Pacific Gas and 

Electric Company® 

August26,2015 

PG&E Letter DCL-15-099 

U.S. Nuclear Regulatory Commission 

ATIN: Document Control Desk 

Washington, DC 20555-0001 

Docket No. 50-275, OL-DPR-80 

Docket No. 50-323, OL-DPR-82 

Diablo Canyon Units ·1 and 2 

Barry S. Allen 

Vice President, Nuclear Services 

10 CFR 50.4 

Diablo Canyon Power Plant 

Mail Code 104/6 

P. 0. Box 56 

Avila Beach, CA 93424 

805.545.4888 

Internal: 691.4888 

Fax: 805.545.6445 

Pacific Gas and Electric Company's Fifth Six-Month Status Report in Response to 

March 12. 2012. Commission Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 

(Order Number EA-12-049) 

References: 

1. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses With 

Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis 

External Events," dated March 12, 2012 

2. PG&E Letter DCL-13-007, "Pacific Gas and Electric Company's Overall 

Integrated Plan in Response to March 12, 2012, Commission Order Modifying 

Licenses with Regard to Requirements for Mitigation Strategies for BeyondDesign-Basis External Events (Order Number EA-12-049)," dated 

February 27, 2013 

Dear Commissioners and Staff: 

On March 12, 2012, the Nuclear Regulatory Commission issued Reference 1 to 

Pacific Gas and Electric Company (PG&E) directing PG&E to develop, implement, 

and maintain guidance and strategies to maintain or restore core cooling, 

containment, and spent fuel pool cooling capabilities in the event of a beyonddesign-basis (BOB) external event. Specific requirements are outlined in Reference 

1 , Attachment 2. 

Pursuant to Reference 1, Section IV, Condition C, PG&E submitted its overall 

integrated plan for mitigation strategies for BOB external events in Reference 2. 

Pursuant to Reference 1, Section IV, Condition C.2, and in accordance with the 

direction provided in NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) 

Implementation Guide," the enclosure to this letter provides PG&E's fifth six-month 

status report of its overall integrated plan. 

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

Callaway • Diablo Canyon • Palo Verde • Wolf Creek 
Document Control Desk 

August 26, 2015 

Page2 

PG&E Letter DCL-15-099 

PG&E is making no new regulatory commitments (as defined by NEI 99-04). This 

letter includes no revisions to existing regulatory commitments. 

If you have any questions, or require additional information, please contact 

Mr. Scott Maze at (805) 781-9791. 

I declare under penalty of perjury that the foregoing is true and correct. 

Executed on August 26, 2015. 

Sincerely, 

Jf7.5.~ Barry S. Allen 

Vice President, Nuclear Services 

dmfn/SAPN 50466122-16 

Enclosure 

cc: Diablo Distribution 

cc:/enc: Marc L. Dapas, NRC Region IV Administrator 

William M. Dean, NRC/NRR Director 

Siva P. Lingam, NRR Project Manager 

John P. Reynoso, NRC Acting Senior Resident Inspector 

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

Callaway • Diablo Canyon • Palo Verde • Wolf Creek 
Enclosure 

PG&E Letter DCL-15-099 

Pacific Gas and Electric Company's Fifth Six-Month Status Report for the 

Implementation of NRC Order EA-12-049 
PG&E Letter DCL-15-099 

Enclosure 

Page 1 of 15 

Pacific Gas and Electric Company's Fifth Six-Month Status Report for the 

Implementation of NRC Order EA-12-049 

1. Introduction 

Pacific Gas and Electric Company (PG&E) developed an overall integrated plan (OIP) 

(Reference 1 [refer to Section 11 of this enclosure for a list of references]), documenting 

diverse and flexible strategies (FLEX), in response to Nuclear Regulatory Commission 

(NRC) Order Number EA-12-049, "Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," 

dated March 12, 2012 (Reference 2). This enclosure provides the fifth update of 

milestone accomplishments since the submittal of Reference 1, including any changes 

to the compliance method, schedule, or need for relief/relaxation and the basis, if any. 

2. Milestone Accomplishments 

As of July 31, 2015, PG&E had three milestone accomplishments since the submittal of 

PG&E Letter DCL-15-026, "Pacific Gas and Electric Company's Fourth Six-Month 

Status Report in Response to March 12, 2012, Commission Order Modifying Licenses 

with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis 

External Events (Order Number EA-12-049)," dated February 23, 2015 (Reference 3). 

These milestone accomplishments are that PG&E has completed the design of Phase 3 

modifications and the Phase 2 Staffing Study and associated submittal. 

3. Milestone Schedule Status 

The following table provides an update to the milestone schedule status provided in 

Reference 3. It provides the activity status of each item, and a revised target 

completion date where applicable. The target dates are subject to change as design 

and implementation details are developed. 

The revised milestone target completion dates do not impact the Order implementation 

dates. 

Target Revised 

Activity Target Activity Completion Status Completion Date Date 

Submit 20-day report Apr 2012 Complete 

Submit 60-day status report Oct 2012 Complete 

Submit Overall lnte_g_rated Plan Feb 2013 Complete 

Submit six-month status updates 

Update 1 Aug 2013 Complete 

Update 2 Feb 2014 Complete 

Update 3 Aug 2014 Complete 

Update 4 Feb 2015 Complete 
Activity 

Update 5 

Update 6 

Update 7 

Modifications timeline 

Phase 1 Modifications 

a. Design 

b. Equipment Procurement 

c. Installation 

Phase 2 Modifications 

a. Design 

b. Large Equipment Procurement 

c. Ancillary Equipment Procurement 

d. Unit 1 Installation 

e. Unit 2 Installation 

Phase 3 Modifications 

a. Design 

b. Large Equipment Procurement 

c. Ancillary Equipment Procurement 

d. Unit 1 Installation 

e. Unit 2 Installation 

Procedure guidance implementation 

a. Unit 1 Strategies 

b. Unit 2 Strategies 

c. Unit 1· Maintenance 

d. Unit 2 Maintenance 

e. Unit 1 Testing 

f. Unit 2 Testing 

FLEX storage facilities 

a. Primary Storage Facility 

b. Secondary Storage Facility 

Staffing analysis 

a. Phase 1 

1. Study Complete 

2. NRC Submittal 

b. Phase 2 

1. Study Complete 

2. NRC Submittal 

Training completion for the strategies 

a. Unit 1 

b. Unit 2 

National SAFER Response Center 2 

(Phoenix) operational 

Communications equipment 

Target 

Completion 

Date 

Aug 2015 

Feb 2016 

Aug 2016 

N/A 

N/A 

N/A 

2/28/15 

12/31/14 

6/30/15 

10/30/15 

5/31/16 

2/28/15 

12/31/14 

6/30/15 

10/30/15 

5/31/16 

10/30/15 

5/31/16 

10/30/15 

5/31/16 

10/30/15 

5/31/16 

4/1/15 

8/1/15 

3/29/13 

4/30/13 

5/27/15 

5/27/15 

10/30/15 

5/31/16 

8/28/14 

PG&E Letter DCL-15-099 

Enclosure 

Page 2 of 15 

Revised 

Activity Target 

Status Completion 

Date 

Complete 

Not started 

Not started 

N/A 

N/A 

N/A 

Started 8/31/15 

Complete 

Started 10/27/15 

Not started 

Not started 

Complete 

Complete 

Started 10/27/15 

Not started 

Not started 

Started 

Started 

Started 

Started 

Started 

Started 

Started 9/30/15 

Started 10/27/15 

Complete 

Complete 

Complete 

Complete 

Started 

Started 

Complete 
Target 

Activity Completion 

Date 

PG&E Letter DCL-15-099 

Enclosure 

Page 3 of 15 

Revised 

Activity Target 

Status Completion 

Date 

implementation (PG&E Letter DCL-12-11 0) 

a. Phase 1 12/31/13 Complete 

b. Phase 2 10/27/15 Started 

Unit 1 Walk-throughs or Demonstrations 10/30/15 Not started 

Unit 2 Walk-throughs or Demonstrations 5/31/16 Not started 

Unit 1 FLEX implementation complete 10/30/15 Not started 

Unit 2 FLEX implementation complete 5/31/16 Not started 

4. Changes to Compliance Method 

The following identifies changes to Reference 3, as applicable, and the reason for each 

change. All changes meet applicable NEI 12-06 compliance methods. 

Change 1 - "General Integrated Plan Elements" 

(1) "Discussion of time constraints identified in Attachment 1A" 

(a) Item (15): The vital de battery load shedding scheme has been 

revised to use Battery 1-3 (2-3) first and then Batteries 1-1 (2-1) 

and 1-2 (2-2) together after the first battery approaches depletion. 

(b) Item (20): The revised vital de battery load shedding scheme and 

associated revised load shed calculation results in Vital Battery 1-3 

(2-3) providing power for at least 21 hours and Batteries 1-1 (2-1) 

and 1-2 (2-2) providing power for at least an additional 9 hours. 

The load shedding scheme was revised to ensure either wide range steam 

generator (SG) level or narrow range SG with auxiliary feedwater (AFW) 

flow indication is available at all times. 

(2) Updated reference documents 4 and 12 from Reference 1 for current 

document revisions used in calculations and evaluations. 

Change 2 - "Maintain Core Cooling and Heat Removal Strategy" 

(1) "Phase 2, Modifications": Updated description of the primary connection 

point on the motor-driven AFW pump discharge crosstie to reflect the 

current design of adding an isolation valve and a threaded connection 

point rather than a flanged connection. 
PG&E Letter DCL-15-099 

Enclosure 

Page 4 of 15 

(2) "Phase 3": Clarified that one train of cooling for each Unit would be 

repowered by a 4 kV generator set rather than a single generator. 

(3) "Phase 3, Strategy- Connections": Clarified that one train of cooling for 

each Unit would be repowered by a 4 kV generator set rather than a single 

generator. 

Change 3- "Maintain RCS Inventory Control Strategy" 

(1) "All Phases- Key reactor parameters": Clarified that the Reactor Vessel 

Level Instrumentation System (RVLIS) is a back up to pressurizer level as 

RVLIS will only be available when Vital Batteries 1-1 (2-1) and 1-2 (2-2) 

are in service together. 

(2) "Phase 2": Removed reference to the 480 volt (V) generator being 

prestaged in the radiological control area (RCA), as this equipment will be 

stored in the FLEX Storage Facilities. The storage location was changed 

during the detailed design of generator storage due to challenges related 

to permanent storage of the generator in the radiological controlled area. 

(3) "Phase 2": The 480 V generator will be staged at either the 115 ft 

elevation RCA bench area or the 85 ft elevation west of the turbine 

building near the turbine building machine shop to provide power to the 

Emergency Reactor Coolant Systems (ERCS) make-up pumps. 

(4) "Phase 2, Strategy- Equipment Storage- Pre-staging inside the RCS": 

Removed reference to the 480 V generator, as this equipment will be 

stored in the Primary Beyond-Design-Basis (BOB) Storage Facility. 

(5) "Phase 2, Strategy- Equipment Storage": Inserted row for equipment 

storage in the Primary BOB Storage Facility: 

Equipment Storage - Equipment Storage - Equipment 

Primary BOB Storage Primary BOB Storage Storage - Primary 

Facility (Figure 1 ): Facility BOB Storage 

Facility: 

A backup ERCS make-up This storage facility will be 

pump, associated high- located in Warehouse B as N/A 

pressure hoses, a 480 V shown on Figure 1. 

generator, and associated Warehouse B will be 

equipment will be stored at upgraded to meet ASCE 7-1 0 

this facility. The pump, per NEI 12-06, Section 

hoses, and generator will be 5.3.1.1.b. The equipment at 

transported to its staging this facility will be protected in 

location and deployed. accordance with NEI 12-06, 
j Section 5.3.1. 

PG&E Letter OCL-15-099 

Enclosure 

Page 5 of 15 

(6) "Phase 2, Strategy- Equipment Storage- Secondary BOB Storage 

Facility": Removed reference to the backup ERCS make-up pump and 

associated high pressure hoses, as this backup equipment will be stored 

in the Primary BOB Storage Facility. 

Change 4 - "Maintain Containment" 

(1) "All Phases, Key containment parameters": Containment temperature was 

added as a key containment parameter. Containment temperature can be 

monitored from the control room using the indicator on the post-accident 

monitoring panels. 

(2) "Phase 3": Clarified that one train of cooling for each Unit would be 

repowered by a 4 kV generator set rather than a single generator 

Change 5 - "Maintain Spent Fuel Pool Cooling" 

(1) "Phase 2, Strategy- Equipment Storage": Storage boxes are being 

installed on the 140 ft elevation of the fuel handling building next to each 

spent fuel pool (SFP). These storage boxes will be anchored to the floor 

within the seismically qualified building. Hoses, fittings, nozzles, and 

associated equipment required to be deployed early in the Maintain SFP 

Cooling strategy will be stored in the boxes. 

(2) "Phase 3": Clarified that one train of cooling, including a SFP cooling 

pump, for each Unit would be repowered by a 4 kV generator set rather 

than a single generator. 

Change 6 - "Safety Functions Support" 

(1) "Phase 1, Electrical": The revised vital de battery load shedding scheme 

and associated revised load shed calculation results in Vital Battery 1-3 

(2-3) providing power for at least 21 hours and Batteries 1-1 (2-1) and 1-2 

(2-2) providing power for at least an additional 9 hours. 

Change 7- Attachment 1A, "Sequence of Events Timeline" 

(1) Action Item 20: Revised elapsed time, action, and time constraint for 

switching from Battery 1-3 (2-3) to Batteries 1-1 (2-1) and 1-2 (2-2) to align 
PG&E Letter DCL-15-099 

Enclosure 

Page 6 of 15 

with the changes to the de battery load shedding scheme and timing as 

described in Change 1, Item 1 of this document. 

(2) Action Item 24: Elapsed time and time constraint to repower battery 

chargers to align with the changes to the de battery load shedding scheme 

and timing as described in Change 1, Item 1 of this document. 

Change 8- OIP Attachment 2, "DCPP Units 1 and 2 Implementation Milestone 

Schedule" 

Refer to Section 3 of this Enclosure. 

5. Need for Relief/Relaxation and Basis for the Relief/Relaxation 

PG&E expects to comply with the order implementation date and no relief/relaxation is 

required at this time. 

6. Open Items from Overall Integrated Plan 

The following provides a summary and status of the open items documented in 

Reference 1. Open items identified as completed in References 3 and 4 require no 

further update. 

01-1: 

Required staffing levels will be verified by walkthroughs, tabletops, and simulations of 

the identified FLEX strategies as a part of the Phase 2 staffing studies conducted in 

accordance with NEI 12-01. 

01-6: 

Status: This item is complete. The Phase 2 staffing study was completed and 

submitted to the NRC in PG&E Letter DCL-15-063, "Response to March 12, 

2012, NRC 10 CFR 50.54(f) Request for Information Regarding 

Recommendation 9.3, Phase 2 Staffing Assessment," dated May 27, 2015. 

PG&E will develop procedures to read this instrumentation locally, where applicable, 

using a portable instrument as required by NEI 12-06, Section 5.3.3. 

Status: Procedures are currently scheduled to be issued by October 30, 2015, 

for Unit 1 and May 31, 2016, for Unit 2. 
7. NRC FLEX Audit RAI Updates 

PG&E Letter OCL-15-099 

Enclosure 

Page 7 of 15 

PG&E provided its response to NRC FLEX Audit requests for additional information 

(RAis) in November 2013. In its response, PG&E committed to provide an update of 

specific items in the six-month status reports prepared pursuant to NRC Order 

EA-12-049. RAis identified as completed in Reference 11 require no further update. 

The following provides a summary of the NRC FLEX RAI status updates: 

049-RAI-OCPP-01 0: 

PG&E will provide parking locations of the trucks required to support the movement of 

the FLEX equipment within the required timeframes. 

Status: This item is complete. PG&E will be parking the trucks required to 

support the movement of the FLEX equipment within the required timeframes at 

the Primary BOB Storage Facility and the Secondary BOB Storage Facility. 

8. Interim Staff Evaluation Open and Confirmatory Item Updates 

The following provides PG&E's response to the NRC Interim Staff Evaluation open item 

and confirmatory items. Open item and confirmatory items identified as completed in 

Reference 11 require no further update: 

Confirmatory Item 3.1.1 .4.A (049-RAI-OCPP-006): 

Off-Site Resources- Confirm RRC local staging area, evaluation of access routes, and 

method of transportation to the site. 

Response: PG&E will confirm National SAFER Response Center (NSRC), 

formerly Regional Response Center (RRC), local staging area, evaluation of 

access routes, and method of transportation to the site in the final compliance 

letter. 

Confirmatory Item 3.2.1.B: 

RCS cooling and heat removal, and RCS inventory control- The licensee provided 

information regarding the analysis from WCAP-17601 applicable to DCPP in response 

to NRC staff requests. The NRC staff is continuing to review this information to ensure 

the licensee sufficiently justifies the analysis being applied. Additional information may 

be needed to confirm appropriate use of the analysis. 

Response: PG&E notes that the NRC Staff is continuing to review information 

regarding the analysis from WCAP-17601 applicable to OCPP in response to 
PG&E Letter DCL-15-099 

Enclosure 

Page 8 of 15 

NRC Staff requests. PG&E will provide additional information, if required, in the 

final compliance letter. 

Confirmatory Item 3.2.1.4.A: 

The licensee used the Modular Accident Analysis Program (MAAP) code in petforming 

its ELAP analyses. Aspects of the MAAP code analyses, such as boundary conditions, 

nodalization, and the selection of code options for modeling key physical phenomena, 

were not discussed in the Integrated Plan. Provide an understanding of the above 

issues to assess the technical adequacy of the code and determining the code's range 

of applicability. 

Response: PG&E will provide information on the MAAP code used in performing 

the Extended Loss of Alternating Current Power (ELAP) analysis to show the 

technical adequacy of the code and the code's range of applicability in the final 

compliance letter. 

Confirmatory Item 32.1.6.A: 

On pages 70 through 73 in the Integrated Plan, the licensee listed elapsed times and 

time constraints in different columns in Attachment 1A (sequence of events timeline). 

The review determined that the times listed in the elapsed time column and the time 

constraint column often are the same and provide no margin between the elapsed time 

and the time constraint time. Provide clarification on how early a step must be begun to 

meet the time constraint, when the licensee actually expects to begin petforming the 

step, information on what margin exists for these critical actions, and whether the time 

can be reasonably met. 

Response: PG&E will provide clarification on how early a step must be begun to 

meet the time constraint, when it is expected to begin performing the step, 

information on what margin exists for these critical actions, and whether the time 

can be reasonably met in the final compliance letter. 

Confirmatory Item 3.2.4.4.A: 

Communications- Confirm that upgrades to the site's communications systems have 

been completed. 

Response: PG&E will confirm the completion of the upgrades to the site's 

communications systems in the final compliance letter. 
Confirmatory Item 3.4.A: 

PG&E Letter DCL-15-099 

Enclosure 

Page 9 of 15 

NEI 12-06, Section 12.2 lists minimum capabilities for offsite resources for which each 

Licensee should establish the availability. Discuss implementation of Guidelines 2 

through 10 in NEI12-06, Section 12.2. 

Response: PG&E will discuss the implementation of Guidelines 2 through 10 in 

NEI 12-06, Section 12.2, in the final compliance letter. 

9. Planned Communications Equipment Status Updates 

PG&E submitted its response to a RAI regarding the Recommendation 9.3 

Communications Assessment in PG&E Letter DCL-12-110, "Pacific Gas and Electric 

Company's Response to Recommendation 9.3 Communications Requests 1 and 3 

and the Evaluation of Existing Communications Systems Power Supplies," dated 

October 29, 2012 (Reference 5). In its response, PG&E committed to provide a status 

update of the planned communications equipment in the six-month status reports 

prepared pursuant to NRC Order EA-12-049, Section IV.C.2. The following provides a 

status update of the planned communication equipment. 

Communications Item 1: 

As discussed in Reference 5, PG&E committed to procure additional hand held satellite 

phones, batteries, and chargers that will be provided with portable generator back-up 

power by December 31, 2013. 

In Reference 6, PG&E concluded that a total of 9 satellite phones, 27 satellite phone 

batteries, and 5 multi-unit satellite phone chargers are required to ensure that the 

control room (CR), technical support center (TSC), and emergency operations facility 

have a dedicated line to perform State and County notifications. In addition, PG&E 

concluded that 8 satellite phones, 18 satellite phone batteries, and 5 multi-unit satellite 

phone chargers need to be procured. 

Status: 

(1) PG&E has procured an additional eight satellite phones and placed into 

service nine satellite phones. The procurement of the additional satellite 

phones was reported as complete in Reference 1 0. 

(2) PG&E has procured 18 satellite phone batteries. The procurement of the 

satellite phone batteries was reported as complete in Reference 1 0. 

(3) PG&E has procured five multi-unit satellite phone chargers. The 

procurement of the satellite phone chargers was reported as complete in 

Reference 10. 
PG&E Letter DCL-15-099 

Enclosure 

Page 10 of 15 

(4) Refer to Communications Item 5 for a status of the portable diesel 

generators. Until the portable diesel generators are received and placed 

in service, the hand held satellite phone chargers will be provided with 

back-up power using the communications trailer diesel generator. A 

procedure for charging the satellite phones using the communications 

trailer was reported as completed in Reference 1 0. 

Clarification: As discussed in Reference 6, the portable hand held satellite 

phones have a talk time of 3.1 hours and a recharge time of 4 hours. 

However, the additional batteries procured for the portable hand held satellite 

phones have talk time of 6 hours. The recharge time for the portable hand held 

satellite phones is 6 hours. 

Communications Item 2: 

As discussed in Reference 5, PG&E committed to install a fixed satellite phone with an 

external antenna in the Sheriff Watch Commander's office by October 27, 2015. As 

discussed in Reference 6, back-up power for the Sheriff Watch Commander's fixed 

satellite phone will be provided by an existing diesel generator with a 1 000-gallon tank 

that is capable of providing 120 hours of power. 

Status: This item is complete. PG&E has installed a fixed satellite phone with an 

external antenna in the Sheriff Watch Commander's office. 

Communications Item 3: 

As discussed in Reference 6, PG&E committed to procure additional single- and dualband radio batteries and chargers that will be provided with portable generator back-up 

power by October 27, 2015. 

Based on a review of the radio specifications in Reference 6, PG&E concluded that a 

total of 160 dual-band radio batteries, 150 single-band radio batteries, 14 6-unit and 

20 single-unit dual-band chargers, and 13 6-unit and 20 single-unit single-band 

chargers are required to maintain communications within a 24-hour period. Reference 5 

also stated that 80 dual-band radio batteries and 75 single-band radio batteries need to 

be procured. 

Status: 

(1) This item is complete. PG&E has received an additional 75 single- and 80 

dual-band radio batteries. 
PG&E Letter DCL-15-099 

Enclosure 

Page 11 of 15 

(2) PG&E has 14 6-unit and 20 single-unit dual-band chargers, and 13 6-unit 

and 20 single-unit single-band chargers. This item was reported as 

complete in Reference 10. 

(3) Refer to Communications Item 5 for a status of the portable diesel 

generators. 

Communications Item 4: 

As discussed in Reference 11, a radio console will not be installed in the operational 

support center. PG&E will store radios, batteries, and chargers in a FLEX storage 

facility to support continued radio communications. This equipment will be stored in a 

FLEX storage facility by October 27, 2015. 

Status: The radios, batteries, and chargers will be relocated to a FLEX storage 

facility as part of Phase 2, which is scheduled for October 27, 2015. Refer to 

Communications Item 3 for a status of the procurement of the additional radios, 

batteries, and chargers . 

. Communications Item 5: 

As discussed in Reference 5, PG&E committed to procure portable generators and 

equipment to ensure that adequate power will exist to support extended operations. 

This equipment will be placed in service with approved procedures as part of Phase 2, 

which is scheduled for October 27, 2015. 

Status: The portable generator enhancements are on schedule. 

Communications Item 6: 

As discussed in Reference 5, PG&E committed to relocate the SmartMsg and Zetron 

pager systems from their current location to an existing structure that is seismically 

robust. This will be completed by October 27, 2015. 

As discussed in Reference 6, the paging system battery will be battery backed, with 

capability to be provided from a portable diesel generator, to ensure that adequate 

power will exist to support extended operations beyond 24 hours. Refer to 

Communications Item 5 for a status of the portable generators. 

Status: The relocation of the SmartMsg and Zetron pager systems is on 

schedule. 
Communications Item 7: 

PG&E Letter DCL-15-099 

Enclosure 

Page 12 of 15 

As discussed in Reference 6, PG&E committed to establish credited manual actions 

and their procedures in accordance with NEI12-01 and NRC Order EA-12-049. 

Credited manual actions and procedures for the Phase 1 communications are 

scheduled to be completed by December 31, 2013. Credited manual actions and 

procedures for the Phase 2 communications are currently scheduled to be completed by 

October 27, 2015. 

Status: Credited manual actions and procedures for Phase 1 communication 

were reported as complete in Reference 10. 

Completion of Phase 2 credited manual actions and their procedures are on 

schedule. 

Communications Item 8: 

As discussed in Reference 6, PG&E committed to establish maintenance procedures for 

the planned enhancements, including operability testing, in accordance with NEI 12-01 

and NRC Order EA-12-049. Maintenance procedures for the Phase 1 communications 

are currently scheduled to be completed by December 31, 2013. Maintenance 

procedures for the Phase 2 communications are currently scheduled to be completed by 

October 27, 2015. 

Status: Temporary maintenance procedures for the Phase 1 communications 

were reported as complete in Reference 10. A permanent procedure for 

maintenance of the Phase 1 communications will be completed with Phase 2 

procedures. Completion of Phase 2 maintenance procedures are on schedule. 

Communications Item 9: 

As discussed in Reference 6, PG&E committed to establish periodic inventory 

checks for the planned enhancements in accordance with NEI 12-01 and NRC 

Order EA-12-049. Periodic inventory checks for the Phase 1 communications are 

currently scheduled to be completed by December 31, 2013. Periodic inventory 

checks for the Phase 2 communications are currently scheduled to be completed by 

October 27, 2015. 

Status: A temporary procedure for inventory checks of the Phase 1 

communications equipment was reported as completed in Reference 10. A 

permanent procedure for inventory checks of the Phase 1 communications 

equipment will be completed with Phase 2 procedures. Completion of Phase 2 

inventory procedures is on schedule. 
Communications Item 1 0: 

PG&E Letter DCL-15-099 

Enclosure 

Page 13 of 15 

As discussed in Reference 6, PG&E committed to develop training plans for response 

personnel in plant groups such as the emergency response organization, fire, security, 

emergency planning, operations, engineering, and maintenance. The training plans will 

be developed in accordance with DCPP procedures using the systematic approach to 

training and will be implemented to ensure that the required DCPP staff is trained in 

accordance with NEI 12-01 and NRC Order EA-12-049. Training for applicable plant 

staff on the Phase 1 communications equipment was scheduled to be completed by 

December 31, 2013. Training for plant staff on the Phase 2 communications equipment 

is currently scheduled to be completed by October 27, 2015. 

Status: Training plans and training for applicable plant staff on the Phase 1 

communications equipment were reported complete in Reference 10. Phase 2 

plant staff training is on schedule. 

Communications Item 11: 

As discussed in Reference 5, PG&E committed to relocate onsite Field Monitoring 

Team (FMT) satellite phones to the onsite FMT vehicle. Currently, the onsite FMT 

satellite phones are not stored in a structure that is considered to be seismically robust 

in accordance with NEI 12-01. This commitment will be implemented as part of 

Phase 2, which is scheduled for October 27, 2015. 

Status: PG&E will relocate the onsite FMT satellite phones to an onsite FLEX 

storage facility. The FLEX storage facility will be seismically robust in 

accordance with NEI 12-01 and NEI 12-06. The FMT satellite phone relocation is 

on schedule. 

Communications Item 12: 

As discussed in Reference 6, PG&E committed to provide power from an uninterrupted 

power supply with 6 hours of back-up power to the CR and TSC fixed satellite phones 

by October 27, 2015. 

Status: PG&E will provide power from an uninterrupted power supply with 

24 hours of back-up power to the CR and TSC fixed satellite phones to ensure 

that the CR and TSC fixed satellite phones will be functional for a 24-hour 

duration. The uninterrupted power supply improvements are on schedule. 

10. Potential Draft Safety Evaluation Impacts 

There are no potential impacts to the Draft Safety Evaluation identified at this time. 
11. References 

PG&E Letter DCL-15-099 

Enclosure 

Page 14 of 15 

The following references support the updates to the OIP described in this enclosure: 

(1) PG&E Letter DCL-13-007, "Pacific Gas and Electric Company's Overall 

Integrated Plan in Response to March 12, 2012, Commission Order 

Modifying Licenses with Regard to Requirements for Mitigation Strategies 

for Beyond-Design-Basis External Events (Order Number EA-12-049)," 

dated February 27, 2013 

(2) NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to 

Requirements for Mitigation Strategies for Beyond-Design-Basis External 

Events," dated March 12, 2012 

(3) PG&E Letter DCL-15-026, "Pacific Gas and Electric Company's Fourth SixMonth Status Report in Response to March 12, 2012, Commission Order 

Modifying Licenses with Regard to Requirements for Mitigation Strategies 

for Beyond-Design-Basis External Events," dated February 23, 2015 

(4) PG&E Letter DCL-13-081, "Pacific Gas and Electric Company's First SixMonth Status Report in Response to March 12, 2012, Commission Order 

Modifying Licenses with Regard to Requirements for Mitigation Strategies 

for Beyond-Design-Basis External Events," dated August 22, 2013 

(5) PG&E Letter DCL-12-110, "Pacific Gas and Electric Company's Response 

to Recommendation 9.3 Communication Requests 1 and 3 and the 

Evaluation of Existing Communications Systems Power Supplies," dated 

October 29, 2012 

(6) PG&E Letter DCL-13-012, "30-Day Response to Request for Additional 

Information Regarding the Recommendation 9.3 Communications 

Assessment," dated February 21, 2013 

(7) PG&E Letter DCL-12-048, "60-Day Response to NRC Letter, 'Request for 

Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) 

Regarding Recommendations 2.1, 2.3, and 9.3 ofthe Near-Term Task 

Force Review of Insights from the Fukushima Dai-ichi Accident,"' dated 

March 12, 2012 

(8) NRC Interim Staff Guidance, "Diablo Canyon Power Plant, Unit Nos. 1 

and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in 

Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0958 

and MF0959)," dated February 3, 2014 
PG&E Letter DCL-15-099 

Enclosure 

Page 15 of 15 

(9) NRC Letter, "Requestfor Information Pursuant to Title 10 of the Code of 

Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 

9.3, of the Near-Term Task Force Review of Insights from the Fukushima 

Dai-ichi Accident," dated March 12, 2012 

(1 0) PG&E Letter DCL-14-014, "Pacific Gas and Electric Company's Second 

Six-Month Status Report in Response to March 12, 2012, Commission 

Order Modifying Licenses with Regard to Requirements for Mitigation 

Strategies for Beyond-Design-Basis External Events (Order Number 

EA-12-049)," dated February 26, 2014 

(11) PG&E Letter DCL-14-076, "Pacific Gas and Electric Company's Third SixMonth Status Report in Response to March 12, 2012, Commission Order 

Modifying Licenses with Regard to Requirements for Mitigation Strategies 

for Beyond-Design-Basis External Events," dated August 21, 2014 

(12) PG&E Letter DCL-15-026, "Pacific Gas and Electric Company's Fourth SixMonth Status Report in Response to March 12, 2012, Commission Order 

Modifying Licenses with Regard to Requirements for Mitigation Strategies 

for Beyond-Design-Basis External Events," dated February 23, 2015