PNP 2017-059, License Amendment Request Supplement - Cyber Security Plan Implementation Schedule

License Amendment Request Supplement - Cyber Security Plan Implementation Schedule

ML17290A342
Person / Time
Site:	Palisades
Issue date:	10/17/2017
From:	Arnone C Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PNP 2017-059
Download: ML17290A342 (14)

Text

Entergy Nuclear Operations, Inc.

-c-=-= Et n ergx Palisades Nuclear PI~nt 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269-764-2000 Charles F. Arnone Site Vice President PNP 2017-059 October 17,2017 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

License Amendment Request Supplement - Cyber Security Plan Implementation Schedule Palisades Nuclear Plant Docket 50-255 Renewed Facility Operating License No. DPR-20

REFERENCES:

1. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2017-007, License Amendment Request - Cyber Security Plan Implementation Schedule, dated March 30, 2017 (ADAMS Accession No. ML17116A590)

2. Entergy Nuclear Operations, Inc., letter to NRC, PNP 2017-058, Certification of Permanent Cessation of Power Operations, dated September 28,2017 (ADAMS Accession No. ML17271A233)

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. (ENO) submitted a license amendment request (LAR) to the Nuclear Regulatory Commission (NRC) to propose a change to the PNP Cyber Security Plan (CSP) Milestone 8 full implementation date as set forth in the CSP Implementation Schedule (Reference 1). Subsequently, ENO submitted to the NRC a certification of permanent cessation of power operation on September 28, 2017 that changed the date that PNP will permanently cease power operation from October 1, 2018 to the spring of 2022 (Reference 2).

Due to this change in date for the permanent cessation of power operations at PNP, ENO is requesting a change to the Milestone 8 implementation date proposed in the original LAR in Reference 1. As a result, the following attachments in Reference 1 require revision:

Attachment 1 (the analysis of the proposed operating license change), Attachment 4 (the corresponding CSP implementation schedule) and Attachment 5 (the list of regulatory commitments). This supplement to Reference 1 provides these revisions to Attachments 1, 4, and 5 in the original LAR. Therefore, Attachments 1, 2, and 3 in this supplement replace Attachments 1, 4, and 5 in Reference 1 in their entirety.

Attachment 2 in Reference 1, which contains a mark-up of the proposed operating license changes, and Attachment 3 in Reference 1, which contains operating license pages change instructions and revised operating license pages, are not affected by this supplement and continue to be applicable.

PNP 2017-059 Page 2 of 2 Summary of Commitments This letter contains one revised commitment related to the full implementation of the PNP CSP, which is listed in Attachment 3.

Should you have any questions concerning this letter, or require additional information, please contact Jim Miksa at 269-764-2945.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 17, 2017.

Sincerely, CFA/jse Attachments: 1. Analysis of Proposed Operating License Change

2. Revised Cyber Security Plan Implementation Schedule

3. List of Revised Regulatory Commitments cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC State of Michigan

ATTACHMENT 1 Analysis of Proposed Operating License Change Seven pages follow

PNP 2017-007 ATTACHMENT 1

-ANALYSIS OF PROPOSED OPERATING LICENSE CHANGE 1.0

SUMMARY

DESCRIPTION This license amendment request (LAR) includes a proposed change to the Entergy Nuclear Operations, Inc. (ENO), Palisades Nuclear Plant (PNP) Cyber Security Plan (CSP) implementation schedule Milestone 8 full implementation date, and a proposed revision to Section 2.E of the PNP renewed facility operating license (RFOL), which references the CSP amendments containing the milestones. This analysis replaces Attachment 1 of PNP 2017-007, dated March 30, 2017 (Reference 9), in order to support ENO's decision to continue operating PNP until the spring of 2022 rather than permanently ceasing power operations on October 1, 2018 (Reference 10).

2.0 DETAILED DESCRIPTION In Reference 1, the Nuclear Regulatory Commission (NRC) issued a license amendment to the RFOL for PNP that approved the PNP CSP and associated implementation schedule for Milestones 1 through 8. In Reference 5, the NRC issued a license amendment that revised the Milestone 8 full implementation date to December 15, 2017. In Reference 6, ENO notified the NRC that PNP would permanently cease power operations on October 1, 2018. Since this notification, ENO has continued to maintain the previously implemented cyber security Milestones 1 through 7, which were inspected for compliance by the NRC as described in References 3 and 4. Recently, ENO decided to continue operating PNP until the spring of 2022.

This resulted in ENO submitting a new certification of permanent power cessation for PNP to the NRC on September 28, 2017 (Reference 10). ENO had originally planned to delay full implementation of CSP Milestone 8 until May 31, 2020, after PNP was permanently defueled and the fuel in the SFP decayed beyond the analyzed zirconium fuel cladding fire period, at which time the CSP license requirement would no longer be necessary and could be removed from the PNP RFOL (Reference 9). However, to support ENO's decision to continue operation of PNP until the spring of 2022, ENO is instead proposing a change to the Milestone 8 full implementation date, from December 15, 2017, to March 31, 2019.

The proposed schedule date of March 31, 2019 is requested because, upon the original ENO December 2016 announcement to permanently cease PNP operations in October 2018, work on completing CSP Milestone 8 activities was suspended. In addition, site information technology (IT) staff working on the PNP CSP project were lost due to the impending plant closure, so, to ensure a quality product, time is required to prepare new IT staff prior to starting CSP Milestone 8 assessments. Lastly, time is required to identify and implement modifications, if any, during the planned PNP fall 2018 refueling outage, and to complete CSP Milestone 8 assessments after the 2018 refueling outage.

In Reference 2, the NRC provided criteria to be used for evaluation of license amendment requests to revise the CSP Implementation Schedule Milestone 8 date. The information requested by Reference 2 is provided in Section 3.0 below.

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PNP 2017-007 ATTACHMENT 1 ANALYSIS OF PROPOSED OPERATING LICENSE CHANGE

3.0 TECHNICAL EVALUATION

On July 26, 2010, in accordance with 10 CFR 73.54, Protection of digital computer and communications systems and networks (nuclear cyber security rule), ENO submitted a proposed schedule for PNP achieving full compliance with the cyber security rule. The schedule was approved (Reference 1) and consists of eight milestones, with interim Milestones 1 through 7, as amended by Reference 7, having been completed by December 31,2012. Milestones 1 through 7 were subsequently inspected for compliance by the NRC in 2015 (Reference 3),

closed by PNP in 2016 (Reference 4), and finding closure inspected by the NRC, with no new findings, in 2016 (Reference 8, pages 27 and 28). Presently, Milestone 8 (full compliance with the rule) is required to be completed by December 15, 2017. However, with ENO's decision to permanently cease power operations at PNP in the spring of 2022 (Reference 10) rather than on October 1,2018 (Reference 6), ENO is proposing a change to the Milestone 8 full implementation date, from December 15, 2017, to March 31 , 2019.

Below is ENO's discussion of the eight evaluation criteria listed in Reference 2:

1. Identification of the specific requirement or requirements of the CSP that the licensee needs additional time to implement.

ENO requests that full implementation of CSP requirements per Milestone 8 be rescheduled from December 15, 2017 to March 31 , 2019. The specific requirement is described in Cyber Security Plan, Section 3.1 , "Analyzing Digital Computer Systems and Networks and Applying Cyber Security Controls."

During this additional period, ENO will continue to comply with the requirements of Milestones 1 through 7.

2. Detailed justification that describes the reason additional time is required to implement the specific requirement or requirements identified.

On January 4, 2017, in accordance with 10 CFR 50.82, Termination of license, ENO notified the NRC of the intent to permanently cease power operations at PNP effective October 1, 2018 (Reference 6). After this notification, PNP continued to maintain the previously implemented Milestone 1-7 actions, but suspended work toward achieving Milestone 8.

However, in September 2017, ENO decided to continue operating PNP until the spring of 2022 (Reference 10) as described above in Section 2.0. Additional time is required to achieve Milestone 8 because of (1) the time lost while work was suspended between December 2016 and the September 2017 ENO announcement to continue PNP operation until 2022, (2) the time required to prepare new IT staff prior to starting CSP Milestone 8 assessments to ensure a quality product, (3) the time required to identify and implement modifications, if any, during the planned PNP fall 2018 refueling outage, and (4) the time required to complete CSP Milestone 8 assessments after the 2018 refueling outage.

3. Proposed completion date for Milestone 8 consistent with the remaining scope of work to be conducted and the resources available.

The proposed completion date for Milestone 8 is March 31,2019.

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PNP 2017-007 ATTACHMENT 1 ANALYSIS OF PROPOSED OPERATING LICENSE CHANGE

4. Evaluation of the impact that the additional time to implement the requirements will have on the effectiveness of the overall cyber security program in the context of milestones already completed.

Cyber security protections provided by the completion and maintenance of Milestones 1 through 7 actions ensure that the program will continue to be effective in significantly mitigating the risk of the design basis threat (DBT) via cyber means. Most notably, safety-related, important-to-safety, and security CDAs will continue to be deterministically isolated from external networks; stringent control of portable media and mobile devices connected to CDAs will continue, including use of standalone scanning kiosks, use of passive media in the file transfer process, and use of level-specific kiosks and media; and implementation of technical cyber security controls and security officer observation for CDAs that support physical security target set functions. Additionally, although not required until Milestone 8, ENO is in the process of implementing procedures governing CDA configuration management, cyber security incident response and recovery, and cyber security training.

5. Description of the methodology for prioritizing completion of work for CDAs associated with significant SSEP consequences and with reactivity effects in the balance of plant.

CDAs are plant components, that are subject to the maintenance prioritization and normal work management process which places the highest priority on apparent conditions adverse to quality in system, structure, and component (SSC) design function and related factors such as safety risk and nuclear defense-in-depth, as well as threats to continuity of electric power generation in the balance-of-plant (BOP). Further, in regard to deterministic isolation and control of portable media and mobile devices (PMMD) for safety-related, important-to-safety (including BOP), and security CDAs, maintenance of one-way or air-gapped configurations and implementation of control of PMMD remains high priority.

This prioritization enabled timely completion of cyber security Interim Milestones 3 and 4.

High focus continues to be maintained on prompt attention to any emergent issue with CDAs that would potentially challenge the established cyber protective barriers.

6. Discussion of the cyber security program performance up to the date of the license amendment request.

No compromise of SSEP functions by cyber means has been identified. As documented in References 3 and 4, an NRC inspection at PNP of ENO's compliance with Milestones 1 through 7 was concluded on September 17, 2015, and findings were determined to be of very low significance (green non-cited, granted enforcement discretion). Additionally, at PNP, an annual ENO quality assurance (QA) audit has been conducted every year since 2013 pursuant to the physical security program review required by 10 CFR 73.55(m),

Security program reviews. The QA audit includes review of cyber security program implementation. The audits have identified no significant findings related to overall cyber security program performance and effectiveness.

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PNP 2017-007 ATTACHMENT 1 ANALYSIS OF PROPOSED OPERATING LICENSE CHANGE

7. Discussion of cyber security issues pending in the corrective action program.

No cyber security issues that would constitute a threat to proper CDA function or that would call into question cyber security program effectiveness are currently pending in the corrective action program.

8. Discussion of modifications completed to support the cyber security program and a discussion of pending cyber security modifications.

Modifications completed include those required to deterministically isolate Level 3 and 4 CDAs, as required by nuclear cyber security implementation schedule interim Milestone 3.

No modifications are pending.

This LAR includes the proposed change to the existing operating license condition for Section 2.E of the PNP renewed facility operating license (RFOL), which references the CSP amendments containing the milestones. This LAR contains the proposed revised CSP implementation schedule, and also provides a revised list of regulatory commitments.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 73.54, Protection of digital computer and communications systems and networks, requires licensees to maintain and implement a CSP. PNP's RFOL No. DPR-20 includes a Physical Protection license condition that requires ENO to fully implement and maintain in effect all provisions of the NRC 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 Nuclear Operations, Inc. (ENO) is requesting an amendment to the Palisades Nuclear Plant (PNP) Renewed Facility Operating License (RFOL) to revise the Physical Protection license condition as it relates to the Cyber Security Plan (CSP). This change includes a proposed change to a CSP implementation schedule milestone date and a proposed revision to the PNP RFOL to include the proposed deviation. Specifically, ENO is proposing a change to the Implementation Milestone 8 completion date.

ENO 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 Page 4 of 7

PNP 2017-007 ATTACHMENT 1 ANALYSIS OF PROPOSED OPERATING LICENSE CHANGE 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 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, ENO 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; Page 5 of 7

PNP 2017-007 ATTACHMENT 1 ANALYSIS OF PROPOSED OPERATING LICENSE CHANGE 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, pursuantto 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 Nuclear Operations, Inc., Palisades Nuclear Plant -Issuance of Amendment Regarding the Cyber Security Plan: (TAC No. ME4355), dated July 28,2011 (ADAMS Accession No. ML111801243)

2. NRC Internal Memorandum to Barry Westreich from Russell Felts, Review Criteria for Title 10 of the Code of Federal Regulations Part 73.54, Cyber Security Implementation Schedule Milestone 8 License Amendment Requests, dated October 24, 2013 (ADAMS Accession No. ML13295A467)

3. NRC letter to Entergy Nuclear Operations, Inc., Palisades Nuclear Plant, Unit 1 -

Inspection of Temporary Instruction 22011004, "Inspection of Implementation of Interim Cyber Security Milestones 1-7" Inspection Report 0500025512015407, dated October 14, 2015 (ADAMS Accession No. ML15289A409)

4. Entergy Nuclear Operations, Inc., letter to NRC, Closure Notification - Cyber Security Violations Documented in Inspection of Implementation of Interim cyber Security Milestones 1-7 Inspection Report, dated March 24, 2016 (ADAMS Accession No. ML16084A074)

5. NRC letter to Entergy Nuclear Operations, Inc., Palisades Nuclear Plant -Issuance of Amendment Re: Cyber Security Plan Implementation Schedule (CAC No. MF6351), dated May 2, 2016 (ADAMS Accession No. ML16078A068)

6. Entergy Nuclear Operations, Inc., letter to NRC, Certification of Permanent Cessation of Power Operations, dated January 4, 2017 (ADAMS Accession No. ML17004A062)

7. NRC letter to Entergy Nuclear Operations, Inc., Palisades Nuclear Plant -Issuance of Amendment Re: Revised Cyber Security Plan Implementation Schedule Milestone 6 (TAC No. ME8944), dated December 5, 2012 (ADAMS Accession No. ML12279A157)

8. NRC letter to Entergy Nuclear Operations, Inc., Palisades Nuclear Plant - NRC Integrated Inspection Report 0500025512016004; 0500025512016501; 0720000712015001; and 0720000712016001, dated February 14, 2017 (ADAMS Accession No. ML17045A709)

9. Entergy Nuclear Operations, Inc. letter to NRC, License Amendment Request - Cyber Security Plan Implementation Schedule, dated March 30, 2017 (ADAMS Accession No. ML17116A590)

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PNP 2017-007 ATTACHMENT 1 ANALYSIS OF PROPOSED OPERATING LICENSE CHANGE

10. Entergy Nuclear Operations, Inc., letter to NRC, Certification of Permanent Cessation of Power Operations, dated September 28, 2017 (ADAMS Accession No. ML17271A233)

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PNP 2017-059 ATTACHMENT 2 Revised Cyber Security Plan Implementation Schedule One page follows

PNP 2017-059 ATTACHMENT 2 Revised Cyber Security Plan Implementation Schedule

1. Implementation Milestone Completion Date Basis 8 Full implementation of March 31, 2019 By the completion date, the PNP Cyber Palisades Nuclear Plant Security Plan will be fully implemented (PNP) Cyber Security Plan for all SSEP functions in accordance for all safety, security, and with 10 CFR 73.54. This date also emergency preparedness bounds the completion of all individual (SSEP) functions will be asset security control design achieved. remediation actions including those that require a refueling outage for implementation.

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PNP 2017-059 ATTACHMENT 3 List of Revised Regulatory Commitments One page follows

PNP 2017-059 ATTACHMENT 3 List of Revised Regulatory Commitments The following table identifies those actions committed to by Entergy Nuclear Operations, Inc. 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 Full implementation of Palisades Nuclear Plant Cyber Security Plan for all safety, X March 31, 2019 security, and emergency preparedness functions will be achieved.

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