ML11109A060

Response to Request for Additional Information Regarding Cyber Security Plan License Amendment Request

ML11109A060
Person / Time
Site:	Sequoyah
Issue date:	04/07/2011
From:	Krich R Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TS-09-06
Download: ML11109A060 (14)

Text

SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 Tennessee Valley Authority 1101 Market Street, LP 3R Chattanooga, Tennessee 37402-2801 R. M. Krich Vice President Nuclear Licensing April 7, 2011 10 CFR 50.4 TS-09-06 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328

Subject:

Response to Request for Additional Information Regarding Sequoyah Nuclear Plant Cyber Security Plan License Amendment Request

References:

1. Letter from TVA to NRC, "Request for Approval of the Sequoyah Nuclear Plant Cyber Security Plan," dated November 23, 2009

2. Letter from TVA to NRC, "Request for Approval of the Sequoyah Nuclear Plant Cyber Security Plan - Supplement," dated December 11, 2009 3 Letter from TVA to NRC, "Supplement to Request for Approval of the Sequoyah Nuclear Plant Cyber Security Plan," dated December 18, 2009 4 Letter from WVA to NRC, "Third Supplement to Request for Approval of the Sequoyah Nuclear Plant Cyber Security Plan,"

dated July 23, 2010

5. Letter from NRC (Lingam) to TVA (Krich), "Browns Ferry Nuclear Plant, Units 1, 2 and 3, Sequoyah Nuclear Plant, Units 1 and 2 and Watts Bar Nuclear Plant, Units 1 and 2 - Request for Additional Information Regarding Cyber Security Plans Based on Nuclear Energy Institute 08-09, Revision 6 (TAC Nos. ME4952, ME4953, ME4954, ME4955, ME4956, ME4951 and ME4958)," dated March 8, 2011 SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 ENCLOSURES 1, 2, AND 4 TO THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. SECURITY-RELATED INFORMATION CLASSIFICATION DOES NOT APPLY TO THIS PAGE WHEN SEPARATED FROM ENCLOSURES 1, 2, AND 4.

printed on recycled paper

SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 U.S. Nuclear Regulatory Commission Page 2 April 7, 2011 In Reference 1, as supplemented by References 2, 3 and 4, the Tennessee Valley Authority (TVA), submitted a request for amendment to the Facility Operating Licenses (FOL) for the Sequoyah Nuclear Plant (SQN), Units 1 and 2. The proposed amendment requests NRC approval of the Cyber Security Plan for SQN and provides revisions to the existing FOL Physical Protection license condition and to the Cyber Security Plan Implementation Schedule for SQN.

By letter dated March 8, 2011 (Reference 5), the NRC requested that additional information be submitted by TVA to support the NRC's review of the license amendment request. In Reference 5, the NRC requested that TVA provide a response within 30 days of the date of the letter. Accordingly, this submittal is due by April 7, 2011. provides TVA's responses to the NRC's Request for Additional Information questions in Reference 5. contains the Cyber Security Plan Implementation Schedule for SQN, revised as discussed in Enclosure 1. contains revised pages for the Physical Protection license condition for SQN, Units 1 and 2, to add a reference date of April 7, 2011, to this supplement. The pages in Enclosure 3 replace, in their entirety, the marked-up and re-typed pages previously submitted in Attachments 1 and 2 to Enclosure 1 of Reference 4. provides a revised copy of the Cyber Security Plan for SQN, Revision 0, which incorporates the changes discussed in Enclosure 1. No other changes have been made to the Cyber Security Plan. The Cyber Security Plan for SQN provided in replaces, in its entirety, the Cyber Security Plan previously submitted as of Reference 4.

Enclosures 1, 2, and 4 contain security-related information. TVA requests that Enclosures 1, 2, and 4 be withheld from public disclosure in accordance with 10 CFR 2.390, "Public inspections, exemptions, requests for withholding."

Additionally, in accordance with 10 CFR 50.91 (b)(1), WVA is sending a copy of this letter and attachments to the Tennessee State Department of Environment and Conservation.

The changes discussed clarify the information submitted in Reference 4 and do not impact the conclusions of the no significant hazards consideration determination previously provided in Reference 3.

SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 ENCLOSURES 1, 2, AND 4 TO THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. SECURITY-RELATED INFORMATION CLASSIFICATION DOES NOT APPLY TO THIS PAGE WHEN SEPARATED FROM ENCLOSURES 1, 2, AND 4.

SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 U.S. Nuclear Regulatory Commission Page 3 April 7, 2011 There are no commitments associated with this submittal. If you have any questions regarding this submittal, please contact Kara Stacy at (423) 751-3489.

I declare under the penalty of perjury that the foregoing is true and correct. Executed on 7 th day of April, 2011.

Respectfully, R. M. Kr

Enclosures:

1. Response to Request for Additional Information Regarding Sequoyah Nuclear Plant Cyber Security Plan License Amendment Request

2. Cyber Security Plan Implementation Schedule for Sequoyah Nuclear Plant

3. Proposed Facility Operating License Changes

4. Cyber Security Plan for Sequoyah Nuclear Plant cc (Enclosures):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Sequoyah Nuclear Plant Director, Division of Radiological Health - Tennessee State Department of Environment and Conservation (w/o Enclosures 2 and 4)

SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 ENCLOSURES 1, 2, AND 4 TO THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. SECURITY-RELATED INFORMATION CLASSIFICATION DOES NOT APPLY TO THIS PAGE WHEN SEPARATED FROM ENCLOSURES 1, 2, AND 4.

Enclosure 3 Proposed Facility Operating License Change (Marked-Up and Re-Typed)

Sequoyah Nuclear Plant, Unit I Proposed Facility Operating License Change (Marked-Up)

-1 2b-E. Physical Protection

~ 1 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 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: "Sequoyah Nuclear Plant Security Plan, Training And Qualification Plan, And Safeguards Contingency Plan" submitted by letter dated May 8, 2006.

(2) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Sequoyah Nuclear Plant Cyber Security Plan submitted by letter dated April 7, 2011, and withheld from public disclosure wU in accordance with 10 CFR 2.390.

Ur) z October 28, 2008 Amendment No. 10, 53, 73, 193, 200, 213, 223, 292

Sequoyah Nuclear Plant, Unit 2 Proposed Facility Operating License Change (Marked-Up)

-12a-A temporary exemption from General Design Criterion 57 found in Appendix A to 10 CFR part 50 is described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplement No. 5, Section 6.2.4. 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. The exemption, therefore, is hereby granted and shall remain in effect through the first refueling outage as discussed in Section 6.2.4 of Supplement 5 to the Safety Evaluation Report. The granting of the exemption is authorized with the issuance of the Facility Operating License. The facility will operate, to the extent authorized herein, in conformity with the application as amended, the provisions of the Act, and the regulations of the Commission. Additional Exemptions are listed in Attachment 2.

E. Physical Protection INSERT Eq 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 contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Sequoyah Nuclear Plant Security Plan, Training And Qualification Plan, And Safeguards Contingency Plan" submitted by letter dated May 8, 2006.

F. Reactor Safety Methodology Applications Programs (Section 24.0)

TVA will provide a report prepared by the Kaman Sciences Corporation (KSC) on a full scale nuclear safety and availability analysis within six months from the date of the KSC report.

G. This amended license is subject to the following additional condition for the protection of the environment:

Before engaging in additional construction or operational activities which may result in an environmental impact that was not evaluated by the Commission, Tennessee Valley Authority will prepare and record an environmental evaluation of such activity. When the evaluation indicates that such activity may result in a significant adverse environmental impact that was not evaluated, or that is significantly greater than that evaluated in the Final Environmental Statement prepared by the Tennessee Valley Authority and the Environmental Impact Appraisal prepared by the Commission in May 1979, the Tennessee Valley Authority shall provide a written evaluation of such activities and obtain prior approval from the Director, Office of Nuclear Reactor Regulation.

H. Deleted

1. TVA shall immediately notify the Commission of any accident at this facility which could result in an unplanned release of quantities of fission products in excess of allowable limits for normal operation established by the Commission.

J. TVA 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.

INSERT (2) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Sequoyah Nuclear Plant Cyber Security Plan submitted by letter dated April 7, 2011, and withheld from public disclosure in accordance with 10 CFR 2.390.

October 28, 2008 Amendment 2, 65, 162, 170, 204, 214, 267, 273, 282

K. This amended license is effective as of the date of issuance and shall expire September 15, 2021.

FOR THE NUCLEAR REGULATORY COMMISSION Harold R. Denton, Director Office of Nuclear Reactor Regulation Attachments:

1. Attachment 1

2. Appendices A and B Technical Specifications Date of Issuance: September 15, 1981 December 29, 1988 Amendment No. 2, 83

Sequoyah Nuclear Plant, Unit I Proposed Facility Operating License Change (Re-Typed)

-12b-E. Physical Protection (1) 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 contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Sequoyah Nuclear Plant Security Plan, Training And Qualification Plan, And Safeguards Contingency Plan" submitted by letter dated May 8, 2006.

(2) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Sequoyah Nuclear Plant Cyber Security Plan submitted by letter dated April 7, 2011, and withheld from public disclosure in accordance with 10 CFR 2.390.

Amendment No. 10, 53, 73, 193, 200, 213, 223, 292,

Sequoyah Nuclear Plant, Unit 2 Proposed Facility Operating License Change (Re-Typed)

-12a-A temporary exemption from General Design Criterion 57 found in Appendix A to 10 CFR part 50 is described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplement No. 5, Section 6.2.4. 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. The exemption, therefore, is hereby granted and shall remain in effect through the first refueling outage as discussed in Section 6.2.4 of Supplement 5 to the Safety Evaluation Report. The granting of the exemption is authorized with the issuance of the Facility Operating License. The facility will operate, to the extent authorized herein, in conformity with the application as amended, the provisions of the Act, and the regulations of the Commission. Additional Exemptions are listed in Attachment 2.

E. Physical Protection (1) 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 contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Sequoyah Nuclear Plant Security Plan, Training And Qualification Plan, And Safeguards Contingency Plan" submitted by letter dated May 8, 2006.

(2) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Sequoyah Nuclear Plant Cyber Security Plan submitted by letter dated April 7, 2011, and withheld from public disclosure in accordance with 10 CFR 2.390.

F. Reactor Safety Methodology Applications Programs (Section 24.0)

TVA will provide a report prepared by the Kaman Sciences Corporation (KSC) on a full scale nuclear safety and availability analysis within six months from the date of the KSC report.

G. This amended license is subject to the following additional condition for the protection of the environment:

Before engaging in additional construction or operational activities which may result in an environmental impact that was not evaluated by the Commission, Tennessee Valley Authority will prepare and record an environmental evaluation of such activity. When the evaluation indicates that such activity may result in a significant adverse environmental impact that was not evaluated, or that is significantly greater than that evaluated in the Final Environmental Statement prepared by the Tennessee Valley Authority and the Environmental Impact Appraisal prepared by the Commission in May 1979, the Tennessee Valley Authority shall provide a written evaluation of such activities and obtain prior approval from the Director, Office of Nuclear Reactor Regulation.

H. Deleted TVA shall immediately notify the Commission of any accident at this facility which could result in an unplanned release of quantities of fission products in excess of allowable limits for normal operation established by the Commission.

Amendment 2, 65, 162, 170, 204, 214, 267, 273, 282,

J. TVA 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.

K. This amended license is effective as of the date of issuance and shall expire September 15, 2021.

FOR THE NUCLEAR REGULATORY COMMISSION Harold R. Denton, Director Office of Nuclear Reactor Regulation Attachments:

1. Attachment 1

2. Appendices A and B Technical Specifications Date of Issuance: September 15, 1981 Amendment No. 2, 83,