ML17296A235

Request for Additional Information -10/23/17 E-mail from R.Guzman to R.Louie Cyber Security Plan Milestone 8 Implementation Schedule (CAC Nos. MF9656, MF9657, MF9658; EPID: L-2017-LLA-0217)

ML17296A235
Person / Time
Site:	Indian Point
Issue date:	10/23/2017
From:	Richard Guzman Plant Licensing Branch 1
To:	Louie R Entergy Nuclear Operations
Guzman R
References
CAC MF9656, CAC MF9657, CAC MF9658, EPID: L-2017-LLA-0217
Download: ML17296A235 (2)

Text

From: Guzman, Richard To: Louie, Richard Cc: Mirzai, Mahvash; Walpole, Robert W; Danna, James

Subject:

Indian Point Units 1, 2, and 3 - Cyber Security Plan Milestone 8 Implementation Schedule LAR - Request for Additional Information (CAC NOS. MF9656, MF9657, MF9658, EPID: L-2017-LLA-0217)

Date: Monday, October 23, 2017 11:56:12 AM Mr. Louie, By letter dated April 28, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17129A612), as supplemented on August 9, 2017 (ADAMS Accession No. ML17228A044) and September 28, 2017 (ADAMS Accession No. ML17277A140), Entergy Nuclear Operations, Inc. (Entergy), submitted a license amendment request (LAR) for Indian Point Nuclear Generating Unit Nos. 1, 2, and 3. The proposed amendments would extend the cyber security plan Milestone 8 full implementation date from December 31, 2017 to December 31, 2018.

The Nuclear Regulatory Commissions (NRC) staff is reviewing the submittal and has determined that additional information is needed to complete its review. The specific request for additional information (RAI) questions are provided below. The RAI questions were provided in draft form to you via e-mail on October 19, 2017. The draft RAI were sent to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. As we discussed today, I understand that you will provide a formal response to this RAI by November 3, 2017.

If you have any questions, please contact me at (301) 415-1030. A copy of this e-mail will be made publicly available in ADAMS.

Thanks,

~~~~~~~~~

Rich Guzman Sr. PM, Division Operator Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Office: O-9C7 l Phone: (301) 415-1030 Richard.Guzman@nrc.gov REQUEST FOR ADDITIONAL INFORMATION ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING, UNIT NOS. 1, 2, AND 3 LICENSE AMENDMENT REQUEST RELATED TO CYBER SECURITY PLAN IMPLEMENTATION SCHEDULE DOCKET NOS.50-003, 50-247, 50-286 CAC NOS. MF9656, MF9657, MF9658 EPID: L-2017-LLA-0217

RAI-1

In its license amendment request (LAR) dated April 28, 2017 (NL-17-049), Entergy (the licensee) proposes a probabilistic risk assessment model-based approach for identifying and screening Critical Digital Assets (CDAs). By letter dated August 9, 2017 (NL-17-096),

the licensee revised the LAR to simplify the approach for identifying the CDAs for completion or deferral of Milestone 8 actions. The letter also states that the simplified approach replaces the PRA model-based approach described in Section 2.0, Detailed Description, of the LAR. In Section 3.0, Technical Evaluation, of the LAR, under evaluation criterion 2, the licensee states, in part:

Completion of the remaining Milestone 8 actions by December 31, 2017 is not a prudent use of Entergy resources because the CDAs that remain after partial implementation of Milestone 8 do not pose as significant a risk as the CDAs that are included in the partial implementation of Milestone 8.

Please clarify whether this risk-based statement should also be removed as part of the intended revision of the August 9, 2017 letter; and if so, update the response for evaluation criterion 2, accordingly.

RAI-2

By letter dated September 28, 2017 (NL-17-124), the licensee revised its original proposed Milestone 8 full implementation date from December 31, 2022 to December 31, 2018. In Section 3.0, Technical Evaluation, of the LAR, under evaluation criterion 3, the licensee states:

The proposed completion date for Milestone 8 is December 31, 2022. By this date, the IPEC operating reactors will have ceased power operations, and it is anticipated that the reactors will have been defueled, and the fuel stored in the spent fuel pools are expected to have decayed to the point where the risk of a fire in the zirconium fuel cladding following a beyond-design-basis event involving the loss of spent fuel pool water inventory is significantly reduced, which is based on industry direction of 16 to 18 months. Once these plant conditions are achieved, the CSP license conditions are no longer required and Entergy plans to submit a LAR to remove the conditions from the OLs of the IPEC units.

Please update the response for evaluation criterion 3 based on the supplemental letter dated September 28, 2017, which cites a Milestone 8 full implementation date of December 31, 2018.