NRC 2010-0006, License Amendment Request 263, Cyber Security Plan Supplement
| ML100190093 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/18/2010 |
| From: | Meyer L Point Beach |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC 2010-0006 | |
| Download: ML100190093 (5) | |
Text
January 18,2010 NRC 201 0-0006 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units I and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 License Amendment Request 263 Cvber Securitv Plan Su~plement
Reference:
( 1 NextEra Energy Point Beach, LLC letter to NRC, dated November 23,2009, License Amendment Request 263, Cyber Security (ML093310298)
In accordance with the provisions of 10 CFR 50.4 and 50.90, NextEra Energy Point Beach, LLC (NextEra) submitted a request for an amendment (Referencel) to the Renewed Facility Operating Licenses for Point Beach Nuclear Plant (PBNP). This proposed amendment requests NRC approval of the NextEra Cyber Security Plan, provides an implementation schedule and revises License Condition D of the Renewed Facility Operating Licenses to require PBNP to fully implement and maintain in effect all provisions of the Commission-approved Cyber Security Plan. Per discussions with the NRC, it has been determined that the No Significant Hazards Consideration (NSHC) submitted with the amendment request needs to be revised. provides the revised NSHC in Section 4, Regulatory Evaluation. This supplement supersedes the Section 4, Regulatory Evaluation, in Reference (I) in its entirety.
This letter contains no new Regulatory Commitments and no revisions to existing Regulatory Commitments.
The information contained in this letter continues to satisfy the criteria of 10 CFR 51.22 for categorical exclusion from the requirements of an environmental assessment.
The PBNP Plant Operations Review Committee has reviewed the proposed license amendment request supplement.
NextEra Energy Point Beach, LLC, 6610 Nuclear Road, Two Rivers, WI 54241
Document Control Desk Page 2 In accordance with 10 CFR 50.91, a copy of this letter is being provided to the designated Wisconsin Official.
If you have any questions or require additional information, please contact James Costedio, Licensing Manager, at 9201755-7427 I declare under penalty of perjury that the foregoing is true and correct.
Executed on January 18,201 0.
Very truly yours, NextEra Energy Point Beach, LLC jM+
p y
Meyer Site Vice President Enclosure cc:
Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW
ENCLOSURE 1 NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST 263 CYBER SECURITY PLAN SUPPLEMENT REGULATORY EVALUATION 2 pages follow
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirementslcriteria This license amendment request is submitted pursuant to 10 CFR 73.54 which requires licensees currently licensed to operate a nuclear power plant under 10 CFR 50 to submit a Cyber Security Plan as specified in 10 CFR 50.4 and 10 CFR 50.90.
4.2 Significant Hazards Consideration The proposed amendment request seeks NRC approval of the NextEra Energy Point Beach, LLC (NextEra) Cyber Security Plan, provides an implementation schedule, and adds a sentence to the existing Renewed Facility Operating License Physical Protection license condition to require NextEra to fully implement and maintain in effect all provisions of the Commission approved Cyber Security Plan.
NextEra has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed amendment incorporates a new requirement in the Renewed Facility Operating License to implement and maintain a Cyber Security Plan as part of the facility's overall program for physical protection. Inclusion of the Cyber Security Plan in the Renewed Facility Operating License itself does not involve any modifications to the safety-related structures, systems or components (SSCs). Rather, the Cyber Security Plan describes how the requirements of 10 CFR 73.54 are to be implemented to identify, evaluate, and mitigate cyber attacks up to and including the design basis cyber attack threat, thereby achieving high assurance that the facility's digital computer and communications systems and networks are protected from cyber attacks. The Cyber Security Plan will not alter previously evaluated Final Safety Analysis Report (FSAR) design basis accident analysis assumptions, add any accident initiators, or affect the function of the plant safety-related SSCs as to how they are operated, maintained, modified, tested, or inspected.
Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
This proposed amendment provides assurance that safety-related SSCs are protected from cyber attacks. Implementation of 10 CFR 73.54 and the inclusion of a plan in the Renewed Facility Operating License do not result in the need of any new or different FSAR design basis accident analysis. It does not introduce new equipment that could create a new or different kind of accident, and no new equipment failure modes are created. As a result, no Page 1 of 2
new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of this proposed amendment.
Therefore, the proposed amendment does not create a possibility for an accident of a new or different type than those previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed amendment would not alter the way any safety-related SSC functions and would not alter the way the plant is operated. The amendment provides assurance that safety-related SSCs are protected from cyber attacks. The proposed amendment would not introduce any new uncertainties or change any existing uncertainties associated with any safety limit. The proposed amendment would have no impact on the structural integrity of the fuel cladding, reactor coolant pressure boundary, or containment structure. Based on the above considerations, the proposed amendment would not degrade the confidence in the ability of the fission product barriers to limit the level of radiation to the public.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, NextEra concludes that the proposed amendment does not involve a 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.
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 proposed manner, (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 security or to the health and safety of the public.
Page 2 of 2