David S. Hoffman ENERGY® · 6a Systems are established for prompt communication among principal emergency response D organizations. 6b Systems are established for prompt communication

(_~ DUKE ENERGY®

Serial: RNP-RA/16-0012

FEB 2 8 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

TRANSMITTAL OF EMERGENCY PROCEDURE REVISION AND 10 CFR 50.54(q) SUMMARY OF ANALYSIS

Ladies and Gentlemen:

David S. Hoffman H. B. Robinson Steam

Electric Plant Unit 2 Director - Nuc Org Effectiveness

Duke Energy Progress 3581 West Entrance Road

Hartsville, SC 29550

0 : 843 857 5239 F: 843 857 1319

[email protected]

10 CFR 50, Appendix E

In accordance with 1 O CFR 50.4(b)(5) and Appendix E to 1 O 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 Please replace the superseded procedure with the enclosed revision.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 1 O CFR 50.54(q)(5), Attachment II 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.

David S. Hoffman Director - Nuc Org Effectiveness

DSH/cac

United States Nuclear Regulatory Commission Serial: RNP-RA/16-0012 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 Ms. Martha Barillas, NRC Project Manager, NRR (w/o Enclosure)

United States Nuclear Regulatory Commission Attachment I to Serial: RNP-RA/16-0012 Page 1 of 1

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2

Procedure Revision and Effective Date

Procedure Revision No.

EPTSC-06, "Emergency Security Team Leader'' 17

Effective Date

02/16/16

United States Nuclear Regulatory Commission Attachment II to Serial: RNP-RA/16-0012 7 Pages (including cover page)


50.54(g)(3) Screen

EMERGENCY PLAN CHANGE SCREENING AND EFFECTIVENESS EVALUATIONS 10 CFR 50.54(0)

10 CFR 50.54(q) Screening Evaluation Form

AD-EP-ALL-0602

Rev. O

ATTACHMENT 4 Page 1 of 6

Screening and Evaluation Number Applicable Sites

BNP D

EREG #: 2001139 CNS D CR3 D HNP D MNS D

5AD #: 1990091 ONS D RNP ~

GO D Document and Revision EPTSC-06 I Rev 17 Emergency Security T earn Leader

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 are the 12ro12osed changes for Qrocedure EPTSC-06 1 Emergency Security Team Leader. Revision 17:

• Cover Page - Updated Company name logo to Duke Energy .

• Cover Page - Updated Level of Use from Reference Use to Information Use .

• Old step 2.6 - Deleted reference to NSD 807 .

• Step 2.6 - Changed CSP-NGGC-0007 reference to AD-EG-ALL-1907 .

• Old Section 4.2 and 4.3 - Deleted detailed instructions for obtaining PMMD .

• Step 4.2 - Added step stating "Refer to AD-EG-ALL-1907, Cyber Security Media Protection Program, to support compliance with requirements for documentation of activities associated with use of PMMD during performance of this procedure."

• Step 5.0, 6.0, and 7.0 - Corrected "N/A" to "None"

• Old Section 5.1 - Deleted detail information about PMMD conditions .


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ATTACHMENT 4 Page 2of6


Part I. Description of Activity Being Reviewed (Continued)

• Old Section 8.13 - Old Section Deleted detailed instructions for returning PMMD.

• Step 8.13.1 - Added step stating to "Refer to AD-EG-ALL-1907, Cyber Security Media Protection Program, to support compliance with requirements for documentation of activities associated with return of PMMD during performance of this procedure."

• Attachment page 2, under Alert, step 5 - Added "IF evacuation of security personnel is required due to plant conditions, THEN CONTACT Site Emergency Coordinator to discuss and determine if 10 CFR 50.54 (x) (y) needs to be implemented."

• Attachment 10.2, step 1 second bullet - Added "Coordinate release of off-site emergency operations center personnel to report to their assigned facilities." (PRR 681852)

Part II. Activity Previously Reviewed? Is this activity Fully bounded by an NRC approved 10 CFR 50.90 submittal or Alert and Notification System Design Report?

If yes, identify bounding source document number or approval reference and ensure the basis for concluding the source document fully bounds the proposed change is documented below:

Justification: N/A

Bounding document attached (optional): N/A

Yes ID 10 CFR 50.54(q) Effectiveness Evaluation is not required. Enter justification below and complete Attachment 4, Part V.

No [8'J Continue to Attachment 4, 10 CFR

50.54(q) Screening Evaluation Form, Part Ill

D


AD-EP-ALL-0602

Rev.a


10 CFR 50.54(q} Screening Evaluation Form

Part Ill. Editorial Change Yes ID No I [8J Is this activity an editorial or typographical change only, such as 10 CFR Continue to formatting, paragraph numbering, spelling, or punctuation that does not 50.54(q) Attachment 4, change intent? Effectiveness Part IV and

Evaluation is address non

The following proposed changes in EPTSC-06, Emergency Security not required. editorial

Team Leader, Revision 17 meet the criteria of editorial as provided in Enter changes

AD-EP-ALL-0602, Emergency Plan Change Screening and justification and complete

Effectiveness Evaluations 10 CFR 50.54(0): Attachment 4,

Cover Page - Updated Company name logo to Duke Energy . Part V & VI.

• Justification: This proposed change is an editorial change that updates the Company logo from Progress Energy to Duke Energy. This proposed editorial change does not change the intent of the procedure.

• Step 5.0, 6.0, and 7.0 - Corrected "N/A" to "None" Justification: This proposed change is an editorial change that corrects "N/A" to "None" in accordance with AD-DC-ALL-0202, Writer's Manual for Controlled Procedure Manual Procedures. This proposed editorial change does not change the intent of the procedure.

• Step 2.6 - Changed CSP-NGGC-0007 reference to AD-EG-ALL-1907. Justification: This proposed change is an editorial change that updates the reference CSP-NGGC-0007, NGG Cyber Security Program to the new Fleet procedure AD-EG-ALL-1907, Cyber Security Media Protection Program. This proposed editorial change does not change the intent of the procedure.

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 1OCFR50.47(b)(1) Assignment of Responsibility (Organization Control)

1a Responsibility for emergency response is assigned. [8J

1b The response organization has the staff to respond and to augment staff on a continuing D basis (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 D



AD-EP-ALL-0602

Rev. O


Part IV. Emergency Planning Element and Function Screen (cont.)

2b The process for timely augmentation of onshift staff is established and maintained. D 3 10 CFR S0.47(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 D plan. (NA for CR3)

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 notification of the declared emergency within 1 S minutes (30 minutes for CR3) after D declaration of an emergency and providing follow-up notification.

Sb Administrative and physical means have been established for alerting and providing prompt D instructions 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 Notification Systems for Nuclear Power Plants, or complies with the licensee's D FEMA-approved ANS design 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 D within the 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 S0.47(b)(9) Accident Assessment

9a Methods, systems, and equipment for assessment of radioactive releases are in use. D 10 10 CFR 50.47(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 to support the formulation of PARs and have been provided to State and local D governmental authorities. (NA for CR3)

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

Rev. 0



Part IV. Emergency Planning Element and Function Screen (cont.)

10c A range of protective actions is available for plant emergency workers during emergencies, ~ including those for hostile action events.

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

11 1 O CFR 50.4 7(b )( 11) Radiological Exposure Control

11a The resources for controlling radiological exposures for emergency workers are established. D 12 10 CFR 50.47(b)(12) Medical and Public Health Support

12a Arrangements are made for medical services for contaminated, injured individuals. D 13 10 CFR 50.47(b)(13) Recovery Planning and Post-accident Operations

13a Plans for recovery and reentry are developed. D 14 10 CFR 50.47(b)(14) Drills and Exercises

14a A drill and exercise program (including radiological, medical, health physics and other D program areas) is established.

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

PART IV. Conclusion If no Part IV criteria are checked, a 10 CFR 50.54(q) Effectiveness Evaluation is not required, then D complete Attachment 4, 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 Attachment 4, 10 CFR 50.54(q) Screening Evaluation Form, Part V and perform a 10 CFR 50.54(q) Effectiveness Evaluation. Shaded block requires final approval of Screen and Evaluation by EP CFAM.



Part V. Signatures:

Preparer Na'D ~ PrifJf4-u._

eviewer Name (Print): be..6 b; e_ b o CA? I', r") Approver (EP , er N~91e (Print):

f)N ?;..o Approver (CFAM, a reguired) Name (Print)

,,,; A-

Part VI. NRG Emergency Plan and Implementing Procedure Submittal Actions

Create two EREG General Assignments.

AD-EP-ALL-0602

Rev.O


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

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

QA RECORD

United States Nuclear Regulatory Commission Attachment Ill to Serial: RNP-RA/16-0012 1 O Pages (including cover page)


50.54(g)(3) Evaluation


10 CFR 50.54(q) Effectiveness Evaluation Form

Screening and Evaluation Number

AD-EP-ALL-0602

Rev. O


Applicable Sites

BNP D EREG #: 2001139 CNS D

CR3 D HNP D MNS D

SAD #: 1990091 ONS D RNP IZI GO D

Document and Revision EPTSC-06 I Rev 17 Emergency Security Team Leader

Part I. Description of Proposed Change: The following are the 12ro12osed changes for 12rocedure EPTSC-06, Emergency Security Team Leader, Revision 17:

• Cover Page - Updated Level of Use from Reference Use to Information Use .

• Old step 2.6 - Deleted reference to NSD 807 .

• Old Section 4.2 and 4.3 - Deleted detailed instructions for obtaining PMMD .


• Old Section 5.1 - Deleted detail information about PMMD conditions .

• Old Section 8.13 - Old Section Deleted detailed instructions for returning PMMD .


• Attachment page 2, under Alert, step 5 - Added "IF evacuation of security personnel is required due to plant conditions, THEN CONTACT Site Emergency Coordinator to discuss and determine if 10 CFR 50.54 (x) (y) needs to be implemented."

• Attachment 10.2, step 1 second bullet - Added "Coordinate release of off-site emergency operations center personnel to report to their assigned facilities."


Rev. 0



Attachment 6, 10 CFR 50.54(q) Initiating Condition (IC) and Emergency Action Level (EAL) and EAL Bases Validation and Verification (V&V) Form, is attached (required for IC or EAL change)

Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

Yes D No 1:8:1

The proposed changes listed in EPTSC-06, Emergency Security Team Leader, Revision 17 included a review of the following Robinson Nuclear Plant (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 to Revision 17 of EPTSC-06, Emergency Security Team Leader does not affect the licensing basis of the emergency plan. The proposed changes continue to meet the intent and requirements established in the documents listed above.

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):

The following proposed changes to Revision 17 of EPTSC-06, Emergency Security Team Leader are administrative enhancements to address procedural level of use designation and the deletion of an unnecessary reference.

• Cover Page - Updated Level of Use from 'Reference Use' to 'Information Use'.

• Old step 2.6 - Deleted reference to NSD-807.

The proposed change to update the level of use from 'Reference Use' to 'Information Use' aligns with the procedure being an administrative procedure in accordance with the level of use designation as established in AD-DC-ALL-0202, Writer's Manual For Controlled Procedure Manual Procedures. The proposed change to delete the reference to NSD-807, Cyber Security Incident Response Plan, is to provide procedural references that apply to Robinson Nuclear Plant as part of Duke Energy, Progress. NSD-807, Cyber Security Incident Response Plan, only applies to Duke Energy, Carolinas. These proposed changes are administrative in nature and do not change the intent of the procedure. These proposed changes do not impact 10 CFR 50.47 or 1 O CFR Appendix E.; therefore, these proposed changes continue to support and comply with the planning standards, as described in 1 O CFR 50.47(b) and the requirements in 10 CFR 50, Aooendix E.



Part Ill. (Continued)

AD-EP-ALL-0602

Rev. 0


The following proposed changes to Revision 17 of EPTSC-06, Emergency Security Team Leader is to align RNP procedures and processes to support compliance with the Cyber Security Media Protection Program for the use of Portable Media and Mobile Devices (PMMDs).

• Old Section 4.2 and 4.3 - Deleted detailed instructions for obtaining PMMD.


• Old Section 5.1 - Deleted detail information about PMMD conditions.



These proposed changes replace the Cyber Security Media Protection Program steps for conditions, instructions, and information related to the use of PMMDs with steps to 'refer' to AD-EG-ALL-1907, Cyber Security Media Protection Program for compliance with the use of PMMDs. The exact information in the steps being replaced with the 'reference statements' is located in AD-EG-ALL-1907. The replacement steps to 'refer' to AD-EG-ALL-1907 ensures that the Emergency Security Team Leader will utilize AD-EG-ALL-1907 to comply with the requirements of the procedure. These proposed changes align with RNP's process to maintain Security Media Protection Program requirements in the Cyber Security Plan procedure and ensures the emergency response procedure references the Cyber Security Plan procedure where applicable. The Cyber Security Plan at RNP outlines the milestones, specifically Milestone 4, for the use of PMMDs, for compliance with 10 CFR 73. 7 4, Protection of Digital Computer and Communication Systems and Networks. These proposed 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.

The following proposed change to Revision 17 of EPTSC-06, Emergency Security Team Leader (ESTL) is an enhancement to the procedure that provides guidance to the ESTL to discuss with the Site Emergency Coordinator (SEC) the need to invoke 1 O CFR 50.54 (x)(y) if plant conditions require Security personnel to evacuate which could adversely affect the Security Plan.

• Attachment page 2, under Alert, step 5 - IF evacuation of security personnel is required due to plant conditions, THEN CONTACT Site Emergency Coordinator to discuss and determine if 10 CFR 50.54 (x) (y) needs to be implemented.

The ESTL is the emergency response member in the Technical Support Center (TSC) that has the most knowledge of Security and the requirements of the Security Plan. In an emergency situation where plant conditions such as radiological and/or environmental hazards requires the evacuation of Security



Part Ill. (Continued)

AD-EP-ALL-0602

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personnel, this proposed change ensures that the ESTL communicates with the SEC to determine if 10 CFR 50.54 (x) (y) needs to be implemented. The SEC has the responsibility to make this determination. This change promotes communication and discussion which allows the SEC to make determinations to respond quickly and efficiently to emergency events. This proposed change continues to support and comply with the requirements of 10 CFR 50.47(b )(1) and 10 CFR 50 Appendix E, Section IV.A.2 by strengthening the authority, responsibility, and duty of the ESTL and SEC.

The following proposed change to Revision 17 of EPTSC-06, Emergency Security Team Leader (ESTL) is an enhancement that provides guidance to the ESTL to coordinate the release of off-site emergency response center personnel to report to their assigned facilities during a Hostile Action Based Event.


In the event of a daytime hostile action based event where Security and the SEC deems the initial adverse condition to be clear and allows plant personnel to move, the Emergency Response Organization (ERO) will be instructed to report to their emergency response facilities onsite for activation. Off-site emergency operations center ERO members will report to the Emergency Operations Facility (EOF) and await instructions. Non-essential personnel will be instructed to report to the designated assembly area. In a hostile action based event, the site may not be secure and/or given an all clear for days. This proposed change ensures the ESTL will coordinate the release of RNP's offsite emergency operations center representatives as soon as it is safe to do so. This coordination provides a measure of protection and safety for RN P's emergency response members and the release ensures that the stations ERO representatives are available to support the State and County Emergency Operation Centers. Overall, this proposed change supports and provides protection for the health and safety of the plant personnel and the general public. This proposed change continues to support and comply with the requirements of 10 CFR 50.47(b)(1), 10 CFR 50.47(b)(10), and 10 CFR Part 50, Appendix E, Sections IV.I to make arrangements for efficient response capabilities.

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):

50.47(b}(1 ), Emergency Response Responsibility (in part) 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. Responsibility for emergency response is assigned.


Rev.a



Part IV (Continued)

Supporting Requirements: 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; c. Authorities, responsibilities, and duties on an onsite emergency coordinator who shall be in

charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.

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.

50.47(b)(10), Emergency Protective Actions (in part) PLANNING STANDARD: A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (Kl), as appropriate. Evacuation time estimates have been developed by applicants and licensees. Licensees shall update the evacuation time estimates on a periodic basis. Evacuation time estimates and updates must be submitted to the NRC for review to confirm adequacy. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.

PS Functions 2. A range of protective actions is available for emergency workers during emergencies,

includino hostile action events.



Part IV (Continued) Supporting Requirements: 10 CFR 50, Appendix E, Section IV. I I. Onsite Protective Actions During Hostile Action

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ATIACHMENT5 Page 6of9

By June 20, 2012, for nuclear power reactor licensees, a range of protective actions to protect onsite personnel during hostile action must be developed to ensure the continued ability of the licensee to safely shut down the reactor and perform the functions of the licensee's emergency plan.

Program Elements • Provisions will be made for evacuation routes and transportation for onsite individuals to some

suitable offsite location, including alternatives for inclement weather, high traffic density, and specific radiological conditions.

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

The following proposed changes to Revision 17 of EPTSC-06, Emergency Security Team Leader are administrative enhancements to address procedural level of use designation and the deletion of an unnecessary reference.

• Cover Page - Updated Level of Use from 'Reference Use' to 'Information Use'.

• Old step 2.6 - Deleted reference to NSD-807.

These proposed changes do not reduce the effectiveness of PLP-007, Robinson Emergency Plan. The proposed change to update the level of use from 'Reference Use' to 'Information Use' aligns with the procedure being an administrative procedure in accordance with the level of use designation as established in AD-DC-ALL-0202, Writer's Manual For Controlled Procedure Manual Procedures. The proposed change to delete the reference to NSD-807, Cyber Security Incident Response Plan, is to provide procedural references that apply to Robinson Nuclear Plant as part of Duke Energy, Progress. NSD-807, Cyber Security Incident Response Plan, only applies to Duke Energy, Carolinas. These proposed changes are administrative in nature and do not reduce any capabilities or functions of the emergency plan.

The following proposed changes to Revision 17 of EPTSC-06, Emergency Security Team Leader is to align RNP procedures and processes to support compliance with the Cyber Security Media Protection Program for the use of Portable Media and Mobile Devices (PMMDs).

• Old Section 4.2 and 4.3 - Deleted detailed instructions for obtaining PMMD.




Part V (Continued)

• Old Section 5.1 - Deleted detail information about PMMD conditions.

AD-EP-ALL-0602

Rev. a




These proposed changes do not reduce the effectiveness of PLP-007, Robinson Emergency Plan. Instead, these proposed changes replace the Cyber Security Media Protection Program steps for conditions, instructions, and information related to the use of PMMDs with steps to 'refer' to AD-EG-ALL-1907, Cyber Security Media Protection Program for compliance with the use of PMMDs. The exact information in the steps being replaced with the 'reference statements' is located in AD-EG-ALL-1907. The replacement steps to 'refer' to AD-EG-ALL-1907 ensures that the Emergency Security Team Leader will utilize AD-EG-ALL-1907 to comply with the requirements of the Cyber Security Plan procedure. These proposed changes align with RNP's process to maintain Security Media Protection Program requirements in the Cyber Security Plan procedure and ensures the emergency response procedure references the Cyber Security Plan procedure where applicable. These proposed changes do not reduce any capabilities or functions of the emergency plan.

The following proposed change to Revision 17 of EPTSC-06, Emergency Security Team Leader (ESTL) is an enhancement to the procedure that provides guidance to the ESTL to discuss with the Site Emergency Coordinator (SEC) the need to invoke 10 CFR 50.54 (x)(y) if plant conditions require Security personnel to evacuate which could adversely affect the Security Plan.

• Attachment page 2, under Alert, step 5 - IF evacuation of security personnel is required due to plant conditions, THEN CONTACT Site Emergency Coordinator to discuss and determine if 10 CFR 50.54 (x) (y) needs to be implemented.

This proposed change does not reduce the effectiveness of PLP-007, Robinson Emergency Plan. Instead, in an emergency situation where plant conditions such as radiological and/or environmental hazards requires the evacuation of Security personnel, this proposed change ensures that the ESTL communicates with the SEC to determine if 10 CFR 50.54 (x) (y) needs to be implemented. The SEC has the responsibility to make this determination. This change promotes communication and discussion which allows the SEC to make determinations to respond quickly and efficiently to emergency events. This change continues to ensure emergency response capabilities described in PLP-007 are adequately maintained and demonstrated. This proposed change in Revision 17 of EPTSC-06 enhances ERO's readiness to support a classified emergency, resulting in an improved capability to ensure health and safety of plant personnel and the general public. PLP-007, Section 5.3, Emergency Response Organization and Section 5.4, Emergency Measures, provide guidance to emergency response personnel on the actions to take when deviations from normal work processes are needed. This proposed change continues to support the guidance provided in PLP-007 with no reduction in effectiveness.


Rev.a



Part V (Continued)

The following proposed change to Revision 17 of EPTSC-06, Emergency Security Team Leader (ESTL) is an enhancement that provides guidance to the ESTL to coordinate the release of off-site emergency response center personnel to report to their assigned facilities during a Hostile Action Based Event.


This proposed change does not reduce the effectiveness of PLP-007, Robinson Emergency Plan. Instead, during a hostile action based event, this coordination ensures the ESTL will coordinate the release of RNP's offsite emergency operations center representatives as soon as it is safe to do so. This change provides a measure of protection and safety for RNP's emergency response members and the release ensures that the stations ERO representatives are available to support the State and County Emergency Operation Centers. This change supports and provides protection for the health and safety of the plant personnel and the general public. This change continues to ensure emergency response capabilities described in PLP-007 are adequately maintained and demonstrated. This proposed change in Revision 17 of EPTSC-06 enhances ERO's readiness to support a classified emergency, resulting in an improved capability to ensure health and safety of plant personnel and the general public. PLP-007, Section 5.3, Emergency Response Organization, and Section 5.4, Emergency Measures, provide guidance to emergency personnel for emergency response activities and emergency measures to be taken as needed. This proposed change continues to support the guidance provided in PLP-007 with no reduction in effectiveness.

The proposed changes in Revision 17 of EPTSC-06, Emergency Security Team Leader 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.

Overall, the proposed changes to EPTSC-06, Emergency Security Team Leader, Revision 17 are improvements to the RNP Emergency Preparedness Program.

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?

2 Does the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in effectiveness)?

3 Does the proposed change maintain the current Emergency Action Level (EAL) scheme?

Yes

IZl Yes

IZl Yes

IZl

No D No D No D

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

Rev. O



Part VI. (Continued)

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 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 D scheme change. Therefore, the activity cannot be implemented without prior NRC approval.

Part VII. Disposition of Proposed Change Requiring Prior NRC Approval

Will the proposed change determined to require prior NRC approval be either revised or Yes No rejected? N/A D D If No, then initiate a License Amendment Request in accordance 1 O 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 50.4 7(b )( 4 ).

Preparer Name (Print): 12> Pt \ .

Reviewer Name (Print): LX._6 6 ; e bow f ~ n

Approver (C AM, as r~uired) Name (Print): N f If

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 [gJ

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 change is put in effect. lZI

QA RECORD

EPTSC-06 Rev. 17 Page 1 of 14

I Information

Use


PLANT OPERATING MANUAL

VOLUME 2

PART 5

EPTSC-06

EMERGENCY SECURITY TEAM LEADER

REVISION 17


SUMMARY OF CHANGES PRR 1969698

EPTSC-06 Rev. 17

SECTION REVISION COMMENTS Cover Page Updated Company name logo to Duke Energy. (Editorial)

Updated Level of Use from Reference Use to Information Use. (Non-Technical)

Justification: Meets requirements of AD-HU-ALL-0004, Procedure and Instruction Use and Adherence

Old 2.6 Deleted reference to NSD 807. (Editorial) Justification: This reference only applies to Duke West.

2.6 Changed CSP-NGGC-0007 reference to AD-EG-ALL-1907. (Editorial)

Justification: Updated to new fleet procedure number.

Old Section 4.2 & 4.3

Deleted detailed instructions for obtaining PMMD. (PRR 1969698)

Justification: AD-EG-ALL-1907, is being implemented with required instructions for the use of PMMD.

Step 4.2 Added step stating "Refer to AD-EG-ALL-1907, Cyber Security Media Protection Program, to support compliance with requirements for documentation of activities associated with use of PMMD during performance of this procedure." (PRR 1969698)


5.0, 6.0, 7.0 Corrected "N/A" to "None" (Editorial)

Justification: Writers manual requires "None"

Old Section 5.1 Deleted detail information about PMMD conditions. (PRR 1969698)

Justification: This is not a precaution and limitation and AD-EG-ALL-1907, is being implemented with required instructions for the use of PMMD.

Old Section 8.13 Deleted detailed instructions for returning PMMD. (PRR 1969698)


8.13.1 Added step stating to "Refer to AD-EG-ALL-1907, Cyber Security Media Protection Program, to support compliance with requirements for documentation of activities associated with return of PMMD during performance of this procedure." (PRR 1969698)

Justification: AD-EG-ALL-1907, is being implemented with required instructions for the return of PMMD.

Attachment 10.1 page 2 under Alert step 5

Added "IF evacuation of security personnel is required due to plant conditions, THEN CONTACT Site Emergency Coordinator to discuss and determine if 10 CFR 50.54 (x) (y) needs to be implemented." (PRR 751231)

Justification: Recommendation from Security

Attachment 10.2 step 1 second bullet

Added "Coordinate release of off-site emergency operations center personnel to report to their assigned facilities." (PRR 681852) Justification: To ensure ERO personnel are released from the site to their designated facility in the event of a HAB event.


TABLE OF CONTENTS

SECTION PAGE

1.0 PURPOSE ............................................................................................................ 4

2.0 REFERENCES ..................................................................................................... 4

3.0 RESPONSIBILITIES ............................................................................................ 4

4.0 PREREQUISITES ................................................................................................ 5

5.0 PRECAUTIONS AND LIMITATIONS ................................................................... 5

6.0 SPECIAL TOOLS AND EQUIPMENT .................................................................. 5

7.0 ACCEPTANCE CRITERIA ................................................................................... 5

8.0 INSTRUCTIONS................................................................................................... 6

9.0 RECORDS............................................................................................................ 8

10.0 ATTACHMENTS .................................................................................................. 8 10.1 EMERGENCY SECURITY TEAM LEADER (ESTL) QUICK START GUIDE .. 9 10.2 EMERGENCY SECURITY TEAM LEADER (ESTL) HAB EVENTS .............. 12


1.0 PURPOSE

1.1 This procedure describes the functional responsibilities and procedure steps for the Emergency Security Team Leader (ESTL).

2.0 REFERENCES

2.1 EPTSC-00, Activation and Operation of the Technical Support Center

2.2 EPSPA-01, Evacuation and Accountability

2.3 EPSPA-02, First Aid and Medical Care

2.4 EPSPA-04, Access Control

2.5 SEC-NGGC-2141, Fitness for Duty Unscheduled Work Call Outs

2.6 AD-EG-ALL-1907, Cyber Security Media Protection Program

3.0 RESPONSIBILITIES

3.1 Provide technical and administrative direction to the Emergency Security Team during an emergency.

3.2 Complete accountability of personnel inside the protected area within 30 minutes of declaration of a Site Area Emergency or higher emergency classification. The primary method for conduct of accountability is the security computer roll call.

3.3 Provide Security personnel trained in First Aid/CPR to treat accident victims and perform search and rescue. Security personnel may not be available for this function during a security event or other events which require significant Security staff. (AR 61951)

3.4 Keep security team members updated on changing radiological conditions for their protection. (AR 61951)


4.0 PREREQUISITES

4.1 As per EPTSC-00, Activation and Operation of the Technical Support Center.

4.2 Refer to AD-EG-ALL-1907, Cyber Security Media Protection Program, to support compliance with requirements for documentation of activities associated with use of PMMD during performance of this procedure.

5.0 PRECAUTIONS AND LIMITATIONS None

6.0 SPECIAL TOOLS AND EQUIPMENT None

7.0 ACCEPTANCE CRITERIA

None


8.0 INSTRUCTIONS

NOTE: Refer to the attachments for a summary of responsibilities/tasks associated with this ERO position (attachment information does not replace the procedure steps).

• Attachment 10.1, Emergency Security Team Leader (ESTL) Quick Start Guide

• Attachment 10.2, Emergency Security Team Leader (ESTL) HAB Events,

8.1 ENSURE appropriate TSC/EOF and OSC access control is implemented.

8.1.1 Appropriate doors are locked and personnel already in facilities are noted / verified.

8.2 REQUEST the Administrative & Logistics Manager (A&LM) and Radiological Control personnel to determine the following:

8.2.1 Specific areas and/or routes for grounds search team.

8.2.2 Possible alternate assembly area location during a security threat.

8.2.3 Names and affiliates of individuals requested to report to the plant (non-company).

8.3 Upon receipt of Emergency Assembly Form, CONTACT the A&LM with status.

NOTE: Use of Hand-Held Accountability Readers is optional.

8.4 REVIEW data from USB Memory Stick output of Hand-Held Accountability Readers, if applicable.

8.4.1 RECEIVE USB Stick from TSC/EOF Security Officer.

8.4.2 PLUG the USB Stick into an available USB Port on the ESTL computer.

8.4.3 RIGHT CLICK Start and SELECT “Open Windows Explore”.

8.4.4 USE the navigation pane and expand the “My Computer” selection.

8.4.5 LOCATE the USB Drive from the list of directories (e.g., USB20FD (F:)).

8.4.6 CLICK on file listed, the report will contain the proximity badge number, badge number and name of each individual not accounted for during the process.


8.5 For an unscheduled call-out, VERIFY with the A&LM, OSC Leader, and SEC that all ERO personnel have completed SEC-NGGC-2141, Attachment 1, Unscheduled Work Call-Out, and information is processed, in accordance with SEC-NGGC-2141 requirements.

8.6 REPORT the names and last known locations of missing persons to the Site Emergency Coordinator (SEC) per EPSPA-01, Evacuation and Accountability.

8.7 If available, PROVIDE qualified Security personnel to participate in search and rescue missions. Missions are briefed and dispatched from the Operational Support Center (OSC).

8.8 If notified with request for offsite transportation for injured personnel, NOTIFY the A&LM when and where an ambulance will be needed.” for clarification.

8.9 After an evacuation is ordered, ASSIGN Security Team Member(s) to sweep the areas outside the Protected Area and Lake Robinson within the 1400 ft. exclusion area, in accordance with EPSPA-01, Evacuation and Accountability.

8.9.1 Mobile Security patrols should be directed to make an announcement at various locations throughout the 1400 ft. exclusion area.

8.9.2 IF individuals are encountered during this sweep, THEN they should be directed to the designated assembly area.

8.9.3 The 1400 feet radius is marked by signs.

8.9.4 Personnel outside the Protected Area are not required to be accounted for within 30 minutes.

8.9.5 If additional manpower is needed, CONTACT the South Carolina Department of Natural Resources and the local law enforcement agencies.

8.9.6 Notify Security personnel at the Firing Range that an assembly/evacuation is in progress, direct them to the assembly location, and advise them that the Emergency Security Team Leader is the lead Security Officer and will be providing additional instructions, as needed.

8.10 ESTABLISH contact with offsite law enforcement, via Darlington County 911 Center, as required.


8.11 DIRECT Access Control Point (ACP) Officers to issue TLDs to offsite responders prior to entering the Owner Controlled Area.

8.11.1 INSTRUCT the ACP Officers to contact the ESTL IF the supply of TLDs at the ACP is diminished to less than ten (10) available for issuance.

8.11.2 IF contacted by the ACP that the TLD supply is less than ten, THEN CONTACT the RCD AND REQUEST additional TLDs be delivered to the ACP.

8.12 When notified by the Radiological Control Director (RCD), DIRECT specific vital areas to be locked when they are classified as a Locked High Radiation Area (LHRA).

8.12.1 Once the area is designated as LHRA, access may not be permitted without the authorization of the RCD.

8.12.2 CONTACT the Security Shift Supervisor to inform him/her of the radiological conditions of the areas AND that access will not be permitted unless approved by the ESTL.

8.13 PMMD Return to M&TE

8.13.1 Refer to AD-EG-ALL-1907, Cyber Security Media Protection Program, to support compliance with requirements for documentation of activities associated with return of PMMD during performance of this procedure.

9.0 RECORDS

9.1 Records generated during a declared emergency should be forwarded to the Emergency Preparedness Unit.

10.0 ATTACHMENTS

10.1 Emergency Security Team Leader (ESTL) Quick Start Guide

10.2 Emergency Security Team Leader (ESTL) HAB Events

ATTACHMENT 10.1 Page 1 of 3


EMERGENCY SECURITY TEAM LEADER (ESTL) QUICK START GUIDE

NOTE: Blanks are provided for place keeping only; logs are the official record. This is a summary level guide and does not replace the procedure steps.

1. SIGN-IN on the facility sign-in board and the TSC Staffing Requirements/Overflow Roster. ANNOUNCE your name and title. _____

2. NOTIFY the A&LM upon your arrival at the TSC. REFER to the ERO Telephone Book. _____

3. PRIORITIZE AND DISTRIBUTE the following assignments: a. Access Control (EPSPA-04, Access Control) _____

- Develop a contingency plan for alternate access points once site access is restricted _____

b. Traffic Control (EPSPA-04, Access Control) _____ c. Accountability (EPSPA-01, Evacuation and Accountability) _____ d. First Aid (EPSPA-02, First Aid and Medical Care) _____ e. Security Officers _____

− Normal Post _____

− Secondary and Central Alarm Station _____

− Any Special Stations.

− Entrance to TSC/EOF and OSC _____

− Administrative Building/Assembly Areas _____ 4. INFORM the SEC, if Security personnel cannot perform any of the

above assigned duties. _____ 5. GATHER information regarding the status of access control for the

TSC/ EOF Building and the OSC, AND PROVIDE it to the A&LM. _____ 6. NOTIFY the SEC of readiness to activate. _____ 7. For an unscheduled call-out, VERIFY with the A&LM, OSC Leader,

and SEC that all ERO personnel have completed SEC-NGGC-2141, Attachment 1, Unscheduled Work Call-Out, AND PROCESS the information in accordance with SEC-NGGC-2141 requirements. _____

8. REFER to procedure steps AND CONTINUE checklist based on classification. _____




UNUSUAL EVENT

1. REQUEST outside assistance (if needed). _____ 2. AUGMENTATION of on-duty security shift (if needed). _____ 3. INCREASE PA/VA Patrols _____

IF ERO facilities are activated at UE, THEN

4. POST Access Control station for EOF/TSC. _____ 5. POST signs posted and LOCK doors in EOF/TSC. _____ 6. POST Access Control station for OSC. _____

ALERT

NOTE: Perform actions described in previous steps, if applicable.

1. POST Access Control station for EOF/TSC. _____ 2. POST signs posted and LOCK doors in EOF/TSC. _____ 3. POST Access Control station for OSC. _____ 4. LIMIT access to site (notify ACP). _____ 5. IF evacuation of security personnel is required due to plant conditions, THEN CONTACT Site Emergency Coordinator to discuss and determine if 10 CFR 50.54 (x) (y) needs to be implemented. _____ 6. DIRECT Security personnel to SWITCH the Security Building #466

HVAC System from “NORMAL MODE” to “EMERGENCY MODE” within 2 hours of the start of a radiological release associated with the event. _____

7. COORDINATE “Assembly Area” location with RCD. _____ 8. RECOMMEND to SEC the assembly of non-essentials from PA. _____ 9. DESIGNATE an Evacuation Assembly Area Leader. _____ 10. COMMUNICATE “Assembly Area” location to the A&LM. _____ 11. CHECK for local evacuation areas in the plant with the RCD. _____

12. CHECK wind direction AND DETERMINE which Security Officer posts that must be moved, if a release should occur. _____




SITE AREA EMERGENCY


1. INITIATE 30 min. clock on accountability. _____ 2. VERIFY HEPA filter EACU-1 in Security Building #466 has been

switched to “EMERGENCY MODE. _____ 3. INITIATE 1400’ boundary patrol to clear area. _____ 4. CONTACT SSS to dispatch a member of the security force with

bull horns to notify personnel to assemble in pre-designated areas if PA system is out of service or in areas where the PA system cannot be heard. _____

5. REQUEST outside assistance (if needed). _____ 6. AUGMENT Security Shift staff (if needed). _____ 7. COMPLETE Protected Area accountability. _____ 8. REPORT completion of accountability to SEC and A&LM. _____ 9. CHECK release conditions with regard to Security posts. _____

GENERAL EMERGENCY


1. CONTACT SSS to dispatch a member of the security force with bull horns to notify personnel to assemble in pre-designated areas if PA system is out of service or in areas where the PA system cannot be heard. _____

2. REQUEST outside assistance. _____ 3. AUGMENT Security Shift staff (if needed). _____ 4. COMPLETE Protected Area accountability (if not already completed.) _____ 5. DETERMINE the need for Protective Clothing, Respirators, Potassium

Iodide, etc. for Security personnel. _____

TERMINATION

1. Upon declaration of event termination, SWITCH the Security Building #466 HVAC System from “EMERGENCY MODE” to “NORMAL MODE”. INFORM the Radiological Control Director. _____



EMERGENCY SECURITY TEAM LEADER (ESTL) HAB EVENTS

1. COMMUNICATIONS

Upon notification of the security event the ESTL shall establish communications with the SSS and receive an update. _____

Coordinate release of off-site emergency operations center personnel to report to their assigned facilities. _____

Verify with the SSS that initial notifications have been made with LLEA. _____

Verify that the SSS has made initial notifications with the C/R. _____

Once onsite, the ESTL will relieve the SSS of communication with LLEA. _____

Establish an ESTL position at the ICP to communicate with LLEA _____

Try to establish continuous communications with SSS and ESTL posted at the ICP. (consider a conference bridge number) _____

Verify through the SSS that the C/R has turned on their security radio. _____




2. PRIORITIZE AND DISTRIBUTE the following assignments:

Access Control to Owner Controlled Area _____

Traffic Control shall be established by the ICP. Verify TCP’s have been established. _____

First Aid – Coordinate with the SSS and Control room to provide escorts for first responders to injured personnel if possible. _____

Damage Control Missions – Coordinate with the SSS to provide Operations personnel escorts for damage control and assessment if needed. _____

Security Officers

o Post ERO facilities when possible _____

o Post EOF/TSC when possible _____

o Establish with SSS available officers for repair mission if needed _____

o ESTL/SSS must track locations of all response teams (LLEA, Security, EMS, etc.) that are within OCA/PA. _____

o Contact Security Training department and relocate all personnel to the ICP to assist LLEA _____

o Consider pairing LLEA with security personnel while within the

OCA _____




3. POST ATTACK

ESTL, LLEA, ESTL (ICP), SSS will coordinate all missions within the PA/OCA. (Example – ENMON teams being dispatched into OCA, Ops performing damage assessment) _____

ESTL, LLEA, ESTL (ICP), SSS will coordinate establishing safe travel paths for:

o ERO facilities o JIC personnel needing to exit site o Offsite fire response to PA o Offsite EMS response to site _____

ESTL, LLEA, ESTL (ICP), SSS will coordinate establishing preservation

of the crime scene _____ ESTL, LLEA, ESTL (ICP), SSS will coordinate a barricade around

neutralized adversaries _____

ESTL and SSS must ensure that the SEC and or Control Room Shift manager understand that when all know adversaries have been neutralized that the site is still in a SECURITY EVENT. _____

Once TSC is established ESTL must consider performing Accountability

if SAE has been declared _____ ESTL, LLEA, ESTL (ICP), SSS will coordinate the notifications to

buildings within the OCA to have non-essential personnel assemble in pre-determined location _____

Contact SSS to dispatch a member of the security force with bull horns

to notify personnel to assemble in pre-designated areas if PA system is out of service or in areas where the PA system cannot be heard. _____

Documents

David S. Hoffman ENERGY® · 6a Systems are established for prompt communication among principal emergency response D organizations. 6b Systems are established for prompt communication