NL-14-016, License Amendment Request - Cyber Security Plan Implementation Schedule

License Amendment Request - Cyber Security Plan Implementation Schedule

ML14043A092
Person / Time
Site:	Indian Point
Issue date:	01/30/2014
From:	Ventosa J Entergy Nuclear Northeast
To:	Document Control Desk, NRC/FSME, Office of Nuclear Reactor Regulation
References
NL-14-016
Download: ML14043A092 (9)

Text

Entergy Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A. Ventosa Site Vice President Administration SECURITY RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 January 30, 2014 NL-14-016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

SUBJECT:

License Amendment Request - Cyber Security Plan Implementation Schedule Indian Point Unit Numbers 1, 2, and 3 Docket Nos.50-003, 50-247 and 50-286 License Nos. DPR-5, DPR-26 and DPR-64

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 Amendments Re: License Amendment Request - Cyber Security Plan, dated August 2, 2011

3. NRC Internal Memorandum to Directors of Regional Divisions of Reactor Safety from Barry Westreich, Enhanced Guidance For Licensee Near-Term Corrective Actions to Address Cyber Security Inspection Findings and Licensee Eligibility for "Good-Faith" Attempt Discretion, dated July 1, 2013

Dear Sir or Madam:

Pursuant to 10 CFR 50.4 and 10 CFR 50.90, Entergy Nuclear Operations, Inc. (Entergy) hereby requests a License Amendment to Operating License DPR-5, Docket No.50-003, to Operating License DPR-26, Docket No. 50-247, and to Operating License DPR-64, Docket SECURITY RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When Attachments 1 (Sections 1, 2, and 3) and 3 are detached, this letter is no longer security related information

NL-14-016 Docket Nos.50-003, 50-247 and 50-286 Page 2 of 3 SECURITY RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 No. 50-286 for Indian Point Generating Units No. 1, 2, and 3 (IP1, IP2, and IP3),

respectively. In accordance with the guidelines provided by Reference 1, this request proposes a change to the Indian Point Energy Center (IPEC) Cyber Security Plan Milestone 8 full implementation date as set forth in the Cyber Security Plan Implementation Schedule approved by Reference 2. Reference 3 provided additional NRC internal guidance.

The proposed changes have been evaluated in accordance with 10 CFR 50.91 (a)(1) using criteria in 10 CFR 50.92(c), and it has been determined that the changes involve no significant hazards consideration. The bases for these determinations are included in which provides an evaluation of the proposed change. Attachment 2 contains proposed marked-up operating License pages for the Physical Protection license condition for IP1, IP2, and IP3 for the schedule commitment change requested in this submittal. contains a change to the date of Implementation for Milestone 8 and contains the associated commitment change.

Entergy requests that Attachments 1 (Sections 1, 2, and 3) and 3, which contain security-related information (SRI), be withheld from public disclosure in accordance with 10 CFR 2.390.

Entergy requests this license amendment be effective as of its date of issuance. Although this request is neither exigent nor emergency, your review and approval is requested prior to December 15, 2014.

A revised commitment is contained in this submittal. Should you have any questions concerning this letter, or require additional information, please contact Robert Walpole, Manager, Licensing at (914) 254-6710.

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

2014.

Sincerely, JAV/sp Attachments: 1. Analysis of Proposed Operating License Change (contains SRI)

2. Proposed IP1, IP2, and IP3 Operating License Changes (mark-up)

3. Revised Cyber Security Plan Implementation Schedule (contains SRI)

4. List of Regulatory Commitments SECURITY RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 When Attachments 1 (Sections 1, 2, and 3) and 3 are detached, this letter is no longer security related information

NL-14-016 Docket Nos.50-003, 50-247 and 50-286 Page 3 of 3 SECURITY RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 cc:

Mr. Douglas Picket, 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 Ms. Bridget Frymire, New York State Dept. of Public Service SECURITY RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When Attachments 1 (Sections 1, 2, and 3) and 3 are detached, this letter is no longer security related information

ATTACHMENT 2 TO NL-14-014 PROPOSED IP1, IP2, AND IP3 OPERATING LICENSE CHANGES (MARK-UP)

ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNITS NO. 1, 2 and 3 DOCKET NOs.50-003, 50-247, and 50-286

and period of operation at each power level.

1.

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.

2.

Records of scrams, including reasons therefor.

3.

Records of principal maintenance operations involving substitution or replacement of facility equipment or components and the reasons therefor.

4.

Records of radioactivity measurements at on-site and off-site monitoring stations.

5.

Records of facility tests and measurements performed pursuant to the requirements of the Technical Specifications.

d)

ENO shall fully implemeent and maintain in efect all praoinains of the physical secrnity, guard tfaining and qu nsafeguards contingenc y

plans, preiously approved by the Commission and all amendments and revisions to CFRs plans (51d PFR 787and 72)tn to the authorfity of 10 F609an10GR 50.54(p). The plans, whiCh entain Safeguards Informiation prtente4-uder1O0 cFR 73.21, are entitled:

"Indian Poit Station, Units 1 and 2 Physical Security Plan," with revisions; submitted through July 25, 1989; "Indian Point Station, Units T aRd 2, Security Guard Training and Qualification Plan, "with revisions submitted through December 8, 1986; and "Indian Po-int Station, Units 1 and-2-,

Safeguards Contingency Plan," with revisions submitted thobergh 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 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 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 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 ENO CSP was approved by License Amendment No. 55 and supplemental amendments.

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 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 ENO CSP was approved by License Amendment No. 266 and supplemental amendments.

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.

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 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 ENO CSP was approved by License Amendment No. 243 and supplemental amendments.

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

Amendment No.

ATTACHMENT 4 TO NL-14-016 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

NL-14-014 Docket Nos.50-003, 50-247 and 50-286 Page 1 of 1 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 Full implementation of IPEC Cyber x

June 30, 2016 Security Plan for all safety, security, and emergency preparedness functions will be achieved.