BVY 17-022, License Amendment Request - Cyber Security Plan License Condition Removal Proposed Change No. 316

License Amendment Request - Cyber Security Plan License Condition Removal Proposed Change No. 316

ML17198A020
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	07/13/2017
From:	Boyle J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 17-022
Download: ML17198A020 (18)

Text

~Entergy Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd.

Vernon, VT 05354 802-257-7711 John W. Boyle Director, Nuclear Decommissioning 10 CFR 50.90 BVY 17-022 Ju ly 13, 2017 Attn : Document Control Desk U.S. Nuclear Regulatory Commission Washington , DC 20555-0001

SUBJECT:

License Amendment Request - Cyber Security Plan License Condition Removal Proposed Change No. 316 Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28 REFERENCES : 1. Letter, Entergy Nuclear Operations , Inc. to USN RC , "Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel ," BVY 15-001 , dated January 12, 2015 (ML15013A426)

2. USNRC Memorandum, Executive Director for Operations to NRC Commissioners , "Cyber Security Requirements for Decommissioning Nuclear Power Plants", dated December 5, 2016 (ML16172A284)

3. Letter, USNRC to Crystal River Nuclear Plant, "Crystal River Unit 3 Nuclear Generating Plant - Issuance of Amendment Approving Removal of the Existing Cyber Security License Condition from the Facility Operating License (TAC No. L53155) ," dated June 22 , 2017 (ML17096A280)

4. Letter, Entergy Nuclear Operations , Inc. to USNRC, "Independent Spent Fuel Storage Installation Physical Security Plan , Revision 0, Proposed Change No. 315 ," BVY 17-003, dated March 29 , 2017 (ML17117A421)

5. Letter, Entergy Nuclear Operations , Inc. to USNRC , "License Amendment Request - Cyber Security Plan Implementation Schedule, Proposed Change No. 314," BVY 17-007, dated May 1, 2017 (ML17124A429)

Dear Sir or Madam :

Pursuant to 10 CFR 50.4 and 10 CFR 50.90, Entergy Nuclear Operations, Inc. (ENO) hereby requests an amendment to the Renewed Facility Operating License (RFOL} for Vermont /A Yankee Nuclear Pow er Station (VY) pertaining to th e Cyber Security Plan (CSP). Specifica lly, S()D

~

this license amendment request (LAR} is for the removal of the existing CSP requirements contained in license condition 3.G , "Security Plan," of the VY RFOL. tf\ \\

~~

BVY 17-022 /Page 2 of 3 VY has been shut down since December 29, 2014. By letter dated January 12, 2015 (Reference 1), ENO submitted to the Nuclear Regulatory Commission (NRC) the certifications of permanent cessation of power operations at VY and permanent defueling of the VY reactor vessel in accordance with 10 CFR 50.82(a)(1)(i) and 10 CFR 50.82(a)(1)(ii), respectively. Upon docketing of these certifications , under 10 CFR 50.82(a)(2) the VY 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. Spent fuel is currently stored onsite in the spent fuel pool (SFP) and in an independent spent fuel storage installation (ISFSI).

This LAR to remove the CSP requirements from the VY RFOL Security Plan license condition is requested to be approved prior to the anticipated completion of the transfer of all spent fuel to dry storage within the ISFSI, considering the cooling period for spent fuel since the VY reactor has been permanently shut down. The regulatory and technical evaluations included in this LAR are consistent with recent NRC guidance on cyber security requirements for decommissioning facilities (Reference 2). In addition , the NRC staff has recently approved a similar amendment request made by Duke Energy Florida , LLC to delete the cyber security license condition from the Crystal River Unit 3 facility license (Reference 3). provides an analysis of the proposed change . Attachment 2 contains the marked-up VY RFOL pages for the proposed change to license condition 3.G, "Security Plan." contains the retyped RFOL pages .

The proposed change has been evaluated in accordance with 10 CFR 50.91(a)(1), Notice for public comment, using criteria in 10 CFR 50.92(c), and it has been determined that the proposed change involves no significant hazards consideration. The bases for this determination as well as the technical rationale for the requested change are included in .

By letter dated March 29, 2017, (Reference 4), ENO submitted a separate LAR pursuant to 10 CFR 50.90 for approval of the VY ISFSI Physical Security Plan (PSP). Reference 4 includes a proposed change to the Security Plan license condition which is independent of the proposed change contained herein.

By letter dated May 1, 2017 (Reference 5), ENO submitted a separate LAR pursuant to 10 CFR 50.90 pertaining to the VY CSP implementation schedule, which included a proposed schedule change for implementation of CSP Milestone 8 from December 15, 2017 to July 31 ,

2019. The proposed implementation date is beyond the anticipated completion of the transfer of all spent fuel to the ISFSI in late 2018, provided that the criteria for transfer are met, including certain regulatory approvals.

Although this request is neither exigent nor emergency, ENO requests NRC approval and issuance of the proposed amendment by December 15, 2017. Once approved, the amendment is requested to be effective as of the date of issuance and shall be implemented within 30 days.

If this LAR to remove cyber security requirements from the Security Plan license condition is approved prior to the current VY Milestone 8 implementation date of December 15, 2017, the

BVY 17-022 /Page 3 of 3 CSP implementation schedule extension LAA (Reference 5) would no longer be needed, and as such, would be withdrawn.

In accordance with 10 CFR 50.91(b), State consultation, ENO is notifying the State of Vermont of this license amendment request by transmitting a copy of this letter and attachments to the designated State official.

This letter contains no new regulatory commitments.

Should you have any questions concerning this letter, or require additional information, please contact Mr. Coley C. Chappell at 802-451-3374.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 13, 2017.

JWB/ccc Attachments: 1. Analysis of Proposed Change

2. Proposed Operating License Changes (mark-up}

3. Revised Operating License Pages (retyped}

cc: Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. Jack D. Parrott, Sr. Project Manager Off ice of Nuclear Material Sat ety and Sateguards U.S. Nuclear Regulatory Commission Mail Stop T-8F5 Washington, DC 20555 Ms. June Tiemey, Commissfoner Vermont Department ot PubHc Service 112 State Street - Drawer 20 Montpelier, Vermont 05602-2601

BVY 17-022 Docket No. 50-271 Attachment 1 Analysis of Proposed Change

BVY 17-022 I Attachment 1 I Page 1 of 8 1.0

SUMMARY

DESCRIPTION Entergy Nuclear Operations, Inc. (ENO) is submitting a request for an amendment to the Renewed Facility Operating License (RFOL) for Vermont Yankee Nuclear Power Station (VY).

Specifically, this license amendment request (LAR) is for the removal of the existing Cyber Security Plan (CSP) requirements contained in license condition 3.G, "Security Plan," of the VY RFOL. This change is requested to support the decommissioning of VY.

2.0 DETAILED DESCRIPTION The VY CSP and implementation schedule, as required by 10 CFR 73.54, "Protection of digital computer and communication systems and networks," consists of eight Milestones. Interim Milestones 1 through 7 were completed by December 31 , 2012, and continue to be maintained.

As approved by Reference 1, CSP Milestone 8 implementation (full implementation of the CSP) is required to be completed by December 15, 2017. Cyber security requirements are described in the second paragraph of the Security Plan license condition .

VY has been shut down since December 29, 2014. By letter dated January 12, 2015

{Reference 2), ENO submitted to the Nuclear Regulatory Commission {NRC) the certifications of permanent cessation of power operations at VY and permanent defueling of the VY reactor vessel in accordance with 10 CFR 50.82(a)(1)(i) and 10 CFR 50.82(a)(1)(ii), respectively. Upon docketing of these certifications , under 10 CFR 50.82(a)(2) the VY 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. Spent fuel is currently stored onsite in the spent fuel pool (SFP) and in an independent spent fuel storage installation (ISFSI).

At the time of this submittal , VY is beyond the cooling period following permanent cessation of reactor operation of 15.4 months, which was determined by site-specific analysis (Reference 3) to allow sufficient time (10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />) to be available to take prompt mitigative actions in response to a postulated zirconium fire scenario in the SFP. This analysis was previously reviewed and approved by the NRC staff in support of approved exemptions from specific requirements of 10 CFR 50.47 and Appendix C to 10 CFR Part 50 for certain emergency planning requirements (Reference 4) .

To support the decommissioning of VY , this LAR is being submitted to remove the existing cyber security requirements from the Security Plan license condition , prior to the completion of the transfer of spent fuel from the SFP to dry storage within the ISFSI. This request considers the cooling period for spent fuel stored in the SFP since the VY reactor has been permanently shut down. The evaluations included in this LAR are consistent with recent NRC guidanoe on cyber security requirements for de*oommissloning faciHties (Reference 5) .

Accordingly, pursuant to the provisions of 10 CFR 50.4 and 10 CFR 50.90, ENO is subm itting this request to amend the VY RFOL to remove the existing cyber security requirements from the Security Plan license condition.

BVY 17-022 I Attachment 1 I Page 2 of 8 The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1). using the criteria in 10 CFR 50.92(c), and it has been determined that the proposed change involves no significant hazards consideration , as discussed in Section 4.2 below. Attachment 2 contains the marked-up VY RFOL pages for the proposed change to license condition 3.G "Security Plan. " Attachment 3 contains the retyped RFOL pages.

By letter dated March 29, 2017, (Reference 6) , ENO submitted a separate LAR pursuant to 10 CFR 50.90 for approval of the VY ISFSI Physical Security Plan (PSP). The proposed ISFSI PSP is appropriate for a permanently shut down facility that has completed the transfer of all spent fuel to the ISFSI. Reference 6 includes a proposed change to the Security Plan license condition which is independent of the proposed change contained herein.

By letter dated May 1, 2017 (Reference 7), ENO submitted a separate LAR pursuant to 10 CFR 50.90 pertaining to the VY CSP implementation schedule, which included a proposed schedule change for implementation of CSP Milestone 8 from December 15, 2017 to July 31 ,

2019. The proposed implementation date is beyond the anticipated completion of the transfer of all spent fuel to the ISFSI in late 2018, provided that the criteria for transfer are met, including certain regulatory approvals. If this LAR to remove the CSP requirement from the Security Plan license condition is approved prior to the current VY Milestone 8 implementation date of December 15, 2017, the CSP implementation schedule extension LAR (Reference 7) would no longer be needed, and as such , would be withdrawn .

3.0 TECHNICAL EVALUATION

The proposed amendment to remove the CSP requirements from the Security Plan license condition is based on the significantly reduced risks for a nuclear power reactor that has permanently ceased operations and has removed all fuel from the reactor vessel. Compared to an operating nuclear power reactor, for a decommissioning facility with a permanently defueled reactor the spectrum of possible accidents is significantly reduced and the risk of an offsite radiological release is significantly lower. Reduced cyber security risk is due, in part, to the fact that there are significantly fewer critical digital assets (CDAs) at a decommissioning facility in comparison to the number at an operating reactor.

Following permanent cessation of reactor operation and removal of fuel from the reactor vessel, the digital computers and communication systems and networks that require cyber protection are primarily those associated with security and emergency preparedness functions , and those safety systems that support operation of the SFP. Following the VY shutdown, while recently irradiated fuel was stored in the SFP. these requirements remained in effect. However, once the spent fuel has sufficiently decayed, the potential consequences of a cyber-attack are significantly reduced.

As documented in Reference 4, since VY is permanently shutdown and defueled, the only design basis accident that could potentially result in an offsite radiological release at VY is the fuel handling

BVY 17-022 I Attachment 1 I Page 3 of 8 accident (FHA). Analysis performed by ENO showed that 17 days after shutdown, the radiological consequence of the FHA would not exceed the limits established by the U.S. Environmental Protection Agency's (EPA's) Protective Action Guidelines (PAGs) at the exclusion area boundary.

Based on the time that VY has been permanently shutdown, there is no longer any possibility of an offsite radiological release from a design basis accident that could exceed the EPA PAGs. With the significant reduction in radiological risk for a power reactor undergoing decommissioning, the consequences of a cyber-attack are significantly reduced.

The spent fuel stored in the SFP has decayed to a point where a fire in the zirconium fuel cladding following a postulated beyond-design-basis event involving the loss of SFP water inventory is unlikely. This is based on analysis showing that after sufficient cooling time following cessation of reactor operations, there is little chance that the spent fuel in the SFP could heat-up to clad ignition temperature within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of fire propagation in a postulated SFP drain down scenario.

The only analyzed beyond-design-basis accident scenario that progresses to a condition where a significant offsite release might occur involves the very unlikely event where the SFP drains in such a way that all modes of cooling or heat transfer are assumed to be unavailable, which is postulated to result in an adiabatic heatup of the spent fuel. This analysis was previously submitted to the NRC staff in support of requested exemptions from specific requirements of 10 CFR 50.47 and Appendix C to 10 CFR Part 50 for certain emergency planning requirements as appropriate for a decommissioning facility (Reference 3) , which was reviewed and approved by the NRC staff with an effective date of April 15, 2016 (Reference 4) . A summary of the analysis and conclusions is as follows:

1. The analysis conservatively assumes that there is no radiative or air cooling of the assemblies: the flow paths that would provide natural circulation cooling are assumed to be blocked.

2. The analysis conservatively assumed the heat up time starts when the SFP has been completely drained, although it is likely that site personnel will start to respond to an incident when drain down starts. This is conservative as it does not include the period of time from the postulated initiating event causing a loss of SFP water inventory until all cooling means are lost, and it is likely that site personnel will start to respond to an incident when drain-down starts.

3. Due to the slow rate of SFP water boil-off, adequate time will be available to restore cooling or makeup, either through restoration of normal systems or through readily available mitigation measures, without significant radiological consequences for plant workers in the reactor building .

4. Furthermore, because of the slow rate of the event scenario and because the duties of the on-shift personnel at a decommissioning reactor facility are not as complicated and diverse as those for an operating reactor, significant time is available to complete actions necessary to mitigate an emergency .

BVY 17-022 I Attachment 1 I Page 4 of 8

5. A temperature of 900°C is the temperature associated with rapid fuel cladding oxidation used to assess the potential onset of fission product release.

6. Adiabatic heatup analysis of the limiting fuel assembly for decay heat shows that, within 15.4 months after shutdown, the time for the limiting fuel assembly to reach 900°C is 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> after the assemblies have been uncovered.

7. Therefore, due to the length of time it would take for the adiabatic heat-up to occur, there is ample time to respond to any partial drain down event that might cause such an occurrence by restoring cooling or makeup , or providing spray. As a result, the likelihood that such a scenario would progress to a zirconium fire is not deemed credible.

At the time of this submittal, the VY spent fuel has decayed well beyond the minimum cooling time of 15.4 months determined by the site-specific analysis. Based on an additional cooling period of approximately 15 months, the analysis (refer to Figure 7-1 in Attachment 2 to Reference 3) indicates significantly more than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> (approximately 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />) would exist to take mitigative actions prior to reaching 900°C , with the same conservatisms applied as described above. Therefore, a sufficient cooling period has occurred in order to mitigate the risk of heat-up to fuel clad ignition temperatures within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> for a postulated drain-down of the SFP with loss of all cooling modes that could result in a zirconium fire accident scenario in the SFP .

In summary, based on (1) no design basis events that could result in an offsite radiological release exceeding the limits established by the U.S . EPA protective action guideline limits and therefore significant reduction in radiological risk including consequences of a potential cyber-attack, and (2) sufficient time (at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />) would exist to take prompt mitigative actions in response to a postulated zirconium fire accident scenario in the SFP , the elimination of the cyber security requirements from the Security Plan license condition is appropriate for the VY facility . This rationale is similar to that used to justify a reduction in emergency prepareqness requirements during decommissioning, as previously approved for VY by Reference 4.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 73 .54, "Protection of digital computer and communication systems and networks,"

establishes the requirements for licensees to maintain and implement a Cyber Security Program (CSP). This regulation specifically states " ... each licensee currently licensed to operate a nuclear power plan under part 50 of this chapter shall submit, as specified in § 50.4 and§ 50.90 of th(s chapter, a cyber security plan that satisfies t:he requirements of thts section for Commission review and approval." In accordance with 10 CFR 50.54, uconditions of licenses," upon approval the CSP becomes a condition in the operating license. VY has an approved CSP as described in the VY RFOL Security Plan lioense condition .

BVY 17-022 I Attachment 1 I Page 5 of 8 By letter dated January 12, 2015 (Reference 2) , ENO submitted to the NRC the certifications of permanent cessation of power operations at VY and permanent defueling of the VY reactor vessel in accordance with 10 CFR 50.82(a)(1)(i) and 10 CFR 50.82(a)(1)(ii) , respectively. Upon docketing of these certifications, under 10 CFR 50.82(a)(2) the VY 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel.

When the final rule for 10 CFR 73.54 was issued in March 2009, neither ISFSl-only facilities nor other facilities that were in the process of decommissioning were required to comply with the cyber security requirements. The NRC specifically limited cyber security requirements to a "licensee currently licensed to operate a nuclear power plant under part 50 ." As discussed in Reference 5, the NRC staff has determined that once the NRC has docketed the certifications required by 10 CFR 50 .82(a)(1)(i) and (ii) , and found in accordance with 10 CFR 50 .82(a)(2) that the licensee is no longer authorized to operate the reactor or place or retain fuel in the reactor vessel, 10 CFR 73. 54 no longer applies to that licensee.

License condition 3.G , "Security Plan ," requires VY to fully implement and maintain in effect all provisions of the Commission-approved CSP , including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). This license condition continues to apply to VY in decommissioning, therefore the licensee remains subject to the CSP provisions contained in the license condition until they are removed from the license pursuant to a 10 CFR 50.90 amendment request.

4.2 No Significant Hazards Consideration Determination Entergy Nuclear Operations, Inc. (ENO) is requesting an amendment to the Vermont Yankee Nuclear Power Station (VY) Renewed Facility Operating License (RFOL) to revise license condition 3.G "Security Plan" as it relates to the Cyber Security Plan (CSP) . This license condition requires VY to fully implement and maintain in effect all provisions of the Commission-approved CSP, including changes made pursuant to the authority of 10 CFR 50 .90 and 10 CFR 50.54(p) . Specifically , the proposed change is to amend the Security Plan license condition to remove the cyber security requirements.

ENO has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

'I . Does the proposed change involve a significant increase in the probability or consequences of an aocident previously evaluated?

Response: No.

Spent fuel at VY is stored in the spent fue l pool (SFP) and in the independent spent fue l storage installation (I SFSI). In this configuration, the spectrum of possible accidents

BVY 17-022 I Attachment 1 I Page 6 of 8 transients and accidents is significantly reduced compared to an operating nuclear power reactor. The design basis accident evaluated in Section 6 of the VY Defueled Safety Analysis Report (DSAR) is the fuel handling accident (FHA}, which is predicated on spent fuel being stored in the SFP. Due to fuel decay since permanent cessation of reactor operations , the risk of an offsite radiological release is also significantly lower.

This proposed change does not alter the FHA analysis assumptions, introduce or alter any initiators, or affect the function of facility structures, systems , and components (SSCs) relied upon to prevent or mitigate any previously evaluated accident or the manner in which these SSCs are operated, maintained, modified, tested , or inspected.

The proposed change does not involve any facility modifications which affect the performance capability of any SSCs relied upon to prevent or mitigate the consequences of any previously evaluated accidents .

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated .

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

This proposed change does not alter accident analysis assumptions, introduce or alter any initiators, or affect the function of facility SSCs relied upon to prevent or mitigate any previously evaluated accident, or the manner in which these SSCs are operated, maintained, modified, tested, or inspected. The proposed change does not involve any facility modifications which affect the performance capability of any SSCs relied upon to mitigate the consequences of previously evaluated accidents and does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated .

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

Plant safety margins are established through limiting conditions for operation , limiting safety system settings , and safety limits specified In the Technical Specifications, and as described in the Defueled Safety Analysis Report (DSAR). The proposed change does not involve any changes to the initial conditions that establish safety margins, and does not involve modifications to any SSCs which are relied upon to provide a margin of safety. Because there is no change to established safety margins as a result of this proposed change, no significant reduction in a margin of safety is involved.

BVY 17-022 I Attachment 1 I Page 7 of 8 Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, ENO concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Precedents The NRC staff has recently approved a similar amendment request made by Duke Energy Florida , LLC to delete the cyber security license condition from the Crystal River Unit 3 facility license (Reference 8) .

4.4 Conclusion In conclusion , based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

S The proposed amendment removes the existing cyber security license condition from the facility operating license. This change relates solely to safeguards matters and does not involve any significant construction impacts, and relates to modifications to systems used for security and/or materials accountability. Accordingly, this amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51 .22(c)(12). Therefore , pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 REFERENCES

1. Letter, USN RC to Entergy Nuclear Operations, Inc., "Vermont Yankee Nuclear Power Station - Issuance of Amendment to Renewed Facility Operating License Re : Cyber Security Plan Implementation Schedule (CAC No. MF6403), " NVY 16-009, dated March 14, 2016(ML16014A169)

2. Letter, Entergy Nuclear Operations, Inc. to USNRC , "Certifications of Permanent Cessation of Po Ner Operations and Permanent Removal of Fuel from the Reactor Vessel," BVY 15-001 ,

dated January 12, 2015 (ML15013A426)

3. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E," BVY 14-009, dated March 14, 20 14(ML14080A141)

BVY 17 -022 I Attachment 1 I Page 8 of 8

4. Letter, USNRC to Entergy Nuclear Operations, Inc. , "Vermont Yankee Nuclear Power Station - Exemptions from Certain Emergency Planning Requirements and Related Safety Evaluation {CAC No. MF3614)," NVY 15-104, dated December 10, 2015{ML15180A054)

5. USNRC Memorandum, Executive Director for Operations to NRC Commissioners, "Cyber Security Requirements for Decommissioning Nuclear Power Plants", dated December 5, 2016 {ML16172A284)

6. Letter, Entergy Nuclear Operations, Inc. to USNRC , "Independent Spent Fuel Storage Installation Physical Security Plan, Revision 0, Proposed Change No. 315," BVY 17-003, dated March 29, 2017 (ML17117A421)

7. Letter, Entergy Nuclear Operations, Inc. to USNRC, "License Amendment Request - Cyber Security Plan Implementation Schedule, Proposed Change No. 314 ," BVY 17-007, dated May 1, 2017(ML17124A429)

8. Letter, USNRC to Crystal River Nuclear Plant, "Crystal River Unit 3 Nuclear Generating Plant - Issuance of Amendment Approving Removal of the Existing Cyber Security License Condition from the Facility Operating License (TAC No. L53155) ," dated June 22, 2017 (ML17096A280)

I I_

BW 17-022 Docket No. 50-271 Attachment 2 Proposed Operating License Changes (mark-up)

(3 pages including Cover Sheet)

NOTE: A separate License Transfer Application has been submitted to transfer ownership of the facility -3 (BVY 17-005)

D. Entergy Nuclear Operations, Inc., pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components.

E. Entergy Nuclear Operations, Inc., pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not to separate, such byproduct and special nuclear material as may be produced by operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34 of 10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Section 50.54 and 50.59of10 CFR Part 50, and Section 70.32of10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect: and is subject to the additional conditions specified below:

A. This paragraph deleted by Amendment No. 263.

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 206, are hereby incorporated in the license. Entergy Nuclear Operations, Inc. shall operate the facility in accordance with the Technical Specifications.

C. Reports Entergy Nuclear Operations, Inc. shall make reports in accordance with the requirements of the Technical Specifications.

D. This paragraph deleted by Amendment No. 226.

E. Environmental Conditions Pursuant to the Initial Decision of the presiding Atomic Safety and Licensing Board issued February 27, 1973, the following conditions for the protection of the environment are incorporated herein:

1. This paragraph deleted by Amendment No. 206, October 22, 2001 .

2. This paragraph deleted by Amendment 131, 10/07/91.

Renewed Facility Operating License No. DPR-28 Amendment No. ~. ~. 92, ~.265

NOTE: Changes to the first paragraph are proposed in independently submitted license amendment request BVY 17-003.

G. Security Plan Entergy Nuclear Operations, Inc. shall f!JllY 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 O,"

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

E:Rtergy Nuclear OperatioRs, !RC. sl=lall fully implemeRt aRd maiRtaiR iR effect all pro'Jisions of the Commission appro'Jed oyber seourity plan (CSP) , inoluding ohanges made pursuant to the authority of 10 CFR 50 .90 aRd 10 CFR 50.54(p) . Entergy P.Juolear Operations, lno. CSP was appro'Jed by LioeRse Amendment P.Jo . 247, as supplemented by ohanges approved by Lioense /\mendment Nos. 251 ,

259, and 265.

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

I. 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.

Renewed Facility Operating License No. DPR-28 Amendment No. 247, ~ . ~ ~ . ~

Corrected by letter dated November 21 , 2012

BVY 17-022 Docket No. 50-27 1 Attachment 3 Revised Operating License Pages (retyped)

(3 pages including Cover Sheet)

D. Entergy Nuclear Operations, Inc., pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components.

E. Entergy Nuclear Operations, Inc., pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not to separate, such byproduct and special nuclear material as may be produced by operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations: 10 CFR Part 20, Section 30.34of10 CFR Part 30, Section 40.41 of 10 CFR Part 40, Section 50.54 and 50.59 of 10 CFR Part 50, and Section 70.32 of 10 CFR Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

A This paragraph deleted by Amendment No. 263.

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. XXX, are hereby incorporated in the license. Entergy Nuclear Operations, Inc. shall operate the facility in accordance with the Technical Specifications.

C. Reports Entergy Nuclear Operations, Inc. shall make reports in accordance with the requirements of the Technical Specifications.

D. This paragraph deleted by Amendment No. 226.

E. Environmental Conditions Pursuant to the Initial Decision of the presiding Atomic Safety and Licensing Board issued February 27, 1973, the following conditions for the protection of the environment are incorporated herein:

1. This paragraph deleted by Amendment No. 206, October 22, 2001 .

2. This paragraph deleted by Amendment 131, 10/07 /91 .

Renewed Facility Operating License No. DPR-28 Amendment No. 2W, 200, 262, 2eJ,26a

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.

H. This paragraph deleted by Amendment No. 107, 8125188.

I. 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.

Renewed Facility Operating license No. DPR-28 Amendment No. 247, 254-, 259,. 2GJ, 26§ Corrected by letter dated No*1ember 21, 2012