JAFP-12-0072, License Amendment Request - Cyber Security Plan Implementation Schedule Milestones

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License Amendment Request - Cyber Security Plan Implementation Schedule Milestones
ML12178A412
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 06/22/2012
From: Michael Colomb
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML121780518 List:
References
JAFP-12-0072, TAC ME4267
Download: ML12178A412 (12)


Text

SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-349-6024 Fax 315-349-6480 Michael J. Colomb Site Vice-President - JAF JAFP-12-0072 June 22, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

License Amendment Request - Cyber Security Plan Implementation Schedule Milestones James A. FitzPatrick Nuclear Power Plant Docket Nos. 50-333 License Nos. DPR-59

References:

1. NRC letter to Entergy, Issuance of Amendment Re: Approval of Cyber Security Plan, ML11152A011, dated August 19, 2011 (TAC NO. ME4267)
2. Entergy letter to NRC, Response to Additional Requests for Additional Information and Revision to the JAF Cyber Security Plan, JAFP-11-0035, dated April 4, 2011 (TAC NO. ME4267)

Dear Sir or Madam:

In Reference 1, the NRC issued license Amendment No. 300 to the Renewed Facility Operating License for James A. FitzPatrick Nuclear Power Plant (JAF) that approved the JAF Cyber Security Plan and associated implementation milestone schedule. The Cyber Security Plan Implementation Schedule contained in Reference 2 was utilized as a portion the basis for the NRCs safety evaluation report provided by Reference 1. Entergy Nuclear Operations, Inc. (Entergy) is planning to implement the requirements of implementation schedule milestone 6 in a slightly different manner than described in the approved implementation schedule. Although no change to the implementation schedule date is proposed, the change to the description of the milestone activity is conservatively considered to be a change to the Implementation Schedule, and in accordance with the provisions of 10 CFR 50.4 and 10 CFR 50.90, Entergy is submitting this request for an amendment to the Facility Operating License (FOL) for JAF. The JAF Cyber Security Plan, Revision 0 was previously provided in Reference 2. provides an evaluation of the proposed change. Attachment 2 contains proposed marked-up operating license pages for the Physical Protection license condition for JAF to reference the commitment change provided in this submittal. Attachment 3 contains the proposed revised operating license pages. Attachment 4 contains a change to the scope of implementation milestone 6. Entergy requests that Attachments 1 and 4, which contains security-related information (SRI), be withheld from public disclosure in accordance with 10 CFR 2.390.

Attachments 1 and 4 contains Sensitive Unclassified Non-Safeguards Information.

When separated from Attachments 1 and 4, this transmittal document is decontrolled.

SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 JAFP-12-0072 Page 2 of 3 contains 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 the 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 31,2012.

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 Mr. Joseph Pechacek, Licensing Manager, at 315-349-6766.

I declare under penalty of perjury that the foregoing is true and correct. Executed on June 22,2012.

Sincerely, Michael J. Colomb Site Vice President MC:JP:mh Attachments: 1. Analysis of Proposed Operating License Change

2. Proposed JAF Facility Operating License (FOL) Changes (mark-up)
3. Revised JAF Facility Operating License (FOL) Pages
4. Revised Cyber Security Plan Implementation Schedule
5. List of Regulatory Commitments cc: next page Attachments 1 and 4 contains Sensitive Unclassified Non-Safeguards Information.

When separated from Attachments 1 and 4, this transmittal document is decontrolled.

SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 JAFP-12-0072 Page 3 of 3 cc:

Mr. William Dean Regional Administrator, Region I U. S. Nuclear Regulatory Commission 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713 Resident Inspectors Office U.S. Nuclear Regulatory Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093 Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Mr. Mohan Thadani, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Ms. Bridget Frymire New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 Mr. Francis J. Murray Jr., President New York State Energy and Research Development Authority 17 Columbia Circle Albany, NY 12203-6399 Document Component(s):

001 Transmittal Letter JAFP-12-0072 002 JAFP-12-0072 Attachments 2, 3, and 5 003 JAFP-12-0072 Attachments 1 and 4 (Security-Related information)

Attachments 1 and 4 contains Sensitive Unclassified Non-Safeguards Information.

When separated from Attachments 1 and 4, this transmittal document is decontrolled.

Attachment 1 JAFP-12-0072 Analysis of Proposed Operating License Change (5 Pages)

Attachment 2 JAFP-12-0072 Proposed JAF Facility Operating License (FOL) Changes (mark-up)

(2 Pages)

FOL Page 3 FOL Page 5

(4) ENO pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess, and use, at any time, any byproduct, source and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration; or associated with radioactive apparatus, components or tools..

(5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; 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 ENO is authorized to operate the facility at steady state reactor core power levels not in excess of 2536 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 301, are hereby incorporated in the renewed operating license.

The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Fire Protection ENO shall implement and maintain in effect all provisions of the approved fire protections program as described in the Final Safety Analysis Report for the facility and as approved in the SER dated November 20, 1972; the SER Supplement No. 1 dated February 1, 1973; the SER Supplement No. 2 dated October 4, 1974; the SER dated August 1, 1979; the SER Supplement dated October 3, 1980; the SER Supplement dated February 13, 1981; the NRC Letter dated February 24, 1981; Technical Specification Amendments 34 (dated January 31, 1978), 80 (dated May 22, 1984), 134 (dated July 19, 1989), 135 (dated September 5, 1989), 142 (dated October 23, 1989), 164 (dated August 10, 1990), 176 (dated January 16, 1992), 177 (dated February 10, 1992), 186 (dated February 19, 1993),

190 (dated June 29, 1993), 191 (dated July 7, 1993), 206 (dated February 28, 1994) and 214 (dated June 27, 1994); and NRC Exemptions and associated safety evaluations dated April 26, 1983, July 1, 1983, January 11, 1985, April 30, 1986, September 15, 1986 and September 10, 1992 subject to the following provision:

Amendment 301

Safeguards Contingency Plan, Revision 0, submitted by letter dated October 26, 2004, as supplemented by letter dated May 17, 2006.

ENO shall fully implement in accordance with an NRC-approved implementation schedule and maintain in effect all provisions of the Commission-approved JAF Cyber Security Plan pursuant to 10 CFR 73.55(c)(6) and 10 CFR 73.54 (74 FR 13970) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The JAF Cyber Security Plan was approved by License Amendment No. 300 as supplemented by a change approved by License Amendment No.

E. Power Uprate License Amendment Implementation The licensee shall complete the following actions as a condition of the approval of the power uprate license amendment.

(1) Recirculation Pump Motor Vibration Perform monitoring of recirculation pump motor vibration during initial Cycle 13 power ascension for uprated power conditions.

(2) Startup Test Program The licensee will follow a startup testing program, during Cycle 13 power ascension, as described in GE Licensing Topical Report NEDC-31897P-1, Generic Guidelines for General Electric Boiling Water Reactor Power Uprate. The Startup test program includes system testing of such process control systems as the feedwater flow and main steam pressure control systems. The licensee will collect steady-state operational data during various portions of the power ascension to the higher licensed power level so that predicted equipment performance characteristics can be verified. The licensee will do the startup testing program in accordance with its procedures. The licensees approach is in conformance with the test guidelines of GE Licensing Topical Report NEDC-31897P-1, Generic Guidelines for General Electric Boiling Water Reactor Power Uprate. June 1991 (proprietary), GE Licensing Topical Report NEDO-31897, Generic Guidelines for General Electric Boiling Water Reactor Power Uprate. February 1992 (nonproprietary), and NEDC-31897P-AA, Class III (proprietary), May 1992.

(3) Human Factors The licensee will review the results of the Cycle 13 startup test program to determine any potential effects on operator training. Training issues identified will be incorporated in Licensed Operator training during 1997. Simulator discrepancies identified will be addressed in accordance with simulator Configuration Management procedural requirements.

F. Additional Conditions The Additional Conditions contained in Appendix C, as revised through Amendment No. 289, are herby incorporated into this renewed operating license. ENO shall operate the facility in accordance with the Additional Conditions.

Amendment 301

Attachment 3 JAFP-12-0072 Revised JAF Facility Operating License (FOL) Pages (2 Pages)

FOL Page 3 FOL Page 5

(4) ENO pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess, and use, at any time, any byproduct, source and special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration; or associated with radioactive apparatus, components or tools..

(5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; 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 ENO is authorized to operate the facility at steady state reactor core power levels not in excess of 2536 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. , are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3) Fire Protection ENO shall implement and maintain in effect all provisions of the approved fire protections program as described in the Final Safety Analysis Report for the facility and as approved in the SER dated November 20, 1972; the SER Supplement No. 1 dated February 1, 1973; the SER Supplement No. 2 dated October 4, 1974; the SER dated August 1, 1979; the SER Supplement dated October 3, 1980; the SER Supplement dated February 13, 1981; the NRC Letter dated February 24, 1981; Technical Specification Amendments 34 (dated January 31, 1978), 80 (dated May 22, 1984), 134 (dated July 19, 1989), 135 (dated September 5, 1989), 142 (dated October 23, 1989), 164 (dated August 10, 1990), 176 (dated January 16, 1992), 177 (dated February 10, 1992), 186 (dated February 19, 1993),

190 (dated June 29, 1993), 191 (dated July 7, 1993), 206 (dated February 28, 1994) and 214 (dated June 27, 1994); and NRC Exemptions and associated safety evaluations dated April 26, 1983, July 1, 1983, January 11, 1985, April 30, 1986, September 15, 1986 and September 10, 1992 subject to the following provision:

Amendment

Safeguards Contingency Plan, Revision 0, submitted by letter dated October 26, 2004, as supplemented by letter dated May 17, 2006.

ENO shall fully implement in accordance with an NRC-approved implementation schedule and maintain in effect all provisions of the Commission-approved JAF Cyber Security Plan pursuant to 10 CFR 73.55(c)(6) and 10 CFR 73.54 (74 FR 13970) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The JAF Cyber Security Plan was approved by License Amendment No. 300 as supplemented by a change approved by License Amendment No.

E. Power Uprate License Amendment Implementation The licensee shall complete the following actions as a condition of the approval of the power uprate license amendment.

(1) Recirculation Pump Motor Vibration Perform monitoring of recirculation pump motor vibration during initial Cycle 13 power ascension for uprated power conditions.

(2) Startup Test Program The licensee will follow a startup testing program, during Cycle 13 power ascension, as described in GE Licensing Topical Report NEDC-31897P-1, Generic Guidelines for General Electric Boiling Water Reactor Power Uprate. The Startup test program includes system testing of such process control systems as the feedwater flow and main steam pressure control systems. The licensee will collect steady-state operational data during various portions of the power ascension to the higher licensed power level so that predicted equipment performance characteristics can be verified. The licensee will do the startup testing program in accordance with its procedures. The licensees approach is in conformance with the test guidelines of GE Licensing Topical Report NEDC-31897P-1, Generic Guidelines for General Electric Boiling Water Reactor Power Uprate. June 1991 (proprietary), GE Licensing Topical Report NEDO-31897, Generic Guidelines for General Electric Boiling Water Reactor Power Uprate. February 1992 (nonproprietary), and NEDC-31897P-AA, Class III (proprietary), May 1992.

(3) Human Factors The licensee will review the results of the Cycle 13 startup test program to determine any potential effects on operator training. Training issues identified will be incorporated in Licensed Operator training during 1997. Simulator discrepancies identified will be addressed in accordance with simulator Configuration Management procedural requirements.

F. Additional Conditions The Additional Conditions contained in Appendix C, as revised through Amendment No. 289, are herby incorporated into this renewed operating license. ENO shall operate the facility in accordance with the Additional Conditions.

Amendment

Attachment 5 JAFP-12-0072 List of Regulatory Commitments (1 Page)

JAFP-12-0072 Attachment 5 List of Regulatory Commitments The following table identifies those actions committed to by Entergy Nuclear Operations, Inc.(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 Entergy will implement milestones 1, 2, 3, X December 31, 2012 4, 5, and 7 described in Attachment 4 of JAFP-11-0035, and the revised Milestone 6 in Attachment 4 of JAFP-12-0072.

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