NL-17-096, Supplemental Information for License Amendment Request - Cyber Security Plan Implementation Schedule

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Supplemental Information for License Amendment Request - Cyber Security Plan Implementation Schedule
ML17228A044
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 08/09/2017
From: Vitale A
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
NL-17-096
Download: ML17228A044 (3)


Text

Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box249 Buchanan, NY 10511-0249 Tel 914 254 6700 Anthony J. Vitale Site Vice President SECURITY-RELATED INFORMATION-WITHHOLD UNDER 10 CFR 2.390 August 9, 2017 NL-17-096 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike, OWFN-2 F1 Rockville, MD 20852-2738

SUBJECT:

Supplemental Information for License Amendment Request - Cyber Security Plan Implementation Schedule (CAC Nos. MF9656, MF9657, MF9658)

Indian Point Unit Nos. 1, 2, and 3 Docket Nos.50-003, 50-247 and 50-286 License Nos. DPR-5, DPR-26, and DPR-64

REFERENCE:

. 1. Entergy Letter NL-17-049 to NRC, "License Amendment Request -

Cyber Security Plan Implementation Schedule," dated April 28, 2017 (ML17129A612)

2. NRC letter to Entergy, "Indian Point Nuclear Generating Unit Nos. 1, 2 and 3 - Issuance of Amendments Re: License Amendment Request -

Cyber Security Plan (TAC Nos ME4212, ME4213, and ME4214),"

dated August 2, 2011 (ML11152A027)

3. NRC letter to Entergy, "Issuance of Amendments Re: Cyber Security Plan Implementation Schedule Milestones," dated November 28, 2012 (ML12258A268)
4. NRC letter to Entergy, "Issuance of Amendments - Cyber Security Plan Implementation Schedule," dated December 11, 2014 (ML14316A526)
5. NRC letter to Entergy, "Indian Point Nuclear Generating Unit Nos. 1, 2 and 3 - Issuance of Amendments Re: Cyber Security Plan Implementation Schedule," dated April 12, 2016(ML16064A215)

. Sool A SECURITY-RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390

/JM sso l When Attachments are detached, this letter is no longer security-related ~t_{L NHS~


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NL-17-096 Docket Nos.50-003, 50-247 and 50-286 Page 2 of 3 SECURITY-RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, Entergy Nuclear Operatior:is, Inc. (Entergy) requested a License Amendment for Indian Point Unit No. 1 (IP1 ), Operating License (OL) DPR-5, Docket No.50-003, for Indian Point Unit No. 2 (IP2), OL DPR-26, Docket No. 50-247, and for Indian Point Unit No. 3 (IP3), OL DPR-64, Docket No. 50-286. The License Amendment Request (LAR) (Reference 1) proposed a change to the Indian Point Energy Center (IPEC) Cyber Security Plan (CSP) Milestone 8 full implementation date as set forth in the CSP Implementation Schedule approved by Reference 2, and as amended by References 3, 4 and 5. A License Amendment is required because the Nuclear Regulatory Commission (NRC) Safety Evaluation Report (SER) provided in Reference 2, states that "All subsequent changes to the NRG-approved CSP implementation schedule will require prior NRC approval pursuant to 10 CFR 50.90.

An NRC onsite audit of the IPEC CSP implementation process was conducted on July 10 and 11, 2017, As a result of discussions between IPEC staff and NRC staff during the audit, Entergy has elected to revise the Reference 1 LAR to simplify the approach used to present the Milestone 8 partial implementation schedule.

The revised presentational approach specifically identifies the Critical Digital Assets (CDAs) planned for completion of the Milestone 8 actions by the partial implementation completion date, and also identifies those CDAs proposed for deferral of the Milestone 8 actions to the full implementation completion date. This simplified approach replaces the approach described in Section 2.0 of the Reference 1 LAR. The supplemental information is provided in Attachments 1 through 5 to this letter, and represents the current plant configuration.

Specifically, Attachments 1 through 4 provide the identified in scope IPEC security system, safety related, hard wired direct trip (causes turbine/reactor trip), and important to safety CDAs, respectively, that will have their Milestone 8 assessment and remediation actions completed by December 31, 2017, as previously committed in Attachment 3 of the Reference 1 LAR. Attachment 5 to this letter provides the identified IPEC CDAs that are proposed to have their Milestone 8 assessment and remediation actions deferred to the December 31, 2022 full implementation date as previously committed in Attachments 2 and 3 of the Reference 1 LAR. The Milestone 1 through 7 actions will be maintained during the interim period.

The supplemental information provided in this letter has been reviewed by the IPEC Cyber Security Assessment Team and On Site Review Committee. -

Entergy has determined that the supplemental information provided in this letter does not alter the conclusion reached in the original LAR (Reference 1) that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c). The supplemental information also does not alter the original LAR's bases for concluding that, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with issuance of the amendment.

SECURITY-RELATED INFORMATION-WITHHOLD UNDER 10 CFR 2.390 When Attachments are detached, this letter is no longer security:-related

NL-17-096 Docket Nos.50-003, 50-247 and 50-286 Page 3 of 3 SECURITY-RELATED INFORMATION-WITHHOLD UNDER 10 CFR 2.390 In accordance with 10 CFR 50.91 (b), State consultation, a copy of this request and the associated Attachments is being submitted to the designated New York State official.

This letter contains no new NRC commitments. Should you have any questions concerning this letter or require additional information, please contact Mr. Robert Walpole, Manager, Regulatory Assurance at (914) 254-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August q~ I 2017 Sincerely, AJV/cdm Attachments: 1. In Scope Security System Critical Digital Assets

2. In Scope Safety Related Critical Digital Assets
3. In Scope Hard Wired Direct Trip Critical Digital Assets
4. In Scope Important to Safety Critical Digital Assets
5. Critical Digital Assets Proposed for Deferral of Milestone 8 Actions (Maintain Milestone 1-7 Actions) cc: Mr. Richard Guzman, Senior Project Manager, NRC NRR DORL Ms. Kimberly A Conway, Project Manager, NRC FSME DWMEP DURLD Mr. Daniel H. Dorman, Regional Administrator, NRC Region 1 NRC Resident Inspector's Office Ms. Alicia Barton, President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service SECURITY-RELATED INFORMATION-WITHHOLD UNDER 10 CFR 2.390 When Attachments are detached, this letter is no longer security-related J