ML111080070

Response to Request for Additional Information Regarding Cyber Security Plan License Amendment Request

ML111080070
Person / Time
Site:	Watts Bar
Issue date:	04/07/2011
From:	Krich R Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
WBN-TS-09-23
Download: ML111080070 (10)

Text

SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 Tennessee Valley Authority 1101 Market Street, LP 3R Chattanooga, Tennessee 37402-2801 R. M. Krich Vice President Nuclear Licensing April 7, 2011 10 CFR 50.4 WBN -TS-09-23 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License No. NPF-90 NRC Docket Nos. 50-390 and 50-391

Subject:

Response to Request for Additional Information Regarding Watts Bar Nuclear Plant Cyber Security Plan License Amendment Request

References:

1. Letter from TVA to NRC, "Request for Approval of the Watts Bar Nuclear Plant Cyber Security Plan," dated November 23, 2009

2. Letter from TVA to NRC, "Supplement to Request for Approval of the Watts Bar Nuclear Plant Cyber Security Plan," dated December 18, 2009 3 Letter from TVA to NRC, "Second Supplement to Request for Approval of the Watts Bar Nuclear Plant Cyber Security Plan,"

dated July 23, 2010

4. Letter from NRC to TVA, "Browns Ferry Nuclear Plant, Units 1, 2 and 3, Sequoyah Nuclear Plant, Units 1 and 2 and Watts Bar Nuclear Plant, Units 1 and 2 - Request for Additional Information Regarding Cyber Security Plans Based on Nuclear Energy Institute 08-09, Revision 6 (TAC Nos. ME4952, ME4953, ME4954, ME4955, ME4956, ME4951, and ME4958)," dated March 8, 2011 SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 ENCLOSURES 1, 2, AND 4 TO THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. SECURITY-RELATED INFORMATION CLASSIFICATION DOES NOT APPLY TO THIS PAGE WHEN SEPARATED FROM ENCLOSURES 1, 2, AND 4.

printed on recycled paper

SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 U.S. Nuclear Regulatory Commission Page 2 April 7, 2011 In Reference 1, as supplemented by References 2 and 3, the Tennessee Valley Authority (TVA), submitted a request for amendment to the Facility Operating License (FOL) for the Watts Bar Nuclear (WBN) Plant, Unit 1. The proposed amendment requests NRC approval of the Plant Cyber Security Plan for WBN and provides revisions to the existing FOL Physical Protection license condition and to the Cyber Security Plan Implementation Schedule for WBN.

By letter dated March 8, 2011 (Reference 4), the NRC requested that additional information be submitted by TVA to support the NRC review of the license amendment request. In Reference 4, the NRC requested that WVA provide a response within 30 days of the date of the letter. Accordingly, this submittal is due by April 7, 2011. provides TVA's responses to the NRC's Request for Additional Information (RAI) questions in Reference 4. contains the Cyber Security Plan Implementation Schedule for WBN, revised as discussed in Enclosure 1. contains revised pages for the Physical Protection license condition for WBN Unit 1 to add a reference date of April 7, 2011, to this supplement. The pages in Enclosure 3 replace, in their entirety, the marked-up and re-typed pages previously submitted in Attachments 1 and 2 to Enclosure 1 of Reference 3. provides a revised copy of the Cyber Security Plan for WBN, Revision 0, which incorporates the changes discussed in Enclosure 1. No other changes have been made to the Cyber Security Plan. The Cyber Security Plan for WBN provided in replaces, in its entirety, the Cyber Security Plan previously submitted as of Reference 3.

Enclosures 1, 2, and 4 contain security-related information. WVA requests that Enclosures 1, 2, and 4 be withheld from public disclosure in accordance with 10 CFR 2.390, "Public inspections, exemptions, requests for withholding."

Additionally, in accordance with 10 CFR 50.91 (b)(1), WVA is sending a copy of this letter and attachments to the Tennessee State Department of Environment and Conservation.

The changes discussed clarify the information submitted in Reference 3 and do not impact the conclusions of the no significant hazards consideration determination previously provided in Reference 2.

SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 ENCLOSURES 1, 2, AND 4 TO THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. SECURITY-RELATED INFORMATION CLASSIFICATION DOES NOT APPLY TO THIS PAGE WHEN SEPARATED FROM ENCLOSURES 1, 2, AND 4.

SECURITY-RELATED INFORMATION -WITHHOLD UNDER 10 CFR 2.390 U.S. Nuclear Regulatory Commission Page 3 April 7, 2011 There are no commitments associated with this submittal. If you have any questions regarding this submittal, please contact Kara Stacy at (423) 751-3489.

I declare under the penalty of perjury that the foregoing is true and correct. Executed on the 7t" day of April, 2011.

Respectfully, R. M. Krich

Enclosures:

1. Response to Request for Additional Information Regarding Watts Bar Nuclear Plant Cyber Security Plan License Amendment Request

2. Cyber Security Plan Implementation Schedule for Watts Bar Nuclear Plant

3. Proposed Facility Operating License Changes

4. Cyber Security Plan for Watts Bar Nuclear Plant cc (Enclosures):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Watts Bar Nuclear Plant, Unit 1 NRC Senior Resident Inspector - Watts Bar Nuclear Plant, Unit 2 Director, Division of Radiological Health - Tennessee State Department of Environment and Conservation (w/o Enclosures 2 and 4)

SECURITY-RELATED INFORMATION - WITHHOLD UNDER 10 CFR 2.390 ENCLOSURES 1, 2, AND 4 TO THIS LETTER CONTAINS SECURITY-RELATED INFORMATION. SECURITY-RELATED INFORMATION CLASSIFICATION DOES NOT APPLY TO THIS PAGE WHEN SEPARATED FROM ENCLOSURES 1, 2, AND 4.

Enclosure 3 Proposed Facility Operating License Change (Marked-Up and Re-Typed)

Wafts Bar Nuclear Plant, Unit 1 Proposed Facility Operating License Change (Marked-Up)

5 (2) The facility was previously granted an exemption from the criticality monitoring requirements of 10 CFR 70.24 (see Special Nuclear Material License No. SNM-1 861 dated September 5, 1979). The technical justification is contained in Section 9.1 of Supplement 5 to the Safety Evaluation Report, and the staffs environmental assessment was published on April 18, 1985 (50 FR 15516). The facility is hereby exempted from the criticality alarm system provisions of 10 CFR 70.24 so far as this section applies to the storage of fuel assemblies held under this license.

(3) The facility requires an exemption from 10 CFR 73.55(c)(1 0). The justification for this exemption is contained in Section 13.6.9 of Supplement 15 and 20 to the Safety Evaluation Report. The staffs environmental assessment was published on April 25, 1995 (60 FR 20291). Pursuant to 10 CFR 73.5, the facility is exempted from the stated implementation schedule of the surface vehicle bomb rule, and may implement the same as late as February 17, 1996.

(4) The facility was previously granted an exemption from certain requirements of 10 CFR 73.55(d)(5) relating to the returning of picture badges upon exit from the protected areas, such that individuals not employed by TVA who are authorized unescorted access into protected areas can take their badges offsite (see 59 FR 66061, December 22, 1994). The granting of this exemption is hereby affirmed.

(5) The facility was previously granted an exemption from certain requirements of 10 CFR 50, Appendix E, such that the State of Tennessee, which is within the ingestion exposure pathway emergency planning zone, need not participate in the November 1995 full-participation exercise (see 60 FR 54526, October 24, 1995). The granting of this exemption is hereby affirmed.

E. TVA shall fully implement and maintain in effect all provisions of the Commission approved physical security, training and qualification, and INSERT safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements (1) revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Watts Bar Nuclear Plant Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 3," submitted by letter dated May 16, 2006.

INSERT F. TVA shall implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Report for the facility, as approved in Supplements 18 and 19 of the SER (NUREG-0847) subject to the following provision:

TVA 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.

(2) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Watts Bar Nuclear Plant Cyber Security Plan submitted by letter dated April 7. 2011. and withheld from public disclosure in accordance with 10 CFR 2,390.

Revised by letter dated August 9, 2007 and Correction letter dated September 18, 2007

5a F. TVA shall implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Report for the facility, as approved in Supplements 18 and 19 of the SER (NUREG-0847) subject to the following provision:

TVA 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.

G. Except as otherwise provided in the Technical Specifications (Appendix A to this license) or Environmental Protection Plan (Appendix B to this license), TVA shall report any violations of the requirements contained in Section 2.C of this license in the following manner: initial notification shall be made within twenty-four (24) hours to the NRC Operations Center via the Emergency Notification System with written follow-up within 30 days in accordance with the procedures described in 10 CFR 50.73 (b), (c), and (e).

H. The licensee shall have and maintain financial protection of such types 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.

Revised by letter dated August 9, 2007 Amendment No. [##]

Watts Bar Nuclear Plant, Unit I Proposed Facility Operating License Change (Re-Typed)

5 (2) The facility was previously granted an exemption from the criticality monitoring requirements of 10 CFR 70.24 (see Special Nuclear Material License No. SNM-1 861 dated September 5, 1979). The technical justification is contained in Section 9.1 of Supplement 5 to the Safety Evaluation Report, and the staffs environmental assessment was published on April 18, 1985 (50 FR 15516). The facility is hereby exempted from the criticality alarm system provisions of 10 CFR 70.24 so far as this section applies to the storage of fuel assemblies held under this license.

(3) The facility requires an exemption from 10 CFR 73.55(c)(10). The justification for this exemption is contained in Section 13.6.9 of Supplement 15 and 20 to the Safety Evaluation Report. The staffs environmental assessment was published on April 25, 1995 (60 FR 20291). Pursuant to 10 CFR 73.5, the facility is exempted from the stated implementation schedule of the surface vehicle bomb rule, and may implement the same as late as February 17, 1996.

(4) The facility was previously granted an exemption from certain requirements of 10 CFR 73.55(d)(5) relating to the returning of picture badges upon exit from the protected areas, such that individuals not employed by TVA who are authorized unescorted access into protected areas can take their badges offsite (see 59 FR 66061, December 22, 1994). The granting of this exemption is hereby affirmed.

(5) The facility was previously granted an exemption from certain requirements of 10 CFR 50, Appendix E, such that the State of Tennessee, which is within the ingestion exposure pathway emergency planning zone, need not participate in the November 1995 full-participation exercise (see 60 FR 54526, October 24, 1995). The granting of this exemption is hereby affirmed.

E. (1) TVA 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 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Watts Bar Nuclear Plant Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 3," submitted by letter dated May 16, 2006.

(2) The licensee shall fully implement and maintain in effect all provisions of the Commission-approved Watts Bar Nuclear Plant Cyber Security Plan submitted by letter dated April 7, 2011, and withheld from public disclosure in accordance with 10 CFR 2.390.

Revised by letter dated August 9, 2007 and Correction letter dated September 18, 2007 Amendment No. [##]

5a F. TVA shall implement and maintain in effect all provisions of the approved fire protection program as described in the Fire Protection Report for the facility, as approved in Supplements 18 and 19 of the SER (NUREG-0847) subject to the following provision:

TVA 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.

G. Except as otherwise provided in the Technical Specifications (Appendix A to this license) or Environmental Protection Plan (Appendix B to this license), TVA shall report any violations of the requirements contained in Section 2.C of this license in the following manner: initial notification shall be made within twenty-four (24) hours to the NRC Operations Center via the Emergency Notification System with written follow-up within 30 days in accordance with the procedures described in 10 CFR 50.73 (b), (c), and (e).

H. The licensee shall have and maintain financial protection of such types 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.

Revised by letter dated August 9, 2007 Amendment No. [##]