NL-11-0033, Response to Request for Additional Information and Revisions to IPEC Cyber Security Plan

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Response to Request for Additional Information and Revisions to IPEC Cyber Security Plan
ML111020655
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 04/01/2011
From: Joseph E Pollock
Entergy Nuclear Operations
To:
Document Control Desk, NRC/FSME, Office of Nuclear Reactor Regulation
References
NL-11-0033
Download: ML111020655 (13)
v • d • e


Text

Indian Point Enerey Center 450 Broadway, GSB m-0fEn7terfgy P.O. Box 249 Buchanan, N.Y. 10511-0249 Tel (914) 734-6700 J.E. Pollock Site Vice President Administration SECURITY RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 NL-1 1-033 April 1,2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Response to Additional Requests for Additional Information (RAIs) and Revision to the IPEC Cyber Security Plan (TAC NOS. ME4212, ME4213, and ME4214)

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

REFERENCES:

1. Entergy Letter NL-1 0-096 to NRC Regarding License Amendment Withdrawal and Request - Cyber Security Plan, dated July 8, 2010.
2. Entergy Letter NL-10-1 18 to NRC, Revision of Commitment to Supplement the Cyber Security Plan Regarding Balance-of-Plant Systems, dated November 30, 2010.
3. Letter from Richard P. Correia (NRC) to Chris Earls (NEI)

Concerning Scope of Systems, dated January 5, 2011.

4. Entergy Letter NL-1 1-015 to NRC, Response to Request for Additional Information Regarding IPEC Cyber Security Plan, dated February 18, 2011.
5. NRC Letter to Entergy, Request for Additional Information Regarding Amendment Application for Approval of the Indian Point Cyber Security Plan (TAC NOS. ME4212, ME4213, AND ME4214),

dated March 3, 2011.

6. Letter from Chris Earls (NEI) to Richard P. Correia (NRC),

Clarification to NEI 08-09, Revision 6 Regarding Records Retention, dated February 28, 2011.

SECURITY RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 When Attachments 1, 4, and 6 are detached, this letter and other Attachments are no longer -2F5 security related information <* I A-sc~/

-'FA'

NL-1 1-033 Docket Nos.50-003, 50-247 and 50-286 Page 2 of 4 SECURITY RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390

7. Letter from Chris Earls (NEI) to Richard P. Correia (NRC),

Template for the Cyber Security Plan Implementation Schedule, dated February 28, 2011.

8. Letter from Richard P. Correia (NRC) to Chris Earls (NEI),

Template for the Cyber Security Plan Implementation Schedule, dated March 1, 2011.

Dear Sir or Madam:

In Reference 1, Entergy Operations, Inc. (Entergy) submitted requests for amendments to the operating licenses for Indian Point Generating Units 1, 2, and 3 (IP1, IP2, and IP3) requesting NRC approval of the Indian Point Energy Center (IPEC) Cyber Security Plan. In accordance with the commitment in Reference 4, Entergy is revising Sections 2.1 "Scope and Purpose" and 4.3, "Defense-In-Depth Protective Strategies," to address clarifications with respect to data diodes/air gaps and emergency plan/preparedness as described in the request for additional information (RAI) responses provided in reference 4. Subsequent to the submittal of these RAI responses, the NRC issued additional generic RAls on the IPEC Cyber Security Plan via Reference 5. Entergy's response to these RAls is provided in . contains proposed marked-up operating license pages for the Physical Protection license condition for IP1, IP2, and IP3 to include the IPEC Cyber Security Plan. contains the proposed revised operating license pages. The marked-up pages in Attachment 2 and the revised pages in Attachment 3 replace, in their entirety, the pages previously submitted in Reference 1. contains the Entergy Operations, Inc. Cyber Security Plan Implementation Schedule. Attachment 5 contains the List of Regulatory Commitments established for implementation of IPEC Cyber Security Plan. provides a revised copy of the IPEC Cyber Security Plan, Revision 0, which incorporates changes to Sections 2.1 "Scope and Purpose," 4.3 "Defense-In-Depth Protective Strategies," and 4.13 "Document Control and Records Retention and Handling."

No other technical changes have been made to the IPEC Cyber Security Plan. The enclosed IPEC Cyber Security Plan replaces, in its entirety, the IPEC Cyber Security Plan previously submitted in Reference 1. The changes discussed in this letter are clarifying or administrative and do not impact the conclusions of the no significant hazards consideration determination previously provided in Reference 1.

Entergy requests that Attachments 1, 4, and 6 which contain security-related information (SRI), be withheld from public disclosure in accordance with 10 CFR 2.390.

SECURITY RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 When Attachments 1, 4, and 6 are detached, this letter and other Attachments are no longer security related information

NL-1 1-033 Docket Nos.50-003, 50-247 and 50-286 Page 3 of 3 SECURITY RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 The revised commitments contained in this submittal are summarized in Attachment 5.

Should you have any questions concerning this letter, or require additional information, please contact Mr. Robert Walpole, Manager, Licensing at (914) 734-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 1,2011.

Sincerely, JEP/sp Attachments: 1. Response to Requests for Additional Information (contains SRI)

2. Marked Up Facility Operating License Changes
3. Revised IP1, IP2, and IP3 Operating License Pages
4. Cyber Security Plan Implementation Schedule (contains SRI)
5. List of Regulatory Commitments
6. Revised IPEC Cyber Security Plan (contains SRI) cc: Mr. John P. Boska, Senior Project Manager, NRC NRR DORL Mr. Stephen Giebel, Project Manager, NRC FSME DWMEP DURLD Mr. William Dean, Regional Administrator, NRC Region 1 NRC Resident Inspectors Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Mr. Paul Eddy, New York State Dept. of Public Service SECURITY RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When Attachments 1, 4, and 6 are detached, this letter and other Attachments are no longer security related information

SECURITY RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 ATTACHMENT 2 TO NL-1 1-033 MARKED UP FACILITY OPERATING LICENSE PAGES Affected Pages IP1 FOL Page 3 IP2 FOL Page 5 IP3 FOL Page 4 Additions are underlined and deletions are double strikeout ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNITS NO. 1, 2 and 3 DOCKET NOs.50-003, 50-247, and 50-286 SECURITY RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When Attachments 1, 4, and 6 are detached, this letter and other Attachments are no longer security related information

and period of operation at each power level.

2. Records showing the radioactivity released or discharged into the air or water beyond the effective control of ENO as measured at or prior to the point of such release or discharge.
3. Records of scrams, including reasons therefor.
4. Records of principal maintenance operations involving substitution or replacement of facility equipment or components and the reasons therefor.
5. Records of radioactivity measurements at on-site and off-site monitoring stations.
6. Records of facility tests and measurements performed pursuant to the requirements of the Technical Specifications.

d) ENO shall fully implement and maintain in efect all provisions of t phytical Security, guard training and qualification, and safeguards clntingency plans previously appurved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10CFR 50.90 and 10'CFR 50.54(p). The plans, which contain Safeguard Inforation protected undee 10 CFR 73.21, are entitled:it

..Indian Point Station;, Units 1 and 2 PhYsical Security Plan," with reviin submitted through July 25, 1989; "Indian Point Station, Units 1 and-2-,

Serity Guard Training and Qualification Plan, "With revisions subMiyP ed through Decemnber 8,1986; and "Indian Point Station, Units 1and 2, Safeguards Contingency Plan," with revisionst subdmteOted throu gh November 7, 1986. ENO 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 CIFR 50.90 and 10 CFR 50.54(p). The combined set of plans' for the Indian Point Energy Center, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Physical Security, Training and Qualification, and Safeguards Contingency Plan, Revision 0," and was submitted by letter dated October 14, 2004, as supplemented by letter dated May 18, 2006. ENO shall fully implement in accordance with an NRC aD~rroved implementation schedule and maintain in effect all provisions of the Commission-approved IPEC Cvber Security Plan pursuant to 10 CFR 73.55(c)(6) and 10 CFR 73.54 (74 FR 13970) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

I The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.

Amendment No. 64

Indian Point Energy Center, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Physical Security, Training and Qualification, and Safeguards Contingency Plan, Revision 0," and was submitted by letter dated October 14, 2004, as supplemented by letter dated May 18, 2006. ENO shall fully implement in accordance with an NRC approved implementation schedule and maintain in effect all provisions of the Commission-approved IPEC Security Plan pursuant to 10 CFR 73.55(c)(6) and 10 CFR 73.54 (74 FR 13970) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

Deleted per Amdt. 133, 7-6-88.

J. Deleted per Amdt. 133, 7-6-88.

K. ENO shall implement and maintain in effect all provisions of the NRC-approved fire protection program as described in the Updated Final Safety Analysis Report for the facility and as approved in the Safety Evaluations Reports dated November 30, 1977, February 3, 1978, January 31, 1979, October 31, 1980, August 22, 1983, March 30, 1984, October 16, 1984, September 16, 1985, November 13, 1985, March 4, 1987, January 12, 1989, and March 26, 1996. ENO may make changes to the NRC-approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

L. Deleted per Amendment 238 M. Deleted per Amendment 238 N. Mitigation Strategy License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance
2. Assessment of mutual aid fire fighting assets
3. Designated staging areas for equipment and materials
4. Command and control
5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:
1. Protection and use of personnel assets
2. Communications
3. Minimizing fire spread
4. Procedures for implementing integrated fire response strategy
5. Identification of readily-available pre-staged equipment
6. Training on integrated fire response strategy (c) Actions to minimize release to include consideration of:
1. Water spray scrubbing
2. Dose to onsite responders Amendment No. mQuir"An by lottor dotod Jul, .1,

G. ENO 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 CFR 50.54(p). The combined set of plans 1 for the Indian Point Energy Center, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Physical Security, Training and Qualification, and Safeguards Contingency Plan, Revision 0," and was submitted by letter dated October 14, 2004, as supplemented by letter dated May 18, 2006. ENO shall fully implement in accordance with an NRC approved implementation schedule and maintain in effect all provisions of the Commission-approved IPEC Cyber Security Plan pursuant to 10 CFR 73.55(c)(6) and 10 CFR 73.54 (74 FR 13970) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

H. ENO shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for Indian Point Nuclear Generating Unit No. 3 and as approved in NRC fire protection safety evaluations (SEs) dated September 21, 1973, March 6. 1979, May 2, 1980, November 18, 1982, December 30, 1982, February 2, 1984, April 16, 1984, January 7, 1987, September 9, 1988, October 21, 1991, April 20, 1994, January 5, 1995, and supplements thereto, subject to the following provision:

ENO may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(DELETED) Amdt. 205 2/27/01 J. (DELETED) Amdt. 205 2/27/01 K. (DELETED) Amdt.49 5-25-84 L. (DELETED) Amdt. 205 2/27/01 M. (DELETED) Amdt. 205 2/27/01 N. (DELETED) Amdt. 49 5-25-84 The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.

Amendment No.Ro'icod by l.ttor d"to. Docombor 21, 2b00

SECURITY RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 ATTACHMENT 3 TO NL-1 1-033 REVISED IP1, IP2 AND IP3 OPERATING LICENSE PAGES Affected Pages IP1 FOL Page 3 IP2 FOL Page 5 IP3 FOL Page 4 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNITS NO. 1, 2 and 3 DOCKET NOs.50-003, 50-247, and 50-286 SECURITY RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When Attachments 1, 4, and 6 are detached, this letter and other Attachments are no longer security related information

and period of operation at each power level.

2. Records showing the radioactivity released or discharged into the air or water beyond the effective control of ENO as measured at or prior to the point of such release or discharge.
3. Records of scrams, including reasons therefor.
4. Records of principal maintenance operations involving substitution or replacement of facility equipment or components and the reasons therefor.
5. Records of radioactivity measurements at on-site and off-site monitoring stations.
6. Records of facility tests and measurements performed pursuant to the requirements of the Technical Specifications.

d) ENO shall fully implement and maintain in effet all provisions of t physital secrity, guard training and qualification, and safeguards icntingency plaen previeusly approved by the Commission and all aMiendmnents and- evions to such plans made prR uiremt t the aueithsoity of 10 CER 50.90 and 10'CFR 50.54(p). The p which lans, contain Safeguards Infomation protected under 10 CFR 73.21, are entitled:

"ndian Point Station, Units 1 and 2 Physical Security Plan," with revisions submitted through July 25, 1989; "Indian Point Station, Units 1and-2-,

Security Guard Training and Qualification Plaa, "with revisions submitted through Decem~ber 8,1986; and "Indian Point Station, Units 1 and 2, Safeguadsi Cntingency Plan," with revisions submitted though Nspemb 7,t 1986. ENO 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 combined set of plans' for the Indian Point Energy Center, which contain Safeguards Information protected under 10 CIFR 73.21, isentitled: "Physical Security, Training and Qualification, and Safeguards Contingency Plan, Revision 0," and was submitted by letter dated October 14, 2004, as supplemented by letter dated May 18, 2006. ENO shall fully implement in accordance with an NRC approved implementation schedule and maintain in effect all provisions of the Commission-approved IPEC Cyber Security Plan pursuant to 10 CFR 73.55(c)(6) and 10 CFR 73.54 (74 FR 13970) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

1 The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.

Amendment No.

Indian Point Energy Center, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Physical Security, Training and Qualification, and Safeguards Contingency Plan, Revision 0," and was submitted by letter dated October 14, 2004, as supplemented by letter dated May 18, 2006. ENO shall fully implement in accordance with an NRC approved implementation schedule and maintain in effect all provisions of the Commission-approved IPEC Cyber Security Plan. pursuant to 10 CFR 73.55(c)(6) and 10 CFR 73.54 (74 FR 13970) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

Deleted per Amdt. 133, 7-6-88.

J. Deleted per Amdt. 133, 7-6-88.

K. ENO shall implement and maintain in effect all provisions of the NRC-approved fire protection program as described in the Updated Final Safety Analysis Report for the facility and as approved in the Safety Evaluations Reports dated November 30, 1977, February 3, 1978, January 31, 1979, October 31, 1980, August 22, 1983, March 30, 1984, October 16, 1984, September 16, 1985, November 13, 1985, March 4, 1987, January 12, 1989, and March 26, 1996.

ENO may make changes to the NRC-approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

L. Deleted per Amendment 238 M. Deleted per Amendment 238 N. Mitigation Strategy License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(d) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance
2. Assessment of mutual aid fire fighting assets
3. Designated staging areas for equipment and materials
4. Command and control
5. Training of response personnel (e) Operations to mitigate fuel damage considering the following:
1. Protection and use of personnel assets
2. Communications
3. Minimizing fire spread
4. Procedures for implementing integrated fire response strategy
5. Identification of readily-available pre-staged equipment
6. Training on integrated fire response strategy (f) Actions to minimize release to include consideration of:
1. Water spray scrubbing
2. Dose to onsite responders Amendment No.

G. ENO 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 CFR 50.54(p). The combined set of plans 1 for the Indian Point Energy Center, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Physical Security, Training and Qualification, and Safeguards Contingency Plan, Revision 0," and was submitted by letter dated October 14, 2004, as supplemented by letter dated May 18, 2006. ENO shall fully implement in accordance with an NRC approved implementation schedule and maintain in effect all provisions of the Commission-approved IPEC Cyber Security Plan. pursuant to 10 CFR 73.55(c)(6) and 10 CFR 73.54 (74 FR 13970) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

H. ENO shall implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Final Safety Analysis Report for Indian Point Nuclear Generating Unit No. 3 and as approved in NRC fire protection safety evaluations (SEs) dated September 21, 1973, March 6. 1979, May 2, 1980, November 18, 1982, December 30, 1982, February 2, 1984, April 16, 1984, January 7, 1987, September 9, 1988, October 21, 1991, April 20, 1994, January 5, 1995, and supplements thereto, subject to the following provision:

ENO may make changes to the approved Fire Protection Program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

I. (DELETED) Amdt. 205 2/27/01 J. (DELETED) Amdt. 205 2/27/01 K. (DELETED) Amdt.49 5-25-84 L. (DELETED) Amdt. 205 2/27/01 M. (DELETED) Amdt. 205 2/27/01 N. (DELETED) Amdt. 49 5-25-84 The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.

Amendment No.

SECURITY RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 ATTACHMENT 5 TO NL-1 1-033 LIST OF REGULATORY COMMITMENTS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNITS NO. 1, 2 and 3 DOCKET NOs.50-003, 50-247, and 50-286 SECURITY RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 When Attachments 1, 4, and 6 are detached, this letter and other Attachments are no longer security related information

NL-1 1-033 Docket Nos.50-003, 50-247 and 50-286 Attachment 5 Page 1 of 1 SECURITY RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 List of Regulatory Commitments The following table identifies those actions committed to by Entergy 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 ONE- DATE TIME CONTINUING (If Required)

ACTION COMPLIANCE Entergy will implement milestones 1 X December 31, 2012 through 7 described in Attachment 4.

Full implementation of IPEC Cyber X December 15, 2014 Security Plan for all safety, security, and emergency preparedness functions will be achieved.

SECURITY RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 When Attachments 1, 4, and 6 are detached, this letter and other Attachments are no longer security related information

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