ML12181A415
| ML12181A415 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/28/2012 |
| From: | Entergy Operations |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML121840038 | List: |
| References | |
| W3F1-2012-0049 | |
| Download: ML12181A415 (3) | |
Text
Attachment 1 to W3F1-2012-0049 Page 3 of 5
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 10 CFR 73.54 requires licensees to maintain and implement a cyber security plan. Waterford Steam Electric Station, Unit 3 (Waterford 3) Facility Operating License, No. NPF-38, includes a Physical Protection license condition that requires Entergy Operations, Inc. (Entergy) to fully implement and maintain in effect all provisions of the Commission-approved cyber security plan, including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).
4.2 Precedent Amendment No. 203 for the Callaway Plant (Reference 5) approved an implementation schedule using the Nuclear Energy Institute (NEI) template (Reference 3), with the exception of Milestone 6. The Callaway Plant deviated from the template for Milestone 6 to address only the NEI 08-09, Revision 6, Appendix D technical controls, excepting for the operational and management controls, on the basis that implementing the technical controls for the target set critical digital assets provides a high degree of protection against cyber related attacks that could lead to radiological sabotage.
The changes being proposed by Entergy in this amendment request are similar to those approved in the Callaway Plant Amendment No. 203.
4.3 Significant Safety Hazards Consideration Entergy is requesting an amendment to the Waterford 3 Facility Operating License to revise the Physical Protection license condition as it relates to the Cyber Security Plan. This change includes a proposed deviation to the scope of a Cyber Security Plan Implementation Schedule milestone and a proposed revision to the Waterford 3 Facility Operating License to include the proposed deviation. Specifically, Entergy proposes a change to the scope of Implementation Milestone 6 to apply to only technical cyber security controls.
Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:
- 1.
Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed change to the Cyber Security Plan Implementation Schedule is administrative in nature. This change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected. The proposed change does not require any plant modifications which affect the performance capability of the structures, systems, and components relied upon to mitigate the consequences of postulated accidents, and has no impact on the probability or consequences of an accident previously evaluated.
to W3F1-2012-0049 Page 4 of 5 Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed change to the Cyber Security Plan Implementation Schedule is administrative in nature. This proposed change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems are operated, maintained, modified, tested, or inspected. The proposed change does not require any plant modifications which affect the performance capability of the structures, systems, and components relied upon to mitigate the consequences of postulated accidents, and does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3.
Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
Plant safety margins are established through limiting conditions for operation, limiting safety system settings, and safety limits specified in the technical specifications. The proposed change to the Cyber Security Plan Implementation Schedule is administrative in nature. Because there is no change to established safety margins as a result of this change, the proposed change does not involve a significant reduction in a margin of safety.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, Entergy concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.
4.4 Conclusion In conclusion, based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
to W3F1-2012-0049 Page 5 of 5
5.0 ENVIRONMENTAL CONSIDERATION
The proposed amendment provides a change to the Cyber Security Plan Implementation Schedule. The proposed amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51.22(c)(12). Therefore, pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 REFERENCES
- 1. NRC letter to Entergy, Issuance of Amendment Re: Approval of Cyber Security Plan(TAC ME4271), dated July 20, 2011 (ADAMS Accession No. ML111800021)
- 2. Entergy letter to NRC, Response to Additional Requests for Additional Information and Revision to the Waterford 3 Cyber Security Plan, dated April 4, 2011 (W3F1-2011-0021, ADAMS Accession No. ML110950122)
- 3. Letter from Chris Earls (NEI) to Richard P. Correia (NRC), Template for the Cyber Security Plan Implementation Schedule, dated February 28, 2011 (ADAMS Accession No. ML110600211)
- 4. Letter from Richard P. Correia (NRC) to Chris Earls (NEI), Template for the Cyber Security Plan Implementation Schedule, dated March 1, 2011 (ADAMS Accession No. ML110070348)
- 5. NRC letter from M. C. Thadani, USNRC, to A. C. Heflin, Union Electric Company, Callaway Plant, Unit 1 - Issuance of Amendment Re: Approval of Cyber Security Plan (TAC NO. ME4536), August 17, 2011 (ADAMS Accession No. ML112140087)