GNRO-2013/00090, License Amendment Request - Cyber Security Plan Implementation Schedule

License Amendment Request - Cyber Security Plan Implementation Schedule

ML14008A081
Person / Time
Site:	Grand Gulf
Issue date:	12/19/2013
From:	Kevin Mulligan Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML14008A079	List: GNRO-2013/00090, License Amendment Request - Cyber Security Plan Implementation Schedule
References
GNRO-2013/00090
Download: ML14008A081 (10)

Text

~Entergy Entergy Operations, Inc.

P.O Box 756 Port Gibson. MS 39150 Kevin J. Mulligan Vice President. Operations Grand Gulf Nuclear Station Tel: 601-437-7500 10 CFR 2.390 Attachments Withheld GNRO-2013/00090 December 19, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

License Amendment Request - Cyber Security Plan Implementation Schedule Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1. NRC Internal Memorandum to Barry Westreich from Russell Felts, Review Criteria for 10 CFR 73.54, Cyber Security Implementation Schedule Milestone 8 License Amendment Requests, dated October 24, 2013

2. NRC letter to Entergy, Issuance of Amendment Re: Approval of Cyber Security Plan, dated July 27, 2011 (GNRI-2011/00088)

3. NRC Internal Memorandum to Directors of Regional Divisions of Reactor Safety from Barry Westreich, Enhanced Guidance For Licensee Near- Term Corrective Actions to Address Cyber Security Inspection Findings and Licensee Eligibility for "Good-Faith" Attempt Discretion, dated July 1, 2013

Dear Sir or Madam:

Pursuant to 10 CFR 50.4 and 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests an amendment to the Facility Operating License for Grand Gulf Nuclear Station (GGNS), Unit 1. In accordance with the guidelines provided by Reference 1, this request proposes a change to the GGNS Cyber Security Plan Milestone 8 full implementation date as set forth in the Cyber Security Plan Implementation Schedule approved by Reference 2.

Reference 3 provided additional NRC internal guidance.

Attachment 1 provides an evaluation of the proposed change. Attachment 2 contains proposed marked-up operating license pages for the Physical Protection license condition for GGNS to reference the commitment change provided in this submittal. Attachment 3 This letter contains security-related information - Attachments 1 and 4 are withheld from public disclosure per 10 CFR 2.390

GNRO-2013/00090 Page 2 of 3 This letter contains security-related information - Attachments 1 and 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 date of Implementation Milestone 8. 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 15,2014.

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 Jeff Seiter at 601-437-2344.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 19,2013.

Sincerely,

~CJ-JeT'- ~ /l1J;;~ Sf/po KJM/cjb (J Attachments: 1. Analysis of Proposed Operating License Change (contains SRI)

2. Proposed GGNS Operating License Changes (mark-up)

3. Revised GGNS Operating License Pages

4. Revised Cyber Security Plan Implementation Schedule (contains SRI)

5. List of Regulatory Commitments This letter contains security-related information - Attachments 1 and 4 are withheld from public disclosure per 10 CFR 2.390

Attachment 2 GN RO-2013/00090 Proposed GGNS Operating License Changes (mark-up)

(b) SERI is required to notify the NRC in writing prior to any change in (i) the terms or conditions of any new or existing sale or lease agreements executed as part of the above authorized financial transactions, (ii) the GGNS Unit 1 operating agreement, (iii) the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19, 1988 attached to Amendment No. 54. In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.

C. The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I 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 or incorporated below:

(1) Maximum Power Level Entergy Operations, Inc. is authorized to operate the facility at reactor core power levels not in excess of 4408 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. ~ are hereby incorporated into this license. Entergy Operations, Inc.

shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an "indicate only" mode and technical specification requirements will not apply to this function. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations. Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be applied to the function; no further operating with this function in an "indicate only" mode will be conducted.

4 Amendment No. ~

(h) This license condition shall expire upon satisfaction of the requirements in paragraph (f) provided that a visual inspection of the steam dryer does not reveal any new unacceptable flaw or unacceptable flaw growth that is caused by fatigue.

D. The facility required exemptions from certain requirements of Appendices A and J to 10 CFR Part 50 and from certain requirements of 10 CFR Part 100. These include: (a) exemption from General Design Criterion 17 of Appendix A until startup following the first refueling outage. for (1) the emergency override of the test mode for the Division 3 diesel engine. (2) the second level undervoltage protection for the Division 3 diesel engine, and (3) the generator ground over current trip function for the Division 1 and 2 diesel generators (Section 8.3.1 of SSER #7) and (b) exemption from the requirements of Paragraph III.D.2(b)(ii) of Appendix J for the containment airlock testing following normal door opening when containment integrity is not required (Section 6.2.6 of SSER #7). These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. In addition, by exemption dated December 20, 1986. the Commission exempted licensees from 10 CFR 100.11(a)(1). insofar as it incorporates the definition of exclusion area in 10 CFR 100.3(a). until April 30, 1987 regarding demonstration of authority to control all activities within the exclusion area (safety evaluation accompanying Amendment No. 27 to License (NPF-29). This exemption is authorized by law. and will not present an undue risk to the public health and safety, and is consistent with the common defense and security. In addition. special circumstances have been found justifying the exemption. Therefore. these exemptions are hereby granted pursuant to 10 CFR 50.12. with the granting of these exemptions, the facility will operate. to the extent authorized herein, in conformity with the application. as amended.

the provisions of the Act and the rules and regulations of the Commission.

E. The licensee shall fully implement and maintain in effect all provision 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 plans. which contain Safeguards Information protected under 10 CFR 73.21. are entitled: "Physical Security, Safeguards Contingency and Training and Qualification Plan," and were submitted to the NRC on May 18. 2006.

The licensee 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). The licensee's CSP was approved by License Amendment No. 192 and xxx.

16f Amendment -l-9 Attachment 3 GNRO-2013/00090 Revised GGNS Operating License Pages

(b) SERI is required to notify the NRC in writing prior to any change in (i) the terms or conditions of any new or existing sale or lease agreements executed as part of the above authorized financial transactions, (ii) the GGNS Unit 1 operating agreement, (iii) the existing property insurance coverage for GGNS Unit 1 that would materially alter the representations and conditions set forth in the Staff's Safety Evaluation Report dated December 19, 1988 attached to Amendment No. 54. In addition, SERI is required to notify the NRC of any action by a lessor or other successor in interest to SERI that may have an effect on the operation of the facility.

C. The license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10CFR Chapter I 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 or incorporated below:

(1) Maximum Power Level Entergy Operations, Inc. is authorized to operate the facility at reactor core power levels not in excess of 4408 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. xxx are hereby incorporated into this license. Entergy Operations, Inc.

shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

During Cycle 19, GGNS will conduct monitoring of the Oscillation Power Range Monitor (OPRM). During this time, the OPRM Upscale function (Function 2.f of Technical Specification Table 3.3.1.1-1) will be disabled and operated in an uindicate only" mode and technical specification requirements will not apply to this function. During such time, Backup Stability Protection measures will be implemented via GGNS procedures to provide an alternate method to detect and suppress reactor core thermal hydraulic instability oscillations. Once monitoring has been successfully completed, the OPRM Upscale function will be enabled and technical specification requirements will be applied to the function; no further operating with this function in an uindicate only" mode will be conducted.

4 Amendment No. +/-%,

(h) This license condition shall expire upon satisfaction of the requirements in paragraph (f) provided that a visual inspection of the steam dryer does not reveal any new unacceptable flaw or unacceptable flaw growth that is caused by fatigue.

D. The facility required exemptions from certain requirements of Appendices A and J to 10 CFR Part 50 and from certain requirements of 10 CFR Part 100. These include: (a) exemption from General Design Criterion 17 of Appendix A until startup following the first refueling outage. for (1) the emergency override of the test mode for the Division 3 diesel engine. (2) the second level undervoltage protection for the Division 3 diesel engine. and (3) the generator ground over current trip function for the Division 1 and 2 diesel generators (Section 8.3.1 of SSER #7) and (b) exemption from the requirements of Paragraph III.D.2(b)(ii) of Appendix J for the containment airlock testing following normal door opening when containment integrity is not required (Section 6.2.6 of SSER #7). These exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. In addition.

by exemption dated December 20. 1986. the Commission exempted licensees from 10 CFR 100.11(a)(1). insofar as it incorporates the definition of exclusion area in 10 CFR 100.3(a). until April 30.

1987 regarding demonstration of authority to control all activities within the exclusion area (safety evaluation accompanying Amendment No. 27 to License (NPF-29). This exemption is authorized by law. and will not present an undue risk to the public health and safety, and is consistent with the common defense and security. In addition, special circumstances have been found justifying the exemption. Therefore. these exemptions are hereby granted pursuant to 10 CFR 50.12. with the granting of these exemptions. the facility will operate. to the extent authorized herein. in conformity with the application. as amended.

the provisions of the Act and the rules and regulations of the Commission.

E. The licensee shall fully implement and maintain in effect all provision 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 plans, which contain Safeguards Information protected under 10 CFR 73.21. are entitled: "Physical Security.

Safeguards Contingency and Training and Qualification Plan." and were submitted to the NRC on May 18. 2006.

The licensee 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). The licensee's CSP was approved by License Amendment No. 192 and xxx.

16f Amendment No. ~,

Attachment 5 GNRO-2013/00090 List of Regulatory Commitments to GNRO-2013/00090 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 DATE ONE-TIME CONTINUING (If Required)

ACTION COMPLIANCE Full implementation of Grand Gulf X June 30, 2016 Nuclear Station Cyber Security Plan for all safety, security, and emergency preparedness functions will be achieved.