SBK-L-14140, License Amendment Request (LAR) 14-05, Request to Amend the Cyber Security Plan Implementation Schedule Submittal of Non-SRI Regulatory and Environmental Evaluations

License Amendment Request (LAR) 14-05, Request to Amend the Cyber Security Plan Implementation Schedule Submittal of Non-SRI Regulatory and Environmental Evaluations

ML14205A421
Person / Time
Site:	Seabrook
Issue date:	07/22/2014
From:	Dean Curtland NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 14-05, SBK-L-14140
Download: ML14205A421 (5)

Text

NEXTera ENERGY V SEABROK July 22, 2014 SBK-L-14140 10 CFR 50.90 Docket No. 50-443 Facility Operating License No. NPF-86 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Seabrook Station License Amendment Request (LAR) 14-05, Request to Amend The Cyber Security Plan Implementation Schedule Submittal of Non-SRI Regulatory and Environmental Evaluations

Reference:

NextEra Energy Seabrook LLC letter SBK-L-14104, "License Amendment Request 14-05, Request to Amend The Cyber Security Plan Implementation Schedule," dated July 10, 2014.

Pursuant to 10 CFR 50.90, NextEra Energy Seabrook, LLC, (NextEra Energy Seabrook) requested to amend the Cyber Security Plan implementation schedule for Seabrook Station in Reference 1. Reference 1 was submitted under the provisions of 10 CFR 2.390 because it contained security - related information (SRI).

At the NRC's request, NextEra is resubmitting a non-SRI version of the Regulatory Evaluation and Environmental Consideration portions of the amendment request in the attachment to this letter.

There are no regulatory commitments contained in this correspondence.

If you have any questions or require additional information, please contact Michael Ossing,.

Licensing Manager, at 603-773-7512.

NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874 ou Jkl E_ý-

U.S. Nuclear Regulatory Commission SBK-L- 14140/Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on July 2z, 2014 Sincerely, NextEra Energy Seabrook, LLC Dean Curtland Site Vice President

Attachment:

Non-SRI Version of the Regulatory Evaluation and Environmental Consideration Portions of License Amendment Request 14-05, Request to Amend The Cyber Security Plan Implementation Schedule cc: W. M. Dean NRC Region I Administrator J. G. Lamb NRC Project Manager P. C. Cataldo NRC Senior Resident Inspector Mr. Perry Plummer Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

Attachment to SBK-L-14140 Non-SRI Version of the Regulatory Evaluation and Environmental Consideration Portions of License Amendment Request 14-05, Request to Amend The Cyber Security Plan Implementation Schedule

Non-SRI Version of the Regulatory Evaluation and Environmental Consideration Portions of License Amendment Request 14-05, Request to Amend The Cyber Security Plan Implementation Schedule

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Regquirements/Criteria 10 CFR 73.54 requires NextEra Energy Seabrook to maintain and implement a Cyber Security Plan (CSP). Seabrook Station, Unit No. 1 NPF-86 includes a Physical Protection license condition that requires NextEra Energy Seabrook to fully implement and maintain in effect all provisions of the Commission-approved CSP, including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

4.2 No Significant Hazards Consideration Determination NextEra Energy Seabrook is requesting approval of changes to Seabrook Station, Unit No. 1 NPF-86 to revise the Physical Protection license condition as it relates to the Cyber Security Plan. This change includes a proposed deviation to the Cyber Security Plan implementation schedule and a proposed revision to the Seabrook Station, Unit No. 1 NPF-86 to include the proposed deviation. Specifically, NextEra Energy Seabrook, LLC proposes to change the completion date for full implementation (Milestone 8) of the Cyber Security Plan.

NextEra Energy Seabrook 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 described 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. The 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, tested, or inspected. The proposed change does not require any plant modifications which affect the performance capability or 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.

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.

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L 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 of operation, limiting safety systems 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 in these established safety margins as 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, NextEra Energy Seabrook 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.

4.3 Conclusion Based on the considerations described 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 in compliance with the Commission's regulations, and (3) the issuance of amendments will not be inimical to the common defense and security or to the health and safety of the public.

5. 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)(9), (10), (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 this amendment.

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