ML11199A217
| ML11199A217 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/15/2011 |
| From: | Krich R Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC ME4951, TAC ME4952, TAC ME4953, TAC ME4954, TAC ME4955, TAC ME4956, TAC ME4958, TS-470 | |
| Download: ML11199A217 (16) | |
Text
Tennessee Valley Authority 1101 Market Street, LP 3R Chattanooga, Tennessee 37402-2801 R. M. Krich Vice President Nuclear Licensing July 15, 2011 TS-470 10 CFR 50.4 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296
Subject:
References:
Response to Requested Changes Regarding Browns Ferry Nuclear Plant Cyber Security Plan License Amendment Request
- 1. Letter from TVA to NRC, "Request for Approval of the Browns Ferry Nuclear Plant Cyber Security Plan," dated November 23, 2009
- 2. Letter from TVA to NRC, "Supplement to Request for Approval of the Browns Ferry Nuclear Plant Cyber Security Plan," dated December 18, 2009
- 3. Letter from TVA to NRC, "Second Supplement to Request for Approval of the Browns Ferry Nuclear Plant Cyber Security Plan,"
dated July 23, 2010
- 4. 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
- 5. Letter from WVA to NRC, "Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant Cyber Security Plan License Amendment Request," dated April 7, 2011 In Reference 1, as supplemented by References 2 and 3, the Tennessee Valley Authority (TVA) submitted a request for an amendment to the Facility Operating Licenses (FOLs) for the Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3. The proposed amendment requests NRC approval of the Cyber Security Plan for BFN and S~oiA printed on recycled paper
U.S. Nuclear Regulatory Commission Page 2 July 15, 2011 provides revisions to the existing FOL Physical Protection license condition, and also provides the Cyber Security Plan Implementation Schedule for BFN.
By letter dated March 8, 2011 (Reference 4), the NRC requested that additional information be submitted by TVA within 30 days of receipt of the March 8 letter in order to support the NRC review of the license amendment request. Reference 5 provided the requested 30-day response information. Based on subsequent correspondence from the NRC, the submitted supplemental information was acceptable and there were no further questions. During a July 6, 2011, telephone call between NRC and TVA representatives, the NRC requested that the proposed change to the FOL Physical Protection license condition be revised slightly to incorporate the language as agreed to during internal discussions among the NRC staff, and that this revision be submitted by July 15, 2011.
The Enclosure to this letter contains the revised pages for the FOL Physical Protection license condition for BFN, Units 1, 2, and 3, which incorporates the revised language as requested by the NRC. The pages in the Enclosure to this letter replace, in their entirety, the marked-up and re-typed pages previously submitted as Enclosure 3 of Reference 5. No other changes have been made to the previous submittals regarding the Cyber Security Plan.
Additionally, in accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and Enclosure to the Alabama Department of Public Health.
The changes discussed herein are of an editorial nature and do not impact the conclusions of the no significant hazards consideration determination previously provided in Reference 2.
There are no commitments associated with this submittal. If you have any questions regarding this submittal, please contact Clyde Mackaman at 423-751-2834.
I declare under the penalty of perjury that the foregoing is true and correct. Executed on the 1 5 th day of July 2011.
Respectfully, R. M. Krich
Enclosure:
Proposed Facility Operating License Changes (Marked-Up and Re-Typed) cc (Enclosure):
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant State Health Officer - Alabama Department of Public Health
Enclosure Proposed Facility Operating License Changes (Marked-Up and Re-Typed)
Browns Ferry Nuclear Plant, Unit I Proposed Facility Operating License Changes (Marked-Up)
(8)
Deleted.
(9)
Deleted.
(10)
Deleted.
INSERT (a)
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:
"Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.
(12)
Deleted.
(13)
Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for BFN as approved in the safety evaluations dated December 8, 1988; March 31, 1993; April 1, 1993; November 2, 1995; April 25, 2007, and Supplement dated November 3, 1989; subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
(14)
The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).
(15)
The licensee is required to confirm that the conclusions made in TVA's letter dated September 17, 2004, for the turbine building remain acceptable using seismic demand accelerations based on dynamic seismic analysis prior to the restart of Unit 1.
(16)
Upon implementation of Amendment No. 275, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c.(i), the assessment of the CRE habitability as required by TS 5.5.13.c.(ii), and the measure of CRE INSERT pressure as required by TS 5.5.13.d, shall be considered met.
(b)
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 CSP was approved by License Amendment No. [###].
I BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 275 October 16, 2009
Browns Ferry Nuclear Plant, Unit 2 Proposed Facility Operating License Changes (Marked-Up)
(8)
Deleted.
(9)
Deleted.
(10)
Deleted.
MINSERT (a)
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: "Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.
(12)
Deleted.
(13)
Deleted.
(14) Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for BFN as approved in the safety evaluations dated December 8, 1988; March 31, 1993; April 1, 1993; November 2, 1995; April 25, 2007, and Supplement dated November 3, 1989; subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
(15)
The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).
(16)
Upon complementation of Amendment No. 302, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5.13.c(ii), and the measurement of CRE pressure as required by TS 5.5.13.d, shall be considered met.
INSERT (b)
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 CSP was approved by License Amendment No. [###].
BFN-UNIT 2 Renewed License No. DPR-52 Rovised by ltte-dated August 16, 2007, Amendment 302 October 16, 2009
Browns Ferry Nuclear Plant, Unit 3 Proposed Facility Operating License Changes (Marked-Up)
(3)
The licensee is authorized to relocate certain requirements included in Appendix A and the former Appendix B to licensee-controlled documents.
Implementation of this amendment shall include the relocation of these requirements to the appropriate documents, as described in the licensee's application dated September 6, 1996; as supplemented May 1, August 14, November 5 and 14, December 3, 4, 11, 22, 23, 29, and 30, 1997; January 23, March 12, April 16, 20, and 28, May 7, 14, 19, and 27, and June 2, 5, 10 and 19, 1998; evaluated in the NRC staffs Safety Evaluation enclosed with this amendment. This amendment is effective immediately and shall be implemented within 90 days of the date of this amendment.
(4)
Deleted.
(5)
Classroom and simulator training on all power uprate related changes that affect operator performance will be conducted prior to operating at uprated conditions. Simulator changes that are consistent with power uprate conditions will be made and simulator fidelity will be validated in accordance with ANSI/ANS 3.5-1985. Training and the plant simulator will be modified, as necessary, to incorporate changes identified during startup testing. This amendment is effective immediately.
(6)
The licensee shall fully implement and maintain in effect all provisions of INSERT the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant (a) 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: "Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," Revision 4, submitted by letter dated April 28, 2006.
(7)
Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for BFN as approved in the safety evaluations dated December 8, 1988; March 31, 1993; April 1, 1993; November 2, 1995; April 25, 2007, and Supplement dated November 3, 1989; subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
INSERT (8)
Deleted.
(b)
The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to 10 CFR 50.90 and 10 CFR 50.54(p). The licensee CSP was approved by License Amendment No. [###].
BFN-UNIT 3 Renewed License No. DPR-68 Amendment No. 259 April 25, 2007
Browns Ferry Nuclear Plant, Unit I Proposed Facility Operating License Changes (Re-Typed)
(8)
Deleted.
(9)
Deleted.
(10)
Deleted.
(11)(a) 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:
"Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.
(b) 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 CSP was approved by License Amendment No. [##].
(12)
Deleted.
(13)
Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for BFN as approved in the safety evaluations dated December 8, 1988; March 31, 1993; April 1, 1993; November 2, 1995; April 25, 2007, and Supplement dated November 3, 1989; subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
(14)
The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).
(15)
The licensee is required to confirm that the conclusions made in TVA's letter dated September 17, 2004, for the turbine building remain acceptable using seismic demand accelerations based on dynamic seismic analysis prior to the restart of Unit 1.
(16)
Upon implementation of Amendment No. 275, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c.(i), the assessment of the CRE habitability as required by TS 5.5.13.c.(ii), and the measure of CRE pressure as required by TS 5.5.13.d, shall be considered met.
BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 27-, [#]
[Month ##, ##]
Browns Ferry Nuclear Plant, Unit 2 Proposed Facility Operating License Changes (Re-Typed)
(8)
Deleted.
(9)
Deleted.
(10)
Deleted.
(11)(a) 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:
"Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," submitted by letter dated April 28, 2006.
(b) 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 CSP was approved by License Amendment No. [m].
(12)
Deleted.
(13)
Deleted.
(14)
Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for BFN as approved in the safety evaluations dated December 8, 1988; March 31, 1993; April 1, 1993; November 2, 1995; April 25, 2007, and Supplement dated November 3, 1989; subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
(15)
The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).
(16)
Upon implementation of Amendment No. 302, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c.(i), the assessment of the CRE habitability as required by TS 5.5.13.c.(ii), and the measure of CRE pressure as required by TS 5.5.13.d, shall be considered met.
BFN-UNIT 2 Renewed License No. DPR-52 Revisod by letteFr dted August 16, 2007, Amendment 302-, [#
[Month ##,##]
Browns Ferry Nuclear Plant, Unit 3 Proposed Facility Operating License Changes (Re-Typed)
(3)
The licensee is authorized to relocate certain requirements included in Appendix A and the former Appendix B to licensee-controlled documents.
Implementation of this amendment shall include the relocation of these requirements to the appropriate documents, as described in the licensee's application dated September 6, 1996; as supplemented May 1, August 14, November 5 and 14, December 3, 4, 11, 22, 23, 29, and 30, 1997; January 23, March 12, April 16, 20, and 28, May 7, 14, 19, and 27, and June 2, 5, 10 and 19, 1998; evaluated in the NRC staffs Safety Evaluation enclosed with this amendment. This amendment is effective immediately and shall be implemented within 90 days of the date of this amendment.
(4)
Deleted.
(5)
Classroom and simulator training on all power uprate related changes that affect operator performance will be conducted prior to operating at uprated conditions. Simulator changes that are consistent with power uprate conditions will be made and simulator fidelity will be validated in accordance with ANSI/ANS 3.5-1985. Training and the plant simulator will be modified, as necessary, to incorporate changes identified during startup testing. This amendment is effective immediately.
(6)(a) 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: "Browns Ferry Nuclear Plant Physical Security Plan, Training and Qualification Plan, and Contingency Plan," Revision 4, submitted by letter dated April 28, 2006.
(b) 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 CSP was approved by License Amendment No. [###].
(7)
Browns Ferry Nuclear Plant shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for BFN as approved in the safety evaluations dated December 8, 1988; March 31, 1993; April 1, 1993; November 2, 1995; April 25, 2007, and Supplement dated November 3, 1989; subject to the following provision:
The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.
BFN-UNIT 3 Renewed License No. DPR-68 Amendment 2-W, [##]
[Month #,
- ]
(8) Deleted.
(9) The licensee shall maintain the Augmented Quality Program for the Standby Liquid Control System to provide quality control elements to ensure component reliability for the required alternative source term function defined in the Updated Final Safety Analyses Report (UFSAR).
(10) 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 (c) Actions to minimize release to include consideration of:
- 1. Water spray scrubbing
- 2. Dose to onsite responders (11) The licensee shall implement and maintain all Actions required by to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.
(12) Upon completion of Amendment No. 261, adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.3.4, in accordance with TS 5.5.13.c(i), the assessment of the CRE habitability as required by TS 5.5.13.c(ii), and the measurement of the CRE pressure as required by TS 5.5.13.d, shall be considered met.
BFN-UNIT 3 Renewed License No. DPR-68 Amendment 264, [###]
[Month ##, ####]