ML11199A218

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Response to Requested Changes Regarding Cyber Security Plan License Amendment Request
ML11199A218
Person / Time
Site: Sequoyah  
Issue date: 07/15/2011
From: Krich R
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TS-09-06
Download: ML11199A218 (12)


Text

IFVIA Tennessee Valley Authority 1101 Market Street, LP 3R Chattanooga, Tennessee 37402-2801 R. M. Krich Vice President Nuclear Licensing July 15, 2011 TS-09-06 10 CFR 50.4 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:

References:

Response to Requested Changes Regarding Sequoyah Nuclear Plant Cyber Security Plan License Amendment Request

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 TVA 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 WVA (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
6. Letter from WVA to NRC, "Response to Request for Additional Information Regarding Sequoyah Nuclear Plant Cyber Security Plan License Amendment Request," dated April 7, 2011 In Reference 1, as supplemented by References 2, 3, and 4, the Tennessee Valley Authority (TVA), submitted a request for an amendment to the Facility Operating K\\QLt,4 printed on recycled paper

U.S. Nuclear Regulatory Commission Page 2 July 15, 2011 Licenses (FOLs) 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 also provides 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 within 30 days of receipt of the March 8 letter in order to support the NRC's review of the license amendment request. Reference 6 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 revised pages for the FOL Physical Protection license condition for SQN, Units 1 and 2, 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 6. 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 Tennessee State Department of Environment and Conservation.

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 3.

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.

Respectfuly 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 - Sequoyah Nuclear Plant Director, Division of Radiological Health - Tennessee State Department of Environment and Conservation

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

Sequoyah Nuclear Plant, Unit 1 Proposed Facility Operating License Changes (Marked-Up)

-12b-E.

Physical Protection Fi SET 71*

IThe licensee shall fully implement and maintain in effect all provisions of the Commission-L1"1 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.

INSERT (2)

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. [###].

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

Sequoyah Nuclear Plant, Unit 2 Proposed Facility Operating License Changes (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.

E.

Physical Protection (1)I 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 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 N INSERTJ 1amended, to cover public liability claims.

(2)

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. [###].

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

Sequoyah Nuclear Plant, Unit I Proposed Facility Operating License Changes (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 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. [##].

[Month ##, ####]

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.

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 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. [###].

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 I.

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.

[Month ##, ####]

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

[Month ##, ####]

Amendment No. 2, 83, [#]