Text

Transmittal of Emergency Procedure Revision and 10 CFR 50.54(q) Summary of Analysis, Revision 27 to AOP-034, Security Events.
	ML16089A037
Person / Time
Site:	Robinson
Issue date:	03/24/2016
From:	Hoffman D; Duke Energy Progress
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RNP-RA/16-0019
	Download: ML16089A037 (76)
	v • d • e

David S. Hoffman

(~ DUKE H. B. Robinson Steam Electric Plant Unit 2 ENERGY~ Director - Nuc Org Effectiveness Duke Energy Progress 3581 West Entrance Road Hartsville, SC 29550 0 . 843 857 5239 F: 843 8571319 David.Hoffman@duke-energy.com 10 CFR 50, Appendix E Serial: RNP-RA/16-0019 MAR 2 4 2016 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 TRAN SM ITTAL OF EMERGENCY PROCEDURE REVISION AND 10 CFR 50.54(q)

SUMMARY

OF ANALYSIS Ladies and Gentlemen:

In accordance with 10 CFR 50.4(b)(5) and Appendix E to 10 CFR 50, Duke Energy Progress, Inc.

is transmitting a revision to the H.B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, Emergency Implementing Procedure.

A description of the procedure change is provided on the "Summary of Changes" page included within the emergency procedure. Please replace the superseded procedure with the enclosed revision. The procedure revision and effective date is listed in Attachment I to this letter.

In accordance with 10 CFR 50.54(q)(5), Attachments II and Ill includes a summary of the analysis associated with the procedure change provided in Attachment I.

This document contains no new Regulatory Commitments.

If you have any questions concerning this matter, please contact Scott Connelly, Acting Manager -

Nuclear Regulatory Affairs at (843) 857-1569.

Sincerely, Da~!li7/v--

Director - Nuc Org Effectiveness DSH/cac

United States Nuclear Regulatory Commission Serial: RNP-RA/16-0019 Page 2 of 2 Attachments:

I. Procedure Revision and Effective Date II. 50.54(q)(3) Screen Ill. 50.54(q)(3) Evaluation Enclosure c: NRC Regional Administrator, NRC, Region II NRC Resident Inspector, HBRSEP Mr. Dennis Galvin, NRC Project Manager, NRA (w/o Enclosure)

United States Nuclear Regulatory Commission Attachment I to Serial: RNP-RA/16-0019 Page 1 of 1 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 Procedure Revision and Effective Date Procedure Revision Effective Date No.

AOP-034, "Security Events" 27 03/07/16

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/16-0019 5 Pages (including cover page)

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 50.54(g)(3) Screen

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev.1 ATTACHMENT 4 Page 1 of 4 10 CFR 50.54(q) Screening Evaluation Form Screening and Evaluation Number Applicable Sites BNP D EREG #: 1998183 CNS D CR3 D HNP D MNS D SAD#: 1974717 ONS D RNP x GO D Document and Revision AOP-034 Revision 27 Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan}:

The following proposed changes are for procedure AOP-034, Security Events, Revision 27:

Main Body: Step 1, Old Step 19(Del}, & Attachment 2: Old Step 19(Del}:

Moved dispatch of EDG Operator to top of page Step 1.

Added dispatch of a CCW Pump room operator when in modes 5 & 6.

Attachment 3 Step 1:

Added "and exit the attachment" once Security is notified of the threat.

Attachment 6 Old Step 1 (Del}:

Removed initial step to dispatch the EDG operator. The operator is dispatched as the first step in the procedure and was redundant here. This is editorial.

Attachments 5, 6, 7:

Upgraded layout and verbiage to conform to current standards with no change to intent or logic flow. These are editorial enhancements to improve the usability.

Attachment 7 Step 23, 23.a., 23.b, & Caution:

Added steps to consolidate RCP Seal isolation requirements and decision and include new Attachment 8.

Added Caution regarding reduced allowable RCP Seal Loss times for Safe Shutdown I SBO considerations.

Attachment 7 Step 27:

Included starting 'C' Charging Pump and deleted old step 27. The necessary conditions have been established in Step 23, 23.a, & 23.b

Attachment 8:

Added new attachment with table to determine maximum time RCP Seal cooling can be lost before the need to isolate.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev.1 ATTACHMENT 4 Page 2 of 4 10 CFR 50.54(q) Screening Evaluation Form Part II. Activity Previously Reviewed? Yes 10 No Ix Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or 10 CFR 50.54(q) Continue to Alert and Notification System Design Report? Effectiveness Attachment 4, Evaluation is not 10CFR If yes, identify bounding source document number or approval reference and required. Enter 50.54(q) ensure the basis for concluding the source document fully bounds the proposed justification Screening change is documented below: below and Evaluation complete Form, Part Ill Justification: Attachment 4, Part V.

Bounding document attached (optional) 10 Part Ill. Editorial Change Yes lo No Ix Is this activity an editorial or typographical change only, such as formatting, 10 CFR 50.54(q) Continue to paragraph numbering, spelling, or punctuation that does not change intent? Effectiveness Attachment 4, Evaluation is not Part IV and The following proposed changes for procedure AOP-034, Security Events, required. Enter address non Revision 27, meet the criteria of editorial. justification and editorial complete changes Attachments 5, 6, 7: Attachment 4, Upgraded layout and verbiage to conform to current standards with Part V & VI.

no change to intent or logic flow.

Justification: These are editorial enhancements to improve the usability. Old Step 1 (Del): Removed initial step to dispatch the EDG operator.

Justification: This is editorial. The operator is dispatched as the first step in the procedure and was redundant here.

Part IV. Emergency Planning Element and Function Screen (Reference Attachment 1, Considerations for Addressing Screening Criteria)

Does this activity involve any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II? If answer is yes, then check box.

1 10 CFR 50.47(b)(1) Assignment of Responsibility (Organization Control) 1a Responsibility for emergency response is assigned. x 1b The response organization has the staff to respond and to augment staff on a continuing basis x (24-7 staffing) in accordance with the emergency plan.

2 10 CFR 50.47(b}(2} Onsite Emergency Organization 2a Process ensures that onshift emergency response responsibilities are staffed and assigned x 2b The process for timely augmentation of onshift staff is established and maintained . D 3 10 CFR 50.47(b)(3) Emergency Response Support and Resources 3a Arrangements for requesting and using off site assistance have been made. D 3b State and local staff can be accommodated at the EOF in accordance with the emergency plan. D (NA for CR3)

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 1 ATTACHMENT 4 Page 3 of 4 10 CFR 50.54(q) Screening Evaluation Form Part IV. Emergency Planning Element and Function Screen {cont.)

4 10 CFR S0.47{b){4) Emergency Classification System 4a A standard scheme of emergency classification and action levels is in use. D (Requires final approval of Screen and Evaluation by EP CFAM.)

s 10 CFR S0.47(b)(S) Notification Methods and Procedures Sa Procedures for notification of State and local governmental agencies are capable of initiating D notification of the declared emergency within 1S minutes (30 minutes for CR3) after declaration of an emergency and providing follow-up notification.

Sb Administrative and physical means have been established for alerting and providing prompt instructions D to the public within the plume exposure pathway. (NA for CR3)

Sc The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS desigr:i report and supporting FEMA approval letter. (NA for CR3) 6 10 CFR S0.47(b){6) Emergency Communications 6a Systems are established for prompt communication among principal emergency response D organizations.

6b Systems are established for prompt communication to emergency response personnel. D 7 10 CFR S0.47(b)(7) Public Education and Information 7a Emergency preparedness information is made available to the public on a periodic basis within the D plume exposure pathway emergency planning zone (EPZ). (NA for CR3) 7b Coordinated dissemination of public information during emergencies is established. D 8 10 CFR S0.47(b)(8) Emergency Facilities and Equipment Ba Adequate facilities are maintained to support emergency response. D Bb Adequate equipment is maintained to support emergency response. D 9 10 CFR S0.4 7(b )(9) Accident Assessment 9a Methods, systems, and equipment for assessment of radioactive releases are in use. D 10 10 CFR S0.47(b)(10) Protective Response 10a A range of public PARs is available for implementation during emergencies. (NA for CR3) D 10b Evacuation time estimates for the population located in the plume exposure pathway EPZ are available D to support the formulation of PARs and have been provided to State and local governmental authorities. (NA for CR3) 10c A range of protective actions is available for plant emergency workers during emergencies, including D those for hostile action events.

10d Kl is available for implementation as a protective action recommendation in those jurisdictions that D chose to provide Kl to the public.

11 10 CFR S0.47(b)(11) Radiological Exposure Control 11a The resources for controlling radiological exposures for emergency workers are established. D 12 10 CFR S0.47(b)(12) Medical and Public Health Support 12a Arrangements are made for medical services for contaminated, injured individuals. D 13 10 CFR S0.47(b)(13) Recovery Planning and Post-accident Operations 13a Plans for recovery and reentry are developed. D

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 1 ATTACHMENT 4 Page 4 of 4 10 CFR 50.54(q) Screening Evaluation Form Part IV. Emergency Planning Element and Function Screen (cont.)

14 10 CFR 50.47(b)(14) Drills and Exercises 14a A drill and exercise program (including radiological, medical, health physics and other program areas) 0 is established.

14b Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, D and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses.

14c Identified weaknesses are corrected. D 15 10 CFR 50.47(b)(15) Emergency Response Training 15a Training is provided to emergency responders. D 16 10 CFR 50.47(b)(16) Emergency Plan Maintenance 16a Responsibility for emergency plan development and review is established. D 16b Planners responsible for emergency plan development and maintenance are properly trained. D PART IV. Conclusion If no Part IV criteria are checked, a 10 CFR 50.54(q) Effectiveness Evaluation is not required, then complete D , 10 CFR 50.54(q) Screening Evaluation Form, Part V. Go to Attachment 4, 10 CFR 50.54(q)

Screening Evaluation Form, Part VI for instructions describing the NRC required 30 day submittal.

If any Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV criteria are checked, then complete , 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q) x Effectiveness Evaluation. Shaded block requires final approval of Screen and Evaluation by EP CFAM.

Part V. Signatures:

Preparer Name (Print): Date:

Debbie Dowling ~ "Lj I Co Reviewer Name (Print): Date:

Lisa Hall Approver (EP Manager Name (Print):

Tony Pilo Approver (CFAM, as required) ame (Print)

Part VI. NRC Emergency Plan and Implementing Procedure Submittal Actions Create two EREG General Assignments.

One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR 50.54(q), x to Licensing.

One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the change is put in effect. x QA RECORD

United States Nuclear Regulatory Commission Attachment Ill to Serial: RNP-RA/16-0019 9 Pages (including cover page)

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 50.54(q)(3) Evaluation

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 0 ATTACHMENT 5 Page 1 of 8 10 CFR 50.54(q) Effectiveness Evaluation Form Screening and Evaluation Number Applicable Sites BNP D EREG#: 1998183 CNS D CR3 D HNP D MNS D SAD#: 1974717 ONS D RNP x GO D Document and Revision: AOP-034 Revision 27 Part I. Description of Proposed Change:

The following proposed changes are for procedure AOP-034, Security Events, Revision 27:

Main Body: Step 1, Old Step 19(Del), & Attachment 2: Old Step 19(Del):

Moved dispatch of EOG Operator to top of page Step 1.

Added dispatch of a CCW Pump Room operator when in modes 5 & 6.

Attachment 3 Step 1:

Added "and exit the attachment" once Security is notified of the threat.

Attachment 7 Step 23, 23.a., 23.b, & Caution:

Added steps to consolidate RCP Seal isolation requirements and decision and include new Attachment 8.

Added Caution regarding reduced allowable RCP Seal Loss times for Safe Shutdown I SBO considerations.

Attachment 7 Step 27:

Included starting 'C' Charging Pump and deleted old step 27. The necessary conditions have been established in Step 23, 23.a, & 23.b

Attachment 8:

Added new attachment with table to determine maximum time RCP Seal cooling can be lost before the need to isolate. , 10 CFR 50.54(q) Initiating Condition {IC) and Emergency Action Level (EAL) and EAL Yes D Bases Validation and Verification (V&V) Form , is attached (required for IC or EAL change) No x

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. O ATTACHMENT 5 Page 2 of 8 10 CFR 50.54(q) Effectiveness Evaluation Form Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

The proposed changes in Revision 27, of AOP-034, Security Events, included a review of the following RNP emergency plan licensing basis documents:

PLP-007, Robinson Emergency Response Plan (Revision 0, dated 1982)

PLP-007, Robinson Emergency Plan (Revision 85)

NRC Correspondence - May 11, 1983:

Subject:

NUREG-0737 Item 111.A.2.1 - Emergency Plan Upgrade To Meet Rule (H.B. Robinson Unit 2)

H.B. Robinson Steam Electric Plant, Unit No. 2, Updated Final Safety Analysis Report, Chapter 13.3 This review concludes that the proposed changes in Revision 27 of AOP-034, Security Events do not affect the licensing basis of PLP-007, Robinson Emergency Plan.

Part Ill. Description of How the Proposed Change Complies with Regulation and Commitments .

If the emergency plan, modified as proposed, no longer complies with planning standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50, then ensure the change is rejected, modified, or processed as an exemption request under 10 CFR 50.12, Specific Exemptions, rather than under 10 CFR 50.54(q):

These following proposed changes for Revision 27 of AOP-034, Security Events, are enhancements to ensure timely dispatch of the Auxiliary Building operator to the Emergency Diesel Generator (EOG) "B" Room and Component Cooling Water (CCW) Pump Room operator to the CCW Pump Room. The movement and addition of the dispatch steps to the beginning of the section ensures personnel respond and start emergency equipment in a timely manner to implement AOP-034 and EPP-28, Loss of Ultimate Heat Sink, if required. The addition to dispatch a CCW Pump Room operator in modes 5 & 6 supports checking Motor Driven Auxiliary Feedwater Pump "A" in accordance with EPP-28. This step ensures an operator for CCW Pump Room contingencies is available for dispatch. Incorporating these enhancements address concerns that conditions may change preventing Operations from reaching the required location.

The responsibilities and functions of the organizations remain unchanged and therefore no new positions, responsibilities or functions are created by theses proposed changes in regards to maintaining and responding to onsite and offsite Emergency Plans. These changes maintain planning standard functions 10 CFR 50.47(b)(1) and 10 CFR 50.47(b)(2) for assigned responsibility for emergency response and response organization staff to respond and augment on a continuing basis (24/7 staffing) in accordance with the E-plan. Also, these proposed changes continue to comply with planning standards, as described in 10 CFR 50, Appendix E Sections IV.A.2, IV.A.2.a, b; IV.A.9, and IV. C, requirements.

Main Body: Step 1, Old Step 19(Del), & Attachment 2: Old Step 19(Del):

Moved dispatch of EOG Operator to top of page Step 1.

Added dispatch of a CCW Pump Room operator when in modes 5 & 6.

The following proposed change, for Revision 27 of AOP-034, Security Events, is an enhancement that allows Operations to exit the attachment after notifying Security to initiate Scenario 21 of the Emergency Response Organization Notification System. Exiting the attachment allows Operations to implement the procedure in a timely manner. This change does not impact 10 CFR 50.47 or 10 CFR Appendix E.; therefore, this change continues to support and comply with the Planning Standards, as described in 10 CFR 50.47(b) and the requirements in 10 CFR 50, Appendix E.

Attachment 3 Step 1: Added "and exit the attachment" once Security is notified.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 0 ATTACHMENT 5 Page 3 of 8 10 CFR 50.54(q) Effectiveness Evaluation Form Part Ill. Description of How the Proposed Change Complies with Regulation and Commitments.

The following proposed changes, for Revision 27 of AOP-034, Security Events, are enhancements that consolidate and address the time allowed for restoration of Reactor Coolant Pump seal cooling being reduced to less than 15 minutes when initial seal leakoff flow is greater than 3.2 gpm as described in OP-101, Reactor Coolant System and Reactor Coolant Pump Startup and Operation, Rev. 75, Precaution and Limitation Step 5.2.1.25. This information eliminates the need to branch from one procedure to the other. These proposed changes do not change the intent.

These changes do not impact 10 CFR 50.47 or 10 CFR Appendix E.; therefore, these changes continue to support and comply with the Planning Standards, as described in 10 CFR 50.47(b) and the requirements in 10 CFR 50, Appendix E.

Attachment 7 Step 23, 23.a, 23.b, & Caution: Added steps to consolidate RCP Seal isolation requirements and decision and include new Attachment 8. Added Caution regarding reduced allowable RCP Seal Loss times for Safe Shutdown I SBO considerations.

Attachment 7 Step 27:

Included conditional for starting of 'C' Charging Pump and deleted old step 27. The necessary conditions have been established in Step 23, 23.a, & 23.b

Attachment 8: Added new attachment with table to determine maximum time RCP Seal cooling can be lost before the need to isolate.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 0 ATTACHMENT 5 Page 4 of 8 10 CFR 50.54(q) Effectiveness Evaluation Form Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part IV of associated Screen):

10 CFR 50.47(b)(1), Emergency Response Responsibility PLANNING STANDARD: Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

PS FUNCTIONS:

1. Process ensures that on-shift emergency response responsibilities are staffed and assigned.

2. The response organization has the staff to respond and augment on a continuing basis (24/7 staffing) in accordance with the E-plan.

Supporting Requirements (in part): 10 CFR Part 50, Appendix E, Sections IV.A.2 A. Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

2. A description of the onsite emergency response organization with a detailed discussion of:

a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;

b. Plant staff emergency assignments Program Elements

Primary responsibilities for emergency response by the nuclear facility licensee, and by State and local organizations within the Emergency Planning Zones have been assigned.

The emergency responsibilities of the various supporting organizations have been specifically established.

Each organization and sub-organization having an operational role shall specify its concept of operations, and its relationship to the total effort.

Each organization shall identify a specific individual by title who shall be in charge of the emergency response.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 0 ATTACHMENT 5 Page 5 of 8 10 CFR 50.54(q) Effectiveness Evaluation Form Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change (Address each function identified in Attachment 4, 10 CFR 50.54(q} Screening Evaluation Form ,

Part IV of associated Screen}:

10 CFR 50.47(b)(2) Onsite Emergency Organization states:

PLANNING STANDARD: On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the interfaces among various onsite response activities and offsite support and response activities are specified.

The emergency planning functions associated with 10 CFR 50.47(b)(2) state:

Process ensures that on-shift emergency response responsibilities are staffed and assigned.

The applicable supporting requirement which is described in 10 CFR 50, Appendix E Sections IV.A.2.a, b; IV.A.9; and IV. C states (in part):

A . Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

2. A description of the onsite emergency response organization with a detailed discussion of:

a. Authorities, responsibilities, and duties of the individual(s} who will take charge during an emergency;

b. Plant staff emergency assignments; 9 . By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

C. Activation of Emergency Organization

2. By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.

Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded . Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(Q)

Rev. 0 ATTACHMENT 5 Page 6 of 8 10 CFR 50.54(q) Effectiveness Evaluation Form Program Elements

Responsibilities for emergency response are defined and have adequate staffing to provide initial facility accident response in key functional areas. Provide timely augmentation of response capabilities and interface among various onsite response activities and offsite support and response activities are specified.

Specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal shift complement.

Designate an individual as emergency coordinator who shall be on shift at all times and who shall have the authority and responsibility to immediately and unilaterally initiate any emergency actions, including providing protective action recommendations to authorities responsible for implementing offsite emergency measures.

Specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situation, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled "Minimum Staffing Requirements for Nuclear Power Plant Emergencies." The minimum on-shift staffing levels shall be as indicated in Table B-1. The site will be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability is indicated in Table B-1.

Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

AOP-034, Security Events, is a supporting procedure that describes how to respond to a threat to the facility from external security events. The following proposed changes in Revision 27 of AOP-034 do not result in a reduction in effectiveness to onsite emergency organization of plant staff personnel. The proposed changes do not reduce the effectiveness of the Robinson Emergency Plan (PLP-007). PLP-007, Section 5.3, Emergency Response Organization, provides assigned responsibility for emergency response and response organization staff to respond and augment on a continuing basis (24/7 staffing). These proposed changes continue to support the guidance provided in PLP-007 with no reduction in effectiveness.

The responsibilities and functions of the organizations remain unchanged and therefore no new positions, responsibilities or functions are created by theses proposed changes in regards to maintaining and responding to onsite and offsite Emergency Plans. These change have no impact to the NEI 10-05 On-Shift Staffing Analysis for H. B. Robinson Nuclear Plant - 2015, May 2015 Revision 1 . The Design Basis Threat and Aircraft Probable Threat scenario was reviewed and determined to have no impact to On-Shift Staffing Analysis.

These proposed changes are enhancements to ensure timely response to a threat to the facility from external security events. These enhancements ensure timely dispatch of the Auxiliary Building operator to the EDG "B" Room and Component Cooling Water (CCW) Pump Room operator to the CCW Pump Room. The addition to dispatch a CCW Pump Room operator in modes 5 & 6 supports checking Motor Driven AFW Pump "A" in accordance with EPP-28. This step ensures an operator for CCW Pump Room contingencies is available for dispatch. Incorporating these enhancements address concerns that conditions may change preventing Operations from reaching the required location.

Main Body: Step 1, Old Step 19(Del), & Attachment 2: Old Step 19(Del):

Moved dispatch of EDG Operator to top of page Step 1 .

Added dispatch of a CCW Pump Room operator when in modes 5 & 6.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 0 ATTACHMENT 5 Page 7 of 8 10 CFR 50.54(q) Effectiveness Evaluation Form Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

The following proposed change does not reduce the effectiveness of the PLP-007, Robinson Emergency Plan.

This change is an enhancement that allows Operations to exit the attachment after notifying Security to initiate Scenario 21 of the Emergency Response Organization Notification System .. Exiting the attachment allows Operations to implement the procedure in a timely manner.

Attachment 3 Step 1: Added "and exit the attachment" once Security is notified.

The following proposed changes do not reduce the effectiveness of the Robinson Emergency Plan (PLP-007).

These changes are enhancements that consolidate and address the time allowed for restoration of RCP seal cooling being reduced to less than 15 minutes when initial seal leakoff flow is greater than 3.2 gpm as described in OP-101, Reactor Coolant System and Reactor Coolant Pump Startup and Operation, Rev. 75, Precaution and Limitation Step 5.2.1.25. Including these changes in AOP-034 eliminates the need to branch from one procedure to the other.

Attachment 7 Step 23, 23.a, 23.b, & Caution: Added steps to consolidate RCP Seal isolation requirements and decision and include new Attachment 8. Added Caution regarding reduced allowable RCP Seal Loss times for Safe Shutdown I SBO considerations.

Attachment 7 Step 27:

Included conditional for starting of 'C' Charging Pump and deleted old step 27. The necessary conditions have been established in Step 23, 23.a, & 23.b

Attachment 8: Added new attachment with table to determine maximum time RCP Seal cooling can be lost before the need to isolate.

Overall, the proposed changes to AOP-034, Security Events, Revision 27 are improvements to the RNP Emergency Preparedness Program . The proposed changes described in this revision continue to provide additional assurance that the ERO has the ability and capability to:

respond to an emergency;

perform functions in a timely manner;

effectively identify and take measures to ensure protection of the public health and safety; and.

effectively use response equipment and emergency response procedures.

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev. 0 ATTACHMENT 5 Page 8 of 8 10 CFR 50.54(q) Effectiveness Evaluation Form Part VI. Evaluation Conclusion.

Answer the following questions about the proposed change.

1 Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? YesX No D 2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no YesX No D reduction in effectiveness)?

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme? Yes X No D 4 Choose one of the following conclusions:

a The activity does continue to comply with the requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, and the activity does not constitute a reduction in effectiveness or change in the current Emergency Action Level (EAL} scheme. Therefore, the activity can be implemented without prior NRC x

approval.

b The activity does not continue to comply with the requirements of 10 CFR 50.47(b) or 10 CFR 50 Appendix E or*the activity does constitute a reduction in effectiveness or EAL scheme change.

Therefore, the activity cannot be implemented without prior NRC approval. D Part VII. Disposition of Proposed Change Requiring Prior NRC Approval Will the proposed change determined to require prior NRC approval be either revised or I Yes D I No D rejected?

If No, then initiate a License Amendment Request in accordance 10 CFR 50.90 and AD-LS-ALL-0002, Regulatory Correspondence, and include the tracking number:

Part VIII. Signatures: EP CFAM Final Approval is required for changes affecting risk significant planning standard 10 CFR 50.47(b)(4).

Preparer Name (Print): ~arer Si9natu~e:/"") ~

/1 Debbie Dowling (}.... j ) DjJ...t'..h_p )\. t_ 1111 J. Y '.

Reviewer Name (Print):

Lisa Hall Approver (EP Manager) Name (Print): \ ~ppro~ignatur~: / LP7/l_

Tony Pilo -,p Al '/ ff &.rr7 ;r v Approver (CFAM, as required) Name Approve( Signature:' /

(Print):

/..J I A If the proposed activity is a change to the E-Plan or implementing procedures, then create two EREG General Assignments.

One for EP to provide the 10 CFR 50.54(q) summary of the analysis, or the completed 10 CFR X 50.54(q), to Licensing.

One for Licensing to submit the 10 CFR 50.54(q) information to the NRC within 30 days after the X change is put in effect.

QA RECORD

Continuous Use AOP-034 SECURITY EVENTS REVISION 27

Rev. 27 AOP-034 SECURITY EVENTS Page 2 of 59 Purpose and Entry Conditions (Page 1 of 1)

1. PURPOSE The purpose of this procedure is to provide instructions to respond to a threat to the facility from external security events.

NOTE This procedure is NOT intended for a Bomb Threat. SEC-NGGC-2170, Security Event Procedures, provides actions for a Bomb Threat.

2. ENTRY CONDITIONS

a. On receipt of communication of a specific threat against RNP.

b. On notification by Security Personnel that an actual attack on the facility is in progress.

- END -

Rev. 27 AOP-034 SECURITY EVENTS Page 3 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED

1. DISPATCH Assigned Operators:

a. DISPATCH the Auxiliary Building Operator to EDG "B" Room with a Copy of AOP-034 and EPP-28

b. CHECK plant status - MODE 5 b. GO TO Step 2.

OR 6

c. DISPATCH CCW Pump Room Operator to the CCW Pump Room with a copy of EPP-28 NOTE The accelerated call made to the NRC in Step 24 should be initiated within 15 minutes of discovery of an imminent threat or attack against the station. This accelerated call will not be allowed to interfere with plant or personnel safety or physical security response.

2. Document relevant times in the table below:

Contact Time Contact Source Time of expected Attack / Impact (T-0)

Time Five Minutes prior to expected Attack / Impact (T-5)

Time 30 Minutes prior to expected Attack / Impact (T-30)

Time Five Minutes after expected Attack / Impact (T+5)

Rev. 27 AOP-034 SECURITY EVENTS Page 4 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED NOTE Threat messages received from the NRC are authenticated using the code provided daily during the NRC plant status update call. The codes are valid for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from 0800 to 0800 the following day.

3. PERFORM Action For Applicable Threat:

THREAT ACTION Attack In Progress GO TO Step 6.

Threat Message Received GO TO Step 5.

from Plant Security Threat Message Received GO To Step 5.

from NRC AND Authentication Code Confirmed All Other Threat Messages Perform Attachment 1, Credibility Evaluation, received prior to continuing.

4. CHECK Threat Status From RETURN TO procedure and Step in Attachment 1 - VERIFIED effect.

CREDIBLE

Rev. 27 AOP-034 SECURITY EVENTS Page 5 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED

5. NOTIFY Plant Personnel Of Impending Attack

a. PLACE VLC Switch in EMERG position

b. ANNOUNCE available information:

Nature of Attack Expected time of Attack

c. REPEAT Announcement

d. PLACE VLC Switch in NORM position

6. CHECK Threat - AIRCRAFT Go to step 7.

ATTACK GO TO Attachment 2, Aircraft Attack

Rev. 27 AOP-034 SECURITY EVENTS Page 6 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED NOTE Action sequences may repeat while awaiting the next decision point.

Actions should be verified to be complete or in progress during subsequent passes.

PA Announcements may be repeated or withheld as directed by SM /CRS

7. PERFORM ACTION For The Conditions Indicated:

Condition / Time relative to expected Attack ACTION Attack In Progress or Less than Five minutes prior GO TO Step 17 to expected Attack (T-5)

Less than 30 minutes prior to expected Attack GO TO Step 15 (T-30)

Greater than 30 minutes prior to expected Attack GO TO Step 8 (T-30)

Threat has been Nullified NOTIFY NRC within five minutes AFTER expected Attack time (T+5) and Attack has NOT occurred Return to Procedure and Step in effect

8. CONTACT Plant General Manager CONTACT Station Duty Manager.

To Discuss The Event And Determine The Need For Plant Shutdown / Site Evacuation

a. CHECK Plant Shutdown - a. GO TO Step 9.

DIRECTED

b. TRIP the Reactor AND GO TO EOP-E-0, Reactor Trip Or Safety Injection while CONTINUING WITH this procedure

Rev. 27 AOP-034 SECURITY EVENTS Page 7 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED

9. NOTIFY The Fire Brigade Incident Commander Of The Nature Of The Threat

10. INITIATE Call Out For Selected Support Personnel Using Attachment 3, ERO Notification for Security Events

11. IMPLEMENT EALs

12. CHECK Availability And Expedite Return To Service Of Any Of The Following Equipment:

Emergency Diesel Generators Safeguards Systems DSDG

13. FILL The Following Tanks To Maximum Capacity Allowed By Procedure CST PWST

14. CHECK Preemptive Evacuation - GO TO Step 30.

DESIRED

Rev. 27 AOP-034 SECURITY EVENTS Page 8 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED NOTE When moving personnel about the plant to respond to events, such as requesting the Emergency Communicator to the Control Room, consideration should be given to the type of threat, possible routes, and whether a Security escort is necessary.

15. PERFORM Site Evacuation AND DIRECT ERO Personnel to Remote Facilities

a. PLACE VLC Switch in EMERG Position

b. PLACE AND HOLD Evacuation Alarm Switch to SITE Position for 5 Seconds

c. PERFORM the following PA Announcement:

"Security Announcement: Plant Attack Expected."

"ALL Non-Essential Personnel EVACUATE the Site" "ALL ERO Personnel not performing plant actions GO TO the Remote Emergency Response Facility"

d. PLACE AND HOLD Evacuation Alarm Switch to SITE Position for 5 Seconds

e. REPEAT Announcement

f. PLACE VLC Switch in NORM Position

16. CHECK Time To Anticipated GO TO Step 30.

Attack- LESS THAN 30 MINUTES

Rev. 27 AOP-034 SECURITY EVENTS Page 9 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED

17. CHECK Trip Breakers - CLOSED GO TO step 18.

a. TRIP the Reactor AND GO TO EOP-E-0, Reactor Trip Or Safety Injection while CONTINUING WITH this procedure

b. CHECK SDAFW Pump - b. ATTEMPT to start the SDAFW RUNNING Pump from the RTGB.

18. ACTUATE CONTROL ROOM DOOR DISABLE Pushbutton

19. CHECK Control Room Ventilation ALIGN ventilation:

System - ALIGNED FOR EMERGENCY RECIRCULATION a. START CONT RM AIR CLEANING, HVE-19A OR HVE-19B.

b. PLACE CONT RM AIR EXHAUST, HVE-16 switch to STOP.

c. CHECK the following dampers CLOSED:

CR-D1A-SA, CR EXH DMPR CR-D1B-SB, CR EXH DMPR

d. CLOSE the following dampers:

OUTSIDE AIR DAMPER "A" OUTSIDE AIR DAMPER "B"

20. INITIATE Call Out For Selected Support Personnel Using Attachment 3, ERO Notification for Security Events

21. IMPLEMENT EALs

22. CHECK Attack Status - IN GO TO Step 29.

PROGRESS Or IMMINENT (Less Than 5 minutes)

Rev. 27 AOP-034 SECURITY EVENTS Page 10 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED

23. PERFORM PA Announcement:

a. PLACE VLC Switch in EMERG Position

b. PERFORM the Following Announcement:

"ALL Personnel Seek Shelter DO NOT Move about the Plant"

c. REPEAT PA Announcement

d. PLACE VLC Swich in NORM Position NOTE This accelerated call shall not be allowed to interfere with plant or personnel safety or physical security response.

24. NOTIFY NRC Via NRC ENS Phone:

"This is Robinson Nuclear Plant" "A Land / Water Attack is Imminent / In Progress / Repelled" "The event has been classified as ________" (Only if EP Classification has been performed)

25. CHECK Emergency Busses - START And LOAD the EDGs using ENERGIZED BY EDGs Attachment 6, Start and Loading of the EDGs while CONTINUING WITH this procedure.

Rev. 27 AOP-034 SECURITY EVENTS Page 11 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED

26. CHECK Emergency Busses - IF Power is lost to the Emergency REMAINED ENERGIZED BY EDGs Busses after alignment to the EDGs, THEN ATTEMPT to restore power to Emergency Busses using Attachment 7, Energizing the Emergency Busses from an Offsite Source.

27. DETERMINE EPP-28 Applicability:

a. CHECK either event - IN a. IF either a Loss of all SW or PROGRESS Dam Integrity occurs, THEN PERFORM EPP-28, Loss Of Total loss of SW Ultimate Heat Sink, while continuing with this procedure.

OR Go To Step 28.

Loss of Lake Robinson Dam Integrity

b. PERFORM EPP-28, Loss Of Ultimate Heat Sink, while continuing with this procedure

28. CONTACT Security To Check Status Of Law Enforcement Personnel Called In

29. CHECK RCS Temperature - GO TO Step 30.

GREATER THAN 350°F

a. INITIATE Cooldown using Attachment 5, RCS Cooldown while continuing.

30. CHECK Original Threat ESTABLISH continuous Notification Source - WAS NRC communication with the NRC HQ Operations Center at the earliest practical time.

31. CHECK Fuel Movement - STOP Fuel Movement.

STOPPED

32. CHECK CV Closure - WHEN conditions allow, THEN ESTABLISHED IMPLEMENT CV Closure.

33. MAINTAIN Contact With Security For Updates On The Threat

Rev. 27 AOP-034 SECURITY EVENTS Page 12 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED NOTE Consideration should be given to the location and type of threat when attempting to contact personnel so their safety is not compromised.

34. CONTACT Shift Personnel For Accountability And Sharing Of Pertinent Information Regarding The Threat

35. CONSIDER The Following For Non-Vital Area Actions:

NOT performing EOP/AOP Actions in non-vital areas Limiting personnel actions to areas within the vital areas Where access to non-vital areas is required, contact Security to determine if an armed escort is available and to provide expected movement of the operator

36. CONSIDER The Need To Pre-Stage Off-Site Assistance At A Location Nearby Ambulance Fire Trucks

37. CHECK TS For Applicable Action Statements

38. RETURN TO Step 7

- END -

Rev. 27 AOP-034 SECURITY EVENTS Page 13 of 59 Attachment 1 Credibility Evaluation (Page 1 of 1)

NOTE IF at any time during performance of this attachment verification of the threat is received from the NRC with the proper Authentication Code OR Plant Security, THEN the threat is considered credible.

1. IF the caller is from a Federal or State Agency other than the NRC OR the NRC Authentication Code was NOT valid, THEN PERFORM the following:

a. OBTAIN the following information from the caller:

Name Position/Title Estimated time event will occur

b. CONTACT the NRC via NRC ENS phone AND request assistance for verification of threat credibility.

2. MAINTAIN continuous communication with multiple aircraft threat notification agencies until the NRC acknowledges that the NRC will provide threat information to RNP.

3. IF the caller is NOT from a Federal OR State Agency, THEN ATTEMPT to ascertain the following information via questioning the caller:

Is the caller rational OR sober?

Ask the caller when the event will occur.

Does the caller know the specifics concerning the plant?

Ask the caller why they are making the call.

As a final question, ask the caller his/her name.

4. IF the call is received directly in the Control Room, THEN NOTIFY Security that a threat call has been received.

5. If time permits, THEN CONTACT the Plant General Manager or On-Call Manager for consultation.

6. WHEN a determination for credibility is made, THEN RETURN to the Main Body, Step in effect.

- END -

Rev. 27 AOP-034 SECURITY EVENTS Page 14 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 2 Aircraft Attack (Page 1 of 13)

NOTE EDMG-000, Extreme Damage Initial Actions, provide guidance for the SEC to assess results and ensure initial response for an extreme damage initiating event following relocation of designated shift personnel due to an aircraft attack.

1. ESTABLISH And MAINTAIN Communications:

a. CHECK original threat source - a. ESTABLISH continuous NRC communication with the NRC HQ Operations Center at the earliest practical time.

b. CHECK NRC Acknowledges b. MAINTAIN continuous NRC will provide threat communication with original information to RNP threat notification source until NRC Acknowledges it will provide threat information.

Rev. 27 AOP-034 SECURITY EVENTS Page 15 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 2 Aircraft Attack (Page 2 of 13)

NOTE Action sequences may repeat while awaiting the next decision point.

Actions should be verified to be complete or in progress during subsequent passes.

PA Announcements may be repeated or withheld as directed by SM /CRS.

2. PERFORM ACTION for conditions indicated:

Condition / Time relative to expected Impact ACTION Less than Five minutes prior to expected Attack GO TO Step 18 (T-5)

Less than 30 minutes prior to expected Impact GO TO Step 17 (T-30)

Greater than 30 minutes prior to expected Impact GO TO Step 3 (T-30)

Impact has Occurred GO To Step 18 Threat has been Nullified Notify NRC within five minutes AFTER expected Attack time (T+5) and Attack has NOT occurred Return to Procedure and Step in effect Updated Estimated Time of Impact Obtained Make PA Announcement using VLC to Notify Plant Personnel of Updated Impact Time GO TO Step 1

Rev. 27 AOP-034 SECURITY EVENTS Page 16 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 2 Aircraft Attack (Page 3 of 13)

3. PERFORM Site Evacuation AND DIRECT ERO Personnel to Remote ERFs

a. PLACE VLC Switch in EMERG Position

b. PLACE And HOLD Evacuation Alarm Switch to SITE Position for 5 Seconds

c. PERFORM PA Announcement:

"Security Announcement: Aircraft Attack Expected at time _____."

"ALL Non-Essential Personnel EVACUATE the Site" "ALL ERO Personnel not performing plant actions GO TO the Remote Emergency Response Facility"

d. PLACE And HOLD Evacuation Alarm Switch to SITE Position for 5 Seconds

e. REPEAT Announcement

f. PLACE VLC Switch in NORM Position

4. CHECK Notification Status - NOTIFY Security of the status of the SECURITY AWARE OF THREAT threat.

Rev. 27 AOP-034 SECURITY EVENTS Page 17 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 2 Aircraft Attack (Page 4 of 13)

NOTE When activating facilities during normal working hours and outages with large number of personnel on-site, the local facility should be activated when less than 30 minutes is available prior to the arrival of the aircraft, and the remote emergency response facility if 30 minutes or greater is available. During off normal hours when few personnel are on-site, the remote emergency response facility should be activated.

5. NOTIFY Security To Open PA Gates For Evacuation While Continuing To Defend Site.

6. INITIATE Call Out For Selected Support Personnel Using Attachment 3, ERO Notification for Security Events

7. IMPLEMENT EALs

Rev. 27 AOP-034 SECURITY EVENTS Page 18 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 2 Aircraft Attack (Page 5 of 13)

8. CHECK Control Room Ventilation ALIGN Ventilation:

System - ALIGNED FOR EMERGENCY RECIRCULATION a. START CONT RM AIR CLEANING, HVE-19A OR HVE-19B.

b. PLACE CONT RM AIR EXHAUST, HVE-16 switch to STOP.

c. CHECK the following dampers Closed:

CR-D1A-SA, CR EXH DMPR CR-D1B-SB, CR EXH DMPR

d. CLOSE the following dampers:

OUTSIDE AIR DAMPER "A" OUTSIDE AIR DAMPER "B"

9. CHECK Status Of Aircraft Profile - GO TO Step 10.

HAS BEEN DETERMINED THAT ATTACK ON RNP IS INTENDED

a. TRIP the Reactor and GO TO EOP-E-0, Reactor Trip Or Safety Injection while CONTINUING WITH this procedure

b. CHECK SDAFW Pump - b. ATTEMPT to start the SDAFW RUNNING Pump from the RTGB.

Rev. 27 AOP-034 SECURITY EVENTS Page 19 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 2 Aircraft Attack (Page 6 of 13)

10. DETERMINE Need For Outage Actions:

a. CHECK Outage - IN a. GO TO Step 11.

PROGRESS

b. STOP refueling activities

c. CHECK personnel in the CV and SFP - EVACUATING

d. CHECK available time - WILL d. GO TO Step 10.f.

ALLOW ESTABLISHING CV CLOSURE

e. IMPLEMENT CV Closure

f. FILL RCS to maximum allowable value for current configuration

11. STOP Maintenance:

a. STOP all testing in progress

b. CHECK systems needed for safe b. CONTACT Maintenance to shutdown - AVAILABLE restore all systems needed for safe shutdown to service that have been removed for routine maintenance that can be readily restored.

12. FILL Makeup Tanks:

a. CHECK Plant Status - MODE 5, a. GO TO Step 12.c.

Loops Filled, OR MODE 1-4

b. FILL the CST to the maximum capacity allowed by procedure

c. FILL the PWST to the maximum capacity allowed by procedure

Rev. 27 AOP-034 SECURITY EVENTS Page 20 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 2 Aircraft Attack (Page 7 of 13)

13. CHECK Status Of SFP Systems:

a. CHECK SFP Purification - IN a. GO TO Step 13.c.

SERVICE

b. REMOVE SFP Purification from service using OP-910, Spent Fuel Pit Cooling and Purification System

c. REDUCE SFP temperature to the minimum allowable

d. RAISE SFP level to the maximum allowable

14. CONSIDER Need To Pre-Stage Off-Site Assistance At A Location Nearby Ambulance Fire Trucks

15. MONITOR Activities Associated With The Incoming Aircraft And Continue Preparation Activities

16. RETURN TO Step 1

17. DETERMINE Need For Outage Actions:

a. CHECK Outage - IN a. GO TO Step 18.

PROGRESS

b. STOP refueling activities

c. CHECK personnel in CV and SFP - EVACUATING

d. FILL RCS to maximum allowable for current configuration

Rev. 27 AOP-034 SECURITY EVENTS Page 21 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 2 Aircraft Attack (Page 8 of 13)

18. CHECK Trip Breakers - CLOSED GO TO step 19.

a. TRIP the Reactor and GO TO EOP-E-0, Reactor Trip Or Safety Injection while continuing with this procedure

b. CHECK The SDAFW Pump - b. ATTEMPT to start the SDAFW RUNNING Pump from the RTGB.

Rev. 27 AOP-034 SECURITY EVENTS Page 22 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 2 Aircraft Attack (Page 9 of 13)

NOTE The assigned location for the CRS, RO and BOP is the Control Room.

The assigned location for the SM, STA and CR-EC is the B.5.b area located in the South-West corner of the Admin Bldg.

The assigned location for the Operations personnel outside the Control Room and the Shift RC & EC Techs is the PAP West Building Final Access Control area. The WCC SRO will need to bring the following documentation: EPCLA-01, EPNOT-01, AOP-034, AOP-041, EDMGs.

Weather or hostile action could impede the relocation or evacuation of personnel

19. NOTIFY PLANT PERSONNEL:

a. CHECK conditions that would a. PERFORM applicable impede relocation / evacuation - announcements based on NONE current conditions.

b. PLACE VLC Switch in EMERG position

c. PERFORM PA announcement:

"Security Announcement: Aircraft Impact Expected at time _______"

"Designated shift personnel report to your assigned location" "ALL Emergency Response Personnel assemble in the EOF/TSC" "ALL remaining site personnel assemble in the interior of the Lower Level Admin. Building"

d. PLACE and HOLD Evacuation Alarm Switch to SITE for 5 seconds

e. REPEAT PA Announcement

f. PLACE and HOLD Evacuation Alarm switch to SITE for 5 seconds

g. PLACE VLC switch in NORM position

Rev. 27 AOP-034 SECURITY EVENTS Page 23 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 2 Aircraft Attack (Page 10 of 13)

20. CHECK Control Room Ventilation ALIGN Ventilation:

System - ALIGNED FOR EMERGENCY RECIRCULATION a. START CONT RM AIR CLEANING, HVE-19A or HVE-19B.

b. PLACE CONT RM AIR EXHAUST, HVE-16 switch to STOP.

c. CHECK the following dampers Closed:

CR-D1A-SA, CR EXH DMPR CR-D1B-SB, CR EXH DMPR

d. CLOSE the following dampers:

OUTSIDE AIR DAMPER "A" OUTSIDE AIR DAMPER "B"

21. CHECK Notification Status - NOTIFY Security of the status of the SECURITY AWARE OF THREAT threat.

22. INITIATE Call Out For Selected Support Personnel Using Attachment 3, ERO Notification for Security Events

23. IMPLEMENT EALs

Rev. 27 AOP-034 SECURITY EVENTS Page 24 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 2 Aircraft Attack (Page 11 of 13)

24. CHECK Time Of Threat - DURING At Unit 2 Lighting Control Panel DAYLIGHT HOURS TURN the following lights OFF:

Turbine Deck and Transformer Yard Unit 2 Switchyard CONTACT Security to EXTINGUISH High Mast Lighting using Attachment 4, Exterior Lighting Reduction.

IF Security is unable to extinguish the High Mast Lighting, THEN CONTACT WCC to BRIEF available operations personnel regarding the purpose and life safety considerations and DISPATCH to perform Attachment 4, Exterior Lighting Reduction.

25. CHECK Status Of Aircraft Impact RETURN TO Step 1.

- EXPECTED IN LESS THAN 5 MINUTES

26. CHECK Emergency Busses - START and LOAD the EDGs using ENERGIZED BY EDGs Attachment 6, Start and Loading of the EDGs while continuing with this procedure.

27. STOP Auxiliary Building Ventilation:

a. PLACE the selector switch for the in service REACTOR AUX BLDG EXH FAN in STOP:

HVE-2A HVE-2B

28. ACTUATE CONTROL ROOM DOOR DISABLE Pushbutton

Rev. 27 AOP-034 SECURITY EVENTS Page 25 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 2 Aircraft Attack (Page 12 of 13)

29. DETERMINE Need For Refueling Actions:

a. CHECK Refueling - IN a. GO TO Step 30.

PROGRESS

b. STOP refueling activities

c. CHECK Personnel In CV AND SFP - EVACUATING

30. CHECK Status Of Aircraft - HAS RETURN TO Step 1.

IMPACTED

31. CHECK Continuous ESTABLISH continuous Communication With NRC HQ communication with the NRC HQ Operations Center - MAINTAINED Operations Center at the earliest practical time.

32. RESPOND To Crash Using AOP-041, Response To Fire Event

33. CHECK Emergency Busses - IF power is lost to the Emergency REMAINED ENERGIZED BY EDGs Busses after alignment to the EDGs, THEN ATTEMPT to restore power to Emergency Busses using Attachment 7, Energizing the Emergency Busses from an Offsite Source.

34. NOTIFY HP To Initiate Local Monitoring Of Auxiliary Building Due To Securing Of Building Ventilation

Rev. 27 AOP-034 SECURITY EVENTS Page 26 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 2 Aircraft Attack (Page 13 of 13)

35. DETERMINE EPP-28 Applicability:

a. CHECK either of the below a. RETURN to procedure and step events - IN PROGRESS in effect.

Total loss of SW OR Loss of Lake Robinson Dam Integrity

b. GO TO EPP-28, Loss Of Ultimate Heat Sink

- END -

Rev. 27 AOP-034 SECURITY EVENTS Page 27 of 59 Attachment 3 ERO Notification for Security Events (Page 1 of 3)

1. IF The Threat Is An Aircraft Attack AND Greater Than Or Equal To 5 Minutes From Impact, THEN NOTIFY Security To Initiate Scenario 21 AND EXIT This Attachment.

2. IF a LAN Computer Will Be Used To Notify The ERO, THEN GO TO Step 4.

3. IF EverBridge Interactive Voice Response Will Be Used To Notify The ERO, THEN GO TO Step 16.

4. LOG Onto The Emergency Response Organization Notification System On An NGG computer:

For Windows 7 Desktop: SELECT Start > All Programs > DAE > Shortcuts Tab

> Search EverBridge > Select EverBridge and Run Application OR OPEN an internet browser and type www.everbridge.net.

5. TYPE RNPactivation (not case sensitive) In The Member ID field Of The Initial Login Screen.

NOTE Passwords are provided in pre-designated locations.

6. ENTER The Password From The Password Card.

7. SELECT GO or PRESS Enter On The Keyboard.

8. SELECT "Scenario Manager" From Left Side Of The Screen.

9. SELECT "Send Scenario" Under "Scenario Manager".

Rev. 27 AOP-034 SECURITY EVENTS Page 28 of 59 Attachment 3 ERO Notification for Security Events (Page 2 of 3)

NOTE Scenario NO. 21, FIRE BRIGADE - REPORT TO STATION 8 will assemble Fire Brigade and Operations personnel at Fire Station #8 (Pine Ridge).

10. USE The Previous And Next Cursors To Scroll Through The Scenario List To LOCATE AND CONFIRM Scenario NO. 21 And FIRE BRIGADE - REPORT TO STATION 8 On The Send Scenarios Screen.

11. CLICK FIRE BRIGADE - REPORT TO STATION 8 in EverBridge once you have located and confirmed that the Scenario Number and Scenario Title are correct.

NOTE A satellite dish animation will appear on the screen to indicate transmission of the message.

12. SELECT Send Message At Bottom Of The List Unscheduled Messages Screen.

13. CLICK On Broadcast ID To CHECK Broadcast Results. Responses Will Be Displayed. Screen Will Refresh Approximately Every 60 Seconds.

14. NOTIFY The CR-SEC/SM that Call Out For Selected Support Personnel In Accordance With Attachment 3, ERO Notification For Security Events, Is Complete.

15. RETURN TO Procedure And Step In Effect

16. DIAL EverBridge At 888-440-4911

Rev. 27 AOP-034 SECURITY EVENTS Page 29 of 59 Attachment 3 ERO Notification for Security Events (Page 3 of 3)

17. LISTEN To The IVR Command AND FOLLOW The Instructions:

a. ENTER the Member ID followed by the # sign.

ENTER 132508341 #

b. ENTER site specific password. See Password Card for site password.

NOTE Upon completion of the following steps, activation of the ERO will occur.

18. To Launch A Broadcast Scenario, PRESS The Number 3.

19. To Select A Scenario By Number, PRESS The Number 1.

NOTE Scenario NO. 21, FIRE BRIGADE - REPORT TO STATION 8 will assemble Fire Brigade and Operations personnel at Fire Station #8 (Pine Ridge).

20. ENTER Scenario Number 21, Followed By The # Sign.

21. Voice Will State Title Of The Scenario. CHECK That This Is The Correct Entry.

22. To Select This Scenario, PRESS the # Key A Second Time.

23. To Launch This Scenario Now, PRESS The Number 1.

24. END The Call.

25. NOTIFY The CR-SEC/SM That Call Out For Selected Support Personnel In Accordance With Attachment 3, ERO Notification for Security Events, Is Complete.

- END -

Rev. 27 AOP-034 SECURITY EVENTS Page 30 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 4 Exterior Lighting Reduction (Page 1 of 1)

CAUTION Performance of this Attachment shall NOT prevent personnel from sheltering at least 10 minutes prior to anticipated impact.

NOTE Turning off exterior lighting may make the plant structures more difficult to see and target from the air at night. The control locations for exterior lighting are listed in order of greatest effect, however they all may not be accessible given the time frame and security situation.

Actions may be performed in any sequence or simultaneously as resources permit.

1. TURN OFF High Mast Lights By Taking The Switch On The Associated Panel To OFF:

Central Alarm Station, Building 466 inside SD-09 (Main PA Lighting):

Panel LC-E1 Panel LC-E2 ISFSI Storage Building Electrical Room (ISFSI Lighting):

Panel LC1 PAP West, west wall inside Door #21(Intake Lighting)

(Security Key may be required):

Panel TB-C

- END -

Rev. 27 AOP-034 SECURITY EVENTS Page 31 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 5 RCS Cooldown (Page 1 of 11)

NOTE Cooldown actions in this Attachment may conflict with EOP-ES-0.1 actions for plant stabilization. For a Security Event, the actions to cooldown and depressurize the plant are necessary to enhance Reactor Core Safety.

1. BORATE RCS To Cold Shutdown Boron Concentration While Continuing With This Procedure:

a. ALIGN Charging Pump a. BORATE the RCS using ONE of suction to the RWST the choices below:

MOV-350 OR Normal boration using OP-301, Chemical And Volume Control System (CVCS)

2. CHECK CRDM Cooling Fans - START available CRDM Cooling RUNNING Fans.

HVH-5A HVH-5B

Rev. 27 AOP-034 SECURITY EVENTS Page 32 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 5 RCS Cooldown (Page 2 of 11)

CAUTION Excessive steam dump using the steam line PORVs may initiate a high steam line P SI.

NOTE Cooldown will only be performed to the point where RHR would normally be placed in service, however, RHR will NOT be placed in service.

3. INITIATE RCS Cooldown To Mode 4:

a. CHECK RCPs - ALL STOPPED a. MAINTAIN cooldown rate in RCS cold legs less than 100°F/hr.

GO TO Step 3.d.

b. CHECK Status of CRDM Cooling b. MAINTAIN cooldown rate in Fans, HVH-5A AND HVH-5B - RCS cold legs less than 10°F/hr BOTH RUNNING AND subcooling greater than 100°F.

GO TO Step 3.d.

c. MAINTAIN cooldown rate in RCS cold legs less than 25°F/hr

d. MAINTAIN RCS temperature and pressure - WITHIN LIMITS OF CURVE 3.4, REACTOR COOLANT SYSTEM PRESSURE - TEMPERATURE LIMITATIONS FOR COOLDOWN

e. CHECK steam dump to e. DUMP steam using STEAM Condenser LINE PORVs.

- AVAILABLE GO TO Step 3.g.

f. DUMP steam to Condenser

g. CONTROL feed flow to maintain S/G levels - BETWEEN 39% and 50%

Rev. 27 AOP-034 SECURITY EVENTS Page 33 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 5 RCS Cooldown (Page 3 of 11)

4. CHECK RCS Temperature - WHEN RCS temperature LESS THAN 543°F is less than 543°F, THEN GO TO Step 5.

5. RESTORE Steam Dumps:

a. CHECK steam dump to a. CONTINUE RCS Cooldown Condenser using STEAM LINE PORVs.

- AVAILABLE OBSERVE the Note prior to Step 6 and GO TO Step 6.

b. Momentarily PLACE STEAM DUMP CONTROL Switch to BYPASS T-AVG INTLK position

c. CHECK APP-006-F5, STEAM DUMP ARMED - ILLUMINATED

d. CONTINUE RCS cooldown using Steam Dump to Condenser NOTE Low Tavg SI initiation circuits will automatically unblock if Tavg increases to greater than 543°F.

6. DEFEAT Low Tavg Safety Injection Signal:

a. Momentarily PLACE SAFETY INJECTION T-AVG Selector Switch to BLOCK position

b. CHECK LO TEMP SAFETY INJECTION BLOCKED status light - ILLUMINATED

Rev. 27 AOP-034 SECURITY EVENTS Page 34 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 5 RCS Cooldown (Page 4 of 11)

NOTE Supplement K is available for optimizing Auxiliary Spray below.

7. DEPRESSURIZE RCS To 1950 PSIG:

a. USE normal PZR Spray to a. DEPRESSURIZE the RCS as depressurize RCS follows:

1) IF Letdown is in service, THEN PERFORM the following:

a) USE CVC-311, AUX PZR SPRAY VALVE, to depressurize the RCS to less than 1950 psig.

2) IF Letdown is isolated, THEN USE one PZR PORV to depressurize the RCS to less than 1950 psig.

GO TO Step 7.b.

b. CHECK RCS pressure - LESS b. WHEN RCS pressure less than THAN 1950 PSIG 1950 psig, THEN GO TO Step 7.c.

c. STOP RCS depressurization

Rev. 27 AOP-034 SECURITY EVENTS Page 35 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 5 RCS Cooldown (Page 5 of 11)

NOTE Low Pressure SI initiation circuits will automatically unblock if PZR pressure increases to greater than 2000 psig.

8. DEFEAT Low Pressure Safety Injection Signal:

a. Momentarily PLACE PZR PRESS/HI STM LINE DP Switch to BLOCK position

b. CHECK LO PRESS SAFETY INJECTION BLOCKED Status Light - ILLUMINATED

9. MONITOR RCS Cooldown: RAISE steaming rate from intact S/Gs.

CHECK Core exit T/Cs -

LOWERING CHECK RCS hot leg temperatures - LOWERING CHECK RCS subcooling RISING

Rev. 27 AOP-034 SECURITY EVENTS Page 36 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 5 RCS Cooldown (Page 6 of 11)

10. CONTINUE RCS Cooldown And Depressurization:

a. MAINTAIN cooldown rate in RCS cold legs AND Subcooling at previously determined values

b. MAINTAIN RCS temperature and pressure - WITHIN LIMITS OF CURVE 3.4, REACTOR COOLANT SYSTEM PRESSURE - TEMPERATURE LIMITATIONS FOR COOLDOWN

c. CONTROL feed flow to maintain S/G levels - BETWEEN 39% AND 50%

11. CHECK For Steam Void GO TO Step 13.

In Reactor Vessel:

CHECK PZR level - LARGE UNEXPECTED VARIATIONS OR CHECK RVLIS upper range indication - LESS THAN 100%

12. ATTEMPT To Collapse Voids:

a. CHECK PZR HTRs - a. GO TO Step 13.

AVAILABLE

b. REPRESSURIZE RCS within limits of Curve 3.4, Reactor Coolant System Pressure -

Temperature Limitations For Cooldown

Rev. 27 AOP-034 SECURITY EVENTS Page 37 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 5 RCS Cooldown (Page 7 of 11)

13. CHECK RCS Pressure - LESS WHEN RCS pressure is less than THAN 1000 psig, THEN PERFORM 1000 PSIG Steps 14 through 19.

GO TO Step 20.

14. PLACE Key Switches For Following Valves In The NORMAL Position SI-862A SI-862B SI-863A SI-863B SI-864A SI-864B SI-866A SI-866B SI-869

15. CHECK MCC ENERGIZED GO TO Step 17.

Rev. 27 AOP-034 SECURITY EVENTS Page 38 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 5 RCS Cooldown (Page 8 of 11)

NOTE When moving personnel about the plant to respond to events, consideration should be given to the type of threat, possible routes, and whether a Security escort is necessary.

16. Locally CLOSE Breakers For The Following Valves:

SI-878A. SI PUMPS A&B DISCHARGE CROSS CONNECT (MCC-5, CMPT 2C)

SI-865C, ACCUMULATOR C DISCHARGE (MCC-5, CMPT 9F)

SI-865A, ACCUMULATOR A DISCHARGE (MCC-5, CMPT 14F)

17. CHECK MCC ENERGIZED GO TO Step 19.

Rev. 27 AOP-034 SECURITY EVENTS Page 39 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 5 RCS Cooldown (Page 9 of 11)

NOTE When moving personnel about the plant to respond to events, consideration should be given to the type of threat, possible routes, and whether a Security escort is necessary.

18. Locally CLOSE Breakers For The Following Valves:

SI-865B, ACCUMULATOR B DISCHARGE (MCC-6, CMPT 1OJ)

SI-878B. SI PUMPS B&C (MCC-6, CMPT 15C)

DISCHARGE CROSS CONNECT

19. From The RTGB, CHECK All VENT any unisolated accumulator:

ACCUM DISCHS - CLOSED

a. ENSURE SI-855, ACC SI-865A NITROGEN ISO, is closed.

SI-865B

b. OPEN the appropriate ACCUM SI-865C VENT Valves:

SI-853A SI-853B SI-853C

c. OPEN HIC-936, ACC VENT HDR FLOW.

20. CHECK RCS Temperature - LESS RETURN TO Step 10.

THAN 360°F.

Rev. 27 AOP-034 SECURITY EVENTS Page 40 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 5 RCS Cooldown (Page 10 of 11)

21. STABILIZE RCS Temperature:

a. STOP RCS cooldown

b. MAINTAIN RCS cold leg temperature - LESS THAN OR EQUAL TO 360°F.

NOTE Supplement K is available for optimizing Auxiliary Spray below.

22. DEPRESSURIZE RCS To 375 PSIG:

a. USE normal PZR Spray to a. DEPRESSURIZE the RCS:

depressurize the RCS

1) IF Letdown is in service, THEN PERFORM the following:

a) USE CVC-311, AUX PZR SPRAY VALVE, to depressurize the RCS to less than 375 psig.

2) IF Letdown is isolated, THEN USE one PZR PORV to depressurize the RCS to less than 375 psig.

GO TO Step 22.b.

b. CHECK RCS pressure - LESS b. WHEN RCS pressure less than THAN 375 PSIG 375 psig, THEN GO TO Step 22.c.

c. STOP RCS depressurization

Rev. 27 AOP-034 SECURITY EVENTS Page 41 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 5 RCS Cooldown (Page 11 of 11)

23. PLACE LTOPP In Service:

a. CHECK RCS temperature - a. RETURN TO Step 11.

LESS THAN 360°F

b. CHECK RCS pressure - LESS b. RETURN TO Step 11.

THAN 375 PSIG

c. PLACE PZR PORV switches to AUTO:

PCV-455C PCV-456

d. PLACE PZR PORV key operated switches to LOW PRESSURE:

PCV-455C PCV-456

24. MAINTAIN Current Plant Conditions RCS Temperature 350°F to 360°F RCS Pressure 325 PSIG to 375 PSIG

25. CONTACT Plant Staff For Additional Guidance For Cooldown.

- END -

Rev. 27 AOP-034 SECURITY EVENTS Page 42 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 6 Start and Loading of the EDGs (Page 1 of 4)

NOTE EDG "B" Is started first due to EPP-28 guidance for using EDG "B" as the first choice for "D" Deepwell Cooling.

1. START EDG "B":

a. At EDG "B" Engine Control Panel, Quickly PLACE the Local/Remote Switch in LOCAL

b. CHECK White Local Light is ILLUMINATED

c. DEPRESS START pushbutton

Rev. 27 AOP-034 SECURITY EVENTS Page 43 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 6 Start and Loading of the EDGs (Page 2 of 4)

2. LOAD EDG "B":

a. CHECK EDG "B" - RUNNING a. GO TO Step 3.

b. ADJUST EDG "B" Speed Control Lever to Indicate Generator Frequency of 60 Hertz

c. ADJUST EDG "B" voltage using Automatic Voltage Control Knob to 480V on GENERATOR voltmeter

d. NOTIFY Control Room to perform the following:

1) OPEN 480V BUS E2 MAIN BKR, 52/28B

2) CHECK CLOSED EMERG DG B TO BUS E2 BKR 52/27B

e. ADJUST EDG "B" Speed Control Lever to indicate generator frequency of 60 Hertz

f. ADJUST EDG "B" voltage using Automatic Voltage Control Knob to 480V on GENERATOR voltmeter

Rev. 27 AOP-034 SECURITY EVENTS Page 44 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 6 Start and Loading of the EDGs (Page 3 of 4)

3. START EDG "A":

a. CHECK EDG "A" - SHUTDOWN a. GO TO Step 4.

b. CHECK EPP IN b. GO TO Step 3.f.

PROGRESS

c. CHECK EDG "B" - RUNNING c. GO TO Step 3.f.

d. NOTIFY Control Room that EDG "A" will NOT be started, Attachment 6 is complete

e. EXIT This Attachment

f. At EDG "A" Engine Control Panel, Quickly PLACE the Local/Remote Switch in LOCAL

g. CHECK White Local Light is illuminated

h. DEPRESS START pushbutton

Rev. 27 AOP-034 SECURITY EVENTS Page 45 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 6 Start and Loading of the EDGs (Page 4 of 4)

4. LOAD EDG "A":

a. CHECK EDG "A" - RUNNING

b. CHECK EPP IN b. GO TO Step 4.f.

PROGRESS

c. CHECK EDG "B" - RUNNING c. GO TO Step 4.f.

LOADED

d. NOTIFY the Control Room that EDG "A" will NOT be loaded, Attachment 6 is complete

e. EXIT this Attachment

f. ADJUST EDG "A" Speed Control Lever to indicate generator frequency of 60 Hertz

g. ADJUST EDG "A" voltage using Automatic Voltage Control Knob to 480V on GENERATOR voltmeter

h. NOTIFY the Control Room to perform the following:

1) OPEN 480V BUS E1 MAIN BKR, 52/18B

2) CHECK CLOSED EMERG DG A TO BUS E1 BKR 52/17B

i. ADJUST EDG "A" Speed Control Lever to indicate generator frequency of 60 Hertz

j. ADJUST EDG "A" voltage using Automatic Voltage Control Knob to 480V on GENERATOR voltmeter

- END -

Rev. 27 AOP-034 SECURITY EVENTS Page 46 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 7 Energizing the Emergency Busses from an Offsite Source (Page 1 of 10)

NOTE Attachment 7 is entered when the Emergency Busses that were energized from the EDGs become de-energized.

Attachment 7 will restore power to the Emergency Busses when EOP-ECA-0.0, Loss Of All AC Power actions can not be performed or are unsuccessful in energizing an Emergency Bus due to the Security Event in progress.

1. CHECK Emergency Bus - GO TO Step 3.

DEENERGIZED FROM STOPPING AN EDG IN EPP-28

2. RETURN TO Main Body /

Attachment 2 Step In Effect

3. CHECK Status Of Offsite Power - GO TO Step 7.

REMAINED AVAILABLE

4. CLOSE 480V BUS E1 MAIN BKR 52/18B To Energize E1

5. CLOSE 480V BUS E2 MAIN BKR 52/28B To Energize E2

6. OBSERVE Caution Prior to Step 23 And GO TO Step 23

7. CHECK Offsite Power - RETURN TO Main Body /

AVAILABLE Attachment 2 Step In Effect.

Startup Transformer -

CAPABLE OF BEING ENERGIZED AND 115KV Span Bus - ENEGIZED OR CAPABLE OF BEING ENERGIZED

Rev. 27 AOP-034 SECURITY EVENTS Page 47 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 7 Energizing the Emergency Busses from an Offsite Source (Page 2 of 10)

CAUTION Normal Radiation Protection Procedures are not applicable during the performance of this Attachment.

NOTE An Armed Officer will be required to escort an Operator to close breaker 52/11A in the 4KV Switchgear Room. This is required to provide cooling for the Startup Transformer.

8. NOTIFY Security Of Need For Armed Escort

9. CHECK the following 4KV Manually OPEN Breakers.

Breakers OPEN:

START-UP TO 4KV BUS 2 BKR 52/12 START-UP TRANSFORMER TO 4KV BUS 3 BKR 52/17

Rev. 27 AOP-034 SECURITY EVENTS Page 48 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 7 Energizing the Emergency Busses from an Offsite Source (Page 3 of 10)

NOTE Breakers 52/22B and 52/29B are normally racked out unless SI PUMP "B" is aligned for service.

10. CHECK Following Breakers TRIPPED OR RACKED OUT 480V BUS E1 MAIN BKR, 52/18B 480V BUS E2 MAIN BKR, 52/28B EMERG DG A TO BUS E1 BKR 52/17B EMERG DG B TO BUS E2 BKR 52/27B 480V BUS E1 SUPPLY TO SI PUMP "B", 52/22B 480V BUS E2 SUPPLY TO SI PUMP "B", 52/29B 480V BUS 2A MAIN BKR, 52/8B 480V BUS 2B MAIN BKR, 52/9B SST-2A TO 480V SYSTEM BKR 52/1B 480V BUS 1 MAIN BKR 52/2B 480V BUS 3 MAIN BKR 52/15B SST-2C TO 480V SYSTEM BKR 52/16B

Rev. 27 AOP-034 SECURITY EVENTS Page 49 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 7 Energizing the Emergency Busses from an Offsite Source (Page 4 of 10)

11. CHECK The Following Breaker Manually OPEN Breakers.

Positions:

a. UNIT AUX TO 4KV BUS 1 BKR 52/7 - OPEN

b. UNIT AUX TO 4KV BUS 4 BKR 52/20 - OPEN

12. PLACE Control Switches For BOTH Condenser Vacuum Pumps To STOP:

VACUUM PUMP A VACUUM PUMP B

13. PLACE Control Switches For BOTH EH Fluid Pumps To PULL-TO-LOCK GOV FLUID PUMP A GOV FLUID PUMP B NOTE Resetting the Lockout Relays is necessary to restore power to the Emergency Busses.

14. CHECK Relays RESET, On Manually RESET Lockout Relays.

Generator Protection Relay Panel in Control Room:

Generator Lockout Relay 86P Generator Back-up Lockout Relay 86BU

Rev. 27 AOP-034 SECURITY EVENTS Page 50 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 7 Energizing the Emergency Busses from an Offsite Source (Page 5 of 10)

15. CHECK 115KV Switchyard Span WHEN the 115KV Switchyard Span Bus - ENERGIZED Bus is energized, THEN GO TO Step 16.

CAUTION The length of time the Startup Transformer is energized without cooling fans running shall be minimized to prevent overheating and possible damage to the transformer.

Without cooling fans the transformer can be maintained at rated voltage for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months at no load without causing any damage.

16. CHECK LINE DISCONNECT Manually CLOSE Disconnect.

SWITCH (Motor Operated Disconnect) - CLOSED NOTE When energizing a dead bus, the synchroscope will NOT come to the 12 o'clock position until after the breaker is closed and the dead bus is energized.

17. ENERGIZE 4KV Bus 2:

a. INSERT key into STARTUP TRANSF synchroscope switch AND TURN switch to STARTUP BUS 2 position

b. CLOSE START-UP TO 4KV BUS 2 BKR 52/12

c. TURN synchroscope key switch to the MID POSITION

Rev. 27 AOP-034 SECURITY EVENTS Page 51 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 7 Energizing the Emergency Busses from an Offsite Source (Page 6 of 10)

18. ENERGIZE 4KV Bus 1:

a. INSERT key into 4KV TIES synchroscope switch AND TURN switch to BUS 1 & 2 position.

b. CLOSE 4KV BUS 1-2 TIE BKR 52/10

c. TURN synchroscope key switch to the MID POSITION NOTE WHEN a breaker is operated to energize a dead-bus, the breaker switch should be held in the closed position for 4 to 8 seconds to allow time for the UV coil to be energized.

19. CLOSE 480V BUS 2B MAIN BKR 52/9B To Energize 480V Bus 2B

Rev. 27 AOP-034 SECURITY EVENTS Page 52 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 7 Energizing the Emergency Busses from an Offsite Source (Page 7 of 10)

20. ENERGIZE MCC-3:

a. CHECK Armed Officer Available a. WHEN an Armed Officer escort to escort an Operator to 4KV is available, THEN ACCESS the Switchgear Room 4KV Switchgear Room.

b. Locally CLOSE breaker 52/11A, FEED TO MCC-3

c. CHECK Startup Transformer c. WHEN access to the Startup Access- AVAILABLE Transformer is available, THEN PERFORM Step 20.d.

GO TO Step 21.

d. PERFORM the following at the Startup Transformer:

CHECK the cooling fans and oil pumps operating RESET local alarms

21. ENERGIZE 4KV Bus 3:

a. INSERT key into STARTUP TRANSF synchroscope switch AND TURN switch to STARTUP BUS 3 position.

b. CLOSE START-UP TRANSFORMER TO 4KV BUS 3 BKR 52/17

c. TURN synchroscope key switch to MID-POSITION

22. ENERGIZE 480V Bus E1:

a. CLOSE 480V BUS E1 MAIN BKR 52/18B

b. CHECK 480V Bus E1 is ENERGIZED

Rev. 27 AOP-034 SECURITY EVENTS Page 53 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 7 Energizing the Emergency Busses from an Offsite Source (Page 8 of 10)

CAUTION The allowable RCP Seal Cooling loss time is reduced from 15 minutes when Number 1 Seal Leakoff Flow is Greater Than 3.2 gpm.

23. ESTABLISH RCP Seal Cooling Alignment:

a. CHECK Highest RCP Number 1 a. DETERMINE Maximum Seal Leakoff - LESS THAN OR Allowable Cooling Loss Time EQUAL TO 3.2 GPM using Attachment 8, RCP No. 1 Seal Leak-off Vs. Time to Restore Cooling.

b. CHECK Loss of RCP Seal b. ISOLATE Seal Cooling:

Cooling has been Less Than:

1) CLOSE FCV-626, THERM 15 minutes BAR FLOW CONT.

OR 2) Locally CLOSE RCP SEAL WATER FLOW CONTROL Time Determined Above VALVEs:

CVC-297A CVC-297B CVC-297C

3) CLOSE CVC-381, SEAL WTR RETURN ISO.

Rev. 27 AOP-034 SECURITY EVENTS Page 54 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 7 Energizing the Emergency Busses from an Offsite Source (Page 9 of 10)

24. ESTABLISH E1 Loads:

a. CHECK Service Water Pump "A" a. START Service Water Pump "A".

- SECURED FOR EPP-28

b. CHECK Service Water Pump "B" b. START Service Water Pump "B".

- SECURED FOR EPP-28

c. START Component Cooling Water Pump "B"

d. CHECK Motor Driven AFW d. START Motor Driven AFW Pump Pump "A" - SECURED FOR "A" .

EPP-28

25. ESTABLISH RCS Makeup:

a. CHECK suction source for a. ESTABLISH Charging Pump Charging Pumps - AVAILABLE Suction Source:

VCT OR RWST

b. START Charging Pump "B"

26. ENERGIZE 480V Bus E2:

a. CHECK 480V Bus E2 - a. GO TO Step 27.

DEENERGIZED

b. CLOSE 480V BUS E2 MAIN BKR 52/28B

c. CHECK 480V Bus E2 is ENERGIZED

Rev. 27 AOP-034 SECURITY EVENTS Page 55 of 59 STEP ACTION/EXPECTED RESPONSE RESPONSE NOT OBTAINED Attachment 7 Energizing the Emergency Busses from an Offsite Source (Page 10 of 10)

27. ESTABLISH The Following Component Alignment:

a. CHECK Service Water Pumps - a. START Service Water Pumps TWO RUNNING not secured by EPP-28 to establish two running.

b. CHECK Component Cooling b. START CCW Pumps to establish Water Pumps - AT LEAST ONE at least one running.

RUNNING

c. CHECK Motor Driven AFW c. START Motor Driven AFW Pump - AT LEAST ONE Pumps not secured by EPP-28 RUNNING to establish at least one running.

d. CHECK RCS Makeup - d. START Charging Pump "C" ADEQUATE

- END -

Rev. 27 AOP-034 SECURITY EVENTS Page 56 of 59 Attachment 8 RCP No. 1 Seal Leak-off Vs. Time to Restore Cooling (Page 1 of 1)

No. 1 Seal Leak-Off TIME (GPM) (Minutes) 3.21 15:00 3.32 14:30 3.44 14:00 3.56 13:30 3.70 13:00 3.85 12:30 4.01 12:00 4.18 11:30 4.37 11:00 4.58 10:30 4.81 10:00 5.06 9:30 5.34 9:00 5.66 8:30 6.01 8:00

Rev. 27 AOP-034 SECURITY EVENTS Page 57 of 59 AOP-034, Revision 27 Summary of Changes (PRR 01965855)

Main Body Step 1, 19(Del),

Att. 2 Step 19(Del): Moved dispatch of EDG Operator to top of the procedure and added dispatch of a CCW Pp room operator when in modes 5&6.

PRR 01965855 Step 1: Appended Step to exit the attachment if Security will make the notification. (Training Feedback)

Attachments 5, 6, 7: Upgraded layout and verbiage to conform to current standards with no change to intent or logic flow.

Step 1 (Del): Removed initial step to dispatch the EDG operator. The operator is dispatched as the first step in the procedure and was redundant here.

Step 23:

New step to consolidate RCP Seal isolation requirements and decision. Added Caution regarding reduced allowable RCP Seal Loss times for Safe Shutdown / SBO considerations.

PRR 486552 Step 27: Included conditional starting of 'C' Charging Pump and deleted old step 27. The necessary conditions have already been established : New attachment with table to determine maximum time RCP Seal cooling can be lost before the need to isolate. PRR 486552

Rev. 27 AOP-034 SECURITY EVENTS Page 58 of 59 CONTINUOUS ACTION

SUMMARY

FOR AOP-034 MAIN BODY 2 Document relevant times. (updates)

7. Perform action specified in table. Re-perform if times change

26. IF Power is lost to the Emergency Busses after alignment to the EDGs, THEN ATTEMPT to restore power to Emergency Busses using Attachment 7, Energizing The Emergency Busses From An Offsite Source

27. IF either a Loss of all SW or Dam integrity occurs, THEN PERFORM EPP-28, Loss Of Ultimate Heat Sink, while continuing in this procedure.

ATTACHMENT 2

2. Perform action specified in table. Re-perform if times change

9. IF it is determined that attack on RNP is intended, THEN TRIP the Reactor.

33 IF Power is lost to the Emergency Busses after alignment to the EDGs, THEN ATTEMPT to restore power to Emergency Busses using Attachment 7, Energizing The Emergency Busses From An Offsite Source ATTACHMENT 5

13. WHEN RCS pressure is less than 1000 psig, THEN PERFORM Steps 14 through 19.

ATTACHMENT 7

20. WHEN access to the Startup Transformer is available, THEN PERFORM Step 20.d

Rev. 27 AOP-034 SECURITY EVENTS Page 59 of 59 CONTINUOUS ACTION

SUMMARY

FOR AOP-034 MAIN BODY 2 Document relevant times. (updates)

7. Perform action specified in table. Re-perform if times change

26. IF Power is lost to the Emergency Busses after alignment to the EDGs, THEN ATTEMPT to restore power to Emergency Busses using Attachment 7, Energizing The Emergency Busses From An Offsite Source

27. IF either a Loss of all SW or Dam integrity occurs, THEN PERFORM EPP-28, Loss Of Ultimate Heat Sink, while continuing in this procedure.

ATTACHMENT 2

2. Perform action specified in table. Re-perform if times change

9. IF it is determined that attack on RNP is intended, THEN TRIP the Reactor.

33 IF Power is lost to the Emergency Busses after alignment to the EDGs, THEN ATTEMPT to restore power to Emergency Busses using Attachment 7, Energizing The Emergency Busses From An Offsite Source ATTACHMENT 5

13. WHEN RCS pressure is less than 1000 psig, THEN PERFORM Steps 14 through 19.

ATTACHMENT 7

20. WHEN access to the Startup Transformer is available, THEN PERFORM Step 20.d

David S. Hoffman

(~ DUKE H. B. Robinson Steam Electric Plant Unit 2 ENERGY~ Director - Nuc Org Effectiveness Duke Energy Progress 3581 West Entrance Road Hartsville, SC 29550 0 . 843 857 5239 F: 843 8571319 David.Hoffman@duke-energy.com 10 CFR 50, Appendix E Serial: RNP-RA/16-0019 MAR 2 4 2016 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 TRAN SM ITTAL OF EMERGENCY PROCEDURE REVISION AND 10 CFR 50.54(q)

SUMMARY

OF ANALYSIS Ladies and Gentlemen:

In accordance with 10 CFR 50.4(b)(5) and Appendix E to 10 CFR 50, Duke Energy Progress, Inc.

is transmitting a revision to the H.B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, Emergency Implementing Procedure.

A description of the procedure change is provided on the "Summary of Changes" page included within the emergency procedure. Please replace the superseded procedure with the enclosed revision. The procedure revision and effective date is listed in Attachment I to this letter.

In accordance with 10 CFR 50.54(q)(5), Attachments II and Ill includes a summary of the analysis associated with the procedure change provided in Attachment I.

This document contains no new Regulatory Commitments.

If you have any questions concerning this matter, please contact Scott Connelly, Acting Manager -

Nuclear Regulatory Affairs at (843) 857-1569.

Sincerely, Da~!li7/v--

Director - Nuc Org Effectiveness DSH/cac

United States Nuclear Regulatory Commission Serial: RNP-RA/16-0019 Page 2 of 2 Attachments:

I. Procedure Revision and Effective Date II. 50.54(q)(3) Screen Ill. 50.54(q)(3) Evaluation Enclosure c: NRC Regional Administrator, NRC, Region II NRC Resident Inspector, HBRSEP Mr. Dennis Galvin, NRC Project Manager, NRA (w/o Enclosure)

United States Nuclear Regulatory Commission Attachment I to Serial: RNP-RA/16-0019 Page 1 of 1 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 Procedure Revision and Effective Date Procedure Revision Effective Date No.

AOP-034, "Security Events" 27 03/07/16

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/16-0019 5 Pages (including cover page)

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 50.54(g)(3) Screen

EMERGENCY PLAN CHANGE SCREENING AND AD-EP-ALL-0602 EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

Rev.1 ATTACHMENT 4 Page 1 of 4 10 CFR 50.54(q) Screening Evaluation Form Screening and Evaluation Number Applicable Sites BNP D EREG #: 1998183 CNS D CR3 D HNP D MNS D SAD#: 1974717 ONS D RNP x GO D Document and Revision AOP-034 Revision 27 Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan}:

The following proposed changes are for procedure AOP-034, Security Events, Revision 27:

Main Body: Step 1, Old Step 19(Del}, & Attachment 2: Old Step 19(Del}:

Moved dispatch of EDG Operator to top of page Step 1.

Added dispatch of a CCW Pump room operator when in modes 5 & 6.

Attachment 3 Step 1:

Added "and exit the attachment" once Security is notified of the threat.

Attachment 6 Old Step 1 (Del}:

Removed initial step to dispatch the EDG operator. The operator is dispatched as the first step in the procedure and was redundant here. This is editorial.

Attachments 5, 6, 7:

Upgraded layout and verbiage to conform to current standards with no change to intent or logic flow. These are editorial enhancements to improve the usability.

Attachment 7 Step 23, 23.a., 23.b, & Caution:

Added steps to consolidate RCP Seal isolation requirements and decision and include new Attachment 8.

Added Caution regarding reduced allowable RCP Seal Loss times for Safe Shutdown I SBO considerations.

Attachment 7 Step 27:

Included starting 'C' Charging Pump and deleted old step 27. The necessary conditions have been established in Step 23, 23.a, & 23.b

Attachment 8: