BVY 12-046, Proposed Change No. 301 - Cyber Security Plan Implementation Schedule Milestones

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Proposed Change No. 301 - Cyber Security Plan Implementation Schedule Milestones
ML121910298
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 07/02/2012
From: Wamser C
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 12-046
Download: ML121910298 (17)


Text

SEn tergy Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd Vernon, VT 05354 Tel 802 257 7711 Christopher J. Wamser Site Vice President 10 CFR 2.390 Attachments Withheld BVY 12-046 July 2, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Proposed Change No. 301 - Cyber Security Plan Implementation Schedule Milestones Vermont Yankee Nuclear Power Station Docket No. 50-271 License Number DPR-28

References:

1. Letter, NRC to Entergy Nuclear Operations, Inc., "Vermont Yankee Nuclear Power Station- Issuance of Amendment Re: License Amendment Request - Cyber Security Plan (TAC No. ME4296)," dated July 20, 2011, NVY 11-056
2. Letter, Entergy Nuclear Operations, Inc. to NRC, "Technical Specifications Proposed Change 292, Supplement 2, Response to Request for Additional Information (RAI) and Revision to the Vermont Yankee Cyber Security Plan," dated April 4, 2011, BVY 11-023

Dear Sir or Madam:

In Reference 1, the NRC issued License Amendment No. 247 to the Facility Operating License for Vermont Yankee (VY) that approved the Vermont Yankee Cyber Security Plan and associated implementation milestone schedule. The Cyber Security Plan Implementation Schedule contained in Reference 2 was utilized as a portion of the basis for the NRC's safety evaluation report provided by Reference 1. Entergy is planning to implement the requirements of Implementation Schedule Milestone 6 in a slightly different manner than described in the approved Implementation Schedule. Although no change to the Implementation Schedule date is proposed, the change to the description of the milestone activity is conservatively considered to be a change to the Implementation Schedule, and in accordance with the provisions of 10 CFR 50.4 and 10 CFR 50.90, Entergy is submitting this request for an amendment to the Facility Operating License for Vermont Yankee. The Vermont Yankee Cyber Security Plan, Revision 0 was previously provided in Reference 2. provides an evaluation of the proposed change. Attachment 2 contains proposed marked-up operating license pages for the Physical Protection license condition for Vermont Yankee to reference the commitment change provided in this submittal.

This letter contains security-related information - Attachment 1 (Sections 1, 2, 3) and Attachment 4 are withheld from public disclosure per 10 CFR 2.390 sc)c)) A

BVY 12-046 / Page 2 of 3 This letter contains security-related information - Attachment 1 (Sections 1, 2, 3) and Attachment 4 are withheld from public disclosure per 10 CFR 2.390 contains the proposed revised operating license pages. Attachment 4 contains a change to the scope of Implementation Milestone 6. Entergy requests that Attachments 1 (Sections 1, 2, and 3) and 4 which contain security-related information (SRI) be withheld from public disclosure in accordance with 10 CFR 2.390.

The proposed changes have been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c), and it has been determined that the changes involve no significant hazards consideration. The bases for these determinations are included in .

Entergy requests this license amendment be effective as of its date of issuance. Although this request is neither exigent nor emergency, your review and approval is requested prior to December 31, 2012.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Vermont Official.

The revised commitment contained in this submittal is summarized in Attachment 5. Should you have any questions concerning this letter, or require additional information, please contact Robert J. Wanczyk at 802-451-3166.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 2, 2012.

Sincerely, CJW/jmd Attachments: 1. Analysis of Proposed Operating License Change (contains SRI)

2. Proposed Vermont Yankee Operating License Changes (mark-up)
3. Revised Vermont Yankee Operating License Pages
4. Revised Cyber Security Plan Implementation Schedule (contains SRI)
5. List of Regulatory Commitments This letter contains security-related information - Attachment 1 (Sections 1, 2, 3) and Attachment 4 are withheld from public disclosure per 10 CFR 2.390

BVY 12-046 / Page 3 of 3 This letter contains security-related information - Attachment 1 (Sections 1, 2, 3) and Attachment 4 are withheld from public disclosure per 10 CFR 2.390 cc: Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. Richard V. Guzman Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Rd Vernon, Vermont 05354 Ms. Elizabeth Miller, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601 This letter contains security-related information - Attachment 1 (Sections 1, 2, 3) and Attachment 4 are withheld from public disclosure per 10 CFR 2.390

Docket 50-271 BVY 12-046 Attachment 2 Proposed Change No. 301 Proposed Vermont Yankee Operating License Changes (mark-up)

Safety Analysis Report for the facility and as approved in the SER dated January 13, 1978, and supplemental SERs, dated 9/12/79, 2/20/80, 4/15/80, 7/3/80, 10/24/80, 11/10/81, 1/13/83, 7124/84, 3/25/86, 1211/86, 12/8/89, 11/29/90, 8/30/95, 3/23/97, 6/9/97, 8/12/97, 3/6/98, 3/31/98, 912/98, and 2/24199, subject to the following provisions:

Entergy Nuclear Operations, Inc. may make changes to the approved Fire Protection Program without prior approval of the Commission only ifthose changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

G. Security Plan Entergy Nuclear Operations, Inc. shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans',

which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Vermont Yankee Nuclear Power Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 0,"

submitted by letter dated October 18, 2004, as supplemented by letter dated May 16, 2006.

l Entergy Nuclear Operations, Inc. shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

Entergy Nuclear Operations, Inc. CSP was approved by License Amendment H. This paragraph deleted by Amendment No. 107, 8/25/88.

1. This paragraph deleted by Amendment No. 131, 10/7/91.

J. License Transfer Conditions On the closing date of the transfer of Vermont Yankee Nuclear Power Station (Vermont Yankee), Entergy Nuclear Vermont Yankee, LLC shall obtain from Vermont Yankee Nuclear Power Corporation all of the accumulated decommissioning trust funds for the facility, and ensure the deposit of such funds into a decommissioning trust for Vermont Yankee established by Entergy Nuclear Vermont Yankee, LLC. Ifthe amount of such funds does not meet or exceed the minimum amount required for the facility pursuant to 10 CFR 50.75, Entergy Nuclear Vermont Yankee, LLC shall at such time deposit additional funds into the trust and/or obtain a parent company guarantee (to be updated annually) and/or obtain a surety pursuant to 10 CFR 50.75(eX1 )(iii) in a form acceptable to the NRC and in an amount or amounts which, when combined with the decommissioning trust funds for the facility that have been obtained and deposited as required above, equals or 1 The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.

Rinecvd Fleinlity Op, eting Iers I lal . 2-RIn

Docket 50-271 BVY 12-046 Attachment 3 Proposed Change No. 301 Revised Vermont Yankee Operating License Pages

Safety Analysis Report for the facility and as approved in the SER dated January 13, 1978, and supplemental SERs, dated 9/12/79, 2/20/80, 4/15/80, 7/3/80, 10/24/80, 11/10/81, 1/13/83, 7/24/84, 3/25/86, 12/1/86, 12/8/89, 11/29/90, 8/30/95, 3/23/97, 6/9/97, 8/12/97, 3/6/98, 3/31/98, 9/2/98, and 2/24/99, subject to the following provisions:

Entergy Nuclear Operations, Inc. may make changes to the approved Fire Protection Program without prior approval of the Commission only ifthose changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

G. Security Plan Entergy Nuclear Operations, Inc. shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans 1 ,

which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Vermont Yankee Nuclear Power Station Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 0,"

submitted by letter dated October 18, 2004, as supplemented by letter dated May 16, 2006.

Entergy Nuclear Operations, Inc. shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

Entergy Nuclear Operations, Inc. CSP was approved by License Amendment No. 247, as supplemented by a change approved by License Amendment No. xxx.

H. This paragraph deleted by Amendment No. 107, 8/25/88.

1. This paragraph deleted by Amendment No. 131, 10/7/91.

J. License Transfer Conditions On the closing date of the transfer of Vermont Yankee Nuclear Power Station (Vermont Yankee), Entergy Nuclear Vermont Yankee, LLC shall obtain from Vermont Yankee Nuclear Power Corporation all of the accumulated decommissioning trust funds for the facility, and ensure the deposit of such funds into a decommissioning trust for Vermont Yankee established by Entergy Nuclear Vermont Yankee, LLC. If the amount of such funds does not meet or exceed the minimum amount required for the facility pursuant to 10 CFR 50.75, Entergy Nuclear Vermont Yankee, LLC shall at such time deposit additional funds into the trust and/or obtain a parent company guarantee (to be updated annually) and/or obtain a surety pursuant to 10 CFR 50.75(e)(1)(iii) in a form acceptable to the NRC and in an amount or amounts which, when combined with the decommissioning trust funds for the facility that have been obtained and deposited as required above, equals or 1 The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.

Rcnc-wd Facility Opcrating Liccnsc No. DPR 2-8

Docket 50-271 BVY 12-046 Attachment 5 Proposed Change No. 301 List of Regulatory Commitments

BVY 12-046 / Attachment 5 / Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED (Check One) COMPLETION COMMITMENT ONE- DATE TIME CONTINUING (If Required)

ACTION COMPLIANCE Entergy will implement milestones 1, 2, 3, X December 31, 2012 4, 5, and 7 described in Attachment 4 of letter BVY 11-023 dated April 4, 2011, and the revised Milestone 6 in Attachment 4 of this submittal.