DCL-11-040, Response to Request for Additional Information E-mail Dated March 4, 2011, from the U.S. NRC Concerning Cyber Security Plan License Amendment Request 09-05

Response to Request for Additional Information E-mail Dated March 4, 2011, from the U.S. NRC Concerning Cyber Security Plan License Amendment Request 09-05

ML11103A044
Person / Time
Site:	Diablo Canyon
Issue date:	04/04/2011
From:	Becker J Pacific Gas & Electric Co
To:	Document Control Desk
References
PG&E Letter DCL-11-040, TAC ME4290, TAC ME4291
Download: ML11103A044 (1)

Text

ý;eeurity Relazc ~ted z:z7 WN*;;3il~ 1-1;; 10-GR2.3 Q Pacific Gas and Electric Company" James R.Becker Diablo Canyon Power Plant Site Vice President Mail Code 104/5/601 P0. Box 56 Avila Beach, CA 93424 805.545.3462 April 4, 2011 Internal: 691.3462 Fax: 805.545.6445' PG&E Letter DCL-1 1-040 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Response to Request for Additional Information E-mail dated March 4, 2011, from the U.S. Nuclear Regulatory Commission (ME4290 and ME4291) Concerning the Diablo Canyon Power Plant, Units 1 and 2, Cyber Security Plan License Amendment Request 09-05

Dear Commissioners and Staff:

Pacific Gas and Electric Company (PG&E) submitted PG&E Letter DCL-10-087, "License Amendment Request 09-05, Request for Approval of the Diablo Canyon Power Plant Cyber Security Plan and Revision to the Facility Operating Licenses,"

on July 22, 2010 (ML102150081). On March 4, 2011, the NRC sent an e-mail to PG&E with a request for additional information (RAI) regarding records retention, implementation schedule, and scope of systems associated with the Diablo Canyon Power Plant (DCPP) Cyber Security Plan (CSP) (ML110630071). In response to the RAI, PG&E provides the following supplemental information and replaces documents provided in the July 22, 2010, License Amendment Request.

Enclosure 1 provides PG&E's responses to the RAI.

Enclosure 2 provides an updated markup of the facility operating license.

Enclosure 3 provides a copy of the revised DCPP Cyber Security Plan Implementation Schedule. The actions and dates on the schedule are regulatory commitments.

Enclosure 4 provides a copy of the updated DCPP Cyber Security Plan dated March 2011, which is a stand-alone document that will be incorporated by reference into the DCPP Physical Security Plan upon approval. The revised DCPP CSP incorporates changes needed to address the NRC RAIs, as well as other changes consistent with NEI 08-09 Revision 6. Changes are indicated with revision bars.

6ccurity Pckhc'd In Rfmztio9i Withheld Under 10 CF-R2.39Q Enclosures 1, 3, and 4 contain "SECURITY-RELATED INFORMATION,"

Upon separationof enclosures 1, 3, and 4, this letter is "DECONTROLLED."

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

• Comanche Peak

• Diablo Canyon

• Palo Verde

• San Onofre o South Texas Project

• Wolf Creek

Geecr-ty Related~ lz rma-Ize VA-lthhel Updeir 10 CF R 2.0190 Document Control Desk PG&E Letter DCL-1 1-040 April 4, 2011 Page 2 Enclosures 1, 3, and 4 contain security-related sensitive information, vOhich could reasonably be expected to be useful to potential adversaries. PG&E therefore requests that Enclosures 1, 3 and 4 be withheld from public disclosure in accordance with 10 CFR 2.390.

If you have any questions regarding this response, please contact Mr. Thomas Baldwin, Regulatory Services Manager, at (805) 545-4720.

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

Executed on April 4, 2011.

James--ecke Site Vice President Imp/50379537 Enclosures cc: Gary W. Butner, Branch Chief, California Department of Public Health Elmo E. Collins, NRC Region IV Regional Administrator Michael S. Peck, NRC Senior Resident Inspector Diablo Distribution cc/enc. James T. Polickoski, NRC Licensing Project Manager Alan B. Wang, NRC Licensing Project Manager Security Reclated Infor-mation Withheld Under 10 CFR 2.390 Enclosures 1, 3, and 4 contain "SECURITY-RELATED INFORMATION,"

Upon separationof enclosures 1, 3, and 4, this letter-is "DECONTROLLED,"

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway o Comanche Peak e Diablo Canyon 9 Palo Verde

• San Onofre 9 South Texas Project

• Wolf Creek

Enclosure 2 PG&E Letter DCL-I 1-040 Proposed Facility Operating License Change (Mark-Up)

Enclosure 2 PG&E Letter DCL-1 1-040 Page 1 of 3 Proposed Facility Operating License Change (Mark-Up)

Insert the following text within the current facility operating license condition for Physical Protection and after its existing text:

By December 31, 2015, PG&E shall fully implement and maintain in effect all provisions of the Commission-approved DCPP Cyber Security Plan submitted by letter dated April 4, 2011, and withheld from public disclosure in accordance with 10 CFR 2.390.

Enclosure 2 PG&E Letter DCL-1 1-040 Page 2 of 3 E. Physical Protection The licensee 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 to the authority of 10 CFR 50.90 and 10 CFR 50.54 (p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:

"Diablo Canyon Power Plant, Units 1 and 2 Physical Security Plan, by Training and Qualification Plan, and Safeguards Contingency Plan," submitted by letter dated May 16, 2006.

By December 31, 2015, PG&E shall fully implement and maintain in effect all provisions of the Commission-approved DCPP Cyber Security Plan submitted by letter dated April 4, 2011, and withheld from public disclosure in accordance with 10 CFR 2.390.

F. Deleted.

G. Deleted.

H. Financial Protection PG&E shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

I. Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures DCPP Operating License Unit 1 Rev 44 Page 11 of 12 License No. DPR-80

Enclosure 2 PG&E Letter DCL-1 1-040 Page 3 of 3 D. Exemption (SSER 31, Section 6.2.6)

An exemption from certain requirements of Appendix J to 10 CFR Part 50 is described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplement No. 9. This exemption is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest. Therefore, this exemption previously granted in Facility Operating License No. DPR-81 pursuant to 10 CFR 50.12 is hereby reaffirmed.

The facility will operate, with the exemption authorized, in conformity with the application, as amended, the provisions of the Act, and the regulations of the Commission.

E. Physical Protection The licensee 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 provision of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Diablo Canyon Power Plant, Units 1 and 2 Physical Security Plan, Training and Qualification Plan and Safeguards Contingency Plan," submitted by letter dated May 16, 2006.

By December 31, 2015, PG&E shall fully implement and maintain in effect all provisions of the Commission-approved DCPP Cyber Security Plan submitted by letter dated April 4, 2011, and withheld from public disclosure in accordance with 10 CFR 2.390.

F. Deleted.

G. Deleted.

DCPP Operating License Unit 2 Rev 46 Page 8 of 9 License No. DPR-82