NOC-AE-11002664, Submittal of Supplement to License Amendment Request for Approval of Cyber Security Plan

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Submittal of Supplement to License Amendment Request for Approval of Cyber Security Plan
ML11123A216
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 04/28/2011
From: Gerry Powell
South Texas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-11002664, STI: 32853751
Download: ML11123A216 (7)
v • d • e


Text

6Z711F Nuclear Operating Company 17ATTACHMENT 2 OF ENCLOSURE 1 AND ENCLOSURE 2 CONTAIN SECURITY-RELATED Z 'LI LP.O INFORMATION - WITHHOLD UNDER 10 CFR 2.390.

South Texas ProjectElectric 6enerating Spam P.. Box April 28, 2011 NOC-AE-1 1002664 10 CFR 50.90 10 CFR 2.390 STI: 32853751 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Submittal of Supplement to License Amendment Request for Approval of Cyber Security Plan

Reference:

1. Letter from STP Nuclear Operating Company to the NRC Document Control Desk, "License Amendment Request for Approval of Cyber Security Plan," dated November 19, 2009 (ML093280720) (NOC-AE-09002480)
2. Letter from STP Nuclear Operating Company to the NRC Document Control Desk, "Revised License Amendment Request for Approval of Cyber Security Plan," dated January 25, 2010 (ML100290367) (NOC-AE-10002502)
3. Letter from STP Nuclear Operating Company to the NRC Document Control Desk, "License Amendment Request for Approval of Cyber Security Plan," dated July 27, 2010 (ML102150159 ) (NOC-AE- 10002568)

In the referenced letters, STP Nuclear Operating Company (STPNOC) requested a license amendment to the Facility Operating Licenses (FOL) NPF-76 and NPF-80 for South Texas Project Units 1 and 2. The proposed amendment would document NRC approval of the STPNOC Cyber Security Plan. The Nuclear Regulatory Commission staff issued a request for additional information (RAI) in a letter dated March 4, 2011 (ML110620370). STPNOC responded to the RAI by letter dated April 4, 2011.

Each of the three questions in the RAI is an industry-generic question developed by NRC staff following discussions with the Nuclear Energy Institute (NEI) and the industry Cyber Security Task Force. The three questions involve the topics of Records Retention, Implementation Schedule, and Scope of Systems.

For each of the three questions, STPNOC provided a response consistent with an agreed upon method between NEI and the NRC Staff. These RAI responses required changes in the license amendment request (LAR) for the STPNOC Cyber Security Plan. In response to the RAI, STPNOC provides the following supplemental information and replaces documents provided in the July 27, 2010, License Amendment Request.

" Attachment I provides the existing FOL pages marked up to show the proposed change.

  • Attachment 2 provides a copy of the revised STPNOC Cyber Security Plan Implementation Schedule. STPNOC requests that Attachment 2 of Enclosure 1, which contains security sensitive information, be withheld from public disclosure in accordance with 10 CFR 2.390.

[oo/4-

NOC-AE-11002664 Page 2 of 2 Enclosure 2 provides a copy of the revised STPNOC Cyber Security Plan which is a standalone document that will be incorporated by reference into the STPNOC Physical Security Plan upon approval. STPNOC requests that Enclosure 2, which contains security sensitive information, be withheld from public disclosure in accordance with 10 CFR 2.390.

The revised STPNOC Cyber Security Plan incorporates changes needed to address the NRC RAls. The changes do not deviate from the agreed upon method between NEI and the NRC Staff.

Changes are indicated with revision bars. The actions and dates on the schedule are regulatory commitments.

In accordance with 10 CFR 50.91(b), STPNOC is notifying the State of Texas of this request for license amendment by providing a copy of this letter and its attachments.

STPNOC requests an implementation period of 90 days following NRC approval of the license amendment.

If there are any questions regarding the proposed amendment, please contact Marilyn Kistler at (361) 972-8385 or me at (361) 972-8720 I declare under penalty of perjury that the foregoing is true and correct.

Executed on Da te1j Date G. T. Powell Vice President, Technical Support & Oversight - Marked FOL pages - Revised STPNOC Cyber Security Plan Implementation Schedule. - Revised STPNOC Cyber Security Plan mk/

NOC-AE- 11002664 Page 2 of 2 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 612 East Lamar Blvd, Suite 400 Arlington, Texas 76011-4125 Balwant K. Singal U. S. Nuclear Regulatory Commission Balwant K. Singal John Ragan Senior Project Manager Catherine Callaway U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8B1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Ed Alarcon Senior Resident Inspector Kevin Polio U. S. Nuclear Regulatory Commission Richard Pena P. 0. Box 289, Mail Code: MN116 City Public Service Wadsworth, TX 77483 C. M. Canady Peter Nemeth City of Austin Crain Caton & James, P.C.

Electric Utility Department 721 Barton Springs Road C. Mele Austin, TX 78704 City of Austin Richard A. Ratliff Texas Department of State Health Services Alice Rogers Texas Department of State Health Services

NOC-AE- 11002664 Attachment 1 ATTACHMENT 1 OPERATING LICENSES MARKED WITH PROPOSED CHANGES

NOC-AE- 11002664 Attachment 1 Page 1 of 3 SOUTH TEXAS LICENSE (1) The facility has been granted a schedular exemption from Section 50.71(e)(3)(i) of 10 CFR 50 to extend the date for submittal of the updated Final Safety Analysis Report to no later than one year after the date of issuance of a low power license for the South Texas Project, Unit 2. This exemption is effective until August 1990. The staff's environmental assessment was published on December 16, 1987 (52 FR 47805).

E. Fire Protection STPNOC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment No. 55 and the Fire Hazards Analysis Report through Amendment No. 19, and submittals dated April 29, May 7, 8 and 29, June 11, 25 and 26, 1987, February 3, March 3, and November 20, 2009; January 20, 2010; and as approved in the SER (NUREG-0781) dated April 1986 and its Supplements, subject to the following provision:

STPNOC 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.

F. Physical Security STPNOC shall fully implement and maintain in effect all provisions of the physical security, guard training and qualification, and safeguards contingency plans previously approved by the Commission and all amendments and revisions to such plans made pursuant to the authority under 10 CFR 50.90 and 10 CFR 50.54(p).

The licensee 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 the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73 .21, is entitled: "South Texas Project Electric Generating Station Security, Training and Qualification, and Safeguards Contingency Plan, Revision 2" submitted by letters dated May 17 and 18, 2006.

TPNOC shall fully implement and maintain in effect all provisions of thfe ommission-approved STPNOC Cyber Security Plan submitted by letter dated Aprii Amendment No.

NOC-AE- 11002664 Attachment 1 Page 2 of 3 SOUTH TEXAS LICENSE G. Not Used H. Financial Protection The owners shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

Effective Date and Expiration This license is effective as of the date of issuance and shall expire at midnight on August 20, 2027.

FOR THE NUCLEAR REGULATORY COMMISSION original signed by Thomas E. Murley, Director Office of Nuclear Reactor Regulation

Enclosures:

1. Appendix A, Technical Specifications (NUREG-1305)
2. Appendix B, Environmental Protection Plan Date of Issuance: March 22, 1988 Amendment No. 4,,

NOC-AE- 11002664 Attachment 1 Page 3 of 3 (2) The facility was previously granted exemption from the criticality monitoring requirements of 10 CFR 70.24 (See Materials License No. SNM-1 983 dated August 30, 1988 and Section III.E. of the SER dated August 30, 1988). The South Texas Project Unit 2 is hereby exempted from the criticality monitoring provisions of 10 CFR 70.24 as applied to fuel assemblies held under this license.

(3) The facility requires a temporary exemption from the schedular requirements of the decommissioning planning rule, 10 CFR 50.33(k) and 10 CFR 50.75. The justification for this exemption is contained in Section 22.2 of Supplement 6 to the Safety Evaluation Report. The staff's environmental assessment was published on December 16, 1988 (53 FR 50604). Therefore, pursuant to 10 CFR 50.12(a)(1),

50.12(a)(2)(ii) and 50.12(a)(2)(v), the South Texas Project, Unit 2 is hereby granted a temporary exemption from the schedular requirements of 10 CFR 50.33(k) and 10 CFR 50.75 and is required to submit the decommissioning plan for both South Texas Project, Units 1 and 2 on or before July 26, 1990.

E. Fire Protection STPNOC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment No. 62 and the Fire Hazards Analysis Report through Amendment No. 19, and submittals dated April 29, May 7, 8 and 29, June 11, 25 and 26, 1987, February 3, March 3, and November 20, 2009; January 20, 2010; and as approved in the SER (NUREG-0781) dated April 1986 and its Supplements, subject to the following provisions:

STPNOC 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.

F. Physical Security The licensee 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 the authority of 10 CFR 50.90 and 10 CFR 50.54(p) . The combined set of plans, which contain Safeguards Information protected under 10 CFR 73 .21, is entitled: "South Texas Project Electric Generating Station Security, Training and Qualification, and Safeguards Contingency Plan, Revision 2" submitted by letters dated May 17 and 18, 2006.

'STPNOC shall fully implement and maintain in effect all provisions of th-e, Commission-approved STPNOC Cyber Security Plan submitted by letter dated Apr_

UP 2011._

G. Not Used Amendment No. R:R

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