ML14097A088

Wolf Creek Nuclear Operating Corporation - Redacted Version of License Amendment Request (LAR) for Revision to Cyber Security Plan Implementation Schedule Completion Date

ML14097A088
Person / Time
Site:	Wolf Creek
Issue date:	03/31/2014
From:	Smith R A Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
WO 14-0033
Download: ML14097A088 (20)

Text

W. SLF CREEK'NUCLEAR OPERAFING CORPORATION March 31, 2014Russell A. SmithSite Vice President and Chief Nuclear Operating OfficerWO 14-0033U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555

References:

1) Letter WO 14-0001, dated January 23, 2014, from R. A. Smith,WCNOC, to USNRC

Subject:

Docket No. 50-482: Redacted Version of License Amendment Request (LAR) for Revision to Cyber Security Plan Implementation Schedule Completion DateGentlemen:

Reference 1 provided the Wolf Creek Nuclear Operating Corporation (WCNOC) application toamend the Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station (WCGS). This amendment request proposed a change to the Cyber Security Plan forWolf Creek Nuclear Operating Corporation, Wolf Creek Generating Station (hereafter referredto as Cyber Security Plan) Implementation Milestone

1. 8 completion date. With this submittal, WCNOC provides a redacted version of the license amendment request which does not containsecurity related information and is suitable for public disclosure.

Attachment I contains the redacted version of the Evaluation that was included as Attachment Ito the Reference I letter. The redacted version of the Evaluation does not contain securityrelated information.

Attachment II contains the same proposed marked-up operating licensepage for the physical protection license condition for WCGS to reference the commitment change provided in this submittal.

Attachment III contains the proposed revised operating license page.In accordance with 10 CFR 50.91(b),

"State consultation,"

a copy of the redacted amendment application, with attachments, is being provided to the designated Kansas State official.

P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831An Equal Opportunity Employer M/F/HCNET Z-WO 14-0033Page 2 of 3This letter contains no new commitments.

If you have any questions concerning this matter,please contact me at (620) 364-4156, or Mr. Michael J. Westman at (620) 364-4009.

Sincerely, Russell A. SmithRAS/rlt

Attachment:

IIIllEvaluation of Proposed Change (Redacted)

Proposed Renewed Facility Operating License Change (Mark-up)

Retyped Renewed Facility Operating License Changecc: M. L. Dapas (NRC), w/aT. A. Conley (KDHE), w/aC. F. Lyon (NRC), w/aN. F. O'Keefe (NRC), w/aSenior Resident Inspector (NRC), w/a WO 14-0033Page 3 of 3STATE OF KANSASCOUNTY OF COFFEY))Russell A. Smith, of lawful age, being first duly sworn upon oath says that he is Site VicePresident and Chief Nuclear Operating Officer of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executedthe same for and on behalf of said Corporation with full power and authority to do so; and thatthe facts therein stated are true and correct to the best of his knowledge, information and belief.By ___ __Russell A. SmithSite Vice President and Chief Nuclear Operating Officerand sworn to before me this 3l1/day ofSUBSCRIBED

,2014......RY RHONDA L. TIEMEYER--- :T MAyAppointment ExpiresJanuary 11, 2018Notary Public"10. -' ýdl-willl(dýExpiration Date SECURITY RELATED INFORMATION WNITHHOLD UNDER 10 CFR 2.390Attachment I to WO 14-0033Page 1 of 13EVALUATION OF PROPOSED CHANGE

Subject:

Revision to Cyber Security Plan Implementation Schedule Completion Date1. SUMMARY DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Significant Hazards Consideration

4.3 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES REDACTED SECURITY RELATED INFORMATION WITHHOLD UNDER 10 CFR 2.390Attachment I to WO 14-0033Page 2 of 131. SUMMARY DESCRIPTION The proposed license amendment request includes the proposed completion date change to animplementation schedule milestone and a proposed revision to the renewed facility operating license physical protection license condition (Paragraph 2.E of the Renewed Facility Operating License No. NPF-42).2. DETAILED DESCRIPTION In Reference 1, the Cyber Security Plan for Wolf Creek Nuclear Operating Corporation, WolfCreek Generating

Station, (hereafter referred to as Cyber Security Plan) and associated implementation schedule were approved by the Nuclear Regulatory Commission (NRC).Because the Cyber Security Plan Implementation Schedule contained in Reference 2 wasutilized as a portion of the basis for the NRC's safety evaluation provided by Reference 1, thisproposed amendment request includes:

1) a proposed change to the existing renewed facilityoperating license condition for the physical protection license condition to reference a deviation for the completion date for an implementation schedule milestone and 2) a proposed RevisedCyber Security Plan Implementation Schedule for the completion date of Implementation Milestone

1. 8. Implementation Milestone

1. 8 requires the full implementation of the Wolf CreekNuclear Operating Corporation (WCNOC) Cyber Security Plan for all SSEP (safety related andimportant-to safety functions, security functions, and emergency preparedness functions including offsite communications) functions by no later than December 31, 2014. This changeproposes a revision to the completion date of Implementation Milestone

1. 8.3. TECHNICAL EVALUATION In Reference 3, the Nuclear Energy Institute (NEI) transmitted to the NRC an implementation schedule template to aid compliance with the NRC's cyber security regulations codified in 10CFR 73.54 which was acknowledged in Reference 4 by the NRC. NEI engaged the industry inan effort to ensure that utilities submit an implementation schedule consistent with the templateprovided by Reference

3. WCNOC provided the requested implementation schedule inReference 2 in accordance with the template which the NRC acknowledged in Reference

4.

SECURITY RELATED INFORMATION WITHHOLD UNDER 10 CFR 2.390Attachment I to WO 14-0033Page 3 of 13An NRC memorandum (Reference

7) provides eight criteria for the review of licenseamendment requests to revise implementation schedule Milestone 8 dates. The following technical evaluation provides information concerning eight criteria that serves to explain thecurrent status of the WCNOC cyber security program and the need for the Implementation Milestone

1. 8 completion date revision.

The evaluation describes how prioritization ofWCNOC's complete and planned implementation actions will provide assurance that digitalcomputer and communication systems and networks are adequately protected against cyberattacks up to and including the design basis threat established by 10 CFR 73.1(a)(1)(v),

untilthe full program is implemented by the proposed completion date.

SECURITY RELATED INFORMATION WITHHOLD UNDER 10 CER 2.390Attachment I to WO 14-0033Page 4 of 13 SECURITY RELATED INFORMATION WAITHHOLD UNDER 10 CFR 2.390Attachment I to WO 14-0033Page 5 of 13 SECURITY RELATEDINFORMATION WITHHOLD UNDER 10 C!F=2.390 Attachment I to WO 14-0033Page 6 of 13 SECURITY RELATEDINFORMATION W'ITHHOLD 10" FR 2.390Attachment I to WO 14-0033Page 7 of 13 SECURITY RELATED INFORMATION WITHHOLD UNDER 10 CFR 2.390Attachment I to WO 14-0033Page 8 of 13 SECURITY RELATED INFORMATION

-WITHHOLD !0 CFR 2.390Attachment I to WO 14-0033Page 9 of 13 SECURITY REL-ATEDINFORMATION WITHHOLD UNDER 10 CFR 2.390Attachment I to WO 14-0033Page 10 of 13This license amendment request includes the proposed change to the existing renewed facilityoperating license condition for physical protection (Attachments II and Ill) for WCGS. Thislicense amendment request also contains the proposed revised WCNOC Cyber Security PlanImplementation Schedule (Attachment IV).4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 73.54 requires licensees to maintain and implement a cyber security plan. Wolf CreekGenerating Station (WCGS) renewed facility operating license includes a physical protection license condition (Paragraph 2.E of the Renewed Facility Operating License No. NPF-42) thatrequires Wolf Creek Nuclear Operating Corporation (WCNOC) to fully implement and maintainin effect all provisions of the Commission-approved cyber security plan, including changesmade pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

4.2 No Significant Hazards Consideration Pursuant to 50.90, "Application for amendment of license, construction permit, or early sitepermit,"

Wolf Creek Nuclear Operating Corporation (WCNOC) hereby requests an amendment to the Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station(WCGS). This amendment request proposes a change to the Implementation Milestone

1. 8completion date specified in the WCNOC Cyber Security Plan Implementation Schedule.

SECURITY RELATED INFORMATION WITHHOLD UNDER 10 .FR 2.390Attachment I to WO 14-0033Page 11 of 13WCNOC has evaluated whether or not a significant hazards consideration is involved with theproposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuanceof amendment, as discussed below:1. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?

Response:

NoThe proposed change to the WCNOC Cyber Security Plan Implementation Schedule isadministrative in nature. This change does not alter accident analysis assumptions, add anyinitiators, or affect the function of plant systems or the manner in which systems are operated, maintained,

modified, tested, or inspected.

The proposed change does not require any plantmodifications which affect the performance capability of the structures,

systems, andcomponents (SSCs) relied upon to mitigate the consequences of postulated accidents, and hasno impact on the probability or consequences of an accident previously evaluated.

Therefore, the proposed changes do not involve a significant increase in the probability orconsequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accidentfrom any accident previously evaluated?

Response:

NoThe proposed change to the WCNOC Cyber Security Plan Implementation Schedule isadministrative in nature. This proposed change does not alter accident analysis assumptions, add any initiators, or affect the function of plant systems or the manner in which systems areoperated, maintained,

modified, tested, or inspected.

The proposed change does not requireany plant modifications which affect the performance capability of the SSCs relied upon tomitigate the consequences of postulated accidents, and does not create the possibility of a newor different kind of accident from any accident previously evaluated.

Therefore, the proposed change does not create the possibility of a new or different kind ofaccident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?Response:

NoPlant safety margins are established through limiting conditions for operation, limiting safetysystem settings, and safety limits specified in the technical specifications.

The proposedchange to the WCNOC Cyber Security Plan Implementation Schedule is administrative innature. Since the proposed change is administrative in nature, there is no change to theseestablished safety margins.Therefore the proposed change does not involve a significant reduction in a margin of safety.

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%A11TLJLJC1 r% 1 IkMfD In t-=D 1 'ýtlnAttachment I to WO 14-0033Page 12 of 13Based on the above evaluations, WCNOC concludes that the proposed amendment presentsno significant hazards under the standards set forth in 10 CFR 50.92(c) and, accordingly, afinding of "no significant hazards consideration" is justified.

4.3 Conclusions

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposedmanner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and securityor to the health and safety of the public.5. ENVIRONMENTAL CONSIDERATION WCNOC has evaluated the proposed change and has determined that the change does notinvolve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amount of effluent that may be released

offsite, or (iii) a significant increase inthe individual or cumulative occupational radiation exposure.

Accordingly, the proposedchanges meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (12). Therefore, pursuant to 10 CFR 51.22(b),

an environmental assessment of theproposed change is not required.

6. REFERENCES

1. NRC letter from J. R. Hall, USNRC, to M. W. Sunseri, WCNOC, "Wolf Creek Generating Station -Issuance of Amendment Re: Approval of Cyber Security Plan (TAC NO.ME4265),"

July 27, 2011. (ADAMS Accession No. ML1 11990339)

2. WCNOC letter WO 11-0017, "Response to Request for Additional Information Regarding License Amendment Request for Approval of the Cyber Security Plan," April 1, 2011.(ADAMS Accession No. ML1 10970134)

3. Letter from C. E. Earls, NEI, to R. P. Correia, USNRC, "Template for the Cyber SecurityPlan Implementation Schedule,"

dated February 28, 2011. (ADAMS Accession No.ML110600211)

4. Letter from R. P. Correia, USNRC, to C. E. Earls, NEI, "Template for the Cyber SecurityPlan Implementation Schedule,"

dated March 1, 2011. (ADAMS Accession No.ML110070348)

5. NEI 08-09, "Cyber Security Plan for Nuclear Power Reactors,"

Revision 6, April 2010.6. Memorandum dated July 1, 2013 from B. Westreich, NRC, to T. Blount, NRC, "Enhanced Guidance for Licensee Near-Term Corrective Actions to Address Cyber SecurityInspection Findings and Licensee Eligibility for 'Good-Faith' Attempt Discretion."

SECURITY RELATED INFORMATION WITHHOLD UNDER 10 CFR 2.390Attachment I to WO 14-0033Page 13 of 137. Memorandum dated October 24, 2013, from R. Felts, NRC to B. Westreich, NRC,"Review Criteria for Title 10 of the Code of Federal Regulations Part 73.54, Cyber SecurityImplementation Schedule Milestone 8 License Amendment Requests."

(ADAMSAccession No. ML13295A467)

Attachment II to WO 14-0033Page 1 of 2PROPOSED RENEWED FACILITY OPERATING LICENSE CHANGES (MARK-UP)

Attachment II to WO 14-0033Page 2 of 27(16) Additional Conditions The Additional Conditions contained in Appendix D, as revised throughAmendment No. 163, are hereby incorporated into this license.

WolfCreek Nuclear Operating Corporation shall operate the facility inAccordance with the Additional Conditions.

D. Exemptions from certain, requirements of Appendix J to 10 CFR Part 50, andfrom a portion of the requirements of General Design Criterion 4 of Appendix A to10 CFR Part 50, are described in the Safety Evaluation Report. Theseexemptions are authorized by law and will not endanger life or property or thecommon defense and security and are otherwise in the public interest.

Therefore, these exemptions are hereby granted pursuant to 1.0 CFR 50.12- With thegranting of these exemptions the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act,and the rules and regulations of the Commission.

E. 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 toprovisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73-55 (51 FR 27817 and 27822) and to the authority of10 CFR 50.90 and 10 CFR 50.54(p).

The set of combined plans, which containsSafeguards Information protected under 10 CFR 73.21, is entitled-

"Wolf CreekSecurity Plan, Training and Qualification Plan, and Safeguard Contingency Plan,"and was submitted on May 17,2006.The licensee shall fully implement and maintain in effect all provisions of theCommission-approved cyber security plan (CSP), including changes madepursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The licensee's CSP was approved by License Amendment No. 197, as supplemented by achanges approved.

by License Amendment No. 202 and License Amendment F. Deleted per Amendment No. 141. ENo -Xxx.G. The licensees shall have and maintain financial protection of such type and insuch amounts as the Commission shall require in accordance with Section 170 ofthe Atomic Energy Act of 1954, as amended, to cover public liability claims.H. The Updated Safety Analysis Report (USAR) supplement, as revised, submitted pursuant to 10 CFR 54.21(d),

shall be induded in the next scheduled update tothe USAR required by 10 CFR 50.71(e)(4),

as appropriate, following the issuanceof this renewed operating license.

Until that update is complete, WCNOC maymake. changes, to the programs and activities described in the supplement without prior Commission

approval, provided that WCNOC evaluates suchchanges pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.Renewed License No. NPF-42Amendment No. 4e49, Q.9Z, 202 Attachment III to WO 14-0033Page 1 of 2RETYPED RENEWED FACILITY OPERATING LICENSE CHANGES 7(16) Additional Conditions The Additional Conditions contained in Appendix D, as revised throughAmendment No. 163, are hereby incorporated into this license.

Wolf CreekNuclear Operating Corporation shall operate the facility in Accordance with theAdditional Conditions.

D. Exemptions from certain requirements of Appendix J to 10 CFR Part 50, and from a portion of therequirements of General Design Criterion 4 of Appendix A to 10 CFR Part 50, are described in theSafety Evaluation Report. These exemptions are authorized by law and will not endanger life orproperty or the common defense and security and are otherwise in the public interest.

Therefore, these exemptions are hereby granted pursuant to 10 CFR 50.12. With the granting of theseexemptions the facility will operate, to the extent authorized herein, in conformity with theapplication, as amended, the provisions of the Act, and the rules and regulations of theCommission.

E. 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 SearchRequirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10CFR 50.90 and 10 CFR 50.54(p).

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

"Wolf Creek Security Plan, Training andQualification Plan, and Safeguard Contingency Plan," and was submitted on May 17, 2006.The licensee shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority ofi 0 CFR50.90 and 10 CFR 50.54(p).

The licensee's CSP was approved by License Amendment No. 197,as supplemented by changes approved by License Amendment No. 202 and License Amendment No.F. Deleted per Amendment No. 141.G. The licensees shall have and maintain financial protection of such type and in such amounts asthe Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954,as amended, to cover public liability claims.H. The Updated Safety Analysis Report (USAR) supplement, as revised, submitted pursuant to 10CFR 54.21(d),

shall be included in the next scheduled update to the USAR required by 10 CFR50.71 (e)(4), as appropriate, following the issuance of this renewed operating license.

Until thatupdate is complete, WCNOC may make changes to the programs and activities described in thesupplement without prior Commission

approval, provided that WCNOC evaluates such changespursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements inthat section.Renewed License No. NPF-42Amendment No. 179., 97,-202,