ML14241A422

St. Lucie Units 1 and 2 - Revised License Amendment Request Change of the Milestone 8 Completion Date

ML14241A422
Person / Time
Site:	Saint Lucie
Issue date:	08/19/2014
From:	Jensen J Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2014-271
Download: ML14241A422 (11)

Text

Security-Related Information

-Withhold Under 10 CFR 2.3900 August 19, 2014FPL. L-2014-271 10 CFR 50.90Document Control DeskU.S. Nuclear Regulatory Commission Washington, DC 20555Re: St. Lucie Units 1 and 2Docket Nos. 50-335 and 50-389Facility Operating License Nos. DPR-67 and NPF-16Revised License Amendment RequestChange of the Milestone 8 Completion Date

References:

1. R. Anderson (FPL) letter to Document Control Desk (L-2010-149),

"Resubmittal of Cyber Security Plan," August 2, 2010, (ADAMS Accession No. ML1 02180183).

2. J. Jensen (FPL) letter to Document Control Desk (NRC), (L-2012-220),

"LicenseAmendment Request -Cyber Security Plan Implementation ScheduleMilestones,"

June 21, 2012, (ADAMS Accession No. ML12178A384).

3. T. Orf (NRC) letter to M. Nazar (FPL), "St. Lucie Plant, Units 1 and 2 -Issuanceof Amendments Regarding Approval of the St. Lucie Cyber Security Plan (TACNos. ME4582 and ME4583,"

August 31, 2011, (ADAMS Accession No.ML1 1196A079).

4. T. Orf (NRC) letter to M. Nazar (FPL), "St. Lucie Plant, Units 1 and 2 -Issuanceof Amendments Regarding Revision to Cyber Security Plan Milestone 6 (TACNos. ME9128 and ME9129,"

December 17, 2012, (ADAMS Accession No.ML12339A109).

5. FPL Letter L-2014-271 dated June 30, 2014, "License Amendment RequestChange of the Milestone 8 Completion Date" (ADAMS Accession No.ML14192A022)

In Reference 5, Florida Power & Light (FPL) submitted the request to amend the CyberSecurity Plan for St. Lucie Units 1 and 2 to change the implementation date forMilestone

8. The Cyber Security Plan and implementation schedule were previously provided in References 1 and 2 and approved by the NRC in References 3 and 4.However, Reference 5 conservatively designated all of Attachment 1 as Security-Related Information to be withheld from the public. This letter revises the Attachments to allow additional portions to be released to the public.This submittal revision is considered editorial in nature and the original no significant hazards evaluation remains bounding.

Attachment 1 transmitted herewith contains security-related information 001to be withheld under 10 CFR 2.390. When separated from this transmittal, Florida Power & Light Companythe remaining transmittal document is decontrolled.

6501 S. Ocean Drive, Jensen Beach, FL 34957 Security-Related Information

-Withhold Under 10 CFR 2.390L-2014-271 Page 2Should you have any questions regarding this submittal, please contact Mr. EricKatzman, Licensing Manager at (772) 467-7734.

I declare under penalty of perjury that the foregoing is true and correct to the best of myknowledge.

Executed on day of Au~jrLU , 2014.J_Very truly yours,(,- Yiet 3'k VianýU6e JensenSite Vice President St. Lucie PlantAttachments:

1. Analysis of Proposed Operating License Change2. Regulatory Evaluation

3. Proposed Operating License Change (marked-up pages)4. Revised Operating License (retyped pages)cc: Ms. Cynthia Becker Chief -Florida Bureau of Radiation ControlAttachment 1 transmitted herewith contains security-related information to be withheld under 10 CFR 2.390. When separated from this transmittal, the remaining transmittal document is decontrolled.

L-2014-271 Attachment 2Page 1 of 3Attachment 2Regulatory Evaluation REGULATORY EVALUATION 1.1 Applicable Regulatory Requirements/Criteria 1.2 No Significant Hazards Consideration Determination

1.3 Conclusions

2. ENVIRONMENTAL CONSIDERATION L-2014-271 Attachment 2Page 2 of 3REGULATORY EVALUATION 1.1 Applicable Regulatory Requirements/Criteria 10 CFR 73.54 requires licensees to maintain and implement a Cyber SecurityPlan (CSP). St. Lucie Units 1 and 2, Facility Operating Licenses (FOLs) Nos.DPR-67 and NPF-16, respectively, include a Physical Protection licensecondition that requires FPL to fully implement and maintain in effect allprovisions of the Commission-approved CSP, including changes made pursuantto the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

1.2 No Significant Hazards Consideration Determination FPL is requesting approval of changes to St. Lucie Units 1 and 2, FOLs Nos.DPR-67 and NPF-16, respectively to revise the Physical Protection licensecondition as it relates to the Cyber Security Plan. This change includes aproposed deviation to the Cyber Security Plan implementation schedule and aproposed revision to the St. Lucie FOLs to include the proposed deviation.

Specifically, FPL proposes to change the completion date for full implementation (Milestone

8) of the Cyber Security Plan.FPL has evaluated whether or not a significant hazards consideration is involvedwith the proposed amendment by focusing on the three standards set forth in10 CFR 50.92, "Issuance of Amendment,"

as described below:(1) Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No.The proposed change to the Cyber Security Plan implementation schedule is administrative in nature. The change does not alter accidentanalysis assumptions, add any initiators or affect the function of plantsystems or the manner in which systems are operated, maintained, tested, or inspected.

The proposed change does not require any plantmodifications which affect the performance capability or the structures, systems and components relied upon to mitigate the consequences ofpostulated accidents and has no impact on the probability orconsequences of an accident previously evaluated.

Therefore, theproposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Does the proposed change create the possibility of a new or different kindof accident from any accident previously evaluated?

Response:

No.The proposed change to the Cyber Security Plan implementation schedule is administrative in nature. This proposed change does not alter L-2014-271 Attachment 2Page 3 of 3accident analysis assumptions, add any initiators, or affect the function ofplant systems or the manner in which systems are operated, maintained,

modified, tested, or inspected.

The proposed change does not requireany plant modifications which affect the performance capability of thestructures, systems and a component relied upon to mitigate theconsequences of postulated accidents and does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Therefore, the proposed change does not create thepossibility of a new or different kind of accident from any accidentpreviously evaluated.

(3) Does the proposed change involve a significant reduction in a margin ofsafety?Response:

No.Plant safety margins are established through limiting conditions ofoperation, limiting safety systems settings and safety limits specified inthe technical specifications.

The proposed change to the Cyber SecurityPlan implementation schedule is administrative in nature. Because thereis no change in these established safety margins as result of this change,the proposed change does not involve a significant reduction in a marginof safety. Therefore, the proposed change does not involve a significant reduction in a margin of safety.Based on the above, FPL concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and,accordingly, a finding of "no significant hazards consideration" is justified.

1.3 Conclusion

Based on the considerations described above, (1) there is reasonable assurance thatthe health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be in compliance with the Commission's regulations and(3) the issuance of amendments will not be inimical to the common defense and securityor to the health and safety of the public.2. ENVIRONMENTAL CONSIDERATION The proposed amendment provides a change to the Cyber Security Plan implementation schedule.

The proposed amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51.22(c)(12).

Therefore, pursuant to 10 CFR 51.22(b),

noenvironmental impact statement or environmental assessment need be prepared inconnection with the issuance of this amendment.

L-2014-271 Attachment 3Page 1 of 3Attachment 3St. Lucie Units 1 and 2Facility Operating License Nos. DPR-67 and NPF-16Proposed Operating License Change(marked-up pages)

L-2014-271 Attachment 3Page 2 of 3-4-E. Fire Protection FPL shall implement and maintain in effect all provisions of the approved fireprotection program as described in the Updated Final Safety Analysis Report forthe facility (The fire protection program and features were originally described inFPL submittals L-83-514 dated October 7, 1983, L-83-227 dated April 12, 1983,L-83-261 dated April 25, 1983, L-83-453 dated August 24, 1983, L-83-488 datedSeptember 16, 1983, L-83-588 dated December 14, 1983, L-84-346 datedNovember 28, 1984, L-84-390 dated December 31, 1984, and L-85-71 datedFebruary 21, 1985) and as approved by NRC letter dated July 17, 1984, andsupplemented by NRC letters dated February 21, 1985, March 5, 1987, andOctober 4, 1988, subject to the following provision:

FPL may make changes to the approved fire protection programwithout prior approval of the Commission only if those changes wouldnot adversely affect the ability to achieve and maintain safe shutdownin the event of a fire.F. Physical Protection The licensee shall fully implement and maintain in effect all provisions of theCommission-approved physical

security, training and qualification, and safeguards contingency plans including amendments made pursuant to provision of theMiscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55(51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and10 CFR 50.54(p).

The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:

"Florida Power and Light &FPL Energy Seabrook Physical Security Plan, Training and Qualification Plan andSafeguards Contingency Plan -Revision 3," submitted by letter datedMay 18, 2006. St. Lucie shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes madepursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The St. LucieCSP was approved by License Amendment No. 211 as supplemented byeClarification red by License Amendmtnj No. 214G. Mitigation Strategy Lice nse Conýt' -na NDevelop and maintain strategies for addressing large ires and explosions andthat include the following key areas:(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance2. Assessment of mutual aid fire fighting assets3. Designated staging areas for equipment and materials

4. Command and control5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets2. Communications

3. Minimizing fire spread4. Procedures for implementing integrated fire response strategy5. Identification of readily-available pre-staged equipment Renewed License No. DPR-67Amendment No. 244Revised by letter dated December 17, 2012 L-2014-271 Attachment 3Page 3 of 3-5-F. Physical Protection The licensee shall fully implement and maintain in effect all provisions of theCommission-approved physical

security, training and qualification, andsafeguards contingency plans including amendments made pursuant toprovision 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 50.90and 10 CFR 50.54(p).

The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:

"Florida Power and Light &FPL Energy Seabrook Physical Security Plan, Training and Qualification Planand Safeguards Contingency Plan -Revision 3," submitted by letter datedMay 18, 2006. St. Lucie shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes madepursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

St. Lucie CSPwas approved by Ucense Amendment No. 160 as supplemented

.b .aclarification by License AmrendmwANo.

164 and No. XXX.G. Before engagir.k..ditional construction or operational a dvztV&V&result in a significant adverse environmental impact that was not evaluated orthat is significantly greater than that evaluated in the Final Environmental Statement dated April 1982, FPL shall provide written notification to the Office ofNuclear Reactor Regulation.

H. DELETED1. FPL shall notify the Commission, as soon as possible but not later than onehour, of any accident at this facility which could result in an unplanned release ofquantities of fission products in excess of allowable limits for normal operation established by the Commission.

J. FPL shall have and maintain financial protection of such type and in suchamounts as the Commission shall require in accordance with Section 170 of theAtomic Energy Act of 1954, as amended, to cover public liability claims.K. The use of ZIRLOTM clad fuel at St. Lucie Unit 2 will be subject to the following restrictions:

FPL will limit the fuel duty for St. Lucie Unit 2 to a baseline modified Fuel DutyIndex (mFDI) of 600 with a provision for adequate margin to account forvariations in core design (e.g., cycle length, plant operating conditions, etc).This limit will be applicable until data is available demonstrating the performance of ZIRLOTM cladding at Combustion Engineering 16x16 plants.FPL will restrict the mFDI of each ZIRLOTM clad fuel pin to 110 percent of thebaseline mFDI of 600.For a fraction of the fuel pins in a limited number of assemblies (8), FPL willrestrict the fuel duty of ZIRLOTM clad fuel pins to 120 percent of the baselinemFDI of 600.Renewed License No. NPF-16Amendment No. 4-64Revised by letter dated December 17, 2012 L-2014-271 Attachment 4Page 1 of 3Attachment 4St. Lucie Units 1 and 2Facility Operating License Nos. DPR-67 and NPF-16Revised Operating License(retyped page)

L-2014-271 Attachment 4Page 2 of 3-4-E. Fire Protection FPL shall implement and maintain in effect all provisions of the approved fireprotection program as described in the Updated Final Safety Analysis Report forthe facility (The fire protection program and features were originally described inFPL submittals L-83-514 dated October 7, 1983, L-83-227 dated April 12, 1983,L-83-261 dated April 25, 1983, L-83-453 dated August 24, 1983, L-83-488 datedSeptember 16, 1983, L-83-588 dated December 14, 1983, L-84-346 datedNovember 28, 1984, L-84-390 dated December 31, 1984, and L-85-71 datedFebruary 21, 1985) and as approved by NRC letter dated July 17, 1984, andsupplemented by NRC letters dated February 21,1985, March 5, 1987, andOctober 4, 1988, subject to the following provision:

FPL may make changes to the approved fire protection programwithout prior approval of the Commission only if those changes wouldnot adversely affect the ability to achieve and maintain safe shutdownin the event of a fire.F. Physical Protection The licensee shall fully implement and maintain in effect all provisions of theCommission-approved physical

security, training and qualification, and safeguards contingency plans including amendments made pursuant to provision of theMiscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55(51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and10 CFR 50.54(p).

The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:

"Florida Power and Light &FPL Energy Seabrook Physical Security Plan, Training and Qualification Plan andSafeguards Contingency Plan -Revision 3," submitted by letter datedMay 18, 2006. St. Lucie shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes madepursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The St. LucieCSP was approved by License Amendment No. 211 as supplemented byClarifications approved by License Amendments No. 214 and No. XXX.G. Mitiaation Strateav License Condition Develop and maintain strategies for addressing large fires and explosions andthat include the following key areas:(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance2. Assessment of mutual aid fire fighting assets3. Designated staging areas for equipment and materials

4. Command and control5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets2. Communications

3. Minimizing fire spread4. Procedures for implementing integrated fire response strategy5. Identification of readily-available pre-staged equipment Renewed License No. DPR-67Amendment No. 214Revised by letter dated December 17, 2012 L-2014-271 Attachment 4Page 3 of 3-5-F. Physical Protection The licensee shall fully implement and maintain in effect all provisions of theCommission-approved physical

security, training and qualification, andsafeguards contingency plans including amendments made pursuant toprovision 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 50.90and 10 CFR 50.54(p).

The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled:

"Florida Power and Light &FPL Energy Seabrook Physical Security Plan, Training and Qualification Planand Safeguards Contingency Plan -Revision 3," submitted by letter datedMay 18, 2006. St. Lucie shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes madepursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

St. Lucie CSPwas approved by License Amendment No. 160 as supplemented by clarifications approved by License Amendments No. 164 and No. XXX.G. Before engaging in additional construction or operational activities which mayresult in a significant adverse environmental impact that was not evaluated orthat is significantly greater than that evaluated in the Final Environmental Statement dated April 1982, FPL shall provide written notification to the Office ofNuclear Reactor Regulation.

H. DELETED1. FPL shall notify the Commission, as soon as possible but not later than onehour, of any accident at this facility which could result in an unplanned release ofquantities of fission products in excess of allowable limits for normal operation established by the Commission.

J. FPL shall have and maintain financial protection of such type and in suchamounts as the Commission shall require in accordance with Section 170 of theAtomic Energy Act of 1954, as amended, to cover public liability claims.K. The use of ZIRLOTM clad fuel at St. Lucie Unit 2 will be subject to the following restrictions:

FPL will limit the fuel duty for St. Lucie Unit 2 to a baseline modified Fuel DutyIndex (mFDI) of 600 with a provision for adequate margin to account forvariations in core design (e.g., cycle length, plant operating conditions, etc).This limit will be applicable until data is available demonstrating the performance of ZIRLOTM cladding at Combustion Engineering 16x16 plants.FPL will restrict the mFDI of each ZIRLOTM clad fuel pin to 110 percent of thebaseline mFDI of 600.For a fraction of the fuel pins in a limited number of assemblies (8), FPL willrestrict the fuel duty of ZIRLOTM clad fuel pins to 120 percent of the baselinemFDI of 600.Renewed License No. NPF-16Amendment No. 164Revised by letter dated December 17, 2012