ML14217A496
| ML14217A496 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/04/2014 |
| From: | Entergy Operations |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML14217A494 | List: |
| References | |
| W3F1-2014-0005 | |
| Download: ML14217A496 (7) | |
Text
Attachment 1 to W3F1-2014-0005 Page 6 of 8
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 10 CFR 73.54 requires licensees to maintain and implement a cyber security plan (CSP).
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 CSP, including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).
4.2 Significant Safety Hazards Consideration Entergy is requesting an amendment to the Waterford 3 Facility Operating Licenses to revise the Physical Protection license condition as it relates to the CSP. This change includes a proposed change to a CSP Implementation Schedule milestone date and a proposed revision to the Waterford 3 Facility Operating License to include the proposed deviation. Specifically, Entergy is proposing a change to the Implementation Milestone 8 completion date.
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 CSP 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.
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 CSP 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 to W3F1-2014-0005 Page 7 of 8 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 CSP Implementation Schedule is administrative in nature. In addition, the milestone date delay for full implementation of the CSP has no substantive impact because other measures have been taken which provide adequate protection during this period of time. 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.
4.3 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.
5.0 ENVIRONMENTAL CONSIDERATION
The proposed amendment provides a change to the CSP 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. to W3F1-2014-0005 Page 8 of 8
6.0 REFERENCES
- 1. NRC Internal Memorandum to Barry Westreich from Russell Felts, Review Criteria for 10 CFR 73.54, Cyber Security Implementation Schedule Milestone 8 License Amendment Requests , dated October 24, 2013
- 2. NRC letter to Entergy, Issuance of Amendment Re: Approval of CSP , dated July 20, 2011 (ML111800021)
- 3. NRC internal memorandum from the Director Cyber Security Directorate, Office of Nuclear Security and Incident Response, to the Region I through IV Directors of Reactor Safety, Enhanced Guidance for Licensee Near-Term Corrective Actions to Address Cyber Security Inspection Findings and Licensee Eligibility for "Good-Faith" Attempt Discretion, Enclosure 2, Milestone 4 Resolution Actions, dated July 1, 2013 Attachment 2 W3F1-2014-0005 Proposed Waterford 3 Operating License Change (mark-up) AMENDMENT NO. 171
, 218 , 234 , 239 Revised by letter dated July 26, 2007 (a)The first performance of SR 6.5.17, in accordance with Specification6.5.17.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from April 17,2004, the date of the most recent successful tracer gas test, as stated in the October 8, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since themost recent successful tracer gas test is greater than 6 years.(b)The first performance of the periodic assessment of CREhabitability, Specification 6.5.17.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from April 17,2004, the date of the most recent successful tracer gas test, as stated in the October 8, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since themost recent successful tracer gas test is greater than 3 years.(c)The first performance of the periodic measurement of CREpressure, Specification 6.5.17.d, shall be within 18 months, plus the 138 days allowed by SR 4.0.2, as measured from August 13, 2008,the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.
D.The facility requires an exemption from certain requirements of Appendices E and J to 10 CFR Part 50. These exemptions are described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplement No. 10 (Section 6.1.2) and Supplement No. 8 (Section 6.2.6), respectively. These exemptions are authorized by law and will not endanger life or property or the common defenseand security and are otherwise in the public interest. These exemptions are, therefore, hereby granted pursuant to 10 CFR 50.12. With the granting of these exemptions, the facility will operate, to the extent authorized herein, in conformitywith the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.
E.EOI shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingencyplans 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 plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Physical Security, Safeguards Contingency and Training & Qualification Plan,"
and was submitted on October 4, 2004.
EOI 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 EOI CSP was approved by License Amendment No. 234 and supplemented by a change s approved by Amendment No
- s. 239 and xxx.
Attachment 3 W3F1-2014-0005 Revised Waterford 3 Operating License Page AMENDMENT NO. 171
, 218 , 234 , 239 Revised by letter dated July 26, 2007 (a)The first performance of SR 6.5.17, in accordance with Specification 6.5.17.c.(i), shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.(b)The first performance of the periodic assessment of CRE habitability, Specification 6.5.17.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 4.0.2, as measured from April 17, 2004, the date of the most recent successful tracer gas test, as stated in the October 8, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.(c)The first performance of the periodic measurement of CRE pressure,Specification 6.5.17.d, shall be within 18 months, plus the 138 daysallowed by SR 4.0.2, as measured from August 13, 2008, the date of themost recent successful pressure measurement test, or within 138 days if not performed previously.
D.The facility requires an exemption from certain requirements of Appendices E and J to 10CFR Part 50. These exemptions are described in the Office of Nuclear Reactor Regulation's Safety Evaluation Report, Supplement No. 10 (Section 6.1.2) andSupplement No. 8 (Section 6.2.6), respectively. These exemptions are authorized by lawand will not endanger life or property or the common defense and security and are otherwise in the public interest. These exemptions are, therefore, hereby granted pursuantto 10 CFR 50.12. With the granting of these exemptions, the facility will operate, to theextent authorized herein, in conformity with the application, as amended, the provisions ofthe Act, and the rules and regulations of the Commission.
E.EOI 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 plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Physical Security, Safeguards Contingency and Training & Qualification Plan,"
and was submitted on October 4, 2004.
EOI 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 EOI CSP was approved by License Amendment No. 234 and supplemented by changes approved by Amendment Nos. 239 and xxx.