ML14042A166

License Amendment Request - Cyber Security Plan Implementation Schedule

ML14042A166
Person / Time
Site:	Pilgrim
Issue date:	01/31/2014
From:	Dent J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.14.006
Download: ML14042A166 (7)

Text

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 John A. Dent, Jr.

Site Vice President 10 CFR 2.390 Attachments Withheld January 31, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request - Cyber Security Plan Implementation Schedule Pilgrim Nuclear Power Station (PNPS)

Docket Nos. 50-293 License Nos. DPR-35

REFERENCES:

1. NRC Internal Memorandum to Barry Westreich from Russell Felts, "Review Criteria for 10 CFR 73.54, Cyber Security Implementation Schedule Milestone 8 License Amendment Requests", dated October 24, 2013

2. NRC letter to Entergy, "Issuance of Amendment Re: Approval of Cyber Security Plan",

dated July 22, 2011 (PNPS Letter 1.11.048)

3. NRC Internal Memorandum to Directors of Regional Divisions of Reactor Safety from Barry Westreich, "Enhanced Guidance For Licensee Near-Term Corrective Actions to Address Cyber Security Inspection Findings and Licensee Eligibility for "Good-Faith" Attempt Discretion", dated July 1, 2013 LETTER 2.14.006

Dear Sir or Madam:

Pursuant to 10 CFR 50.4 and 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests an amendment to the Renewed Facility Operating License for Pilgrim Nuclear Power Station (PNPS). In accordance with the guidelines provided by Reference 1, this request proposes a change to the PNPS Cyber Security Plan Milestone 8 full implementation date as set forth in the Cyber Security Plan Implementation Schedule approved by Reference 2.

Reference 3 provided additional NRC internal guidance.

This letter contains security-related information Attachments 1 and 4 are withheld from public disclosure per 10 CFR 2.390

PNPS Letter 2.14.006 Page 2 of 3 This letter contains security-related information Attachments 1 and 4 are withheld from public disclosure per 10 CFR 2.390 provides an evaluation of the proposed change. Attachment 2 contains proposed marked-up operating license page for the Physical Protection license condition for PNPS to reference the commitment change provided in this submittal. contains the proposed revised operating license page. Attachment 4 contains a change to the date of Implementation Milestone 8. Entergy requests that Attachments 1 (Sections 1, 2, and 3) and 4, which contain security-related information (SRI), be withheld from public disclosure in accordance with 10 CFR 2.390.

The proposed changes have been evaluated in accordance with 10 CFR 50.91 (a)(1 ) using criteria in 10 CFR 50.92(c), and it has been determined that the changes involve no significant hazards consideration. The bases for these determinations are included in Attachment 1.

Entergy requests this license amendment be effective as of its date of issuance. Although this request is neither exigent nor emergency, your review and approval is requested prior to December 15, 2014.

The revised commitment contained in this submittal is summarized in Attachment 5. Should you have any questions concerning this letter, or require additional information, please contact Mr.

Joseph R. Lynch, Manager, Regulatory Assurance at 508-830-8403.

I declare under penalty of perjury that the foregoing is true and correct. Executed on January 31, 2014.

Sincerely, Site Vice President JAD/rmb Attachments:

1. Analysis of Proposed Operating License Change (contains SRI)

2. Proposed PNPS Operating License Changes (mark-up)

3. Revised PNPS Operating License Page

4. Revised Cyber Security Plan Implementation Schedule (contains SRI)

5. List of Regulatory Commitments This letter contains security-related information Attachments 1 and 4 are withheld from public disclosure per 10 CFR 2.390

PNPS Letter 2.14.006 Page 3 of 3 This letter contains security-related information - Attachments 1 and 4 are withheld from public disclosure per 10 CFR 2.390 cc:

Mr. William M. Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-1415 U. S. Nuclear Regulatory Commission Director, Office of Nuclear Reactor Regulation One White Flint North 11555 Rockville Pike Rockville, MD 20852 Ms. Nadiyah Morgan, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555 NRC Senior Resident Inspector Pilgrim Nuclear Power Station Mr. John Giarrusso Jr.

Planning, Preparedness & Nuclear Section Chief Mass. Emergency Management Agency 400 Worcester Road Framingham, MA 01702 This letter contains security-related information - Attachments 1 and 4 are withheld from public disclosure per 10 CFR 2.390

Attachment 2 Letter Number 2.14.006 Proposed PNPS Operating License Changes (mark-up BOLD)

provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

A. Maximum Power Level ENO is authorized to operate the facility at steady state power levels not to exceed 2028 megawatts thermal.

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 239 (DELETE), are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

C. Records ENO shall keep facility operating records in accordance with the requirements of the Technical Specifications.

D. Equalizer Valve Restriction - DELETED E. Recirculation Loop Inoperable - DELETED F. Fire Protection ENO shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility and as approved in the SER dated December 21, 1978 as supplemented subject to the following provision:

ENO 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. Physical Protection 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 Search Requirements revisions to 10 CFR 73.55 (51 FR27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Pilgrim Nuclear Power Station Physical Security, Training and Qualification, and Safeguards Contingency Plan, Revision 0" submitted by letter dated October 13, 2004, as supplemented by letter dated May 15, 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 of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee's CSP was approved by License Amendment No. 236, as supplemented by a change approved by Amendment No. 238 and XXX.

Amendment 239 Renewed License No. DPR-35

Attachment 3 Letter Number 2.14.006 Revised PNPS Operating License Page

provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

A. Maximum Power Level ENO is authorized to operate the facility at steady state power levels not to exceed 2028 megawatts thermal.

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. , are hereby incorporated in the renewed operating license.

The licensee shall operate the facility in accordance with the Technical Specifications.

C. Records ENO shall keep facility operating records in accordance with the requirements of the Technical Specifications.

D. Equalizer Valve Restriction - DELETED E. Recirculation Loop Inoperable - DELETED F. Fire Protection ENO shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility and as approved in the SER dated December 21, 1978 as supplemented subject to the following provision:

ENO 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. Physical Protection 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 Search Requirements revisions to 10 CFR 73.55 (51 FR27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Pilgrim Nuclear Power Station Physical Security, Training and Qualification, and Safeguards Contingency Plan, Revision 0" submitted by letter dated October 13, 2004, as supplemented by letter dated May 15, 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 of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee's CSP was approved by License Amendment No. 236, as supplemented by a change approved by Amendment No. 238 and Amendment 239 Renewed License No. DPR-35