RA15-075, Transmittal of the 2014 Regulatory Commitment Change Summary Report

Transmittal of the 2014 Regulatory Commitment Change Summary Report

ML16020A069
Person / Time
Site:	LaSalle
Issue date:	11/20/2015
From:	Vinyard H Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA15-075
Download: ML16020A069 (3)

Text

Ex [n e ertinLaSalle County Station Marseilles, It 61341.

815-415-2000 Telephone www.exeloncorp.com 10 CFR 50.4 RA1 5-075 November 20, 2015 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 . ..

LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-1 1 and NPF-18a NRC Docket Nos. 50-373 and 50-374

Subject:

2014 Regulatory Commitment Change Summary Report Enclosed is the Exelon Generation Company, LLC, (EGG), 2014 Regulatory Commitment Change Summary Report for LaSalle County Station. Revisions to docketed correspondence were processed using the Nuclear Energy Institute's (NEI) 99-04, "Guidelines for Managing NRC Commitment Changes," Revision 0, dated July 1999.

Should you have any questions concerning this letter, please contact Mr. Guy V. Ford, Regulatory Assurance Manager, at (815) 415-2800.

Respetuly 1.

Harold T. Vinyard Plant Manager LaSalle County Station Attachment cc: Regional Administrator, NRC Region Ill NRC Senior Resident Inspector - LaSalle County Station k0v(

2014 Regulatory Commitment Change Summary Report Commitment Date of Original- Original Commitment I Changed.Commitment Basis for Change Change " Commitment Document Tracking No. Change 14-001 10/7/2014 EA-04-170 A number of commitments Relaxation of IV.1land IV.5 of EA-04-170 dated January 6, dated were made by Exelon as part Order EA-04-170 2014. LaSalle County Station, November 22, of a settlement agreement for units 1 and 2 - Relaxation of 2005. workers entering a high Confirmatory Order. Good Confirmatory radiation area which resufted cause was demonstrated to Order Modifying in a violation of Technical relaxing the order due to 1) The License 'Specification 5.7.1 change in maintenance contract Reclassification companies at LaSalle; 2) of Severity *Exelon's compliance with the Level, and order for more than 7 years; 3)

Reduction of integration of the radiation Civil. Penalty safety controls specified in the Order in Exelon fleet-wide procedures and programs; and

4) positive results of the NRC's inspections of Order implementation.14-002 9/15/2014 Letter from Implement Installation of a , The action (AT .1404185-02 and The justification of compliance Darin M. deterministic one-way device -1404185-04) to install the with the commitments of the Benyak, Exelon between lower level devices design change for the existing source documents is fully Generation (level 0,1,2) and the higher* Keyboard Video Mouse (KVM) documented in the Regulatory Company, LLC level devices (level 3,4) as with a secure make and model Commitment Database under a to U.S. Nuclear described in Section 4.3, .that has been verified to prevent separate record (AT 1223694-regulatory "Defense-In-Depth Protective transfer of files between servers 35) as follows.

Commission - Strategies" of the CSP. was removed from the "response to commitment management The Data Diode, as installed by Request for Lower security level devices database. EC 380686, isolates level 3 Additional .(level 0, 1,2 devices) that. from level l and level 2, Information bypass the deterministic allowing data only to flow from Regarding device and connect to level 3 higher level devices [level 3,4]

Exelon Cyber or 4 will be modified-to .pr..event to lower levels [level 0,1,2].

Security Plan, the digital connectivity to the A review of site networks was dated: March 31, higher level or will be modified- performed to ensure that no 2011 to meet cyber securitY " bypasses existed between requirements commensurate lower level devices [level 0, 1,

_____________Letter from Joel with the level 3 or 4 devices to ______________2] and higher level devices Page 1 of 2

2014 Regulatory Commitment Change Summary Report I S. Weibe, U.S. which they connect. [level 3, 4] after installation of Nuclear EC 380686. This review is Regulatory The design modifications that documented by ATI 01242053.

Commission to are not finished by the Michael J. completion date will be This review identified that the Pacilio, Exelon documented in the site PPC connection to the Nuclear (Exelon configuration management instruments located at the river Generation and/or change control program screen house created a Company, LLC to assure completion of the situation that a lower level

- Issuance of. design modification as soon as device was connected to a Amendments possible, but no later than the higher level device bypassing regarding the final implementation date., the data diode. EC 384720 was Exelon Cyber generated to address this issue.

Security Plan, dated August In addition, after installation of 10, 2011 the data diode it was determined that the KVM used in the LaSalle design also posed a bypass path specific to LaSalle installation. EC 390376 was generated to address this issue.

The three identified design changes, EC 380686, EC 384720 and EC 390376, have been finished.

Page 2 of 2

Ex [n e ertinLaSalle County Station Marseilles, It 61341.

815-415-2000 Telephone www.exeloncorp.com 10 CFR 50.4 RA1 5-075 November 20, 2015 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 . ..

LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-1 1 and NPF-18a NRC Docket Nos. 50-373 and 50-374

Subject:

2014 Regulatory Commitment Change Summary Report Enclosed is the Exelon Generation Company, LLC, (EGG), 2014 Regulatory Commitment Change Summary Report for LaSalle County Station. Revisions to docketed correspondence were processed using the Nuclear Energy Institute's (NEI) 99-04, "Guidelines for Managing NRC Commitment Changes," Revision 0, dated July 1999.

Should you have any questions concerning this letter, please contact Mr. Guy V. Ford, Regulatory Assurance Manager, at (815) 415-2800.

Respetuly 1.

Harold T. Vinyard Plant Manager LaSalle County Station Attachment cc: Regional Administrator, NRC Region Ill NRC Senior Resident Inspector - LaSalle County Station k0v(

2014 Regulatory Commitment Change Summary Report Commitment Date of Original- Original Commitment I Changed.Commitment Basis for Change Change " Commitment Document Tracking No. Change 14-001 10/7/2014 EA-04-170 A number of commitments Relaxation of IV.1land IV.5 of EA-04-170 dated January 6, dated were made by Exelon as part Order EA-04-170 2014. LaSalle County Station, November 22, of a settlement agreement for units 1 and 2 - Relaxation of 2005. workers entering a high Confirmatory Order. Good Confirmatory radiation area which resufted cause was demonstrated to Order Modifying in a violation of Technical relaxing the order due to 1) The License 'Specification 5.7.1 change in maintenance contract Reclassification companies at LaSalle; 2) of Severity *Exelon's compliance with the Level, and order for more than 7 years; 3)

Reduction of integration of the radiation Civil. Penalty safety controls specified in the Order in Exelon fleet-wide procedures and programs; and

4) positive results of the NRC's inspections of Order implementation.14-002 9/15/2014 Letter from Implement Installation of a , The action (AT .1404185-02 and The justification of compliance Darin M. deterministic one-way device -1404185-04) to install the with the commitments of the Benyak, Exelon between lower level devices design change for the existing source documents is fully Generation (level 0,1,2) and the higher* Keyboard Video Mouse (KVM) documented in the Regulatory Company, LLC level devices (level 3,4) as with a secure make and model Commitment Database under a to U.S. Nuclear described in Section 4.3, .that has been verified to prevent separate record (AT 1223694-regulatory "Defense-In-Depth Protective transfer of files between servers 35) as follows.

Commission - Strategies" of the CSP. was removed from the "response to commitment management The Data Diode, as installed by Request for Lower security level devices database. EC 380686, isolates level 3 Additional .(level 0, 1,2 devices) that. from level l and level 2, Information bypass the deterministic allowing data only to flow from Regarding device and connect to level 3 higher level devices [level 3,4]

Exelon Cyber or 4 will be modified-to .pr..event to lower levels [level 0,1,2].

Security Plan, the digital connectivity to the A review of site networks was dated: March 31, higher level or will be modified- performed to ensure that no 2011 to meet cyber securitY " bypasses existed between requirements commensurate lower level devices [level 0, 1,

_____________Letter from Joel with the level 3 or 4 devices to ______________2] and higher level devices Page 1 of 2

2014 Regulatory Commitment Change Summary Report I S. Weibe, U.S. which they connect. [level 3, 4] after installation of Nuclear EC 380686. This review is Regulatory The design modifications that documented by ATI 01242053.

Commission to are not finished by the Michael J. completion date will be This review identified that the Pacilio, Exelon documented in the site PPC connection to the Nuclear (Exelon configuration management instruments located at the river Generation and/or change control program screen house created a Company, LLC to assure completion of the situation that a lower level

- Issuance of. design modification as soon as device was connected to a Amendments possible, but no later than the higher level device bypassing regarding the final implementation date., the data diode. EC 384720 was Exelon Cyber generated to address this issue.

Security Plan, dated August In addition, after installation of 10, 2011 the data diode it was determined that the KVM used in the LaSalle design also posed a bypass path specific to LaSalle installation. EC 390376 was generated to address this issue.

The three identified design changes, EC 380686, EC 384720 and EC 390376, have been finished.

Page 2 of 2