective action zones (PAZ). Five categories of population are identified in the report:

Permanent residents Transient population Transit dependent permanent residents Special facility residents Schools The permanent resident population is made up of individuals residing in the EPZ. The total year 2020 permanent resident populations within the EPZ for DCPP are estimated to be 152,149 (reference Table E-1).

The transient population consists of workers employed within the area, recreational sportsmen, and visitors. The total peak transient population within the EPZ is estimated to be 41,056. Sixty-one schools were identified in the DCPP EPZ. KLD Engineering, P.C. contacted the schools to collect current enrollment, staff figures, and the evacuation plan. The total peak population for the schools in the EPZ is estimated to be 52,804.

Transit dependent permanent residents in the EPZ are estimated to be 1,512. This study also considered the voluntary evacuees, who are also known as shadow evacuees that reside within approximately 20 miles from DCPP. KLD Engineering, P.C. used a computer traffic simulation model, DYNEV II, to perform the ETE analyses. For the analyses, the plume exposure pathway EPZ was divided into 12 zones with unique geographic areas including two-mile, six-mile, and the EPZ radius rings, as well as staged evacuation logic. In order to represent the most realistic emergency scenarios, evacuations for the 12 geographic PAZs were modeled individually for the midweek daytime, midweek - weekend evening, and weekend daytime scenarios. Each of these scenarios was then considered under both normal and adverse weather conditions using the 2020 population estimates. A total of 300 evacuation scenarios were considered as part of this study to represent different time of day, staged evacuation, temporal, seasonal and weather conditions (reference Table E-2).

1 KLD report TR-1235, pages 1-10 contain the population figures provided on this page.

E-Plan_Appendix_Eu3r00.DOC 0925.1445 Rev 5.00

E-Plan Appendix E - Diablo Canyon Power Plant Emergency Plan Page 2 of 9 Evacuation Time Estimates Both 100% (Reference Table E-4) and 90% (Reference Table E-3) ETEs for each scenario were collected. Table E-5 defines each of the 25 Evacuation Regions in terms of their respective groups of PAZ and wind direction, as applicable. ..L The factors that contributed to the variations in ETEs between scenarios include differences in the number of evacuating vehicles, the capacity of the evacuation routes used, and/or the distance from the origin PAZ to the EPZ boundary.

Based on the data gathered and the results of the evacuation simulations, the existing evacuation strategy was determined to be functional for the 2022 conditions.

Assumptions used in the ETE will be reviewed when evaluating changes to roadways or evacuation networks to ensure the results of the ETE remain valid. Changes in population will be evaluated using the sensitivity factor developed during the ETE analysis.

One special event case and one major road impediment case were also prepared in the ETE as described in the guidance document.

The full Evacuation Time Estimate was submitted for NRC review in accordance with 10 CFR 50, Appendix E. Following the NRC review, the results of the study and recommendations were reviewed with applicable offsite agencies. The review focused upon utilization of the results of ETE evacuation simulations for comparison to existing protective action strategies.

E-Plan_Appendix_Eu3r00.DOC 0925.1445 Rev 5.00

E-Plan_Appendix_Eu3r00.DOC 0925.1445 E-Plan Appendix E - Diablo Canyon Power Plant Emergency Plan

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E-Plan Appendix E - Diablo Canyon Power Plant Emergency Plan Page 4 of 9 Evacuation Time Estimates Table E-1: EPZ Permanent Resident Population 2010 2020 PAZ Population Population 1 0 0 2 168 160 3 2,736 2,846 4 713 521 5 14,217 14,485 6 6,562 7,170 7 281 85 8 60,962 63,286 9 13,126 13,733 10 37,476 38,380 11 4,205 4,454 12 6,775 7,029 TOTAL 147,221 152,149 EPZ Population Growth: 3.35%

E-Plan_Appendix_Eu3r00.DOC 0925.1445 Rev 5.00

E-Plan Appendix E - Diablo Canyon Power Plant Emergency Plan Page 5 of 9 Evacuation Time Estimates Table E-2: Evacuation Scenario Definitions Day of Scenarios Season2 Week Time of Day Weather Special 1 Summer Midweek Midday Good None 2 Summer Midweek Midday Rain None 3 Summer Weekend Midday Good None 4 Summer Weekend Midday Rain None Midweek, 5 Summer Evening Good None Weekend 6 Winter Midweek Midday Good None 7 Winter Midweek Midday Rain None 8 Winter Weekend Midday Good None 9 Winter Weekend Midday Rain None Midweek, 10 Winter Evening Good None Weekend Firework Shows at Avila Beach3, 11 Summer Midweek Evening Good Pismo Beach, and Morro Bay Harbor Lane Closure outbound on 12 Summer Midweek Midday Good US 101 Southbound 2

Winter assumes that school is in session (also applies to spring and autumn). Summer assumes that school is not in session.

3 Transients present at Avila Beach to observe the fireworks show at Pismo Beach E-Plan_Appendix_Eu3r00.DOC 0925.1445 Rev 5.00

E-Plan_Appendix_Eu3r00.DOC 0925.1445 E-Plan Appendix E - Diablo Canyon Power Plant Emergency Plan Table E-3. Time to Clear the Indicated Area of 90 Percent of the Affected Population Summe.r Summer Sumrne,r Winter Winte,r Winter Summer Summer Midweek Midweek Midweek Midweek Weekend Midweek Weekend Midweek Weekend Weekend Weekend Scenario: {1} (2) (3) (4) (5) (6) (7) (8) (9) (10} (11} (12)

Midday Midday Evening Midday Midday Evening Evening Midday Region Good Good Good Good Good Good Special Roadway Rain Rain Rain Rain Weather Weather Weather Weather Weather Weather Event Impact Entire 2-Mile Region, 6-Mile Region, FEMA EPZ and Full EPZ R01 (PAZ 1) 1:00 1:00 1:00 1:00 1:00 1:00 1:00 1:00 1:00 1:00 1:00 1:00 R02 (PAZ 1, 2) 1:15 1:15 1:30 1:30 1:25 1:15 1:15 1:45 1:45 1:30 1:25 1:15 R03 (PAZ 1, 2, 3, 4, 5) 3:00 3:15 2:50 3:00 3:00 3:00 3:10 2:45 3:00 2:55 3:15 3:35 R04 (PAZ 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12) 8:40 9:35 8:15 9:05 8:20 9:10 10:05 7:55 8:45 8:10 14: 30 11:05 6-Mile Ring and Keyhole to FEMA EPZ Evacuation Time Estimates ROS (PAZ 1, 2, 5) 3:05 3:20 3:00 3:25 3:05 3:10 3:20 3:00 3:25 3:00 3:05 3:05 R06 (PAZ 1, 2, 4, 5) 3:10 3:30 3:05 3:20 3:10 3:10 3:25 3:05 3:20 3:05 3:15 3:30 R07 (PAZ 1, 2, 3, 4) 2:00 2:05 1:45 1:55 1 :55 1:55 2:05 1:50 2:00 2:05 3:05 3:40 R08 (PAZ 1, 2, 3) 1:55 2:05 1:45 1:55 1 :45 2:00 2:05 1:45 1:55 1 :55 3:05 3:35 Evacuate 6-Mile Radius and Downwind to Full EPZ Boundary R09 (PAZ 1, 2, 5, 9) 4:15 4:20 4: 05 4:20 4:00 4:05 4:25 3:50 4:10 4:00 5:55 4:15 R10 (PAZ 1, 2, 4, 5, 8, 9) 5:30 6:15 4:40 5:35 5:00 6:05 6:50 4:50 5:20 4:50 7:15 7:00 R11 (PAZ 1, 2, 3, 4, 5, 8, 9) 5:20 6:05 4:50 5:15 4:35 6:10 6:55 4: 45 5:15 4:35 7:30 7:00 R12 (PAZ 1, 2, 3, 4, 5, 7, 8, 9, 11) 5:35 6:00 4:55 5:30 4:40 6:15 7:05 5:00 5:40 4:40 7:30 7:00 R13 (PAZ 1, 2, 3, 4, 6, 7, 8, 10, 11, 12) 8:40 9:20 8:05 9:15 8:40 8:25 9:20 7:40 8:25 8:00 13:50 12:00 R14 (PAZ 1, 2, 3, 6, 7, 10, 11, 12) 6:40 7:25 7:00 7:40 7:10 6:45 7:35 6:20 7:10 6:30 12:45 10:15 R15 (PAZ 1, 2, 3, 10, 12) 5:55 6:40 5:50 6:35 6:20 5:35 6: 40 5:30 6:10 5:35 7:25 9:00 Site Specific Regions R16 (PAZ 1, 2, 4) 1:50 1:50 2:10 2:10 2:15 1:50 1:50 2:25 2:25 2:20 2:15 1:50 R17 (PAZ 1, 2, 3, 6) 2:55 3:10 2:55 3:15 2:45 2:45 3:05 2:40 2:55 2:25 9:20 5:10 R18 (PAZ 3, 4) 1:55 2:05 1:45 1:55 1 :55 2:00 2:05 1:45 1:55 2:05 3:05 3:45 R19 (PAZ 4, 5) 3:10 3:25 3:00 3:20 3:05 3:15 3:25 3:00 3:20 3:00 3:05 3:15 Staged Evacuation Mile Radius Evacuates, then Evacuate Downwind to 6 Miles R.20 (PAZ 1, 2) 1:15 1:15 1:30 1:30 1:30 1:15 1:15 1:45 1:45 1:30 1:30 1:15 Staged Evacuation Mile Radius Evacuates, then Evacuate Downwind to FEMA EPZ R21 (PAZ 1, 2, 5) 3:40 4:10 3:35 3:50 3:35 3:40 4:00 3:35 3:55 3:35 3:40 3:45 R22 (PAZ 1, 2, 4, 5) 3:45 4: 00 3:40 3:55 3:40 3:45 4:05 3:40 4:05 3:40 3:40 3:45 R.23 (PAZ 1, 2, 3, 4, 5) 3:25 3:40 3:25 3:35 3:30 3:30 3:40 3:25 3:40 3:30 3:30 4:00 Page 6 of 9 R24 (PAZ 1, 2, 3, 4) 2:05 2:10 1:55 2:00 2:05 2:05 2:05 2:00 2:00 2:10 3:05 3:35 R25 (PAZ 1, 2, 3) 2:00 2:05 1:55 2:00 2:00 2:00 2:05 2:00 2:00 2:05 3:10 3:35 Rev 5.00

E-Plan_Appendix_Eu3r00.DOC 0925.1445 E-Plan Appendix E - Diablo Canyon Power Plant Emergency Plan Table E-4. Time to Clear the Ind icated Area of 100 Percent of the Affected Population Summer Summer Summer Winter Winter Winter Summer Summer Midweek Midweek Midweek Midweek Weekend Midweek Weekend Midweek Weekend Weekend Weekend Sceriario: (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12)

Midday Midday Evening Midday Midday Evening Evening Midday Region Good Good Good Good Good Good Specia l Roadway Rain Rain Rain Rain Weather Weather Weather Weather Weather Weather Event Impact Entire 2-Mile Region, 6-Mile Region, FEMA EPZ and Full EPZ R01 (PAZ 1) 1:35 1:35 1:30 1:30 1 :30 1:35 1:35 1:30 1:30 1 :30 1 :30 1:35 R02 {PAZ 1, 2) 4:50 4:50 4:50 4:50 4:50 4:50 4 :50 4:50 4:50 4:50 4:50 4:50 R03 {PAZ 1, 2, 3, 4, 5) 4:55 4:55 4:55 4:55 4:55 4:55 4 :55 4:55 4:55 4:55 4:55 4:55 R04 {PAZ 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12) 10:50 12:10 10:50 11:55 11:45 11:05 12:10 10:05 10:50 10:35 20 :10 15:00 6-Mile Ring and Keyhole to FEMA EPZ Evacuation Time Estimates ROS (PAZ 1, 2, 5) 4:55 4:55 4:55 4:55 4:55 4:55 4:55 4:55 4:55 4:55 4:55 4:55 R06 (PAZ 1, 2, 4, 5) 4: 55 4:55 4:55 4:55 4:55 4:55 4 :55 4:55 4:55 4:55 4 :55 4:55 R07 (PAZ 1, 2, 3, 4) 4:55 4:55 4:55 4:55 4:55 4:55 4 :55 4:55 4:55 4:55 4:55 4:55 R08 {PAZ 1, 2, 3) 4:55 4:55 4:55 4:55 4:55 4:55 4 :55 4:55 4:55 4:55 4:55 4:55 Evacuate 6-Miile Radius and Downwind to Full EPZ Boundary R09 (PAZ 1, 2, 5, 9) 5:10 5:35 5:15 5:40 5: 10 5:10 5:45 5:00 5:10 5: 10 7: 00 5:15 R10 {PAZ 1, 2, 4, 5, 8, 9) 8:10 9:10 7:05 8:20 7:10 9:0 0 10:10 7:15 8:00 7:10 9:40 9:25 Rll (PAZ 1, 2, 3, 4, 5, 8, 9) 8:30 9:20 8:50 9:30 9:05 7:50 8:50 7:45 8:2 5 8:10 10 :10 11:00 R12 {PAZ 1, 2, 3, 4, 5, 7, 8, 9, 11) 8:25 9:15 7:45 8:25 7:20 9:20 10:35 7:50 8:25 7:25 10:05 9:20 R13 (PAZ 1, 2, 3, 4, 6, 7, 8, 10, 11, 12) 10:50 11:45 10:35 11:50 11:20 10:20 11:30 9:20 10:05 9 :50 18:55 15:15 R14 (PAZ 1, 2, 3, 6, 7, 10, 11, 12) 9:00 9:55 9:40 10:05 9:45 8:45 9:35 8 :15 9:10 8:55 18:35 12: 40 R15 (PAZ 1, 2, 3, 10, 12) 8:15 9:10 7:35 8:05 7:10 9:15 10:05 7:25 8:05 7: 05 12:30 9:20 Site Specific Regions R16 (PAZ 1, 2, 4) 4:55 4:55 4:55 4:55 4:55 4:55 4 :55 4 :55 4:55 4 :55 4:55 4:55 R17 (PAZ 1, 2, 3, 6) 5:00 5:00 5:00 5:00 5:00 5:00 5:00 5:00 5:00 5:00 13 :40 6:15 R18 {PAZ 3, 4) 4:55 4:55 4:55 4:55 4:55 4:55 4 :55 4:55 4:55 4:55 4:55 4:55 R19 {PAZ 4, 5) 4:55 4:55 4:55 4:55 4:55 4:55 4 :55 4:55 4:55 4:55 4:55 4:55 Sta~ed Evacuation Mile Radius Evacuates, t hen Evacuate Downwind to 6 Miles R20 {PAZ 1, 2) 4:50 4:50 4:50 4:50 4:50 4:50 4 :50 4:50 4:50 4:50 4:50 4:50 Staged Evacuation Mile Radius Evacuates, then Evacuate Downwind to FEMA EPZ R21 (PAZ 1, 2, 5) 4:55 4:55 4:55 4:55 4:55 4:55 4 :55 4:55 4:55 4:55 4:55 4:55 R22 (PAZ 1, 2, 4, 5) 4:55 4:55 4:55 4:55 4 :55 4:55 4 :55 4:55 4:55 4:55 4 :55 4:55 R23 (PAZ 1, 2, 3, 4, 5) 4: 55 4:55 4:55 4:55 4:55 4:55 4 :55 4:55 4:55 4 :55 4 :55 4:55 Page 7 of 9 R24 (PAZ 1, 2, 3, 4) 4:55 4:55 4:55 4:55 4:55 4:55 4 :55 4:55 4:55 4:55 4 :55 4:55 R25 (PAZ 1, 2, 3) 4:55 4:55 4:55 4:55 4:55 4:55 4 :55 4:55 4:55 4 :55 4:55 4:55 Rev 5.00

E-Plan Appendix E - Diablo Canyon Power Plant Emergency Plan Page 8 of 9 Evacuation Time Estimates Table E-5: Description of Evacuation Regions PAZ Region Description 1 2 3 4 5 6 7 8 9 10 11 12 R01 2-Mile Ring X 6-Mile Ring R02 X X (similar to the FEMA 5-mile ring)

R03 FEMA EPZ X X X X X R04 Full EPZ X X X X X X X X X X X X Evacuate 2-Mile Radius and Downwind to 6 Miles Wind Direction PAZ Region From: 1 2 3 4 5 6 7 8 9 10 11 12 ESE, SE, SSE, S, SSW, SW,

- Refer to Region R02 WSW, W, WNW, NW, NNW

- N, NNE, NE, ENE, E Refer to Region R01 Evacuate 6-Mile Radius and Downwind to 10 miles Wind Direction PAZ Region From: 1 2 3 4 5 6 7 8 9 10 11 12 R05 SE, SSE, S X X X R06 SSW X X X X

- SW, WSW Refer to Region R03 R07 W, WNW X X X X R08 NW, NNW X X X

- N, NNE, NE, ENE, E, ESE Refer to Region R02 Evacuate 6-Mile Radius and Downwind to EPZ Boundary Wind Direction PAZ Region From: 1 2 3 4 5 6 7 8 9 10 11 12 R09 SE, SSE, S X X X X R10 SSW X X X X X X R11 SW X X X X X X X R12 WSW X X X X X X X X X R13 W, WNW X X X X X X X X X X R14 NW X X X X X X X X R15 NNW X X X X X

- N, NNE, NE, ENE, E, ESE Refer to Region R02 E-Plan_Appendix_Eu3r00.DOC 0925.1445 Rev 5.00

E-Plan Appendix E - Diablo Canyon Power Plant Emergency Plan Page 9 of 9 Evacuation Time Estimates Table E-5: Description of Evacuation Regions (continued)

Site Specific Regions PAZ Wind Direction Region From: 1 2 3 4 5 6 7 8 9 10 11 12 R16 - X X X R17 - X X X X R18 - X X X X R19 - X X X X Advanced Emergency Classification, 100% of the PAZ(s) PAZ(s) Monitor and PAZ(s) already evacuated Prepare Evacuate Staged Evacuation Mile Radius Evacuates, then Evacuate Downwind to 6 Miles Wind Direction PAZ Region From:

1 2 3 4 5 6 7 8 9 10 11 12 ESE, SE, SSE, S, SSW, SW, R20 X X WSW, W, WNW, NW, NNW

- N, NNE, NE, ENE, E Refer to Region R01 PAZ(s) Monitor and PAZ(s)

Shelter-in-Place until 90% ETE for R01, then Evacuate Prepare Evacuate Staged Evacuation Mile Radius Evacuates, then Evacuate Downwind to 10 Miles Wind Direction PAZ Region From: 1 2 3 4 5 6 7 8 9 10 11 12 R21 SE, SSE, S X X X R22 SSW X X X X R23 SW, WSW (& FEMA EPZ) X X X X X R24 W, WNW X X X X R25 NW, NNW X X X

- N, NNE, NE, ENE, E, ESE Refer to Region R02 PAZ(s) Monitor and PAZ(s)

Shelter-in-Place until 90% ETE for R02, then Evacuate Prepare Evacuate E-Plan_Appendix_Eu3r00.DOC 0925.1445 Rev 5.00

Enclosure 5 PG&E Letter DCL-23-128 PG&E Letter DIL-23-010 Current revision of Emergency Plan Appendix G, Revision 5.00, Protective Action Recommendation (PAR) Strategy Bases

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 1 of 51 Protective Action Recommendation (PAR) Strategy Bases Table of Contents

1. INTRODUCTION.................................................................................................................. 3

2. NUREG-0654 SUPPLEMENT 3 GUIDANCE AND DCPP SITE SPECIFIC PAR DEVELOPMENT BASES ..................................................................................................... 4 2.1 Development of DCPP Site Specific PAR Methodology and Decision Logic ............... 4 2.1.1 Federal Guidance ......................................................................................... 4 2.1.2 DCPP Site Specific Bases............................................................................. 5 2.2 Notification of PARs at a General Emergency ............................................................. 6 2.2.1 Federal Guidance ......................................................................................... 6 2.2.2 DCPP Site Specific Bases............................................................................. 6 2.3 Termination of Protective Actions................................................................................ 8 2.3.1 Federal Guidance ......................................................................................... 8 2.3.2 DCPP Site Specific Bases............................................................................. 8 2.4 Precautionary Protective Actions at the Site Area Emergency Classification Level ..... 8 2.4.1 Federal Guidance ......................................................................................... 8 2.4.2 DCPP Site Specific Bases............................................................................. 9 2.5 Wind Persistence Issues........................................................................................... 10 2.5.1 Federal Guidance ....................................................................................... 10 2.5.2 DCPP Site Specific Bases........................................................................... 10 2.6 Expansion of Initial Protective Action Recommendations .......................................... 12 2.6.1 Federal Guidance ....................................................................................... 12 2.6.2 DCPP Site Specific Bases........................................................................... 12 2.7 Strategy for Rapidly Progressing Scenarios .............................................................. 14 2.7.1 Federal Guidance ....................................................................................... 14 2.7.2 DCPP Site Specific Bases........................................................................... 15

3. BASIS OF THE DCPP PLUME EXPOSURE PATHWAY EMERGENCY PLANNING ZONE (EPZ)....................................................................................................................... 18

4. APPROVED DCPP EMERGENCY PLAN PAR DETERMINATION METHODOLOGY ....... 28 4.1 Criteria Based Upon Nature of Emergency (Plant-Based PARs) ............................... 28 4.2 Criteria Based Upon Public Exposure (Dose-Based PARs) ...................................... 29

5. DCPP SITE SPECIFIC PAR METHODOLOGY FLOWCHART BASES.............................. 30 5.1 NUREG-0654 Supplement 3 / NEI 12-10 PAR Methodology Flowchart Block Key.... 30 5.1.1 Block A: PAR Determination Methodology Entry Point ................................ 31 5.1.2 Block B: Rapidly Progressing Severe Accident Scenario Decision Point ..... 31 5.1.3 Block G: Rapidly Progressing Severe Accident Scenario PAR Determination.............................................................................................. 32 5.1.4 Block J: Evacuation Timing for Rapidly Progressing Severe Accident Scenarios .................................................................................................... 36 5.1.5 Block D: Impediments to Evacuation Decision Point ................................... 36 5.1.6 Block E: With Impediments Minimum Plant Based PAR .............................. 38 5.1.7 Block F: Impediments Removed.................................................................. 39 5.1.8 Block H: No Impediments Minimum Plant Based PAR ................................ 40 5.1.9 Block M: Evacuation Timing for Downwind Sectors ..................................... 41 5.1.10 Blocks C and N: Continue Assessment ....................................................... 44 5.1.11 Blocks I and K: General Emergency Conditions Remain ............................. 45 5.1.12 Block L: PAR Expansion Only When Protective Action Guidelines (PAGs) Exceeded ....................................................................................... 46 5.2 Additional Protective Action Recommendation 1: Ocean PAR .................................. 46 5.2.1 DCPP Site Specific Bases........................................................................... 46 E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 2 of 51 Protective Action Recommendation (PAR) Strategy Bases 5.3 Additional Protective Action Recommendation 2: Short Term Release ..................... 48 5.3.1 DCPP Site Specific Bases........................................................................... 48 5.4 Additional Protective Action Recommendation 3: Administer Potassium Iodine (KI)

In Accordance With the County Plan......................................................................... 48 5.4.1 DCPP Site Specific Bases........................................................................... 49 5.5 Additional Protective Action Recommendation 4: Plume exposure beyond the EPZ. ......................................................................................................................... 49 5.5.1 DCPP Site Specific Bases........................................................................... 49

6. DCPP SITE SPECIFIC PAR FLOWCHART ....................................................................... 50

7. REFERENCES .................................................................................................................. 51 7.1 NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1 ...... 51 7.2 NUREG-0654, Supplement 3, Guidance for Protective Action Strategies, Rev. 1 ..... 51 7.3 NRC EP FAQ 2013-004 NRC Responses to 8 questions regarding Supplement 3, Rev. 1 ....................................................................................................................... 51 7.4 EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, 1991 ............................................................................................ 51 7.5 NEI 12-10, Guideline for Developing a Licensee Protective Action Recommendation Procedure Using NUREG-0654 Supplement 3, Rev. 0 ................. 51 7.6 Emergency Planning Zones for Serious Nuclear Power Plant Accidents, State of California, Office of Emergency Services, November 1980 ....................................... 51 7.7 KLD TR-498, Diablo Canyon Power Plant Development of Evacuation Time Estimates, Revision 1 ............................................................................................... 51 7.8 State of California Nuclear Power Plant Emergency Response Plan (2008) ............. 51 7.9 San Luis Obispo County/Cities Nuclear Power Plant Emergency Response Plan (2010) ....................................................................................................................... 51 7.10 DCPP 50.54(q) Effectiveness Evaluation 2014-02 .................................................... 51 7.11 DCPP 50.54(q) Effectiveness Evaluation 2014-75 .................................................... 51 7.12 EP RB-10, Protective Action Recommendations ....................................................... 51 7.13 EP G-3, Emergency Notification of Off Site Agencies ............................................... 51 7.14 EP OR-3, Emergency Recovery................................................................................ 51 E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 3 of 51 Protective Action Recommendation (PAR) Strategy Bases

1. INTRODUCTION In November 2011 the Nuclear Regulatory Commission (NRC) issued Supplement 3 to NUREG-0654/FEMA-REP-1 Rev. 1, Guidance for Protective Action Strategies (here-after referred to as Supplement 3). Supplement 3 was revised using recent technical information to provide an acceptable method to comply with 10 CFR 50 Appendix E Section IV, paragraph 3 in the use of evacuation time estimates (ETEs) in the formulation of Protective Action Recommendations (PARs) for the plume exposure Emergency Planning Zone (EPZ).

Supplement 3 also provides guidance for the provisions of §50.47(b)(10) in the development of a range of PARs.

This appendix contains the considerations and bases for the site specific protective action methodology used within the plume exposure EPZ by Diablo Canyon Power Plant (DCPP). It was developed using the guidance in Supplement 3. The Nuclear Energy Institutes (NEI) 12-10, Appendix A - PAR Strategy Development/Evaluation, was used as a standardized means for documenting the development and bases of the protective action methodology described in this appendix.

As specified by the NRC, licensees may develop and implement alternative methods of compliance with the regulatory guidance in Supplement 3 provided sufficient justification is given to the NRC staff that the proposed alternatives demonstrate compliance with applicable NRC regulations. The site specific protective action methodology for DCPP was developed to comply with the applicable NRC regulations and the intent of the Supplement 3 guidance. Rationale for DCPP site specific considerations and alternate methods to the regulatory guidance in Supplement 3 are documented in applicable sections within this appendix.

As stated in Supplement 3, licensees should develop their site specific strategies, decision tools, and procedures in collaboration with the Offsite Response Organizations (ORO) responsible for protective action decision making. For DCPP, the OROs involved in the development of the PAR methodology described in this appendix included San Luis Obispo County and the State of California. During an event, the full protective action methodology is designed such that the ORO decision makers consider utility issued PARs based on technical data related to plant and radiological conditions. The OROs will also use additional offsite factors, such as impediments, in their determination of a final Protective Action Decision (PAD) for the general public.

Section 5 of this appendix contains the site specific protective action methodology flowchart developed per the guidance of Supplement 3 and modified to support the unique characteristics of the local DCPP EPZ geography, EPZ population, State regulations and ORO commitments. Section 5 also provides a correlation between the Supplement 3 flowchart blocks (as indexed in NEI 12-10) with the site specific PAR development bases for DCPP.

E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 4 of 51 Protective Action Recommendation (PAR) Strategy Bases

2. NUREG-0654 SUPPLEMENT 3 GUIDANCE AND DCPP SITE SPECIFIC PAR DEVELOPMENT BASES 2.1 Development of DCPP Site Specific PAR Methodology and Decision Logic 2.1.1 Federal Guidance 10 CFR 50 Appendix E Section IV.D.3 requires licensees to have the capability to notify OROs within 15 minutes of the declaration of an emergency. Additionally,

§50.47(b)(5) requires licensees to establish notification procedures to State and local response organizations that includes the content of initial and follow-up messages and a means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone. In order to meet the above regulation, NUREG-0654 Part II Section E.3 states:

The licensee in conjunction with State and local organizations shall establish the contents of the initial emergency messages to be sent from the plant.

These measures shall contain information about the class of emergency, whether a release is taking place, potentially affected population and areas, and whether protective measures may be necessary.

In accordance with Supplement 3, licensees are responsible for making timely PARs in accordance with regulations, Federal guidance, and plant conditions. Licensees are also responsible for providing PARs to OROs to allow them to make timely and well-informed PADs.

Supplement 3 (Section 2.1) contains the following guidance for development of the site specific PAR and decision logic:

a. The Emergency Plan implementing procedures (EPIPs) used by the ERO include a site specific PAR development tool.

b. A different tool may be used by the augmented ERO, which may have more resources than the shift organization.

c. The PAR must be made rapidly (within 15 minutes), in accordance with approved procedures.

d. EPIPs are expected to include a site specific PAR development tool that enables rapid use by the ERO without the initial need to confer with the ORO personnel (in no case does the NRC intend that licensees delay the PAR in order to confer with OROs at the time of a General Emergency declaration).

e. EPIPs are developed in partnership with the ORO(s) responsible for protective action decision-making (FEMA and the NRC expect licensees to develop PAR procedures that include ORO input for various decision points).

1. The approved PAR EPIPs constitute the licensee's commitment to OROs to provide PARs immediately upon the declaration of a General Emergency in a manner mutually agreed upon.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 5 of 51 Protective Action Recommendation (PAR) Strategy Bases

2. In case a responsible ORO chooses not to participate in the development of a site specific PAR development tool consistent with the Supplement 3 guidance, the licensee may use FEMA approved ORO emergency plans and implementing procedures as a basis to develop the necessary decision points.

3. Efforts to achieve licensee and ORO agreement on protective action strategy decision criteria should be documented in a manner that makes the information available for review by the NRC and FEMA.

2.1.2 DCPP Site Specific Bases The Supplement 3 (Section 2.1) guidance is addressed by the DCPP site specific PAR bases as follows:

a. The DCPP site specific PAR determination methodology and PAR development tool (referred to hereafter as flowchart) are contained in Emergency Plan implementing procedure EP RB-10.

b. The DCPP site specific PAR methodology does not provide different flowcharts for use by the on-shift ERO and the augmented ERO. A single flowchart is used by the on-shift ERO and the augmented ERO.

c. The DCPP site specific PAR methodology and flowchart incorporated in EP RB-10 have been designed to provide the capability to rapidly (within 15 minutes) determine the appropriate PAR.

d. The DCPP site specific PAR methodology and flowchart incorporated in EP RB-10 have been designed to provide the capability to determine the appropriate PAR without the initial need to confer with ORO personnel at the time of General Emergency declaration.

e. The DCPP site specific PAR methodology and flowchart have been developed in partnership with the San Luis Obispo County Office of Emergency Services (SLO OES) and the State of California Office of Emergency Services (Cal OES).

1. DCPP's commitment to provide PARs immediately upon the declaration of a General Emergency in a manner mutually agreed upon is documented in this appendix to the DCPP Emergency Plan. This appendix was reviewed and approved by the responsible OROs.

EP RB-10 is the procedure that implements this commitment.

2. The responsible OROs associated with DCPP participated in the development of this site specific PAR determination methodology consistent with Supplement 3 guidance.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 6 of 51 Protective Action Recommendation (PAR) Strategy Bases

3. Licensee and ORO agreement on the DCPP site specific PAR determination methodology is documented on official DCPP correspondence letters, which are available for review by the NRC and FEMA upon request.

2.2 Notification of PARs at a General Emergency 2.2.1 Federal Guidance Supplement 3 (Section 2.2) contains the following guidance for the notification of PARs at a General Emergency classification level:

a. Licensees are required to be able to provide immediate notification (i.e., within 15 minutes) to OROs upon the declaration of a General Emergency.

(

Reference:

10 CFR 50 Part 50 Appendix E Section IV.D.3)

b. The General Emergency notification is expected to include a PAR.

(

Reference:

10 CFR 50.47(b)(5), as detailed in NUREG-0654 Part II Section E.3 and NUREG-0654 Appendix 1)

c. The PAR must be developed in accordance with the approved Emergency Plan.

d. The PAR procedure should be coordinated with OROs.

2.2.2 DCPP Site Specific Bases The Supplement 3 (Section 2.2) guidance for the development of the notification of PARs at a General Emergency classification level is addressed by this DCPP site specific PAR bases as follows:

a. The site specific method by which DCPP meets this regulatory requirement for 15-minute ORO event notification is contained in Section 4 of the Emergency Plan. EPIP EP G-3 contains the procedure steps that implement the DCPP Emergency Plan requirement for 15-minute ORO notification.

b. The site specific method by which DCPP meets this regulatory requirement is to include a PAR in the notification of a General Emergency as contained in Section 6 of the Emergency Plan. EPIP EP G-3 implements the DCPP Emergency Plan requirement for PAR notification at the General Emergency classification level.

c. The SER approved DCPP Emergency Plan is Revision 3, Change 3 dated 03/31/83. Section 4 of this appendix provides the approved DCPP PAR determination methodology that included the concepts of plant-based and dose-based PARs.

1. The approved DCPP Emergency Plan dose-based PAR lower exposure threshold for whole body was based on a value derived from the California statute for annual exposure (0.5 rem whole body), which was half the EPA-520 Protective action Guide (PAG) threshold. Since the time of NRC approval of the DCPP Emergency Plan Revision 3, Change 3, the E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 7 of 51 Protective Action Recommendation (PAR) Strategy Bases EPA PAGs have been revised (EPA/520/1-75-001 was superseded by EPA 400-R-92-001 in October 1991). The current exposure threshold used for dose-based PARs is now appropriately taken directly from the EPA 400-R-92-001 PAG. EPA 400-R-92-001 PAG further states in Section 5.4 (Dose Projection), "The PAGs set forth in Chapter 2 are specified in terms of the effective dose equivalent. This dose includes that due to external gamma exposure of the whole body, as well as the committed effective dose equivalent from inhaled radionuclides." This is referring to the total effective dose equivalent (TEDE), and the thyroid committed dose equivalent (Thyroid CDE). DCPP's PAR based on EPA 400-R-92-001 is 1000 mrem TEDE.

2. The approved DCPP Emergency Plan dose-based PAR lower exposure threshold for thyroid was based on the EPA-520 Protective action Guide (PAG) threshold for child thyroid.

Since the time of NRC approval of the DCPP Emergency Plan Revision 3, Change 3, the EPA PAGs have been revised (EPA/520/1-75-001 was superseded by EPA 400-R-92-001 in October 1991). The current exposure threshold used for dose-based PARs is now appropriately taken directly from the EPA 400-R-92-001. DCPP's PAR based on EPA 400-R-92-001 is 5000 mrem Thyroid CDE.

3. The approved SER DCPP Emergency Plan plant-based PARs were based on a range of protective actions within the Low Population Zone (LPZ) predicated on evaluation of engineered safety features and other plant conditions tied to the NUREG-0654 emergency action level (EAL) scheme. Protective action zones (PAZs) 1 and 2 make up the LPZ.

Since the time of NRC approval of the DCPP Emergency Plan Revision 3, Change 3, the EAL scheme was revised, submitted and approved by the NRC. Plant-based PARs developed in this site specific PAR bases are consistent with the fission product barrier and plant condition terminology provided in the NRC approved DCPP NEI 99-01 EAL scheme.

The DCPP site specific PAR methodology is fundamentally based upon the guidance of Supplement 3 and the methods of the approved Emergency Plan with regard to plant and dose-based evaluation. Plant and dose-based thresholds have been updated to current PAG value units and EAL fission product barrier terminology.

d. Refer to Section 2.1.2.e for information regarding PAR coordination with the OROs.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 8 of 51 Protective Action Recommendation (PAR) Strategy Bases 2.3 Termination of Protective Actions 2.3.1 Federal Guidance Supplement 3 (Section 2.3) contains the following guidance for the termination of protective actions:

a. Licensees are responsible for declaring a General Emergency and issuing a PAR.

b. The licensee is responsible for downgrading or terminating the General Emergency; however, this action should not be taken without wide consultation. Downgrading an emergency may take time to ensure plant conditions will remain safe and to confer with authorities.

c. OROs are responsible for terminating offsite protective actions. The licensee provides input on plant status to ORO decision makers.

2.3.2 DCPP Site Specific Bases The Supplement 3 (Section 2.3) guidance for the termination of protective actions is addressed by the DCPP site specific PAR bases as follows:

a. Refer to Section 2.2.2.b for information regarding PAR issuance at the General Emergency classification level.

b. Event downgrade or termination is not included in the DCPP site specific PAR methodology. Emergency Plan Section 9 and EPIP EP OR-3, Emergency Recovery, require the Emergency Director to obtain concurrence from County, State and NRC authorities prior to terminating from an event at an Alert or higher emergency classification level. DCPP may terminate from the Unusual Event classification level without ORO consultation.

c. Supplement 3 guidance does not require the licensee to downgrade PARs. It specifically states that the, "OROs are responsible for termination of offsite protective actions." The DCPP site specific PAR methodology does not include the rescission (or termination) of a PAR once it has been given to the County. This applies both during the declared emergency and the recovery phase of the event.

2.4 Precautionary Protective Actions at the Site Area Emergency Classification Level 2.4.1 Federal Guidance Supplement 3 (Section 2.4) contains the following guidance for precautionary protective actions at Site Area Emergency classification level:

a. In some cases, a licensee or ORO may have committed to site specific precautionary actions during the Site Area Emergency, such as the evacuation of beaches or other recreational areas. Licensees should not E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 9 of 51 Protective Action Recommendation (PAR) Strategy Bases interpret Supplement 3 guidance as countermanding any such commitments in licensing-basis documents or in State, Tribal, and local offsite emergency plans and implementing procedures.

2.4.2 DCPP Site Specific Bases The Supplement 3 (Section 2.4) guidance for precautionary actions at the Site Area Emergency classification level is addressed by the DCPP site specific PAR bases as follows:

a. The SLO County/Cities Nuclear Power Plant Emergency Response Plan and Standard Operating Procedures (SOPs) provide the ORO Emergency Services Director with the authority and ability to determine and direct precautionary actions for the public prior to the declaration of a General Emergency.

The SER approved Emergency Plan and current Emergency Plan discuss that consideration of precautionary actions may be appropriate for an Alert or Site Area Emergency classification. Specific actions are not provided for either of those classifications.

Actions considered for an Alert is as follows in the SER approved Emergency Plan and the current Emergency Plan: "Releases at this level would ordinarily not require near-term protective measures, (such as evacuation) beyond the site boundary, although some action within the LPZ (PAZs 1 and 2) might be taken as a precautionary measure if a release near the Technical Specification maximum was actually expected and the potential existed for a release of extended duration or for escalation to a more severe classification."

Actions considered for a Site Area Emergency is as follows in the SER approved Emergency Plan and the current Emergency Plan: "Events in which projected dose assessment results of 100 mRem TEDE or 500 mRem Thyroid CDE at or beyond the site boundary are indicated, for actual or expected releases, would lead to a SITE AREA EMERGENCY classification.

Such a release would almost certainly require that protective measures be taken in the vicinity of the site and may require some precautionary measures to be taken in the downwind LPZ sectors (PAZs 1 and 2). The appropriate near-term response for such an occurrence is to make an assessment of conditions as they actually exist and take action based on this assessment."

Actions considered for a General Emergency is as follows in the SER approved Emergency Plan and the current Emergency Plan: "Lack of available shelter for many of the persons in this area (agricultural workers, visitors to Montana de Oro State Park) makes precautionary evacuation of the LPZ the appropriate response following a declaration of GENERAL EMERGENCY. For areas beyond the LPZ, directing transients to return to their homes, sheltering of permanent residents, and deployment of law enforcement agencies in preparation for possible evacuation are the appropriate responses while actual conditions are assessed."

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 10 of 51 Protective Action Recommendation (PAR) Strategy Bases Discussion with SLO County and the State of California conducted during the development of the DCPP site specific PAR methodology contained within this appendix, determined that PARs that were issued by DCPP prior to the declaration of a General Emergency were not warranted or desired. The OROs expect DCPP to issue PARs based on a technical evaluation of plant and dose-based considerations that meet the definition of the General Emergency classification level.

2.5 Wind Persistence Issues 2.5.1 Federal Guidance Supplement 3 (Section 2.5) contains the following guidance for wind persistence issues:

a. It may be appropriate for licensees to perform a wind persistence analysis (the updated final safety analysis may be used) to determine appropriate modifications to a protective action strategy. The modifications may be appropriate for areas where the typical site meteorology includes wind direction shifts on a timescale that is shorter than the ETE for downwind sectors in the 2 to 5-mile radius. This could result in OROs expanding protective actions while an evacuation is in progress as a result of changes in wind direction. Multiple changes in protective action direction may undermine credibility and increase shadow evacuations and thereby increase evacuation times. In such cases, it may be appropriate to include more than three downwind sectors in an expanded evacuation.

2.5.2 DCPP Site Specific Bases The Supplement 3 (Section 2.5) guidance for wind persistence issues is addressed by the DCPP site specific PAR bases as follows:

a. A wind persistence study was performed for the DCPP EPZ and is documented in Section 2.2.2 of the Cal OES report titled "Emergency Planning Zones for Serious Nuclear Power Plant Accidents." Applicable wind persistence information includes the following:

The data suggest wind directions approximately parallel to the shoreline have the highest probability for extended continuous periods in which the wind blows in the same direction. For example, there is a 15% probability if the wind blows from the NW, it will continue to blow in that direction (toward the SE) for eight hours or more. In fact, there is a 1% probability when the wind blows from the NW it will blow continuously in that direction for 25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months or more. On about four days out of the year the wind can be expected to blow steadily toward the SE for 25 continuous hours or more.

Only the ESE sector approaches the NW sector with respect to the probability of continuous winds for 25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months or more. However, the E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 11 of 51 Protective Action Recommendation (PAR) Strategy Bases probability of the wind blowing constantly from the ESE (toward the WNW) is lower initially than the probability of the wind blowing for one hour or more from the NW. Moreover, the probability of extended periods of continuous wind from the ESE falls off more rapidly than the corresponding extended periods of continuous winds from the NW. It can be seen that the probability of the wind blowing from the ESE for more than eight hours is less than 1%. It should also be observed that when the wind blows toward the WNW, it is simply blowing out to sea.

In most sectors, there is less than a 1% chance that the wind will blow continuously for more than three hours in the indicated direction. Thus, with the exception of the NW sector, the probability of the wind blowing constantly in any given direction in the vicinity of Diablo Canyon for extensive periods (of the order of one day) is very small.

Refer to Section 3 for information regarding the origin and licensing basis of the DCPP site specific EPZ boundary and the Protective Action Zones (PAZ) within the EPZ.

Although a wind persistence study for the DCPP EPZ was done, this is not applicable for use in the PAR methodology described in this appendix. DCPP does not use map sectors to make PARs but uses PAZs. PAZs 1 and 2 encompass the areas 0 to 6 miles surrounding DCPP. PAZs 1 and 2 represent the land area within the generic 5-mile EPZ area. PAZ 1 is equivalent to the land area within the 2-mile generic EPZ and PAZ 2 is equivalent to the land area within the 2 to 5-mile generic EPZ (approximately 6 miles for DCPP).

ETE values are taken from KLD TR-1235 Table 7.1, Time to Clear the Indicated Area of 90 Percent of the Affected Population. Per Supplement 3, ETE values for special events and roadway impact are not included. The longest ETE for PAZs 1 and 2 (90% population scenarios 8 and 9: Winter, Weekend, Midday, Good Weather and Rain) is 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 45 minutes. Using a maximum wind persistence assumption of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and the longest ETE for the combination of PAZ 1 and PAZ 2 of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 45 minutes, a modification to the protective action strategy to include additional downwind PAZs in an expanded evacuation would not be warranted for DCPP.

PAZ 1 permanent and transient populations are 0. PAZ 2 permanent population is 160 and the transient population is 870 (ETE Report Tables 3.1 and 3.4 -

reference 7.7). Based on the remote geography and limited population of PAZs 1 and 2, these areas are always recommended to evacuate or shelter simultaneously. Even if the ETE were to exceed the maximum wind persistence assumption of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months the DCPP site specific PAZ equivalent to the 2-5 mile area (PAZ 2) is not divided into multiple geographic areas, therefore wind persistence is not applicable in the 2-5 mile area for DCPP.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 12 of 51 Protective Action Recommendation (PAR) Strategy Bases 2.6 Expansion of Initial Protective Action Recommendations 2.6.1 Federal Guidance Supplement 3 (Section 2.6) contains the following guidance for expansion of initial PARs:

a. The emergency action level scheme used at nuclear power plants is designed to be anticipatory. A General Emergency is expected to be declared, based on plant conditions, before a radiological release could potentially begin.

b. Licensees will perform radiological assessments throughout the emergency and will recommend to OROs the need to take or expand protective actions if dose projections show that protective action criteria could be exceeded.

c. Dose projections based on effluent monitor data and verified by field monitoring data would provide the strongest basis for a PAR; however, effluent monitor data alone can be sufficient if other data (e.g., plant conditions, area or process monitors) verify the occurrence of a radiological release. Although verification of dose projection data is desirable, the licensee should not delay PARs unduly while waiting for field monitoring data or sample analysis.

d. A more difficult case for dose assessment is a scenario with a large radiological source term in containment and a leak rate at or near the design basis. This is clearly a General Emergency and an initial PAR is expected. As subsequent PARs are implemented, the issue of expansion of protective actions beyond the 5-mile downwind sectors can arise. When expansion of a PAR is considered under this scenario, the condition of containment must be assessed.

e. Changes in wind direction may indicate that if a release begins, it would affect different downwind sectors. If the licensee believes containment may fail, it should pursue the expansion of PARs.

f. If a radiological assessment shows an ongoing release or containment source term is not sufficient to cause exposures in excess of EPA PAGs, licensees should not expand PARs based only on changes in wind direction.

2.6.2 DCPP Site Specific Bases The Supplement 3 (Section 2.6) guidance for expansion of initial PARs is addressed by the DCPP site specific PAR bases as follows:

a. Event declaration and PAR determination are separate planning standards and processes at DCPP. The approved DCPP EAL scheme is based on the industry standard template of NEI 99-01 and contains both plant condition and radiological release EAL thresholds at the General Emergency classification level, which can be met concurrently.

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b. The DCPP site specific PAR methodology includes consideration of radiological release dose assessment results based upon exceeding EPA-400 PAG threshold values. The DCPP dose assessment process provides for continuous monitoring of a radiological release throughout an event. The need to make or expand a PAR for a particular PAZ based on dose assessment or field survey results indicating a PAG could be exceeded is part of the DCPP site specific PAR methodology.

c. The DCPP site specific PAR methodology uses dose projections based upon effluent monitor data that is verified by field monitoring data, but does not delay PAR determination while waiting for field monitoring data or sample results. However, when field monitoring data or sample analysis results are available, dose assessment personnel compare the available information to the dose projections to check for alignment.

d. The DCPP site specific PAR methodology has a continuation loop that progresses through both plant and dose-based evaluations when determining whether expansion of PARs is necessary (additional PARs for the PAZs from 6 miles out to the EPZ boundary). The plant-based evaluation includes thresholds for condition of containment.

e. The DCPP site specific PAR methodology includes plant-based thresholds for condition of containment that when met, indicate a loss or potential loss of containment integrity. Changes in wind direction are evaluated in conjunction with condition of containment thresholds such that expansion of PARs based upon an imminent or actual containment failure would be based on known plant conditions.

f. The DCPP site specific PAR methodology does not include an expansion of PARs based only on changes in wind direction. Only when dose assessment results or field survey results indicate the potential for exceeding an EPA PAG in a new PAZ or area over the Ocean is an expansion of PARs considered.

NRC EP FAQ 2013-004, Question 6 addresses complexities that may arise for decision-makers regarding wind direction and potential containment failure; shelter-in

-place and staged evacuation considerations. Most of these considerations are not applicable to the DCPP site specific PAR methodology. The process for expanding PARs conforms to the guidance in the EP FAQ in that the DCPP protective action strategy minimizes demands upon on-shift decision-makers and eliminates unnecessary PARs.

NRC EP FAQ 2013-004, Question 7 states if there is a wind shift when the control room has command and control, then plant conditions can be used as a basis for expanding the PAR to a new sector. The DCPP PAR methodology maintains the initial PAR of evacuation of PAZ 1 and PAZ 2 (to 6-miles in radius), evacuation of the ocean for a 5 nautical mile radius, administration of KI per the County plan, and monitor and prepare for all other PAZs. This recommendation will remain in effect until results from dose assessment or field monitoring indicate a new PAZ, or areas over the ocean, exceeding EPA PAGs.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 14 of 51 Protective Action Recommendation (PAR) Strategy Bases NRC EP FAQ 2013-004, Question 8 addresses diurnal (variation within the course of a day) wind shifts or passage of storm fronts resulting in extreme wind shifts. The NRC response to Question 8 states, " this consideration need not be included in the control room protective action strategy because the combination of the General Emergency and the extreme weather is unlikely." The DCPP PAR methodology maintains dose assessment capability in the control room and augmented emergency response organization throughout the course of the emergency to include current weather conditions and wind direction. The DCPP PAR methodology includes consideration for PAR expansion based upon the dose assessment and field monitoring results.

2.7 Strategy for Rapidly Progressing Scenarios 2.7.1 Federal Guidance Supplement 3 (Section 2.7) contains the following guidance for rapidly progressing scenarios:

a. The emergency preparedness planning basis includes rapidly progressing scenarios that have a significant radioactive release in about 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

1. For sites at which the 90-percent ETE for the general public of the full EPZ is less than approximately 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months , results showed that, for the rapidly progressing scenario, evacuation is the most appropriate protective action.

2. For sites where this is not the case, the protective actions listed in the table below are most beneficial, unless impediments exist to their implementation.

3. Where evacuation cannot be accomplished in the time specified, a recommendation for shelter in place (SIP) until the plume has passed is more beneficial.

Zone Protective Action If the 90-percent ETE for this area is 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or less, 0 to 2 mile immediately evacuate.

If the 90-percent ETE for this area is 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months or less, 2 to 5 mile immediately evacuate.

5 to 10 mile SIP, then evacuate when it is safe to do so.

b. The evacuation tail generally represents the last 10 percent of the population and describes the population that takes a disproportionately longer time to evacuate than the remaining public. Planning is in place to evacuate 100 percent of the public; however, PARs and decisions should be based on the 90-percent ETE values.

c. Licensees may perform a site specific analysis to determine whether other criteria are more appropriate.

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d. Extreme weather conditions, such as inversion, significant precipitation, or no wind, can change the efficacy of SIP and make evacuation the preferred protective action.

2.7.2 DCPP Site Specific Bases The Supplement 3 (Section 2.7) guidance for rapidly progressing scenarios is addressed by the DCPP site specific PAR bases as follows:

Refer to Section 3 for information regarding the origin and licensing basis of the DCPP site specific EPZ boundary and the PAZs within the EPZ.

a. The DCPP plume exposure EPZ was established by the State of California and SLO County. The DCPP EPZ was originally divided into two sub-zones, the Basic EPZ (from 0 to approximately 10 miles) and the Extended EPZ (from approximately 10 to 22 miles). For the DCPP site specific EPZ:

The 0 - 2 mile land area is covered entirely by PAZ 1.

The 2 - 6 mile land area is covered entirely by PAZ 2.

The 6 - 10 mile land area is divided into three PAZs (3, 4 and 5).

The 10 - 22 mile land area is divided into seven PAZs (6, 7, 8, 9, 10, 11 and 12).

The ocean area associated with the DCPP PAR methodology is divided into three regions: 5 nautical mile radius, 10 nautical mile radius, and beyond 10 nautical miles. The distance appropriate to the PAR is based upon wind direction or projected offsite dose projections, in the case of areas beyond the EPZ.

ETE values are taken from KLD TR-1235 Table 7.1, Time to Clear the Indicated Area of 90 Percent of the Affected Population. Per Supplement 3, ETE values for special events and roadway impact are not included.

1. The longest 90% ETE for evacuation of the Basic EPZ (PAZs 1 - 5),

which is the area out to approximately 10 miles, is 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 15 minutes.

The longest 90% ETE for evacuation of the entire EPZ (PAZs 1 - 12),

which is the area out to approximately 22 miles, is 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months 05 minutes.

The Basic EPZ (PAZs 1-5) is very close to the 3-hour guidance with a worst case time of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 15 minutes. Eight out of the ten 90% ETE scenario times shown in the tables below for the Basic EPZ are 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months or less. Therefore, evacuation is selected as the more appropriate protective action for a rapidly progressing scenario.

PARs for areas beyond 10 miles are based upon dose assessment or field survey results.

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2. The DCPP site specific ETEs fit closest to this section of the Supplement 3 guidance for rapidly progressing scenarios.

0 to 2 mile Zone PAZ 1 is equivalent to the land area within the 2 mile generic EPZ. The 90% ETE for PAZ 1 is 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for all scenarios.

Since the 90% ETE for this area is less than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months the appropriate PAR is to evacuate PAZ 1.

2 to 5 mile Zone PAZ 2 is equivalent to the land area within the 2 to 5 mile generic EPZ.

However, PAZs 1 and 2 are always recommended to evacuate simultaneously (Refer to Section 2.5.2.a).

The longest 90% ETE for PAZs 1 and 2 is 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 45 minutes.

Since the 90% ETE for PAZs 1 and 2 is less than 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months the appropriate PAR is to evacuate PAZs 1 and 2.

5 to 10 mile Zone Supplement 3 provides generic guidance to initially SIP the 5 to 10 mile areas and then evacuate them when it is safe to do so. Staged evacuations of the DCPP PAZ combinations in the 6 mile radius and 10 miles downwind take longer than a simultaneous evacuation of those PAZs for the 90% ETE population in each of the applicable scenarios.

The differences are relatively short being within about one half hour.

Thus, the benefits of the Supplement 3 guidance to SIP the downwind PAZs in the 6 to 10 mile area prior to a staged evacuation are not greater than the plant uncertainties for such an event, the complication of implementing the action for the public or the potential dose avoided. The appropriate DCPP site specific PAR in this case is to evacuate the downwind PAZs in the 6 to 10 mile area. This is supported by the 90%

ETE with a "worst case" evacuation time of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and 15 minutes.

Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R03 3:00 3:15 2:50 3:00 3:00 3:00 3:10 2:45 3:00 2:55 R23 3:25 3:40 3:25 3:35 3:30 3:30 3:40 3:25 3:40 3:30 Difference 0:25 0:25 0:35 0:35 0:30 0:30 0:30 0:40 0:40 0:35 Average 0:32 R03 represents the simultaneous evacuation of PAZ 1, 2, 3, 4, 5 R23 represents the staged evacuation of PAZ 1 & 2 first followed by 3, 4, & 5 E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

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(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R05 3:05 3:20 3:00 3:25 3:05 3:10 3:20 3:00 3:25 3:00 R21 3:40 4:10 3:35 3:50 3:35 3:40 4:00 3:35 3:55 3:35 Difference 0:35 0:50 0:35 0:25 0:30 0:30 0:40 0:35 0:30 0:35 Average 0:34 R05 represents the simultaneous evacuation of PAZ 1, 2, 5 R21 represents the staged evacuation of PAZ 1 & 2 first followed by 5 Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R06 3:10 3:30 3:05 3:20 3:10 3:10 3:25 3:05 3:20 3:05 R22 3:45 4:00 3:40 3:55 3:40 3:45 4:05 3:40 4:05 3:40 Difference 0:35 0:30 0:35 0:35 0:30 0:35 0:40 0:35 0:45 0:35 Average 0:35 R06 represents the simultaneous evacuation of PAZ 1, 2, 4, 5 R22 represents the staged evacuation of PAZ 1 & 2 first followed by 4 & 5 Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R07 2:00 2:05 1:45 1:55 1:55 1:55 2:05 1:50 2:00 2:05 R24 2:05 2:10 1:55 2:00 2:05 2:05 2:05 2:00 2:00 2:10 Difference 0:05 0:05 0:10 0:05 0:10 0:10 0:00 0:10 0:00 0:05 Average 0:06 R07 represents the simultaneous evacuation of PAZ 1, 2, 3, 4 R24 represents the staged evacuation of PAZ 1 & 2 first followed by 3 & 4 Scenario /

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Region R08 1:55 2:05 1:45 1:55 1:45 2:00 2:05 1:45 1:55 1:55 R25 2:00 2:05 1:55 2:00 2:00 2:00 2:05 2:00 2:00 2:05 Difference 0:05 0:00 0:10 0:05 0:15 0:00 0:00 0:15 0:05 0:10 Average 0:06 R08 represents the simultaneous evacuation of PAZ 1, 2, 3 R25 represents the staged evacuation of PAZ 1 & 2 first followed by 3 Ocean Due to the potential radiological consequences of the rapidly progressing scenario, the uncertainty for further degradation of plant conditions and the urgency of the incident, the evacuation of watercraft and people from the ocean is recommended to the distance of 5 or 10 nautical miles depending on wind direction. For wind directions where the affected sector or adjacent sectors contain areas of the ocean or a protective action zone with an ocean harbor, the recommended action is to evacuate to the distance of 10 nautical miles.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 18 of 51 Protective Action Recommendation (PAR) Strategy Bases Impediment Considerations during a Rapidly Progressing Scenario Due to the potential radiological consequences of the rapidly progressing scenario, the uncertainty for further degradation of plant conditions and the urgency of the incident, the DCPP site specific PAR methodology does not take impediments into consideration for this type of event. The OROs may independently consider the impact of impediments during the PAD process.

3. Since the DCPP site specific evacuation can be accomplished in the time specified, a recommendation to SIP the affected areas within 0 to 10 miles until the plume has passed is not determined to be more beneficial.

b. The ETEs used in the development of the DCPP site specific PAR methodology are based on the 90% population values, excluding the special event and roadway impact scenarios.

c. Refer to Section 2.7.2a.2 above regarding the site specific analysis used as the basis and justification for not initially recommending SIP followed by a staged evacuation of the DCPP PAZs in the 5 to 10 mile area during a rapidly progressing scenario.

d. Since SIP of the PAZs in the 0 to 10 mile area is not part of the DCPP site specific PAR methodology, consideration of extreme weather conditions that would warrant evacuation over SIP are not necessary. The County of SLO and DCPP have made an agreement that the County of SLO will be responsible for making determinations concerning impediments to evacuation.

Based on this agreement, DCPP doesn't consider impediments prior to determining a PAR.

NRC EP FAQ 2013-004, Question 1 and NRC final response regarding the definition of "rapidly progressing severe accident" does not affect DCPP bases addressing Supplement 3, Section 2.7. The DCPP protective action strategy bases are aligned with the NRC final response to Question 1.

3. BASIS OF THE DCPP PLUME EXPOSURE PATHWAY EMERGENCY PLANNING ZONE (EPZ)

California State legislation, Section 8610.5 of the Government Code (SB-1183), required a study be conducted by the State Office of Emergency Services (OES) to analyze the consequences of hypothetical serious nuclear power plant accidents.

The study was conducted and subsequent report issued in accordance with the State legislative regulation and contained recommended site specific EPZ boundaries for the nuclear power stations in California. The plume exposure EPZ was defined by two major sub-zones in Section 4.1.3 of the report as follows:

The direct or plume exposure zone has been divided into two sub-zones with somewhat different planning and emergency preparedness requirements -- the Basic EPZ and the Extended EPZ. Within the Basic EPZ, a circular zone of approximately 10 mile radius, the principal objective would be to avoid public exposure to very large E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 19 of 51 Protective Action Recommendation (PAR) Strategy Bases radiation doses and planning for a full range of protective actions, including the capability for total evacuation, should time permit, is necessary. As will be shown subsequently, a radius of about 10 miles will provide protection against early deaths for all but the most extreme of the major containment failure accidents. Moreover, protective measures taken within the approximately ten mile Basic EPZ would provide protection against any significant exposure to the public within the zone for the most probable serious nuclear accidents. For accidents of this classification, a 99% (or greater) probability exists that exposures will not exceed 0.5 rem beyond the 10 mile zone perimeter. Thus essentially no protection would be needed beyond the Basic EPZ for accidents in the Melt-through classification. For such accidents, evacuation and/or sheltering and relocation would be used to reduce population risks to nominal levels within this zone.

.. because the consequences of the more severe accidents (PWR 1-5) could be so great, OES believes it is prudent to develop specific plans beyond the Basic EPZ.

Directions with higher than average wind probabilities must be given special consideration. Therefore, Extended EPZs have been established in these directions for protection of the public downwind from the plants. Within the Extended EPZs plans will be developed for a range of protective actions to include evacuation and/or shelter followed by relocation of the population from any contaminated areas after an accident. As part of the planning process, State and local officials will work together to determine the most appropriate protective actions and warning systems for each area and segment of the population within the Extended EPZ.

The California EPZ characteristics are similar in principal to those of the NRC.

However, the current NRC requirements call for specific planning efforts only within a zone approximately equivalent to the Basic EPZ California is now requiring. Beyond this distance, the NRC has suggested that for more serious accidents protective actions should be implemented on an ad hoc basis in accordance with the real time requirements of a given accident. The principal difference between the California and the NRC requirements is that the OES believes that specific advance planning should also be done to take into account the possible effects of the more serious accidents --

effects which could extend beyond the Basic EPZ. The more serious accidents make up about 10% to 20% of all core-melt accidents. The OES feels that this relative probability is too large to be dealt with in an entirely impromptu fashion. Thus, the OES requires plans be prepared in advance for responding to such accidents, though the criteria for response are not identical to those of the less severe, but more probable accidents.

The report developed the site specific EPZ boundaries in consultation with the State Department of Health Services and the counties in the vicinities of the reactors which were shown to be affected by the hypothesized accidents. From Section 4.2.1:

To simplify control of areas within the zones and notification of the public via the Emergency Broadcast System should it ever become necessary, where possible, specific landmarks, e.g., roads, rivers and lakes, city limits and County boundaries, were used as zone boundaries. Based on the technical dose-distance, dose contour and meteorological data, specific recommendations from the counties determined which landmarks were used to bound the EPZs. Recognizing the uncertainties in the technical data and year-to-year and seasonal variations in meteorology, a reasonable amount of leeway was allowed in the boundary choices.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 20 of 51 Protective Action Recommendation (PAR) Strategy Bases For PWR's, the Basic EPZ has a minimum radius of 10 miles and specific boundaries as recommended by the affected counties. Extended EPZ's have minimum radii of approximately 18 to 20 miles -- a distance corresponding to the 25 rem downwind distance for a penetration leakage accident at the reactor sites.

Consideration was given to wind directional probabilities, wind persistence, and to "worst-case trajectories" encompassing those wind directions and meteorological conditions that would carry a radioactive cloud over large population centers and result in high radiation doses if a major release occurred.

The original plume exposure EPZ boundary for DCPP provided in the Cal OES report (Figure 4-2) and State Emergency Response Plan is shown below.

PACIFIC:

TW!TCl'ELL SAN LUIS. 08/$.PO BA Y F igm;-e 4- 2 Original Cal OES Plume Exposure EPZ for DCPP E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 21 of 51 Protective Action Recommendation (PAR) Strategy Bases California is a home rule State where the final EPZ boundary determination resides at the local agency level, which for DCPP is the SLO County OES. The original plume exposure EPZ boundary for DCPP provided in the SLO County/Cities Nuclear Power Plant Emergency Response Plan (Attachment I.5-3) is shown below.

_'N~,

Vi~;-~** . .

. **tiofl p

--- ~ ...... ,,

lufc l:mertency Plannlr1ci %OM (SEP%)

E1tend1<1

~_-..._ . . .l.

P*!.afimii,tZone ,(EXPZ)

I Original SLO OES Plume Exposure EPZ for DCPP E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 22 of 51 Protective Action Recommendation (PAR) Strategy Bases The current State of California Nuclear Power Plant Emergency Response Plan (dated 2019) provides the following basis for the DCPP EPZ and PAZ boundaries:

Emergency Planning Zones (EPZs)

The federal Nuclear Regulatory Commission (NRC) has established requirements for evacuation planning for a 10 mile radius around each nuclear power plant, referred to as the Emergency Planning Zone (EPZ). The NRC also required planning to approximately 50 miles from the plants to prevent ingestion of contaminated food in the event of a release from a nuclear power plant, referred to as the Ingestion Pathway Zone (IPZ). The State has expanded the EPZ beyond the federal requirements for each nuclear power plant in California.

In addition to the NRC-required zones, the State has established a Public Education Zone (PEZ), which extends from the EPZ boundary to a range of 20 to 35 miles around each plant. The PEZ ensures that residents outside the EPZ are advised of planned emergency activities within the EPZ.

These zones are discussed in the Science Applications, Inc., June 23, 1980, report, "A Study of Postulated Accidents at California Nuclear Power Plants" and the State of California report, November 1980, "Emergency Planning Zones for Serious Nuclear Power Plant Accidents."

Diablo Canyon Power Plant (DCPP) EPZ The State expanded the DCPP EPZ so that it is much larger than the EPZ defined by the federal government. The expanded EPZ defined by the State is divided into twelve smaller Protective Action Zones (PAZs). PAZs 1 through 5 correspond to the ten-mile area where FEMA has primary oversight responsibilities for emergency planning. The State has primary oversight responsibilities for PAZs 6 through 12, outside of the ten-mile area. Residents in PAZs 1 through 12 may be asked to take protective actions, such as take shelter in their homes or evacuate if there is a major emergency.

Surrounding the twelve PAZs are three zones known as Public Education Zones (PEZs). Resident in these areas are not likely to be affected by an emergency at the power plant. However, since residents in the PEZs (zones 13 through 15) are next to the EPZ, general information about DCPP is provided to those residents.

The Emergency Planning Zone at DCPP (Figure 1.4.2) includes the cities of Morro Bay, San Luis Obispo; the "five cities area" (Grover Beach, Pismo Beach, Shell Beach, Oceano, and Arroyo Grande); and the communities of Baywood / Los Osos.

The PEZ (Figure 1.4.3) extends approximately 35 miles southeast (the predominant wind direction from the plant). The Ingestion Pathway Zone around the Diablo Canyon Power Plant is approximately 50 miles and includes portions of San Luis Obispo, Santa Barbara and Monterey Counties, as shown in Figure 1.4.4.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 23 of 51 Protective Action Recommendation (PAR) Strategy Bases The current plume exposure EPZ boundary for DCPP provided in the State of California Nuclear Power Plant Emergency Response Plan (Figure 1.4.2) is shown below.

NW WNW w

WSW SW

~~~l~~:=G~~~~E~7*-

0 t 8l.OCMNON POWEIII PL.AHT *-*-\

ST AH DARO PROTECTIVE ACTION ZONE {PAZJ 'r"'p hoouc.eo ev THE SMrl LUts OBISPO couNril\AGR IC ULTURE r EPARTMEJlt GIS TEAM \

f t~9 ~~-

=---===+-

\+

Current Cal OES Plume Exposure EPZ for DCPP E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 24 of 51 Protective Action Recommendation (PAR) Strategy Bases Section 3.1 of the current SLO County/Cities Nuclear Power Plant Emergency Response Plan (2022) provides the following basis for the DCPP EPZ and PAZ boundaries:

Emergency Planning Zones Technical experts and government agencies have worked to develop nuclear power plant emergency response plans for all of the nuclear power plants in the United States. As part of this planning, the areas around the plants are divided into planning zones. The Nuclear Regulatory Commission and Environmental Protection Agency have determined that a federally defined Emergency Planning Zone (EPZ) for the plume exposure pathway should be an area that is roughly a 10 mile circle around the nuclear power plant and an approximate 50 mile radius limit for the Ingestion Pathway Zone (IPZ). The Federal Emergency Management Agency (FEMA) has oversight responsibilities for San Luis Obispo County's emergency plans within this approximate 10 mile area. FEMA also has oversight responsibilities for the California Department of Public Health emergency plans within the 50 mile IPZ radius.

The State of California adopted San Luis Obispo County's recommendations to expand the Diablo Canyon Emergency Planning Zone so that it is much larger than the 10 mile radius EPZ defined by the federal government. The State of California's Office of Emergency Services has oversight responsibilities for the expanded EPZ beyond the 10 mile area.

Federal Emergency Planning Zones NRC/FEMA have established a 10 mile radius limit for the plume exposure pathway EPZ and an approximate 50 mile radius limit for the IPZ. Figure 3.1.1 illustrates the NRC/FEMA 10 mile EPZ boundary and Figure 3-1.2 illustrates the defined 50 mile IPZ boundary in 22.5 -degree sectors.

State Emergency Planning Zones Based upon an extensive study [A Study of Postulated Accidents of California Nuclear Power Plants, Prepared for the State of California, OES by Science Applications, Inc., July, 1980], the State designated two zones associated with the Diablo Canyon Power Plant, the EPZ and the Public Education Zone (PEZ). Both are illustrated in Figure 3-2. The PEZ continues across the county boundary to include an area of northern Santa Barbara County.

As described earlier, Figure 3.1.2 illustrates the 50 mile radius IPZ, which includes four total counties (San Luis Obispo, Santa Barbara, Monterey and Kern Counties). A summary description of the State study and process of selection of emergency planning zones is given in "Emergency Planning Zones for Serious Nuclear Power Plant Accidents," State of California Office of Emergency Services, November, 1980.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 25 of 51 Protective Action Recommendation (PAR) Strategy Bases County Planning As noted above, the State planning zones form a basis for County planning. The expanded EPZ defined by the State is divided into 12 Protective Action Zones.

PAZs 1 - 5 correspond to the approximate ten mile Federal emergency planning area.

PAZs 6 - 12 are outside the ten mile area.

Having 12 PAZs improve the managing of detailed planning and implementing the protective measures in areas smaller than the entire EPZ.

Surrounding the 12 PAZs are three zones known as Public Education Zones (PEZs).

Residents in these areas (zones 13 - 15) are outside but immediately adjacent to the EPZ. The PEZ was established to ensure general information about Diablo Canyon is provided to residents and businesses surrounding the PAZs.

PAZs and PEZs are described in Table 3.1 (sheet 1 and 2), and shown in Figure 3.2.

The PAZs may be arranged into four groups of generally increasing distance from the plant.

PAZ 1: 2-mile radius PAZ 2: 6-mile radius PAZs 3-5: Approximately 9 to 10 mile radius - Primary federal oversight areas of PAZs 1-5 PAZs 6-12: Balance of State Basic Emergency Planning Zones - State primary oversight PEZs 13-15: Public Education Zone - Area where public education materials are provided. Any emergency protective actions would be on an ad hoc basis.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 26 of 51 Protective Action Recommendation (PAR) Strategy Bases The current NRC-defined plume exposure EPZ boundary for DCPP provided in the SLO County/Cities Nuclear Power Plant Emergency Response Plan (Figure 3.1.1) is shown below.

Ba L

DiabloCa e Power Plant PACIFIC .

San uis Ob1spo p ~*

ism OCEAN Bay Grov~r,rea~h G d

r.r:.o o ran e Ocea I

Current SLO OES NRC Equivalent Plume Exposure EPZ for DCPP E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 27 of 51 Protective Action Recommendation (PAR) Strategy Bases The current agency-defined plume exposure EPZ boundary for DCPP provided in the SLO County/Cities Nuclear Power Plant Emergency Response Plan (Figure 3.2) is shown below.

EMERGENCY PLANNING ZONE MAP PROTH11YE ACTION ZONES IPAZl 1-12 , PUBLIC EDUCAllON ZONES IPEil 13-15 AND PUBLIC SCHOOL RELOCATION mms

/

I I

I

\

\.

PACIFIC

-- N LUIS OBISPO BA Y

/

I B

+ --

0 CE AN N

- - OCEANO DUNES

'\,> = EVAOJATION ROUTES

PROTECTM ACTON ZONES (PAZI 1-12

,. Ml.IC EDUCAOON ZONES (PEZJ 13* 15

- - a FM NAUT1CALMILE SAFETY ZONE

- - ~ TB'4 NAU1lCAl MlE SAFE1Y ZONE Current SLO OES Plume Exposure EPZ for DCPP The DCPP EPZ currently defined by the State OES and SLO County is consistent with the overall guidance given in NUREG-0654 Supplement 3 for the generic 10 mile EPZ (Basic EPZ) and provides definition and structured planning to the risk areas beyond 10 miles (Extended EPZ).

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 28 of 51 Protective Action Recommendation (PAR) Strategy Bases

4. APPROVED DCPP EMERGENCY PLAN PAR DETERMINATION METHODOLOGY The DCPP SER Emergency Plan Rev 3, Change 3 established that the Site Emergency Coordinator developed the applicable protective actions based on the following criteria (Section 6.3.4.2):

4.1 Criteria Based Upon Nature of Emergency (Plant-Based PARs)

During a LOCA, evacuation of some or all of the persons within the LPZ may be recommended for any General Emergency situation regardless of whether or not any radioactive materials have been released from the plant.

Specific plant conditions with associated PARs were provided in Section 6.2.1 as follows:

Loss of Engineered Safety Feature (ESF) (Section 6.2.1.1)

If there is a failure of ESF with no signs of inadequate core cooling, then evacuate the transient population in the LPZ (PAZs 1 and 2), shelter the permanent population in the LPZ and shelter the remainder of the basic EPZ.

If there is a failure of ESF coupled with any signs of inadequate core cooling or loss of containment integrity, then evacuate the LPZ (PAZs 1 and 2) with preferential action taken in the downwind direction, and shelter the remainder of the basic EPZ.

Loss of Containment Isolation (Section 6.2.1.2)

If there is a failure of containment isolation with no signs of inadequate core cooling, then evacuate the transient population in the LPZ (PAZs 1 and 2) and shelter the remainder of the basic EPZ.

If there is a failure of containment isolation coupled with any signs of inadequate core cooling or loss of containment integrity, then evacuate the LPZ (PAZs 1 and 2).

Containment Pressure above Design Pressure (Section 6.2.1.3)

If containment pressure exceeds maximum allowable containment pressure as a function of earthquake strength curve, then evacuate the transient population in the LPZ (PAZs 1 and 2) and shelter the remainder of the basic EPZ.

Containment Radiation Levels (Refer to Section 6.2.1.4)

If containment radiation level exceeds the 100% gap release curve, then evacuate the LPZ (PAZs 1 and 2) and shelter the remainder of the basic EPZ.

Inadequate Core Cooling (Refer to Section 6.2.1.5)

If inadequate core cooling conditions exist, then evacuate the LPZ (PAZs 1 and 2) and shelter the remainder of the basic EPZ.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 29 of 51 Protective Action Recommendation (PAR) Strategy Bases 4.2 Criteria Based Upon Public Exposure (Dose-Based PARs)

Insofar as possible, evacuation of members of the general population should be carried out to prevent persons from receiving doses in excess of those listed in Table 6.3-2. Specific dose conditions with associated PARs were provided in Table 6.3-2 as follows:

If the projected whole body dose is 0.5 to 5 rem or thyroid dose is 5 to 25 rem, then consider evacuation unless constraints make it impractical (shelter as a minimum).

If the projected whole body dose is 5 rem or thyroid dose is 25 rem, then conduct mandatory evacuation (shelter is an alternative if evacuation cannot be promptly accomplished).

The lower action threshold of 0.5 rem deviated from the NRC prescribed EPA-520 guidance.

The DCPP SER approved Emergency Plan justification for this deviation identified it as being based upon guidance from the State of California. The SLO County Emergency Response Plan provides the following additional basis information:

Both California and the Federal government have established standards for radiation exposure. California standards are typically more stringent. The limits adopted in this section generally follow the more restrictive State statutes contained in the California Administrative Code, Title 17, Health and are taken from the State Plan.

The DCPP SER approved Emergency Plan did not include criteria describing how it was determined whether constraints were applicable.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 30 of 51 Protective Action Recommendation (PAR) Strategy Bases

5. DCPP SITE SPECIFIC PAR METHODOLOGY FLOWCHART BASES 5.1 NUREG-0654 Supplement 3 / NEI 12-10 PAR Methodology Flowchart Block Key General Emergency Declared (A)

Continue assessment maintain PAR (C)

No SIP (3) 2-mile rad ius and 5 miles downwind (4), all others monitor

and prepare (5) (E}

Yes No Yes PAR for 2-mile radius and Evacuate 2 mile radius 2-5 mile downwind, and SIP (3) 5 miles depends on. ETE (9), SIP downwind (4), all i . - - - - -Yes-. -------..:;_

5-10 mile downwind (4),

all others monitor and others mon itor and prepare (5) (GJ prepare (5} (H)

No When safer to do so, beg in staged evacuation of all affected areas (10) (J) Expand PAR only to areas where PAGs could be exceeded (L)

Yes After 2-mile ETE (7) evacuate 2-5 miles downwind (4), all others mon itor and prepare (5) (M}

Continue assessment

~ - - - - -~ (1 1)(N)

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 31 of 51 Protective Action Recommendation (PAR) Strategy Bases 5.1.1 Block A: PAR Determination Methodology Entry Point

a. Supplement 3 Development Guidance (No Supplement 3 Attachment A Note for this block)

Entry point for PAR determination (no modification is needed unless site specific PARs are required prior to a General Emergency).

b. DCPP Site Specific Bases The DCPP site specific PAR methodology entry point is the declaration of a General Emergency classification level (Refer to Section 2.4).

5.1.2 Block B: Rapidly Progressing Severe Accident Scenario Decision Point

a. Supplement 3 Development Guidance (Supplement 3 Attachment A Note 1; NRC EP FAQ 2013-004 Question 1)

A rapidly progressing severe accident is a General Emergency with rapid loss of containment integrity (emergency action levels indicate containment barrier loss) and loss of ability to cool the core. This path is used for scenarios in which containment integrity can be determined as bypassed or immediately lost during a GE with core damage. If this scenario cannot be immediately confirmed, assume it is not taking place and answer "no" to this decision block.

Supplement 3 Section 2.7 states "The emergency preparedness planning basis includes rapidly progressing scenarios that have a significant radioactive release in about 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ."

b. DCPP Site specific Bases The DCPP site specific definition of a Rapidly Progressing Severe Accident is as follows:

1. A Rapidly Progressing Severe Accident is occurring if ALL the following are present:

A General Emergency was declared AND Initial PAR AND Any EAL Table F-1 Containment Barrier Loss AND ANY of the following:

Radiation Monitor 30/31 > 5000 R/Hour EAL RG1.1 met for RM-87 > 1.9E-10 amps EAL RG1.1 met for RM-87 > 3.2E-1 µCi/cc E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 32 of 51 Protective Action Recommendation (PAR) Strategy Bases The selection of the DCPP site specific thresholds representing a rapidly progressing severe accident are based on indications readily available to operators and consistent with established EAL thresholds for simultaneous loss of containment, core cooling and fuel clad. Radiation Monitor 30/31 value of > 5000 R/hour is indicative of a loss of fuel clad and also indicates loss of the reactor coolant system (RCS) boundary in the fission product barrier matrix. The EAL RG1.1 threshold for any Table R-1 GE value with a Containment Loss criterion from the Fission Product Barrier Matrix is included to address a condition that bypasses containment. The ERO is trained and qualified to assess these EAL threshold values.

A second decision block was added to determine whether the PAR is the Initial PAR for a General Emergency consistent with clarification from NRC EP FAQ 2013-004, response to Question 1. The response states in part: "This protective action recommendation is the first after a General Emergency has been declared."

5.1.3 Block G: Rapidly Progressing Severe Accident Scenario PAR Determination

a. Supplement 3 Development Guidance (Supplement 3 Attachment A Notes 4, 5 and 9)

1. The licensee should issue an evacuation PAR in scenarios for which the time to evacuate 90% of the population within a 2-mile radius is 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or less. If the ETE is longer, the licensee should recommend SIP (applies to Note 9).

2. The licensee should consider TD for a daytime ETE and TN for a nighttime ETE (applies to Note 9).

3. The licensee should issue an evacuation PAR in scenarios for which the 2- to 5-mile downwind sector evacuation time for 90% completion is 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months or less. If the ETE is longer, the licensee should recommend SIP (applies to Note 9).

4. For all cases, the licensee should recommend SIP for the 5- to 10-mile downwind sectors. Licensees may perform an analysis to determine site specific ETE criteria instead of using this generic guidance (applies to Note 9).

5. To the extent practical and recognizing the urgency of the incident, impediments may be considered. The existence of impediments could change the most effective PAR from evacuation to SIP (applies to Note 9).

6. The ETE values should be representative for the site and should not include special events (applies to Note 9).

7. Extreme weather conditions, such as inversion, significant precipitation, or no wind, can change the efficacy of SIP and make evacuation the preferred protective action (applies to Note 9).

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 33 of 51 Protective Action Recommendation (PAR) Strategy Bases

8. Downwind sectors include a downwind 22.5-degree compass sector(s) and adjacent sectors. Generally, the downwind sectors involve three or four sectors and include all the emergency response planning areas impacted in that area (applies to Note 4).

9. Site specific wind persistence information may indicate the need to include additional sectors with the initial recommendation. However, the licensee should discuss this element with responsible OROs to determine whether expanded initial protective actions are appropriate or desirable.

The size of emergency response planning areas may determine whether there is a site specific need for this contingency (applies to Note 4).

10. The instruction to monitor and prepare is intended to engage the population within the plume exposure pathway Emergency Planning Zone, inform them of the emergency, and advise them that they should monitor the situation and prepare for the possibility of evacuation, SIP, or other protective actions (applies to Note 5).

b. DCPP Site Specific Bases The DCPP site specific PAR for Block G is to:

Evacuate PAZs 1 and 2 and all downwind PAZs to 10 miles Administer KI per SLO County Plan Evacuate the Ocean to 10 nautical miles All other PAZs monitor and prepare.

See discussion in Section 5.2 of this appendix for more information about Ocean PARs.

1. PAZ 1 is equivalent to the land area within the 2 mile generic EPZ. Since the 90% ETE for PAZ 1 is less than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months the appropriate PAR is to evacuate PAZ 1 (refer to Section 2.7.2).

2. The ETE scenarios used to determine the appropriate actions for a rapidly progressing severe accident scenario included daytime and nighttime periods (refer to Section 2.7.2).

3. PAZ 2 is more than equivalent to the land area within the 2 to 5 mile generic EPZ. PAZ 2 goes out to 6 miles. PAZs 1 and 2 are always recommended to evacuate simultaneously. Since the 90% ETE for PAZs 1 and 2 is less than 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months the appropriate PAR is to evacuate PAZs 1 and 2 (refer to Section 2.7.2).

NRC EP FAQ 2013-004, Question 3 and NRC final response does not affect how the DCPP site specific PAR methodology addresses Supplement 3, Note 9. The question pertains to evacuation time considerations for the 0 - 2 mile (PAZ 1) and 0 - 6 mile (PAZ 2) zones.

PAZs 1 and 2 are evacuated during a rapidly progressing severe accident; consequently the variation of wind direction is not applicable to the DCPP protective action strategy.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 34 of 51 Protective Action Recommendation (PAR) Strategy Bases

4. Analysis of the DCPP ETE's indicates it is faster to simultaneously evacuate PAZs 1 through 5 than to implement a staged evacuation. In the majority of the ETE scenarios, the simultaneous evacuation times did not exceed 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . The worst case scenarios for a simultaneous evacuation of PAZs 1 through 5 resulted in an ETE of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months and 15 minutes. This time difference of approximately 15 minutes (3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months versus 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 15 minutes) does not warrant the additional complication involved in a staged evacuation for a rapidly progressing severe accident scenario.

Thus, the appropriate DCPP site specific PAR in this event is to evacuate the downwind PAZs in the 6 to 10 mile area (Refer to Section 2.7.2).

NRC EP FAQ 2013-004, Question 4 and NRC final response does not affect how the DCPP site specific PAR methodology addresses Supplement 3, Note 9 "Evacuate 2 mile radius and SIP 5 miles downwind, all others monitor and prepare" (staged evacuation). The DCPP protective action strategy does not employ staged evacuation; therefore, this response does not affect the DCPP site specific bases.

5. Due to the potential radiological consequences of the rapidly progressing severe accident scenario, the uncertainty for further degradation of plant conditions and the urgency of the incident, the DCPP site specific PAR methodology does not take impediments into consideration. This evaluation is performed by the County as agreed upon with County officials during the development of this appendix.

6. The ETE values used to determine the appropriate actions for a rapidly progressing severe accident scenario were taken from KLD TR-1235 Table 7.1, Time to Clear the Indicated Area of 90 Percent of the Affected Population. ETE values for special events and roadway impacts are not included (Refer to Section 2.7.2).

7. Since SIP of the PAZs in the 6 to 10 mile area is not part of the DCPP site specific PAR methodology, consideration of extreme weather conditions that would warrant evacuation over SIP are not necessary (Refer to Section 2.7.2).

The County of SLO and DCPP, in advance, have made an agreement that the County of SLO will be responsible for making determinations concerning impediments to evacuation; including the impact of adverse weather. DCPP PARs will be issued to the County based on this agreement.

8. The determination of the affected PAZs related to downwind sectors is based upon the information provided in Table 6.1 of the ETE Report. A PAZ is considered affected if any portion of it falls within the affected sector or the adjacent sectors.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 35 of 51 Protective Action Recommendation (PAR) Strategy Bases The DCPP EPZ in the 6-10 mile area is divided into three PAZs (3, 4, & 5).

Since all potential wind directions and their respective downwind and adjacent sectors contain either the ocean or a PAZ containing an ocean harbor, an Ocean PAR distance of 10 nautical miles is established for all rapidly progressing severe accident scenarios.

Wind From 0-6 Mile 6-10 Mile Ocean Affected Sectors (Degrees) PAZs PAZs PAR 349° to < 012° SSW S SSE 1, 2 N/A 10 NM 012° to < 034° SW SSW S 1, 2 N/A 10 NM 034° to < 057° WSW SW SSW 1, 2 N/A 10 NM 057° to < 079° W WSW SW 1, 2 N/A 10 NM 079° to < 102° WNW W WSW 1, 2 N/A 10 NM 102° to < 124° NW WNW W 1, 2 N/A 10 NM 124° to < 147° NNW NW WNW 1, 2 5 10 NM 147° to < 169° N NNW NW 1, 2 5 10 NM 169° to < 192° NNE N NNW 1, 2 5 10 NM 192° to < 214° NE NNE N 1, 2 4, 5 10 NM 214° to < 237° ENE NE NNE 1, 2 3, 4, 5 10 NM 237° to < 259° E ENE NE 1, 2 3, 4, 5 10 NM 259° to < 282° ESE E ENE 1, 2 3, 4 10 NM 282° to < 304° SE ESE E 1, 2 3, 4 10 NM 304° to < 327° SSE SE ESE 1, 2 3 10 NM 327° to < 349° S SSE SE 1, 2 3 10 NM

9. The ETE Report determines whether a PAZ is affected based upon whether its boundary is within the associated or adjacent sectors. This methodology is inherently conservative and thus does not support additional PAZs being specified as affected based on wind persistence (refer to Section 2.5.2). DCPP discussed this element with the responsible OROs and determined that expanded initial protective actions are not appropriate or desirable.

10. "Monitor and prepare" is included for the other PAZs as part of the DCPP PAR.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 36 of 51 Protective Action Recommendation (PAR) Strategy Bases 5.1.4 Block J: Evacuation Timing for Rapidly Progressing Severe Accident Scenarios

a. Supplement 3 Development Guidance (Supplement 3 Attachment A Note 10)

Evacuation after the SIP period is critical for reducing public exposure.

Licensees should discuss the evacuation of the sheltered population with OROs.

b. DCPP Site Specific Bases The DCPP site specific PAR flowchart does not have an equivalent for Block J.

SIP with a subsequent staged evacuation is not performed in the 6 to 10 mile downwind PAZs for the rapidly progressing severe accident scenario at DCPP. ETE results indicate no advantage to implementing staged evacuation.

A PAR of evacuate is issued for the 6 to 10 mile downwind PAZs (refer to 5.1.3b).

5.1.5 Block D: Impediments to Evacuation Decision Point

a. Supplement 3 Development Guidance (Supplement 3 Attachment A Note 2)

1. Evacuation Support (e.g., Traffic Control) - In this situation, the GE is the initial notification, or if a previous notification was made, the GE notification occurs before preparations to support an evacuation are complete.

Many sites have a low population density within 2 miles, and lack of traffic control may not be considered an impediment. The licensee and OROs should discuss this element and reach an agreement.

Otherwise, the licensee and OROs should agree, in advance, on an expected time for evacuation support to be put in place after notification of an emergency classification. The site specific PAR procedure for those sites at which a delay of an initial staged evacuation is necessary, pending support setup, should include this time. The licensee would base procedures on the agreement and would not confer with OROs before making the initial PAR notification.

2. Hostile-Action-Based General Emergency (armed attack) - OROs may determine that an initial recommendation to shelter in place (SIP) rather than evacuation is the preferred path for a hostile action event. The licensee would discuss this element with OROs and reach an agreement during the development process. The licensee would base procedures on the agreement and would not confer with OROs before making the initial PAR notification.

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3. Adverse Weather / Hazardous Conditions - Licensees are not responsible for soliciting information or for making a determination that adverse weather or other impediments for safe public evacuation (e.g., an earthquake or wildfire) exist at the time of the emergency. However, the licensee will consider an impediment to exist if OROs have previously notified it of such an impediment (e.g., roadways are closed because of deep snow). During the planning process, OROs may determine that the licensee does not need to consider adverse weather in its plant PAR procedures.

b. DCPP Site Specific Bases The DCPP site specific PAR flowchart does not contain an equivalent to Block D concerning considerations of impediments for evacuation.

PAZs 1 and 2 represent all of the land area within the generic 5 mile EPZ area. PAZ 1 is equivalent to the land area within the 2 mile generic EPZ and PAZ 2 is equivalent to the land area within the 2 to 5 mile generic EPZ (approximately 6 miles for DCPP). Based on the remote geography and limited population of PAZs 1 and 2, these areas are always recommended to evacuate simultaneously (Refer to Section 2.5.2).

1. DCPP has a low population density within PAZs 1 and 2 (6 miles) which results in favorable evacuation times. The longest 90% ETE for PAZs 1 and 2 is only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 45 minutes. The DCPP site specific PAR methodology does not take impediments into consideration. This evaluation is performed by the County as agreed upon with County officials during the development of this appendix.

2. DCPP has a low population density within PAZs 1 and 2 (6 miles) which results in favorable evacuation times. The longest 90% ETE for PAZs 1 and 2 is only 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 45 minutes. Therefore, the PAR to evacuate PAZs 1 and 2 rather than shelter in place (SIP) was determined to be the preferred path for a hostile action event. This basis was agreed to by the responsible OROs.

3. The responsible OROs determined that DCPP PAR procedures do not need to consider adverse weather or other impediments. SLO County concluded the information from DCPP should provide recommendations based solely upon the plant and radiological conditions. SLO County provides the adjustment to recommendations in their Protective Action Decision process based on impediments to evacuation or other unknown factors DCPP is not aware of.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 38 of 51 Protective Action Recommendation (PAR) Strategy Bases 5.1.6 Block E: With Impediments Minimum Plant Based PAR

a. Supplement 3 Development Guidance (Supplement 3 Attachment A Notes 3, 4 and 5)

1. SIP means that instructions are given to members of the public to remain indoors, turn off heating or air conditioning (as appropriate for the region and season), close windows, monitor communications channels, and prepare to evacuate. The instructions should specify that SIP is safer than evacuation at this time, or that, alternatively, SIP is being implemented in order to keep roadways clear to allow others to evacuate rapidly. The intent of SIP is for members of the public to remain where they currently are or to seek shelter close by, but they should not return home to shelter when more immediate options for sheltering are available (applies to Note 3).

2. Downwind sectors include a downwind 22.5-degree compass sector(s) and adjacent sectors. Generally, the downwind sectors involve three or four sectors and include all the emergency response planning areas impacted in that area (applies to Note 3).

3. Site specific wind persistence information may indicate the need to include additional sectors with the initial recommendation. However, the licensee should discuss this element with responsible OROs to determine whether expanded initial protective actions are appropriate or desirable.

The size of emergency response planning areas may determine whether there is a site specific need for this contingency (applies to Note 4).

4. The instruction to monitor and prepare is intended to engage the population within the plume exposure pathway Emergency Planning Zone, inform them of the emergency, and advise them that they should monitor the situation and prepare for the possibility of evacuation, SIP, or other protective actions (applies to Note 5).

b. DCPP Site Specific Bases The DCPP site specific PAR flowchart does not contain an equivalent for Block E. DCPP does not recommend the protective action to shelter due to impediments to evacuation in response to SLO County request discussed above in Section 5.1.5b. PAZs 1 and 2 go out to 6 miles and have an ETE of less than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to evacuate 90% of the population. Evacuation of PAZs 1 and 2 rather than SIP was determined to be the more effective method of protection at the declaration of a General Emergency. Remaining PAZs will be recommended for evacuation based on field measurements or dose assessment calculations that show EPA-400 PAGs could be exceeded.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 39 of 51 Protective Action Recommendation (PAR) Strategy Bases 5.1.7 Block F: Impediments Removed

a. Supplement 3 Development Guidance (Supplement 3 Attachment A Note 8)

1. Removal of evacuation impediments involves the following:

Evacuation Support. If the OROs identified this contingency as necessary during the planning effort, the licensee should notify OROs with an evacuation PAR when the agreed upon time (e.g.,

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months from the GE notification) has elapsed. The licensee shift staff is not expected to confer with OROs before changing the PAR, but if the augmenting ERO is activated they may do so.

Hostile Action (Armed Attack). OROs may identify this contingency as necessary during the planning effort. It may be appropriate to set up a timeframe for the licensee to notify OROs with an evacuation PAR. The licensee shift staff is not expected to confer with OROs before changing the PAR, but if the augmenting ERO is activated they may do so.

Adverse Weather. If weather or some other roadway disruption caused the impediment, OROs will determine when it is appropriate to change the protective action. Licensees have no responsibility for PAR modification unless a PAR change is necessary because of plant conditions or radiological assessment.

OROs determine when it is safe for the public to evacuate.

b. DCPP Site Specific Bases The DCPP site specific PAR flowchart does not have an equivalent for Block F. DCPP does not recommend sheltering in place (SIP) due to impediments to evacuation. This evaluation is performed by the County as agreed upon with County officials during the development of this appendix.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 40 of 51 Protective Action Recommendation (PAR) Strategy Bases 5.1.8 Block H: No Impediments Minimum Plant Based PAR

a. Supplement 3 Development Guidance (Supplement 3 Attachment A Notes 3, 4 and 5)

1. SIP means that instructions are given to members of the public to remain indoors, turn off heating or air conditioning (as appropriate for the region and season), close windows, monitor communications channels, and prepare to evacuate. The instructions should specify that SIP is safer than evacuation at this time, or that, alternatively, SIP is being implemented in order to keep roadways clear to allow others to evacuate rapidly. The intent of SIP is for members of the public to remain where they currently are or to seek shelter close by, but they should not return home to shelter when more immediate options for sheltering are available (applies to Note 3).

2. Downwind sectors include a downwind 22.5-degree compass sector(s) and adjacent sectors. Generally, the downwind sectors involve three or four sectors and include all the emergency response planning areas impacted in that area (applies to Note 4).

3. Site specific wind persistence information may indicate the need to include additional sectors with the initial recommendation. However, the licensee should discuss this element with responsible OROs to determine whether expanded initial protective actions are appropriate or desirable.

The size of emergency response planning areas may determine whether there is a site specific need for this contingency (applies to Note 4).

4. The instruction to monitor and prepare is intended to engage the population within the plume exposure pathway Emergency Planning Zone, inform them of the emergency, and advise them that they should monitor the situation and prepare for the possibility of evacuation, SIP, or other protective actions (applies to Note 5).

b. DCPP Site Specific Bases The DCPP site specific PAR for Block H is to:

Evacuate PAZs 1 and 2 Evacuate the Ocean to 5 nautical miles Administer KI per SLO County plan All other PAZs monitor and prepare

1. The PAZ 1 and PAZ 2 permanent and transient populations are very small in number (Refer to ETE Report Tables 3-1 and 3-4). Staged evacuation of PAZs 1 and 2 takes approximately the same time as simultaneous evacuation of PAZs 1 and 2 for the 90% population in each of the applicable scenarios (refer to ETE report Table 7.1).

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 41 of 51 Protective Action Recommendation (PAR) Strategy Bases Scenario (1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

/ Region R02 1:15 1:15 1:30 1:30 1:25 1:15 1:15 1:45 1:45 1:30 R20 1:15 1:15 1:30 1:30 1:30 1:15 1:15 1:45 1:45 1:30 Difference 0:00 0:00 0:00 0:00 0:05 0:00 0:00 0:00 0:00 0:00 Average: 0:00 R02 represents the simultaneous evacuation of PAZ 1 & 2 R20 represents the staged evacuation of PAZ 1 first followed by 2 There is no benefit to staged evacuation for these areas. Therefore, PAZs 1 and 2 are always recommended to evacuate simultaneously. SIP for PAZ 2 is not appropriate for the DCPP site specific PAR for this block.

2. The DCPP site specific PAZ equivalent to the 2-5 mile area (PAZ 2) is not divided into multiple geographic areas. Thus there are no downwind areas within this PAZ.

3. The DCPP site specific PAZ equivalent to the 2-5 mile area (PAZ 2) is not divided into multiple geographic areas. Thus wind persistence has no affect for this PAZ. Also, the ocean area is recommended for evacuation from 0 to 5 nautical miles as part of the radial evacuation area completing the 360-degree protective action recommendation.

4. The DCPP PAR methodology includes the provision for the balance of the PAZs to "monitor and prepare" as provided for in the SER approved Emergency Plan.

5. An addition to the DCPP PAR methodology is the administration of KI for the general public per the SLO County Emergency Response Plan. This provision was implemented to be consistent with Federal guidance for licensee recommendations in jurisdictions that opt to provide KI to the public.

5.1.9 Block M: Evacuation Timing for Downwind Sectors

a. Supplement 3 Development Guidance (Supplement 3 Attachment A Notes 7, 4 and 5)

1. Implementation of this element should occur at the time of the site specific 2-mile evacuation time estimate (ETE) for 90-percent evacuation (e.g., T hours (use site specific time) after OROs were notified of the initial PAR to evacuate downwind sectors) (applies to Note 7).

2. Downwind sectors include a downwind 22.5-degree compass sector(s) and adjacent sectors. Generally, the downwind sectors involve three or four sectors and include all the emergency response planning areas impacted in that area (applies to Note 4).

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3. Site specific wind persistence information may indicate the need to include additional sectors with the initial recommendation. However, the licensee should discuss this element with responsible OROs to determine whether expanded initial protective actions are appropriate or desirable.

The size of emergency response planning areas may determine whether there is a site specific need for this contingency (applies to Note 4).

4. The instruction to monitor and prepare is intended to engage the population within the plume exposure pathway Emergency Planning Zone, inform them of the emergency, and advise them that they should monitor the situation and prepare for the possibility of evacuation, SIP, or other protective actions (applies to Note 5).

b. DCPP Site Specific Bases

1. Initial evacuation is for PAZs 1 and 2 which covers the 0 to 6-mile area.

PAZ 1 (0 to 2-mile radius) has a permanent and transient population of 0; therefore, does not have any impact to evacuation. Evacuation of the downwind areas follows or is coincident with evacuation of PAZs 1 and 2 based upon dose assessment or field team data. ETE Report Section 7.6 provides comparison of the evacuation times for staged evacuation and simultaneous evacuation of the respective areas. It concludes there is no benefit of staged evacuation for either the 2-mile or 6-mile regions by adopting a SIP protective action as described in Block H.

2. DCPP and the responsible OROs have taken the emergency response planning areas (ERPAs) and made them into Protective Action Zones.

DCPP uses these PAZs to make PARs to the County. The County then can use DCPP's PAR, along with other factors, to make a PAD. This helps to shorten the PAR to PAD process. This process is different from Supplement 3, but meets the intent to make PARs in a timely manner.

The determination of the affected PAZs related to downwind sectors is based upon the information provided in Table 6-1 of the ETE Report. A PAZ is considered affected if any portion of it falls within that or the adjacent sectors.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 43 of 51 Protective Action Recommendation (PAR) Strategy Bases The DCPP EPZ in the 10-22 mile area is divided into seven PAZs (PAZ 6

- 12). The following Table includes the PAZs for the full EPZ:

Wind From 0-6 Mile 6-10 Mile 10-22 Mile Affected Sectors (Degrees) PAZs PAZs PAZs 349° to < 012° SSW S SSE 1, 2 N/A N/A 012° to < 034° SW SSW S 1, 2 N/A N/A 034° to < 057° WSW SW SSW 1, 2 N/A N/A 057° to < 079° W WSW SW 1, 2 N/A N/A 079° to < 102° WNW W WSW 1, 2 N/A N/A 102° to < 124° NW WNW W 1, 2 N/A N/A 124° to < 147° NNW NW WNW 1, 2 5 9 147° to < 169° N NNW NW 1, 2 5 9 169° to < 192° NNE N NNW 1, 2 5 9 192° to < 214° NE NNE N 1, 2 4, 5 8, 9 214° to < 237° ENE NE NNE 1, 2 3, 4, 5 8, 9 237° to < 259° E ENE NE 1, 2 3, 4, 5 7, 8, 9, 11 259° to < 282° ESE E ENE 1, 2 3, 4 6, 7, 8, 10, 11, 12 282° to < 304° SE ESE E 1, 2 3, 4 6, 7, 8, 10, 11, 12 304° to < 327° SSE SE ESE 1, 2 3 6, 7, 10, 11, 12 327° to < 349° S SSE SE 1, 2 3 10, 12

3. The ETE Report provides evacuation times for combination of PAZs that would be affected by specific wind direction. This methodology is inherently conservative and thus does not support additional PAZs being specified as affected based on wind persistence. Refer to Section 2.5.2.

This basis for not including additional PAZs to the list of affected downwind PAZs due to wind persistence has been reviewed and agreed to by the responsible OROs.

Ocean PARs are expanded from 5 nautical miles to 10 nautical miles based on dose assessment results that show areas over the ocean that could exceed EPA-400 PAGs. This expansion completes the radial evacuation for areas comparable to the land areas that would be evacuated based upon wind direction.

4. The DCPP PAR methodology includes the provision for the balance of the PAZs to "monitor and prepare" as provided for in the SER approved Emergency Plan.

5. An addition to the DCPP PAR methodology is the administration of KI for the general public per the SLO County Emergency Response Plan. This provision was implemented to be consistent with Federal guidance for licensee recommendations in jurisdictions that opt to provide KI to the public.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 44 of 51 Protective Action Recommendation (PAR) Strategy Bases 5.1.10 Blocks C and N: Continue Assessment

a. Supplement 3 Development Guidance (Supplement 3 Attachment A Note 11)

Radiological and meteorological assessments should be continued and evacuation considered for any areas where dose projections or field measurements indicate that PAGs may be exceeded.

b. DCPP Site Specific Bases The DCPP site specific PAR methodology for continuation of assessment is provided throughout the PAR evaluation decision process.

The DCPP site specific PAR methodology has provisions for continuous PAR assessment from each decision branch throughout the event.

The Supplement 3 Block N flowchart dead-ends without providing instruction where the continued assessment should enter back into the flowchart. Thus, the DCPP site specific PAR methodology corrects the dead-end error in the guidance flow-chart by providing specific instruction on where to re-enter.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 45 of 51 Protective Action Recommendation (PAR) Strategy Bases 5.1.11 Blocks I and K: General Emergency Conditions Remain

a. Supplement 3 Development Guidance (Supplement 3 Attachment A Note 6)

1. If the plant has mitigated the conditions that caused the GE declaration (i.e., core cooling is restored), expanding the PAR to evacuate downwind sectors upon completion of the initial staged evacuation may not be necessary. However, if GE emergency action levels are still met, expansion of the PAR to the downwind sectors may be appropriate.

2. If the plant restores core cooling, it must still perform a radiological assessment to identify the extent of contamination, if any.

3. If surveys or dose projections reveal areas under no protective action direction where protective action guidelines (PAGs) could be exceeded, the members of the public in those areas should be evacuated or sheltered, as appropriate.

b. DCPP Site Specific Bases The DCPP site specific PAR methodology evaluates whether a General Emergency is still in effect prior to the development of new PARs while in the "continue assessment" loop.

1. If the emergency classification level is no longer a General Emergency, then additional PARs will not be developed. If the emergency classification level remains at a General Emergency, then exceeding PAGs in areas not already recommended for evacuation will result in additional PARs.

2. If the restoration of core cooling results in the exiting of the General Emergency classification level, then additional PARs will not be developed. If the restoration of core cooling does not result in the exiting of the General Emergency classification level, then continuous assessment to determine the need for additional PARs will continue. In either case, field team activities involving radiological assessment to identify the extent of contamination will continue.

3. Field surveys or dose projections that reveal areas where PAGs could be exceeded are thresholds for the General Emergency classification level and result in the development of PARs for those areas in the DCPP site specific PAR methodology.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 46 of 51 Protective Action Recommendation (PAR) Strategy Bases 5.1.12 Block L: PAR Expansion Only When Protective Action Guidelines (PAGs) Exceeded

a. Supplement 3 Development Guidance (No Supplement 3 Attachment A Note for this block)

The "Expand PAR only to areas where PAGs could be exceeded" is the end point in the Supplement 3 guidance flow-chart when General Emergency conditions are no longer met.

b. DCPP Site Specific Bases The DCPP site specific PAR flowchart provides a series of decision blocks for a methodology to determine appropriate PAR expansion with provisions for beyond the EPZ including the ocean.

The DCPP site specific PAR methodology includes continuous assessment while in a General Emergency classification level that includes the expansion of PARs to areas where PAGs could be exceeded.

If the site is no longer in a General Emergency classification level then additional PARs are not warranted (if a PAG could be exceeded then a General Emergency condition still exists).

5.2 Additional Protective Action Recommendation 1: Ocean PAR 5.2.1 DCPP Site Specific Bases The DCPP site specific PAR flowchart includes ocean evacuation recommendations for 5 nautical miles or 10 nautical miles depending upon plant conditions and/or dose assessment results that indicate EPA-400 PAGs could be exceeded on areas over the ocean.

The DCPP Emergency Plan requires a protective action recommendation for the ocean. DCPP 50.54(q) Effectiveness Evaluation (2014-02) includes the basis used for initial and subsequent expansion of PARs for the ocean. An excerpt of the compliance section of that evaluation explaining the basis for ocean PARs is as follows:

The DCPP procedure that implemented the PAR determination methodology of the SER approved Emergency Plan contained the method that the NRC accepted as compliant with the regulations. The method incorporated by that procedure identified affected areas by sector and by Protective Action Zone (PAZ) within the Emergency Planning Zone (EPZ). Although not explicitly stated, the procedure implied that an evacuation PAR was to be issued for the ocean when an affected or adjacent sector involved the ocean.

Subsequent implementing procedure changes included a table that explicitly translated the 16 wind rose sectors into affected PAZs, including the ocean.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 47 of 51 Protective Action Recommendation (PAR) Strategy Bases The current DCPP PAR methodology does not utilize sectors, but rather directly identifies affected areas by PAZ in order to be consistent with the site specific geographic zones utilized by the offsite agencies. Restoration of the ocean PAR determination methodology has been adapted to use the site specific PAZ methodology for DCPP areas within the EPZ. Restoration of the DCPP ocean PAR methodology resulted in a revision to EP RB-10 that includes three progressively escalating conditions:

a. Consistent with current and historical protective actions for the ocean implemented by the United States Coast Guard (USCG) and the County at the General Emergency classification level, DCPP will recommend evacuation of the ocean out to 5 nautical miles (NM) as a minimum PAR.

b. Consistent with current and historical protective actions for the ocean implemented by the USCG and the County, if an EPA PAG (1000 mrem TEDE or 5000 mrem Thyroid CDE) is exceeded in any area over the ocean beyond 5 miles, DCPP will recommend evacuation of the ocean out to 10 NM.

c. If an EPA PAG (1000 mrem TEDE or 5000 mrem Thyroid CDE) is exceeded in any area over the ocean beyond 10 miles, DCPP will recommend evacuation of the ocean for specific areas developed under the same methodology used to develop PARs for land areas beyond the EPZ boundary.

The first two conditions for ocean PAR determination described above are consistent with the original methodology that implemented the SER approved Emergency Plan, without calling for the translation to geographic zones (PAZs) from generic sectors. Current methodology and terminology for the 12 land based PAZs used by the response agencies and the general public do not use sectors as a means of geographic distinction for the DCPP EPZ. The PAZs were originally developed by California Office of Emergency Services (OES) and SLO County in order to provide for detailed planning and implementation of protective measures in site specific geographic areas within the Basic and Extended EPZs.

The third ocean PAR determination described above was not part of the original methodology that implemented the SER approved Emergency Plan, but is included for consistency with NRC guidance regarding actions beyond the defined EPZ boundary.

Sheltering was dismissed in the 50.54(q) effectiveness evaluation 2014-02. There is no benefit to the use of sheltering for an ocean PAR as boats do not provide a sheltering factor and are by nature mobile; therefore, evacuation is the appropriate protective action used for the Ocean PAR.

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 48 of 51 Protective Action Recommendation (PAR) Strategy Bases 5.3 Additional Protective Action Recommendation 2: Short Term Release NRC EP FAQ - Question 2 and final NRC response is provided in part below:

"Controlled venting could affect an area beyond initial evacuation orders (e.g., five to ten miles downwind). It is difficult to identify scenarios, other than controlled venting, that would include a short term release of known duration. In any case, augmented ERO radiological staff and decision makers should be aware of the possibility. A decision could be made in such cases to SIP for a short duration release, but such considerations would not be appropriate for Control Room guidance.

Finally, the NEI guidance endorsed by RIS 2005-08 notes the use of advisory messaging to direct the public to monitor. This measure has been emphasized in Supplement 3 as direction to "monitor and prepare." SIP is not the same measure as "monitor and prepare." An SIP order that is not necessary prevents families from reuniting when it would be beneficial for evacuation readiness. Automatic SIP for areas not affected by an actual or potential radiological release should not be recommended nor implemented as it has the potential to detract from public health and safety."

5.3.1 DCPP Site Specific Bases The DCPP site specific PAR flowchart provides a shelter PAR for PAZs 1 and 2 if there is a short term, controlled release that will be less than 60 minutes. If the release continues for 60 minutes or longer, then dose assessment results will be used to determine if evacuation is necessary based on the EPA PAGs.

Discussions with Region IV EP and NRC headquarters EP representatives resulted in agreement that a sheltering PAR can be included for a short term release though it is developed with a separate basis from NUREG-0654, Supplement 3. Additional dialogue concerning this aspect of the PAR methodology is contained in the 50.54(q) effectiveness evaluation (2014-75).

The DCPP PAR methodology retains the action to recommend sheltering for short term, controlled releases (less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months in duration). The control room or the augmented ERO can make a shelter PAR. The control room is most cognizant of a controlled evolution, for example containment vent, such that there is a greater assurance of maintaining the release for less than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . A shelter PAR recommendation is provided since the evacuation time for PAZs 1 and 2 (up to 6 miles) is greater than the 60 minute release time.

5.4 Additional Protective Action Recommendation 3: Administer Potassium Iodine (KI) In Accordance With the County Plan.

Licensees are required to provide a recommendation if the respective jurisdictions in the EPZ have elected to include distribution of KI to the general public. (Ref.

10 CFR 50.47(b)(10) planning standard function. See also, discussion in Inspection Manual Chapter 0609, Appendix B for 10 CFR 50.47(b)(10)).

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E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 49 of 51 Protective Action Recommendation (PAR) Strategy Bases 5.4.1 DCPP Site Specific Bases The DCPP site specific PAR flowchart provides for recommending KI be administered per SLO County Plan.

The SLO County Health Officer has the authority and responsibility for directing the general public in San Luis Obispo County to ingest potassium iodide (KI). The County Health Officer and County Emergency Services Director will make the final determination that ingestion of KI is to be implemented.

5.5 Additional Protective Action Recommendation 4: Plume exposure beyond the EPZ.

The licensee is obligated to have the capability to develop protective action recommendations beyond the EPZ. The actions can be ad-hoc in nature.

5.5.1 DCPP Site Specific Bases The DCPP site specific PAR flowchart provides for incremental evacuation at 2-mile segments should EPA PAGs be exceeded in areas beyond PAZs 8, 9, 11, or 12 (EPZ boundary on land) or areas beyond 10 miles over the ocean (EPZ boundary over the ocean).

DCPP methodology evacuates the affected sector and adjacent sectors in two-mile increments, out to a distance where the projected offsite dose is less than 1000 mrem TEDE and 5000 mrem Thyroid CDE E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 50 of 51 Protective Action Recommendation (PAR) Strategy Bases

6. DCPP SITE SPECIFIC PAR FLOWCHART General Emergency Declared Recommend ALL of the following PARs:

Evacuate PAZ 1 and 2 Evacuate PAZ(s) 3, 4, 5 per RPSA Wind Direction Table Event is a Rapidly Progressing Severe Initial PAR Evacuate Ocean to 10 nautical miles YES YES Accident? assessment? Administer KI per SLO County Plan (Note 2) All other PAZs Monitor and Prepare NO THEN GO TO BLOCK A to continue assessment NO Recommend ALL of the following PARs:

Is this a Controlled Shelter PAZ 1 and 2 RPSA Wind Direction Table Short Term Release YES Evacuate Ocean to 5 nautical miles Wind Direction Evacuate Evacuate T < 60 minutes? Administer KI per SLO County Plan (from) PAZ Ocean All other PAZs Monitor and Prepare NO 0° to < 124° 1, 2 10 nautical miles THEN GO TO BLOCK A to continue assessment 124° to < 192° 1, 2, 5 10 nautical miles Recommend ALL of the following PARs:

Evacuate PAZ 1 and 2 192° to < 214° 1, 2, 4, 5 10 nautical miles Evacuate Ocean to 5 nautical miles 214° to < 259° 1, 2, 3, 4, 5 10 nautical miles Administer KI per SLO County Plan All other PAZs Monitor and Prepare BLOCK A 259° to < 304° 1, 2, 3, 4 10 nautical miles 304° to < 349° 1, 2, 3 10 nautical miles THEN continue assessment below 349° to 360° 1, 2 10 nautical miles

~= WHEN Dose Assessment or Field Survey NOTES Dose Assessment or Field NO results are available, 1. -IF flowchart decision block conditions are Survey results available?

THEN GO TO -BLOCK A unknown, -THEN answer "NO".

I

2. A Rapidly Progressing Severe Accident is YES occurring if ALL of the following are present:

A General Emergency was declared AND Evacuation Recommend ALL of the following PARs: Initial PAR threshold exceeded in Evacuate applicable PAZ(s) not already AND ANY PAZ NOT previously YES designated for Evacuation? designated for evacuation Any EAL Table F-1 Containment Barrier Loss Administer KI per SLO County Plan AND ANY of the following:

NO I

RM-30/31 > 5000 R/hr

EAL RG1.1 met for RM-87 > 1.9E-10 amps

EAL RG1.1 met for RM-87 > 3.2E-1 µCi/cc Evacuation Recommend ALL of the following PARs: 3. Evacuation thresholds are based on dose threshold exceeded in Ocean beyond 5 miles? YES______,. Evacuate the Ocean to 10 nautical miles assessment OR field survey results that are Administer KI per SLO County Plan either:

GREATER THAN 1000 mrem TEDE NO I OR

GREATER THAN 5000 mrem Thyroid CDE

4. -IF the plant has mitigated the conditions that Recommend ALL of the following PARs:

caused the GE declaration (i.e., core cooling Evacuation restored, containment integrity restored, etc.),

threshold exceeded beyond PAZ 8, 9, 11 or 12 OR Ocean beyond 10 YES ------. Evacuate affected sector AND adjacent sectors in 2 mile increments to the -THEN expanding the PAR - MAY -NOT be distance at which evacuation threshold is miles?

no longer exceeded appropriate.

Administer KI per SLO County Plan 5. -IF there is no longer a risk to the public because NO the GE conditions are not currently present, THEN GO TO -BLOCK A to continue assessment -THEN no new PAR should be issued.

6. Once a PAR is communicated to SLO County, the PAR stays in effect for the event duration.

IF ANY of the following occurs, THEN GO TO BLOCK A to reassess PARs: 7. Do NOT issue a SHELTER PAR for a PAZ that was Radiological conditions change. previously issued an EVACUATION PAR.

Wind direction changes such that another PAZ may be affected. 8. Dose assessment results are required once a After 60 minutes when a sheltering PAR has been made to check if the radiological release has stopped. release starts and continue until the emergency Dose Assessment or Field Survey results become available. event is terminated.

E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

E-Plan Appendix G - Diablo Canyon Power Plant Emergency Plan Page 51 of 51 Protective Action Recommendation (PAR) Strategy Bases

7. REFERENCES 7.1 NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1 7.2 NUREG-0654 Rev 1, Supplement 3, Guidance for Protective Action Strategies 7.3 NRC EP FAQ 2013-004 NRC Responses to 8 questions regarding Supplement 3, Rev. 1 7.4 EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, 1991 7.5 NEI 12-10, Guideline for Developing a Licensee Protective Action Recommendation Procedure Using NUREG-0654 Supplement 3, Rev. 0 7.6 Emergency Planning Zones for Serious Nuclear Power Plant Accidents, State of California, Office of Emergency Services, November 1980 7.7 KLD TR-1235, Diablo Canyon Power Plant Development of Evacuation Time Estimates, Revision 0 7.8 State of California Nuclear Power Plant Emergency Response Plan (2019) 7.9 San Luis Obispo County/Cities Nuclear Power Plant Emergency Response Plan (2022) 7.10 DCPP 50.54(q) Effectiveness Evaluation 2014-02 7.11 DCPP 50.54(q) Effectiveness Evaluation 2014-75 7.12 EP RB-10, Protective Action Recommendations 7.13 EP G-3, Emergency Notification of Off Site Agencies 7.14 EP OR-3, Emergency Recovery 7.15 NRC letter dated September 25, 2017, B. K. Signal, Senior Project Manager, Nuclear Reactor Regulation to E. D. Halpin, Senior Vice President Generation and Chief Nuclear Officer PGE approval of License Amendments 231 and 233 for EAL conversion to NEI 99-01 Rev. 6 E-Plan_Appendix_Gu3r00.DOC 0925.1441 5.00

Enclosure 6 PG&E Letter DCL-23-128 PG&E Letter DIL-23-010 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Revision Numbers for Emergency Plan Implementing Procedures

Enclosure 6 PG&E Letter DCL-23-128 PG&E Letter DIL-23-010 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Proc. No. Rev. Title EP G-1 46 Emergency Classification and Emergency Plan Activation EP G-2 55 Interim Emergency Response Organization EP G-3 64* Emergency Notification of Off-Site Agencies EP G-4 31 Assembly and Accountability EP G-5 16 Evacuation of Non-Essential Site Personnel EP OR-3 10 Emergency Recovery EP RB-1 9 Personnel Dosimetry EP RB-2 9 Emergency Exposure Guides EP RB-3 10 Stable Iodine Thyroid Blocking EP RB-4 7 Access to and Establishment of Controlled Areas Under Emergency Conditions EP RB-5 9 Alternate Personnel Decontamination Facilities EP RB-8 31 Instructions for Field Monitoring Teams EP RB-10 22* Protective Action Recommendations EP RB-12 12 Plant Vent Iodine and Particulate Sampling During Accident Conditions EP RB-14 12 Core Damage Assessment Procedure EP RB-14A 3 Initial Detection of Fuel Cladding Damage EP RB-15 16 Post Accident Sampling System EP RB-16 19 Operating Instructions for the EARS Computer Program EP RB-17 2 Operating Instructions for QuickDose EP R-2 38 Release of Airborne Radioactive Materials Initial Assessment EP R-3 9 Release of Radioactive Liquids EP R-7 19 Off-Site Transportation Accidents EP EF-1 60 Activation and Operation of the Technical Support Center EP EF-2 44 Activation and Operation of the Operational Support Center EP EF-3 52 Activation and Operation of the Emergency Operations Facility EP EF-4 23 Activation of the Off-Site Emergency Laboratory EP EF-9 13 Backup Emergency Response Facilities EP EF-10 19 Activation and Operation of the Joint Information Center EP EF-11 4 Alternate Emergency Response Facilities / Incident Command Post (ICP)

OM10.ID1 19 Maintaining Emergency Preparedness OM10.DC1 11 Emergency Preparedness Drills and Exercises

Revised Document

Enclosure 7 PG&E Letter DCL-23-128 PG&E Letter DIL-23-010 Summary of the Analysis of changes in EP G-3 Revision 64 Emergency Notification of Off-Site Agencies."

EP G-3 Revision 64 Change Original Content (Rev 63) Revised Content (Rev 64) Description of Change 1 Section 1.1 Section 2.2.1 Changed wording to improve clarity. Added that EP G-3 is also used to transmit PARs This procedure provides instructions for This procedure provides instructions for developed per EP RB-10.

emergency notification of federal, state, and emergency notification of federal, state, and local agencies in the event of an emergency local agencies of emergency declarations per This change does not affect how the EP G-1, "Emergency Classification and current E-Plan meets any planning standard declared per EP G-1, "Emergency Emergency Plan Activation," and of protective functions, elements, or site-specific Classification and Emergency Plan Activation." action recommendations (PARs) per EP RB- commitments. No additional evaluation 10, "Protective Action Recommendations." required.

2 Definition 2.2.9, Rapidly Progressing Severe Definition 2.2.9, Rapidly Progressing Severe Refactored the definition for RPSA to improve Accident Accident usability and incorporate feedback from the ERO.

A Rapidly Progressing Severe Accident is A Rapidly Progressing Severe Accident is occurring if ALL of the following are present: occurring if ALL of the following are present: Added in the lead sentence to establish that RPSA criteria requires all the following

A General Emergency was declared A General Emergency was declared conditions, which was inferred in the existing AND AND content, but not explicitly stated.

Initial PAR Initial PAR AND AND Removed bullets and indented the "ANDs" to

Any containment loss EAL applicable Any EAL Table F-1 Containment Barrier Loss better align with the EAL wallcharts and plant AND AND procedures.

RM-30/31 > 5,000 R/hr OR EAL RG1.1 ANY of the following:

met for any Table R-1 GE value

RM-30/31 > 5000 R/Hr Replaced containment loss EAL with EAL

EAL RG1.1 met for RM-87 > 1.9E-10 Table F-1 Containment Barrier Loss based on amps ERO feedback that the containment loss EAL

EAL RG1.1 met for RM-87 > 3.2E-1 was not as clear as referring to the fission

µCi/cc product barrier matrix table loss criteria.

Refactored the final bulleted item from a compound OR to a multiple ANY to list the Table R-1 values. Substituted the EAL RG1.1 met for any Table R-1 GE value with the actual Table R-1 GE values. This does not change the intent or interpretation of the RPSA criteria but is rather relocating information from Table R-1 in place of a reference to Table R-1.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation Page 1 of 7 Internal

EP G-3 Revision 64 Change Original Content (Rev 63) Revised Content (Rev 64) Description of Change required.

3 Throughout procedure (e.g., step 6.1.3.a) Throughout procedure (e.g., step 6.1.3.a) Added "perform the following" after instances of THEN that did not contain any instruction THEN: THEN perform the following: per AD1.ID1 writing standards.

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 Section 6.3.2 Section 6.3.2 Reworded PAR correction steps to improve clarity. Since the conservativeness of a PAR is For corrections to an incorrect PAR: For corrections to an incorrect PAR: subjective, that wording is removed and is IF the correct PAR is more conservative IF the correct PAR includes more PAZs or replaced with objective descriptions of whether (i.e., includes more PAZs or more more protective actions than the previously the correct PAR is bigger or smaller than the protective actions) than the previously transmitted incorrect PAR (i.e., the correct incorrect PAR.

transmitted incorrect PAR, PAR is bigger),

THEN send an updated initial ENF to THEN send an updated initial ENF to This change does not affect how the correct the issue. correct the issue. current E-Plan meets any planning standard functions, elements, or site-specific IF the correct PAR is less conservative (i.e., IF the correct PAR includes less PAZs or commitments. No additional evaluation includes less PAZs or less protective less protective actions than the previously required.

actions) than the previously transmitted transmitted incorrect PAR (i.e., the correct incorrect PAR, PAR is smaller),

THEN the previously transmitted PAR THEN the previously transmitted PAR should remain on all subsequent ENFs and should remain on all subsequent ENFs and Follow-Up ENFs. Follow-Up ENFs.

5 N/A - added content Section 6.3.3 Added more specific instructions for correcting radiological release status. There is no specific IF the incorrect radiological release status was requirement for how such corrections should chosen on any ENF, be made and this provides clear direction to THEN send an expedited Follow-Up ENF to the user on which form to use. This is the correct the error. desired process based on discussion with the offsite response organizations.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation Page 2 of 7 Internal

EP G-3 Revision 64 Change Original Content (Rev 63) Revised Content (Rev 64) Description of Change required.

6 Section 6.3.4 Section 6.3.4 Changed wording to account for the addition of the radiological release status correction step.

For all corrections other than PAR For all other corrections, send an initial or corrections, send an initial or Follow-Up ENF Follow-Up ENF to correct the issue, based on This change does not affect how the to correct the issue, based on which type of which type of ENF contained the original error. current E-Plan meets any planning standard ENF contained the original error. functions, elements, or site-specific commitments. No additional evaluation required.

7 Attachment 1, Step 1.b Attachment 1, Step 1.b Changed wording to remove superfluous language.

In the event that a General Emergency is If a General Emergency is declared and the declared and the SLO County EOC is not yet SLO County EOC is not yet activated, the This change does not affect how the activated, the USCG will need to be notified by USCG will need to be notified by DCPP of the current E-Plan meets any planning standard DCPP of the emergency classification level emergency classification level and any functions, elements, or site-specific and any applicable PARs. applicable PARs. commitments. No additional evaluation required.

8 Attachment 1, Section 2, block 7, step 4 Attachment 1, Section 2, block 7, step 4 Changed wording to correct grammar.

IF the description is automatically filled in by IF the description is automatically filled in by This change does not affect how the the computer, the computer, current E-Plan meets any planning standard THEN it may be modified to more closely THEN it may be modified to match the actual functions, elements, or site-specific match the actual event. event more closely. commitments. No additional evaluation required.

9 Attachment 1, Section 2, block 9, step 3 Attachment 1, Section 2, block 9, step 3 Changed wording to use parallel construction.

Attachment 2, Section 2, block 9, step 3 Attachment 2, Section 2, block 9, step 3 This change does not affect how the Tertiary Tower 10 meter (if deployed) wind Tertiary Tower 10M (if deployed) wind direction current E-Plan meets any planning standard direction and average wind speed and average wind speed functions, elements, or site-specific commitments. No additional evaluation required.

10 Attachment 1, Section 2, Block 10, step 2.a Attachment 1, Section 2, Block 10, step 2.a Refactored the definition for RPSA to improve usability and incorporate feedback from the

A GENERAL EMERGENCY was declared. A General Emergency was declared ERO. Removed bullets and indented the Page 3 of 7 Internal

EP G-3 Revision 64 Change Original Content (Rev 63) Revised Content (Rev 64) Description of Change AND AND "ANDs" to better align with the EAL wallcharts

Initial PAR Initial PAR and plant procedures.

AND AND

Any containment loss EAL applicable. Any EAL Table F-1 Containment Barrier Loss Replaced containment loss EAL with EAL AND AND Table F-1 Containment Barrier Loss based on

RM 30/31 > 5,000 R/hr ANY of the following: ERO feedback that the containment loss EAL OR

RM-30/31 > 5000 R/hr was not as clear as referring to the fission

EAL RG1.1 met for any Table R-1 GE

EAL RG1.1 met for RM-87 > 1.9E-10 amps product barrier matrix table loss criteria.

value

EAL RG1.1 met for RM-87 > 3.2E-1 µCi/cc Refactored the final bulleted item from a compound OR to a multiple ANY to list the Table R-1 values. Substituted the EAL RG1.1 met for any Table R-1 GE value with the actual Table R-1 GE values. This does not change the intent or interpretation of the RPSA criteria but is rather relocating information from Table R-1 in place of a reference to Table R-1.

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

11 Attachment 1, Section 2, Block 10, step 2.a Attachment 1, Section 2, Block 10, step 2.a Changed description of the evacuation areas table to align with revised table title in EP RB-

Evacuate PAZ 1 and 2.

Evacuate PAZ 1 and 2. 10. Changed wording to simplify directions and

Evacuate all applicable downwind PAZs

Evacuate PAZ(s) 3, 4, 5 per RPSA Wind to align with the updated PAR flow chart in EP (3-5) based on the wind direction table in Direction Table RB-10. Removed specific reference to Attachment 4 of EP RB-10. Attachment 4 as the RPSA Wind Table is generally referenced from the PAR Flowchart

Evacuate the ocean based on the wind

Evacuate ocean to 10 nautical miles. which is provided within the ENF application.

direction table in Attachment 4 of EP RB-10. These changes do not affect how the

Administer KI per the SLO County Plan.

Administer KI per SLO County Plan. current E-Plan meets any planning standard

All other PAZ(s) Monitor and Prepare.

All other PAZs Monitor and Prepare. functions, elements, or site-specific commitments. No additional evaluation required.

Changed the ocean areas evacuation from being based on wind direction to 10 nautical miles for all RPSAs.

Page 4 of 7 Internal

EP G-3 Revision 64 Change Original Content (Rev 63) Revised Content (Rev 64) Description of Change Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-17 for evaluation of the change to the RPSA Ocean PAR strategy.

12 Attachment 1, Section 2, Block 10, step 2.b Attachment 1, Section 2, Block 10, step 2.b Changed General Emergency to not be in caps case to improve readability.

IF a CONTROLLED RELEASE is in progress, IF a CONTROLLED RELEASE is in progress, AND AND ALL of the following conditions exist: Editorial changes to comply with AD1.ID1 ALL of the following conditions exist: writing standards. Changed wording to simplify

A General Emergency was declared directions and to align with the updated PAR

A GENERAL EMERGENCY was declared

Expected release duration LESS THAN flow chart.

Expected release duration LESS THAN 60 minutes 60 minutes This change does not affect how the current E-Plan meets any planning standard THEN recommend ALL of the following THEN recommend ALL of the following functions, elements, or site-specific protective actions: protective actions: commitments. No additional evaluation

Shelter PAZ 1 and 2.

Shelter PAZ 1 and 2. required.

Evacuate ocean to 5 NM.

Evacuate ocean to 5 nautical miles.

Administer KI per the SLO County Plan.

Administer KI per SLO County Plan.

All other PAZ(s) Monitor and Prepare.

All other PAZs Monitor and Prepare.

13 Attachment 1, Section 2, Block 10, step 2.c Attachment 1, Section 2, Block 10, step 2.c Changed General Emergency to not be in caps case to improve readability.

IF a GENERAL EMERGENCY has been IF a General Emergency has been declared, declared, which is NOT either of the following: which is NOT either of the following: Editorial changes to comply with AD1.ID1

RAPIDLY PROGRESSING SEVERE

RAPIDLY PROGRESSING SEVERE writing standards. Changed wording to simplify ACCIDENT ACCIDENT directions and to align with the updated PAR OR OR flow chart.

CONTROLLED RELEASE (expected

CONTROLLED RELEASE (expected release duration LESS THAN 60 minutes) release duration LESS THAN 60 minutes) This change does not affect how the current E-Plan meets any planning standard THEN recommend ALL of the following THEN recommend ALL of the following functions, elements, or site-specific protective actions: protective actions: commitments. No additional evaluation

Evacuate PAZ 1 and 2.

Evacuate PAZs 1 and 2. required.

Evacuate ocean to 5 NM.

Evacuate ocean to 5 nautical miles.

Administer KI per the SLO County Plan.

Administer KI per SLO County Plan.

All other PAZ(s) Monitor and Prepare.

All other PAZs Monitor and Prepare.

14 Attachment 1, Section 2, Block 10, step 3.a Attachment 1, Section 2, Block 10, step 3.a Changed wording to simplify directions and to align with the updated PAR flow chart. The use Page 5 of 7 Internal

EP G-3 Revision 64 Change Original Content (Rev 63) Revised Content (Rev 64) Description of Change IF at any time, the projected offsite dose in IF at any time the projected offsite dose in any of "OR" between substeps is optional and does ANY PAZ not currently recommended for PAZ not currently recommended for evacuation not improve readability in this case. Editorial evacuation exceeds either: exceeds ANY of the following PAGs: changes to comply with AD1.ID1 writing

1000 mrem TEDE

1000 mrem TEDE standards.

OR

5000 mrem Thyroid CDE

5000 mrem Thyroid CDE These changes do not affect how the THEN recommend ALL of the following current E-Plan meets any planning standard THEN recommend ALL of the following protective actions: functions, elements, or site-specific protective actions:

Evacuate applicable PAZs not already commitments. No additional evaluation

Evacuate all affected PAZs. designated for evacuation. required.

Administer KI per the SLO County Plan.

Administer KI per SLO County Plan.

15 Attachment 1, Section 2, Block 10, step 3.b Attachment 1, Section 2, Block 10, step 3.b Changed wording to simplify directions and to align with the updated PAR flow chart. The use IF at any time, the projected offsite dose over IF at any time the projected offsite dose over of "OR" between substeps is optional and does the ocean beyond 5 miles exceeds either the ocean beyond 5 miles exceeds ANY of the not improve readability in this case. Editorial

1000 mrem TEDE following PAGs: changes to comply with AD1.ID1 writing OR

1000 mrem TEDE standards.

5000 mrem Thyroid CDE

5000 mrem Thyroid CDE These changes do not affect how the THEN recommend ALL of the following THEN recommend ALL of the following current E-Plan meets any planning standard protective actions: protective actions: functions, elements, or site-specific

Evacuate the ocean to 10 NM.

Evacuate ocean to 10 nautical miles. commitments. No additional evaluation

Administer KI per the SLO County Plan.

Administer KI per SLO County Plan. required.

16 Attachment 1, Section 2, Block 10, step 4 Attachment 1, Section 2, Block 10, step 4 Changed wording to comply with AD1.ID1 writing standards.

IF the SM/SEC/ED declares a PAR for an area IF the SM/SEC/ED declares a PAR for an area beyond the EPZ boundary, beyond the EPZ boundary, Removed "22.5 degree" as all wind rose THEN: THEN perform the following: sectors used in the emergency response

a. Obtain the affected 22.5 degree wind facilities and data systems are 22.5 degrees.

a. Obtain the affected wind rose rose sector(s) and adjacent sectors sector(s) and adjacent sectors from from the SM/SEC/ED. This change does not affect how the Page 6 of 7 Internal

EP G-3 Revision 64 Change Original Content (Rev 63) Revised Content (Rev 64) Description of Change

b. Obtain distance from SM/SEC/ED for the SM/SEC/ED. current E-Plan meets any planning standard which the PAR needs to be made. b. Obtain distance from SM/SEC/ED for functions, elements, or site-specific

c. Select "Other" which the PAR needs to be made. commitments. No additional evaluation

d. Recommend ALL of the following c. Select "Other" required.

protective actions: d. Recommend ALL of the following

Write in the available text field something protective actions:

similar to:

Write in the available text field a statement to the effect of:

"Evacuate sectors [sectors obtained from SM/SEC/ED] out to [distance obtained from "Evacuate sectors [sectors obtained from SM/SEC/ED] miles [nautical miles if area is SM/SEC/ED] out to [distance obtained from over ocean]." SM/SEC/ED] miles [nautical miles if area is over ocean]."

Administer KI per the SLO County Plan.

Administer KI per SLO County Plan.

17 Attachment 2, Section 2, Block 14, step 3 Attachment 2, Section 2, Block 14, step 3 Minor wording change to improve clarity.

Attachment 2 is instructions for follow-up The "Date" and "Time" is when the Emergency The "Date" and "Time" is when the Follow-Up ENFs.

Notification Form is approved by the SM, SEC, ENF is approved by the SM, SEC, or ED.

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

Page 7 of 7 Internal

Enclosure 8 PG&E Letter DCL-23-128 PG&E Letter DIL-23-010 Summary of the Analysis of changes in EP RB-10 Revision 22 Protective Action Recommendations.

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change 1 Section 2.4.2 Section 2.4.2 Changed wording from "field measurements" to "field survey results". Field survey is the Dose assessment or field measurements Dose Assessment or field survey results common terminology used at DCPP for exceed PAG criteria. exceed PAG criteria. sampling activities performed by the field monitoring teams. Field survey results is also the terminology used in the DCPP EAL scheme.

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

2 Definition 2.9.12, Rapidly Progressing Severe Definition 2.9.12, Rapidly Progressing Severe Refactored the definition for RPSA to improve Accident (RPSA) Accident (RPSA) usability and incorporate feedback from the ERO. Removed bullets and indented the A Rapidly Progressing Severe Accident is A Rapidly Progressing Severe Accident is "ANDs" to better align with the EAL wallcharts occurring if ALL of the following are present: occurring if ALL of the following are present: and plant procedures.

A General Emergency was declared A General Emergency was declared Replaced containment loss EAL with EAL AND AND Table F-1 Containment Barrier Loss based on

Initial PAR Initial PAR ERO feedback that the containment loss EAL AND AND was not as clear as referring to the fission

Any containment loss EAL applicable Any EAL Table F-1 Containment Barrier Loss product barrier matrix table loss criteria.

AND AND

RM-30/31 > 5,000 R/hr OR EAL RG1.1 ANY of the following: Refactored the final bulleted item from a met for any Table R-1 GE value

RM-30/31 > 5000 R/hr compound OR to a multiple ANY to list the

EAL RG1.1 met for RM-87 > 1.9E-10 Table R-1 values. Substituted the EAL RG1.1 amps met for any Table R-1 GE value with the actual

EAL RG1.1 met for RM-87 > 3.2E-1 Table R-1 GE values. This does not change

µCi/cc the intent or interpretation of the RPSA criteria but is rather relocating information from Table R-1 in place of a reference to Table R-1.

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 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change 3 Section 3.5 Section 3.5 Changed Communicator #1 to Control Room Operators to align with the Emergency Plan.

Communicator #1 in the Control Room is The Control Room operators are responsible Preparation and communication of emergency responsible for supporting the SM with the for supporting the SM with the PAR approval notifications may be performed by any PAR approval process by: process by: available operator with the appropriate qualifications.

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 Note 1 preceding Section 6.1 Note 1 preceding Section 6.1 Editorial change to the note to remove the unnecessary word "initial" since the Initial PARs are expected to be issued within PARs are expected to be issued within 15 requirement is to declare and communicate 15 minutes of declaration of a GENERAL minutes of declaration of a General PARs within 15 minutes of a GE declaration.

EMERGENCY. Emergency Within the context of the note, the word "initial" is extraneous. Changed General Emergency to not be in caps case to improve readability.

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

5 Notes 2 and 3 preceding Step 6.1.1 Notes 2 and 3 preceding Step 6.1.1 Changed wording of Note 2 to align with revised wording in the RPSA criteria in Step NOTE 2: Any containment loss EAL applicable NOTE 2: Any EAL Table F-1 Containment 6.1.1. Changed wording in Note 3 for clarity.

means there is an actual loss of the Barrier Loss means there is an actual loss of containment barrier. the containment barrier. This change does not affect how the current E-Plan meets any planning NOTE 3: An RPSA results in an actual loss of NOTE 3: An RPSA is an actual loss of all 3 standard functions, elements, or site-all 3 fission product barriers, which means fission product barriers, which means there is specific commitments. No additional there is a significant ongoing release of a significant ongoing release of airborne evaluation required.

airborne radioactivity to the environment. radioactivity to the environment.

6 Step 6.1.1 Step 6.1.1 Removed superfluous wording "to ensure".

Per AD1.ID1, the ensure action verb should Page 2 of 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change Check to ensure ALL of the following Check if ALL the following conditions are only be used when the procedure user is to conditions present: present: "make it so, if not so" which is not applicable in this case as the user would not intentionally

A General Emergency was declared. A General Emergency was declared make the conditions true.

AND AND

Initial PAR Initial PAR Refactored the definition for RPSA to improve AND AND usability and incorporate feedback from the

Any containment loss EAL applicable. Any EAL Table F-1 Containment Barrier Loss ERO.

AND AND

RM 30/31 > 5,000 R/hr OR EAL RG1.1 ANY of the following: Added in the lead sentence to establish that met for any Table R-1 GE value.

RM-30/31 > 5000 R/hr RPSA criteria requires all the following

EAL RG1.1 met for RM-87 > 1.9E-10 conditions, which was inferred in the existing amps content, but not explicitly stated.

EAL RG1.1 met for RM-87 > 3.2E-1 µCi/cc Removed bullets and indented the "ANDs" to better align with the EAL wallcharts and plant procedures.

Replaced containment loss EAL with EAL Table F-1 Containment Barrier Loss based on ERO feedback that the containment loss EAL was not as clear as referring to the fission product barrier matrix table loss criteria.

Refactored the final bulleted item from a compound OR to a multiple ANY to list the Table R-1 values. Substituted the EAL RG1.1 met for any Table R-1 GE value with the actual Table R-1 GE values. This does not change the intent or interpretation of the RPSA criteria but is rather relocating information from Table R-1 in place of a reference to Table R-1.

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

7 Step 6.2.1 Step 6.2.1 Changed General Emergency to not be in caps case to improve readability.

Check ALL of the following conditions present:

Page 3 of 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change

A GENERAL EMERGENCY is declared. Check if ALL of the following conditions are Reformatted step to comply with AD1.ID1 AND present: writing standards. The use of AND between

A controlled radiological release with an

A General Emergency was declared. substeps is optional and does not improve expected duration of LESS THAN

A controlled radiological release with an readability in this case.

60 minutes is in progress. expected duration of LESS THAN 60 minutes is in progress. Replaced "is" with "was" for consistency throughout the procedure.

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 Step 6.3 Step 6.3 Changed General Emergency to not be in caps case to improve readability.

For any GENERAL EMERGENCY other than For any General Emergency other than a a RAPIDLY PROGRESSING SEVERE RAPIDLY PROGRESSING SEVERE Added "ALL of" to the step to clarify that all ACCIDENT OR CONTROLLED RELEASE ACCIDENT or CONTROLLED RELEASE listed protective actions should be perform the following: perform the following: recommended.

6.3.1 Recommend the following protective 6.3.1 Recommend ALL of the following Reformatted step to comply with AD1.ID1 actions: protective actions: writing standards. With lists of steps where all

Evacuate PAZs 1 and 2. a. Evacuate PAZ 1 and 2. actions are to be performed, number/lettered AND steps should be used rather than bullets. The

Evacuate the ocean to 5 NM. b. Evacuate ocean to 5 nautical miles. use of "AND" between substeps is optional AND and does not improve readability in this case.

Administer KI per the SLO County Plan. c. Administer KI per SLO County Plan.

AND Spelled out "NM" acronym for consistency

All other PAZ(s) monitor and prepare for d. All other PAZs Monitor and Prepare. throughout procedure and flowchart.

possible protective actions. Removed extraneous "the" usage and "for possible protective actions" to align EP RB-10 language for monitor and prepare PAR with language on the Emergency Notification Form (ENF) in EP G-3.

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 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change 9 Step 6.4.1 Step 6.4.1 Added "ALL of" to the step to clarify that all listed protective actions should be Recommend the following protective actions: Recommend ALL of the following protective recommended.

actions:

Reformatted step to comply with AD1.ID1

Evacuate PAZs 1 and 2. a. Evacuate PAZ 1 and 2. writing standards. With lists of steps where all AND actions are to be performed, number/lettered

Evacuate all applicable downwind PAZs b. Evacuate PAZ(s) 3, 4, 5 per Attachment 3, steps should be used rather than bullets. The (3-5) per Attachment 4, Form 69-21870, Form 69-21870, "RPSA Evacuation Areas use of "AND" between substeps is optional "EVACUATION AREAS BASED ON WIND based on Wind Direction." and does not improve readability in this case.

DIRECTION."

AND Changed title of the evacuation areas table

Evacuate the ocean per Attachment 4, c. Evacuate ocean to 10 nautical miles. attachment to align with revised table title.

Form 69-21870, "EVACUATION AREAS Attachment number for this table changed BASED ON WIND DIRECTION." from 4 to 3 based on removing the old AND attachment 2. Attachment 2 was old ETE

Administer KI per the SLO County Plan. d. Administer KI per SLO County Plan. information that was not applicable to the PAR AND determination process at DCPP. Refer to

All other PAZ(s) monitor and prepare for e. All other PAZs Monitor and Prepare. change 19.

possible protective actions.

Spelled out "NM" acronym for consistency throughout procedure and flowchart.

Removed extraneous "the" usage and "for possible protective actions" to align EP RB-10 language for monitor and prepare PAR with language on the Emergency Notification Form (ENF) in EP G-3.

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

Changed the ocean areas evacuation from being based on wind direction to be out to 10 nautical miles for all RPSAs.

Page 5 of 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-17 for evaluation of the change to the RPSA Ocean PAR strategy.

10 Step 6.5.1 Step 6.5.1 Added "ALL of" to the step to clarify that all listed protective actions should be Recommend the following protective actions: Recommend ALL of the following protective recommended.

actions:

Shelter PAZs 1 & 2 Reformatted step to comply with AD1.ID1 AND a. Shelter PAZ 1 and 2. writing standards. With lists of steps where all

Evacuate the ocean to 5 NM actions are to be performed, number/lettered AND b. Evacuate ocean to 5 nautical miles. steps should be used rather than bullets. The

Administer KI per the SLO County Plan use of "AND" between substeps is optional AND c. Administer KI per SLO County Plan. and does not improve readability in this case.

All other PAZ(s) monitor and prepare for possible protective actions d. All other PAZs Monitor and Prepare. Spelled out "NM" acronym for consistency throughout procedure and flowchart.

Removed extraneous "the" usage and "for possible protective actions" to align EP RB-10 language for monitor and prepare PAR with language on the Emergency Notification Form (ENF) in EP G-3.

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

11 Notes preceding Step 6.6 Notes preceding Step 6.6 Changed wording from "issued" to "declared" and removed "issuance of" to improve clarity NOTE 1: PARs are expected to be issued NOTE 1: PARs are expected to be declared regarding the 15-minute expectation regarding within 15 minutes of receiving dose within 15 minutes of receiving dose PAR development and declaration upon dose assessment information that identifies the assessment information that identifies the assessment results becoming available need for issuance of a new PAR. need for a new PAR. indicating the need for a new PAR.

NOTE 2: Dose assessment or field team NOTE 2: Dose assessment or field survey Changed wording from "field team results" to results should be used to identify any areas results should be used to identify any areas "field survey results". Field survey is the where protective action guides (PAGs) may be where protective action guides (PAGs) may be common terminology used at DCPP for exceeded. exceeded. sampling activities performed by the field monitoring teams. Field survey results is also Page 6 of 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change the terminology used in the DCPP EAL scheme.

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

12 Step 6.6 Step 6.6 Changed wording from "field survey information" to "field survey results". Field Check dose assessment or field survey Check dose assessment or field survey results survey is the common terminology used at information available: available: DCPP for sampling activities performed by the field monitoring teams. Field survey results is 6.6.1 IF dose assessment or field survey 6.6.1 IF dose assessment or field survey also the terminology used in the DCPP EAL information is available results are available, scheme.

THEN go to step 6.7. THEN GO TO step 6.7 Changed "WHEN" to "IF at any time" which is 6.6.2 IF dose assessment or field survey is 6.6.2 IF dose assessment or field survey the more applicable conditional statement per NOT available, results are NOT available, AD1.ID1.

THEN continue to assess plant conditions. THEN continue to assess plant conditions.

Moved step 6.6.2.a up to 6.6.3 as it is not

a. WHEN dose assessment or field survey 6.6.3 IF at any time dose assessment or field necessarily a substep of 6.6.2 and steps information becomes available, survey results become available, should not have single substeps per AD1.ID1.

THEN continue with step 6.7. THEN continue with step 6.7.

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 Steps 6.7.1 and 6.7.2 Step 6.7.1 and 6.7.2 Reworded step to clarify that dose-based protective action recommendations are only Check if projected offsite dose in ANY PAZ not Check if projected offsite dose in any PAZ not made for PAZs which have not previously had previously evacuated exceeds either: previously recommended to evacuate exceeds an evacuation PAR.

1000 mrem TEDE ANY of the following PAGs:

OR

1000 mrem TEDE Reformatted step to comply with AD1.ID1

5000 mrem Thyroid CDE

5000 mrem Thyroid CDE writing standards. With lists of steps where all actions are to be performed, number/lettered IF PAGs exceeded, IF PAGs exceeded, steps should be used rather than bullets. The THEN recommend ALL of the following THEN recommend ALL of the following use of "AND" and "OR" between substeps is expanded protective actions: expanded protective actions:

Page 7 of 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change

Evacuate the affected PAZ(s). a. Evacuate applicable PAZ(s) not already optional and does not improve readability in AND designated for evacuation. this case.

Administer KI per the SLO County Plan.

b. Administer KI per SLO County Plan. Updated wording to keep the body of the procedure aligned with the PAR flowchart 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.

14 Steps 6.8.1 and 6.8.2 Steps 6.8.1 and 6.8.2 Reworded step to clarify that the evaluation is based on exceeding any of the listed PAGs.

Check if projected offsite dose over the ocean Check if projected offsite dose over the ocean beyond 5 miles exceeds either: beyond 5 miles exceeds ANY of the following Reformatted step to comply with AD1.ID1

1000 mrem TEDE PAGs: writing standards. With lists of steps where all OR

1000 mrem TEDE actions are to be performed, number/lettered

5000 mrem Thyroid CDE

5000 mrem Thyroid CDE steps should be used rather than bullets. The use of "AND" and "OR" between substeps is IF PAGs exceeded, IF PAGs exceeded, optional and does not improve readability in THEN recommend ALL of the following THEN recommend ALL of the following this case.

expanded protective actions: expanded protective actions:

Evacuate the ocean to 10 NM. a. Evacuate Ocean to 10 nautical miles. Spelled out "NM" acronym for consistency AND throughout procedure and flowchart.

Administer KI per the SLO County Plan. b. Administer KI per SLO County Plan.

Updated wording to keep the body of the procedure aligned with the PAR flowchart 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.

15 Steps 6.9.1 and 6.9.2 Steps 6.9.1 and 6.9.2 Reworded step to clarify that the evaluation is based on exceeding any of the listed PAGs.

Check if the projected offsite dose in ANY area Check if the projected offsite dose in any area beyond the EPZ exceeds either: beyond the EPZ exceeds ANY of the following Reformatted step to comply with AD1.ID1

1000 mrem TEDE PAGs: writing standards. With lists of steps where all Page 8 of 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change OR

1000 mrem TEDE actions are to be performed, number/lettered

5000 mrem Thyroid CDE

5000 mrem Thyroid CDE steps should be used rather than bullets. The use of "AND" and "OR" between substeps is IF PAGs exceeded, IF PAGs exceeded, optional and does not improve readability in THEN recommend ALL of the following THEN recommend ALL of the following this case.

expanded protective actions: expanded protective actions:

Evacuate the affected sector and adjacent a. Evacuate the affected sector AND adjacent Reworded step to align with the revised PAR sectors in two mile increments, out to a sectors in 2-mile increments, out to the flowchart. The immediately prior step directs distance where the projected offsite dose distance at which evacuation threshold is no the evaluation of the protective action is LESS THAN 1000 mrem TEDE AND longer exceeded. guidelines (PAGs) so the restating the PAG 5000 mrem Thyroid CDE. values is unnecessary.

Administer KI per the SLO County Plan. b. Administer KI per SLO County 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.

16 Step 6.10.1 Step 6.10.1 Reformatted step to conditional statement consistent with other steps in the procedure.

IF new PAR NOT required, go to step 6.11. IF new PAR is NOT required, No change in action, which is going to step THEN GO TO step 6.11. 6.11 if a new PAR is not required.

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

17 Step 6.11.1 Step 6.11.1 Changed "at least one" to "any" to comply with AD1.ID1 writing standards for conditional IF at any time AT LEAST ONE of the following IF at any time ANY of the following occurs, statements.

occur, THEN GO TO step 6.6 to reassess PARs:

THEN go to step 6.6: Added "reassess PARs" to provide context to

A change to radiological conditions.

Radiological conditions change. why step 6.6 should be returned to.

OR

A wind direction change affecting a new

Wind direction changes such that another Reworded conditions to improve clarity.

PAZ(s). PAZ may be affected. Described the controlled release scenario OR instead of just providing the term to help drive consistent action without having to refer to the Page 9 of 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change

A controlled release continuing for

After 60 minutes when a sheltering PAR definitions section for controlled release.

GREATER THAN 60 minutes. has been made to check if the radiological Reworded step for controlled releases to OR release has stopped. reference sheltering PARs and to align with

New dose assessment information the updated PAR flowchart.

becoming available.

Dose assessment or field survey results become available. Added "field survey results" as a condition for reevaluating PARs consistent with other sections of the procedure. Removed "new" as PARs should be reassessed anytime dose assessment or field survey results become available to the decision maker.

The use of "OR" between substeps is optional and does not improve readability in this case.

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 Section 7 Records Section 7 Records Added records requirements consistent with other EPIPs.

None 7.1 Documents generated by this procedure during drills are considered non-quality good This change does not affect how the business records and are maintained per current E-Plan meets any planning OM10.ID1, "Maintaining Emergency standard functions, elements, or site-Preparedness." specific commitments. No additional evaluation required.

7.2 Documents generated by this procedure during actual events are quality records and shall be maintained per AD10.ID1, "Storage and Control of Quality Assurance Records."

19 Attachment 2, Evacuation Time Estimates N/A - removed attachment Removed Attachment 2, Evacuation Time (ETE) Estimates (ETE).

Various ETE tables copied from Emergency This attachment included PAZ populations and Plan Appendix E. various ETE results tables. E-Plan Appendix E is available in all ERO facilities and is included as a reference in EP RB-10. E-Plan Appendix G, Protective Action Recommendation (PAR)

Page 10 of 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change Strategy Basis, provides the plant specific analysis performed to determine the PAR strategy implemented in EP RB-10 and is also available in the ERO facilities and referenced in EP RB-10.

As agreed upon between DCPP and SLO County, DCPP does not consider populations or conditions when providing protective action recommendations. That information is considered by SLO County during the protective action decision process. The information provided in Attachment 2 is not used in any part of the protective action recommendation process and was included in EP RB-10 as information only. The PARs outlined in EP RB-10 are informed by the results of the ETE analysis, however, the ETE results themselves are not used by the ERO when determining PARs.

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 Attachment 3, PAR Flowchart Attachment 2, PAR Flowchart Changed formatting, punctuation, and capitalization throughout to improve readability Refer to Addendum C for full chart Refer to Addendum C for full chart based on user feedback.

EVACU TF PAI 1 AIJ '1 Recommen d ALL of t he fo ll ow ing PARs : Changed PAR boxes to include a statement to

EVACU TE PAZ s) 3, 4, 5 PER DTABLE Evacua t e PAZ 1 and 2 "Recommend ALL of the following PARs:".

EVA U It 0CE so 10 P RWl OIA Evacua t e PAZ(s ) 3, 4, 5 per RPSA W ind Dir ecti on Table

ADMINISTER Kl PERSLO COO TY P1.A Evacua t e Ocean t o 10 nau tica l miles Changed the bulleted items to arrows as

ALL OTHER PAZs - M PROTECTIVE ACTIONS ITORANDPR ARE FOR POSSIBLE Ad m inister Kl per SLO Coun ty Plan bullets are primarily used in other plant All oth er PAZs M onit or and Prepa re procedures to indicate a choice rather than a

co UE ASSES ENT requirement to perform all.

THEN GO TO BLOCK A t o continue ass essm ent Spelled out nautical miles to replace the NM acronym throughout.

Page 11 of 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change

Recomm end Al l oft he fo llowin g PARs:

Reworded "ALL OTHER PAZs - MONITOR

She lt er PAZ 1 and 2 AND PREPARE FOR POSSIBLE Evacuate Ocea n t o 5 nautica l m iles Adm i nist er KIi pe r SlO Co unty Plan PROTECTIVE ACTIONS" to "All other PAZs Monitor and Prepare". This is consistent with

p NO Al l ot her PAZs Monit o r and Prepa re the language used in the body of Appendix G and on the Emergency Notification Form used p

to transmit the PAR.

THE N GO TO BLOCK A t o co ntinu e assess m elilt Moved the "continue assessment" step out of the list since it is not a PAR itself. Reworded

Recommend ALL of the following PARs:

"continue assessment" to "THEN GO TO

Evacuate PAZ 1 and 2 BLOCK A to continue assessment" or "THEN

ALL D PRE AR f-OR Evacuate Ocean to 5 nautica l miles continue assessment below", as applicable, to TI Administer Kl per SLO County Plan clarify how the user should continue the PAR

co assessment.

All other PAZs Monitor and Prepare Changed the format of BLOCK A to be THEN continue assessment below consistent in all locations.

Changed the statement "WHEN DOSE IBLOCKA BLOQ( ,A ASSESSMENT OR FIELD RESULTS AVAILABLE RETURN / GO TO" to "WHEN Dose Assessment or Field Survey results are W HIEN Dose Asse.ssment o r Field Survey IELDRESllL available, THEN GO TO". Adding the word res ults a re available, Survey is consistent with all other instances in TH IE N GO TO DILOOK A Appendix G. "Return" is not commonly used in DCPP procedures. "GO TO" is the common wording to direct the user to BLOCK A regardless of if they have been there in the

Reco mm end ALL of the following PARs:

process previously or not.

Evacuate app licable PAZ(s) not already des ignated fo r evacuaUon Ad minist er Kl per SLO Coun ty Plan Reworded "EVACUATE APPLICABLE PAZ(s)

NOT ALREADY EVACUATED" to "Evacuate applicable PAZ(s) not already designated for evacuation" to align the PAR wording with the Reco mm end ALL ofth e fo llow ing PAIRs:

decision making wording.

Evacuate th e Ocean t o 10 naut ica l miles Reworded "ADMINISTER KI PER SLO Administ er Kl per SLO County Plan COUNTY PLAN IN APPLICABLE PAZ(s)" to "Administer KI per SLO County Plan." This is consistent with the body of Appendix G and Page 12 of 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change the Emergency Notification Form. There is no

SECTOR~ D 2 MI Recommend ALL of t he fo ll ow *ng PARs:

Evarna te affected sector A D adj acent method on the form to differentiate where the Administer KI PAR is made, and the box

!STA secto rs in 2 m ile increm ents to t he remains checked as long as any PAR has HRE IS di stance at w hcch eva cuation t hreshold is been made.

no longe r exceeded

Adm inister Kl per SLO Gou nt y Plan Removed the BLOCK B header from the last block in the flowchart. Block B is not referenced in any other part of the chart nor THEN GO TO BlOCK A to contin ue assessm ent anywhere in Appendix G or EP RB-10.

llJ&..i

!EJ'NV OF TH E FO LLO R Added the availability of Field Survey results I!illLGO O.WJ2mA ~p as a trigger for when PARs should be

.IE ANY of the following occurs,

RADIOLOGICAL CH TH EN GO TO BLOCK A to reassess PARs: reassessed.

Radiological conditions change.

Wind direct ion changes such that another PAZ may be affected. Changed the combination of PAZs for a given

After 60 minutes when a sheltering PAR has been made to check wind direction and changed the Evacuate if the radiolog ical release has stopped. Ocean PAR for the RPSA scenario to 10

Dose Assessment or Field Survey results beco me available. nautical miles for all wind directions to implement changes that were made in rev 5.00 of Appendix G.

RPSA Wind Direction Table Wi nd Di rect ion Evacuat e Evacuate (from) PAZ Ocea n Refer to 10 CFR 50.54(q) effectiveness o* t o< 124* 1, 2 10 naut ica l mil es evaluation 2023-14 for evaluation of the 2022 ETE report. Refer to 10 CFR 50.54(q) 124° t o< 192 " 1, 2, 5 10 naut ica l mil es effectiveness evaluation 2023-17 for 192" t o < 214" 1, 2,4,5 10 naut ica l mil es evaluation of the change to the RPSA Ocean PAR strategy.

214° t o < 259" 1, 2, 3, 4, 5 10 naut ica l mil es 259° t o < 304" 1, 2, 3,4 10 naut ica l mil es Removed Wind Sector column as that information is not useful to the decision maker 304° t o< 349" 1, 2,3 10 naut ica l mil es based on the DCPP site-specific PAR 349° t o 360" 1, 2 10 naut ica l mil es strategy. Since the PAZs have been preassigned for each range of wind directions, providing the "from" sector will not aid the decision maker in determining the correct PAR. The wind direction provided by the ERO Meteorologist, plant data computers, and electronic notification form is provided in degrees from, rather than wind sector.

Page 13 of 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change

2. A R pldly Progr sslng S 1Jcr Accldc 1: is 2. A Rapidly Progressing Severe Accident is Table title change to clarify that the table is occurring f /i_ or t; f ollowlng are prcs.en t: occurring if ALL of the fo llowing are present : only used for rapidly progressing severe

A G n r al Em gencv was declared A General Emergency was declared accidents. Spelled out "nautical miles" and AND AND "evacuate" to improve the readability of the

lni ial PAR Initial PAR chart.

Mm AND Any EAL Table F-1 Containment Barrier Loss Reformatted Note 2 by removing bullets and

Any Containment loss EAL applic.abl@ indenting the "ANDs" to better align with the AND ANY of t he fol lowing : EAL wallcharts and plant procedures.

RM 30/3 > 5000 R/h r OR - AL RG 1.1 met

RM-30/31 > 5000 R/hr for ny ble R-1 GE valu .

EA L RGl .1 met for RM -87 > 1.9E-10 amps Refactored the final bulleted item from a

3. EVACUATION th resholds are based on dose

EA L RGl .1 met for RM-87 > 3.2E-1 µCi/cc compound OR to a multiple ANY to list the assessment .aB fie ld team resu lts that are Table R-1 values to better align with the EAL e ithe r: 3. Evacuation thresho lds are based on dose wallcharts and plant procedures.

GR EATER THAN 1000 mrem TEDE assessment O R field su rvey resu lts that are

.aB Substituted the EAL RG1.1 met for any Table either : R-1 GE value with the actual Table R-1 GE

GR EATER THAN 5000 mrem Thyro id COE

GREATER THAN 1000 mrem TED E values. This does not change the intent or OR interpretation of the RPSA criteria but is rather

GREATER THAN 5000 mrem Thyro id COE relocating information from Table R-1 in place of a reference to Table R-1.

Changed "field team results" to "field survey results" to be consistent with other references to field surveys on the wall chart.

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

21 Attachment 4, Evacuation Areas Based on Attachment 3, RPSA Evacuation Areas Based Changed the combination of PAZs for a given Wind Direction on Wind Direction wind direction and changed the Evacuate Ocean PAR for the RPSA scenario to 10 NOTE: This table is only used for determining nautical miles for all wind directions to applicable areas requiring evacuation during a implement changes that were made in rev Rapidly Progressing Severe Accident (RPSA). 5.00 of Appendix G.

Refer to 10 CFR 50.54(q) effectiveness evaluation 2023-14 for evaluation of the Page 14 of 17 Internal

EP RB-10 Revision 22 Change Original Content (Rev 21) Revised Content (Rev 22) Description of Change Evacuation Areas Based on Wind Direction RPSA Evacuation Areas Based on Wind Direction 2022 ETE report. Refer to 10 CFR 50.54(q)

Ocean Wind Direction (From) Evacuate PAZs Evacuate Ocean effectiveness evaluation 2023-17 for evaluation of the change to the RPSA PAZS to be Area to be Wind Direction Evacuated Evacuated 349° to < 12° 1, 2 5NM, 10NM 349° to 360° N, NNE, NE, 1 and 2 10 NM 12° to< 34° 1, 2 5 NM, 10 NM Ocean PAR strategy.

&0" to< 146' ENE, E, ESE and SE 34° to< 57° 1, 2 5NM, 10NM 146' to < 191 ° SSE, S 1, 2, and 5 10 NM 57° to< 79° 1, 2 5NM, 10NM Added a note and changed the title of the table 191 ' to< 214° SSW 1, 2, 4, and 5 10 NM 79° to< 102° 1, 2 5 NM, 10 NM and attachment to clarify that the table is only 214' to< 236° SW 1, 2, 4, and 5 5NM 102° to< 124° 1, 2 5NM, 10NM used for rapidly progressing severe accidents.

236' to < 259° WSW 1 thru 5 5NM 124° to< 147° 1, 2, 5 5NM, 10NM 259' to< 281 ° w 1 thru 4 5NM 147° to < 169° 1, 2, 5 5NM, 10NM Removed Wind Sector column as that 281 ' to< 304° WNW 1 thru 4 10 NM 169° to< 192° 1, 2, 5 5NM, 10NM information is not useful to the decision maker 304

to < 349° NW and NNW 1 thru 3 10 NM 192° to < 214° 1, 2, 4, 5 5NM, 10NM based on the DCPP site-specific PAR 214° to< 237° 1, 2, 3, 4, 5 5NM, 10NM strategy. Since the PAZs have been 237° to < 259° 1, 2, 3, 4, 5 5NM, 10NM preassigned for each range of wind directions, 259° to < 282° 1, 2, 3, 4 5NM, 10NM providing the "from" sector will not aid the 282° to < 304° 1, 2, 3, 4 5NM, 10NM decision maker in determining the correct 304° to < 327° 1, 2, 3 5NM, 10NM PAR. The wind direction provided in all cases 327° to < 349° 1, 2, 3 5NM, 10NM in degrees from, rather than wind sector.

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 15 of 17 Internal

EP RB-10 Revision 22 Addendum C Change 20 - Original Content (Rev 21) - DCPP Site Specific PAR Flowchart TIP,Al 1.uJII}

B/ACIIA Tl. PAZ !, 4. 5 ll[R

, l Mlo<<AII ~ Oti; lONM V,, 1 0 IMIU.

.ACl>I lilil\ I P~R U QXJNiY PIJll

Al, gfii(i P

M ffQIUIIIID Pft A FOIi ~Sll!L TKllY E AtTlDNS

., co lJ[ lt.Mfiv.ifi{f S&IELTIR PAZ l MIil 2 A Tloa:AN5 M A.OM ISllR I P SLO COUN PI.M

AU<JmE! P.Ali - ~ Ofl !WCI

, _Plllll I 0~ POS,!IIIL PRIOT£Ul\4E itCTlOl'IS

00N Uf AW.S:SMUIT NI BL.00:A i.

i

1. Jf flowchart d~I ~on block condi s r~

11mkn.0W1r1.Il::i.Ef:ji aruwtt * <Y'.

, W.CU~Ti A~SU: PAZlbl Ol A Rapidly Pro !l-ssl ng, Scv@FI! Acclden Is.

Al.HAD\' t\lA.CUA111'D o<<urrl"f!l if !?i!!, o t lolkiw ng U! F)fl!SMt:

A G1me,al Emet;lll!llcy was. dl!!dared ANO

ll'llitl PAA 110 A:U.

An y Cont.iinm nt Loss E'AL ar;ipl"e, /bl

RM 30/31 > 5000 R/hr LRGUmt!t for any able R-1 GE value.

3. E\l'ACUATIOfll lhreshold.s are based on dose assessment 91 fleld team N!s.ults di I are

@lthet:

GR TER 'fiM 1000 mrem THIE

~

,. !Y_ACllATI AJJECThD SECTOR

GREAT R Tl-iA 5000 mre Thyr~d CDc

,r,,l)JAClN S[CT~ IN 2 U 4 !ft int !'las m i- ted cxi dit Kln~ th c;;aused the GE declaration (i.e., une mo1* g re$tored. ron~irm, nt integrity re;stored , ek.),

lll:iW. e11J1a di s e PAR.M.e.:1 .t:IW: l>e

5<<l OOUl'ffi' P'LAli appropl'i;jte.

S.. .! t'l!re i,i; no lonser a risk to the i:,ublMI; lL!2W bee<1use th GE OOl'ld Ions. ire nQt currentlv UTfW ~ T~ K!lil.O',\II OCW!II p nt, TH: N non PAR. 51'io ldb 1.$ d.

ltif.:11.GO O IIUKllll lO _ 1:55

6. 011 a PAA !sco:m 1J11 t~ 10 S O coun ;;,

., RADICi!OGICAI.COikDfflO~ ~GE WI IOIIIOIA . [SSUC ,-il'iAT tlwi PAil n ~ In Cll faor lh n-l dtJrMIDn.

., FUTID 7 J;!2 !:illl is~ ,II, SHELTE II PAR ro, .a PAZ '

111 :.\S PM wa$ prewious issued a ri EV OUATIO PAR, H JtMA CKf' R_'-iJIQli) HAS5110Pfll'D 8. Dose .a~ssment .-esw lh .are required cmce a

, l!)05( FSSF COMFAYM r. r e,1$1l' st;;,rt,i; and cont inue until e emergency event

ter *riated.

Page 16 of 17 Internal

EP RB-10 Revision 22 Change 20 - Revised Content (Rev 22) - DCPP Site Specific PAR Flowchart General Emergency Declared Recommend ALL of the following PARs:

Evacuate PAZ 1 and 2 Evacuate PAZ(s) 3, 4, 5 per RPSA Wind Direction Table Event is a Rapidly Progressing Severe Initial PAR Evacuate Ocean to 10 nautical miles YES YES Accident? assessment? Administer KI per SLO County Plan (Note 2) All other PAZs Monitor and Prepare NO THEN GO TO BLOCK A to continue assessment NO Recommend ALL of the following PARs:

Is this a Controlled Shelter PAZ 1 and 2 RPSA Wind Direction Table Short Term Release YES Evacuate Ocean to 5 nautical miles Wind Direction Evacuate Evacuate T < 60 minutes? Administer KI per SLO County Plan (from) PAZ Ocean All other PAZs Monitor and Prepare NO 0° to < 124° 1, 2 10 nautical miles THEN GO TO BLOCK A to continue assessment 124° to < 192° 1, 2, 5 10 nautical miles Recommend ALL of the following PARs:

Evacuate PAZ 1 and 2 192° to < 214° 1, 2, 4, 5 10 nautical miles Evacuate Ocean to 5 nautical miles 214° to < 259° 1, 2, 3, 4, 5 10 nautical miles Administer KI per SLO County Plan All other PAZs Monitor and Prepare BLOCK A 259° to < 304° 1, 2, 3, 4 10 nautical miles 304° to < 349° 1, 2, 3 10 nautical miles THEN continue assessment below 349° to 360° 1, 2 10 nautical miles

~= WHEN Dose Assessment or Field Survey NOTES Dose Assessment or Field Survey results available?

NO results are available, 1. -IF flowchart decision block conditions are THEN GO TO -BLOCK A unknown, -THEN answer "NO".

I

2. A Rapidly Progressing Severe Accident is YES occurring if ALL of the following are present:

A General Emergency was declared AND Evacuation Recommend ALL of the following PARs: Initial PAR AND YES_.

threshold exceeded in Evacuate applicable PAZ(s) not already ANY PAZ NOT previously designated for Evacuation? designated for evacuation Any EAL Table F-1 Containment Barrier Loss Administer KI per SLO County Plan AND ANY of the following:

RM-30/31 > 5000 R/hr NO I

EAL RG1.1 met for RM-87 > 1.9E-10 amps

EAL RG1.1 met for RM-87 > 3.2E-1 µCi/cc

3. Evacuation thresholds are based on dose Evacuation threshold exceeded in Ocean beyond 5 miles? YES _____. Recommend ALL of the following PARs:

Evacuate the Ocean to 10 nautical miles assessment OR field survey results that are Administer KI per SLO County Plan either:

GREATER THAN 1000 mrem TEDE NO OR I

GREATER THAN 5000 mrem Thyroid CDE

4. -IF the plant has mitigated the conditions that Recommend ALL of the following PARs:

caused the GE declaration (i.e., core cooling Evacuation threshold exceeded _____. Evacuate affected sector AND adjacent restored, containment integrity restored, etc.),

beyond PAZ 8, 9, 11 or 12 YES OR Ocean beyond 10 sectors in 2 mile increments to the distance at which evacuation threshold is

-THEN expanding the PAR - MAY -NOT be miles?

no longer exceeded appropriate.

Administer KI per SLO County Plan 5. -IF there is no longer a risk to the public because NO the GE conditions are not currently present, THEN GO TO -BLOCK A to continue assessment -THEN no new PAR should be issued.

6. Once a PAR is communicated to SLO County, the PAR stays in effect for the event duration.

IF ANY of the following occurs, THEN GO TO BLOCK A to reassess PARs: 7. Do NOT issue a SHELTER PAR for a PAZ that was

Radiological conditions change. previously issued an EVACUATION PAR.

Wind direction changes such that another PAZ may be affected. 8. Dose assessment results are required once a

After 60 minutes when a sheltering PAR has been made to check if the radiological release has stopped. release starts and continue until the emergency

Dose Assessment or Field Survey results become available. event is terminated.

Page 17 of 17 Internal

DCL-23-128, Emergency Plan Update

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DCL-23-128, Emergency Plan Update

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