ML11189A064

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R.E. Ginna - Submittal of Revised Cyber Security Plan
ML11189A064
Person / Time
Site: Calvert Cliffs, Nine Mile Point, Ginna  Constellation icon.png
Issue date: 07/01/2011
From: Krakuszeski J A
Calvert Cliffs, Constellation Energy Nuclear Group, EDF Group, Nine Mile Point, Ginna
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME4330, TAC ME4328, TAC ME4329, TAC ME4331, TAC ME4332
Download: ML11189A064 (11)
v • d • e


Text

John A. Krakuszeski Interim Fleet Plant General Manager Constellation Energy Nuclear Group, LLC 100 Constellation Way Suite 1800P Baltimore, MD 21202 CENG_a joint venture of Constegation F July 1, 2011 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION:

SUBJECT:

Document Control Desk Calvert Cliffs Nuclear Power Plant Unit Nos. 1 & 2; Docket Nos. 50-317 & 50-318 Nine Mile Point Nuclear Station Unit Nos. 1 & 2; Docket Nos. 50-220 & 50-410 R. E. Ginna Nuclear Power Plant Docket No. 50-244 Submittal of Revised Cyber Security Plan

REFERENCES:

(a) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), dated April 4, 2011, Response to Request for Additional Information:

Cyber Security Plan (b) Letter from D. V. Pickett (NRC) to M. G. Korsnick (CENG), dated March 3, 2011, Request for Additional Information Re: Cyber Security Plan-Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2, R.E. Ginna Nuclear Power Plant, Nine Mile Point Nuclear Station, Unit Nos. 1 and 2 -(TAC Nos. ME4328, ME4329, ME4330, ME4331, and ME4332)(c) Letter from M. G. Korsnick (CENG) to Document Control Desk (NRC), dated July 16, 2010, Request for Approval of the Constellation Energy Nuclear Group Cyber Security Plan (d) Email from Mr. D. V. Pickett (NRC) to Mr. E.M. Tyler (CENG), dated June 14, 2011, Revised License Conditions for Constellation Cyber Security Plan License Amendments In Reference (a), we stated we would submit revisions to the Constellation Energy Nuclear Group Cyber Security Plan related to our responses to the Nuclear Regulatory Commission's request for additional information (Reference b).Please replace the Plan previously provided with the revised Plan in Attachment (1). The changes in Sections 2 and 4 of the Plan are indicated by vertical bars in the left margin.Reference (d) requested a change in the proposed license conditions submitted in Reference (c). The new J Document Control Desk July 1, 2011 Page 2 wording is included in the license condition markups in Attachments 2-4.There are no regulatory commitments in this correspondence.

Should you have any questions concerning this letter, or require additional information, please contact Bruce Montgomery at 410-470-3777 or Bruce.Montgomery@cengllc.com.

Sincerely, John A. Krakuszeski STATE OF NEW YORK TO WIT: COUNTY OF OSWEGO I, John A. Krakuszeski, state that I am the Interim Fleet Plant General Manager for Constellation Energy Nuclear Group, LLC, for Calvert Cliffs Nuclear Power Plant, LLC, Nine Mile Point Nuclear Station, LLC, and R. E. Ginna Nuclear Power Plant, LLC, and that I am duly authorized to execute and file this submittal on behalf of these companies.

To the best of my knowledge and belief, the statements contained in this document with respect to these companies are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by employees and/or consultants of the companies.

Such information has been reviewed in accordance with company practice, and I believe it to be reliable./N Subscribed and before me, a Notary Public in Onondaga, this J'7 day of )-- , 2011.WITNESS my Hand and Notarial Seal: My Commission Expires: JAK/EMT/bjd and for the State of New York and County of rayA G. ;2)Dale DENNIS E. VANDEPUTTE Notary Public, State of New York No. 01VA61834 0 1 Qualified in Onondaga County Certificate Filed in Osw01oLou0t Commission Expires a Document Control Desk July 1,2011 Page 3 Attachments:

(1)(2)(3)(4)Revised Cyber Security Plan R.E. Ginna Nuclear Power Plant License Markup Nine Mile Point Nuclear Station License Markup Calvert Cliffs Nuclear Power Plant License Markup cc: D. V. Pickett, NRC R. V. Guzman, NRC W. M. Dean, NRC J. T. Wiggins, NRC E. J. Leeds, NRC M. Moon, NERC Resident Inspector, NRC (Calvert Cliffs)Resident Inspector, NRC (Ginna)Resident Inspector, NRC (Nine Mile Point)S. Gray, Maryland DNR ATTACHMENT (2)R.E. GINNA NUCLEAR POWER PLANT LICENSE MARKUP Constellation Energy Nuclear Group, LLC July 1, 2011 -a C3., CL 20 0, 0 0 U accordance with an acceptable calculational model which conforms to the provisions in Appendix K (SER dated April 18, 1978). The exemption will expire upon receipt and approval of revised ECCS calculations.

The aforementioned exemption Is authorized by law and will not endanger life property or the common defense and security and is otherwise in the public interest.

Therefore, the exemption is hereby granted pursuant to 10 CFR 50.12.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 Search Requirements revisions to 10 CFR 73.55 (51 FR 27827 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

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

Ginna LLC shall complete these activities no later than September 18, 2009, and shall notify the Commission in writing when implementation of these activities is complete and can be verified by NRC inspection.

The Updated Final Safety Analysis Report supplement, as revised, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71(e)X4) following issuance of this renewed license. Until that update is complete, Ginna LLC may make changes to the programs and activities described in the supplement without prior Commission approval, provided that Ginna LLC evaluates each such change pursuant to the criteria set forth In 10 CFR 50.59 and otherwise complies with the requirements in that section.G. All capsules in the reactor vessel that are removed and tested must meet the test procedures and reporting requirements of ASTM E 185-82 to the extent practicable for the configuration of the specimens in the capsule. Any changes to the capsule withdrawal schedule, Including spare capsules, must be approved by the NRC prior to Implementation.

Any capsules placed in storage must be maintained for future Insertion, unless approved by the NRC.I Revised by correction letter dated November 12, 2009 ATTACHMENT (3)NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 LICENSE MARKUPS Constellation Energy Nuclear Group, LLC July 1, 2011 D. Thislicense Is subject to the following additional conditions:

(1) The licensee will complete construction of a new Fadwaste facity in conformance with the design defined and evaluated in the FES, to be operational no later than June 1978.(2) Deleted by Ucense Amendment No. 51 (3) Deleted by Lcense Amendment No. 51 ,.<(4, Securiy, Trainin and Qualificathon and SA ranis Contlnenc9 Plans 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 the provisions 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 50.90-and 10 CFR 50.54(p).

The combined set of plans, which contain Safeguards Information protecW under .0 r-I a CFR 73.21 Is entitled 'Nine Mile Point Nuclear Station, LLC Physical E USecurity, Safeguards Contingency, and Security Training and.Qualification Plan, Revision I,' and was submitted by leter dated April 26,2006. .00 o (5) Paragraph 2.0(5) of the license-has been combined with paragraph* .2.D(4) as amended above into a single paragraph.

-0 i (6) Recrculation System Safe-end.Replacement The recirculation system and safe-end replacement program including the cutting and welding of the replacement components and the dose mitigation program (A"ARA) is approved, subject to the following conditions:

a. The licensee shall complete the recirculalion piping stess.r s eanalysis prior to restart of Nine Mile Point Nuclear Power= Station, Unit No. 1. The results of this analysis fbr selected-~ "representative portions of the recirculation system shagt be CL submitted to the NRC prior to restart of the facilty.E -b. All fuel and control rods shall be removed from the reactor pressure vessel and stored in the spent fuel pool during the period that work on the safe-end and teirculation system replacement program is In progress.RIniowd Uclncc No. DP 643 Revived by lettcr dated Foebfuar; 21, 2007 1Amondme-Ont.

105,

System until completion of the first refueling outage to allow the operating licensee to provide qualified isolation devices for Class 1 E/non-IE interfaces described in their letters of June 23, 1987 (NMP2L 1057) and June 25, 1987 (NMP2L 1058). (Section 7.22.10, SSER 6).For the schedular exemptiorns in iv), v), and vi), above, the operating licensee, in accordance with is letter of October 31, 1986, shall certify that all systems, components, and modificatims have been completed to meet the requirements of the regulations for which thexe-mptlons have been granted and shalf provide a summary description of actions taken to ensure that the regulations have been met. This certification and summary shall be provided 1O days prior to the 2 ~ expiration of each exemption period as described above.The exemptions set forth in is SeW16a 2.Dare authorizedbylaw, wilnot*

an undue risk t6 public health and safety, and are c~rsistent with the 0 0 common defense and security.

These exemptions are hereby granted. The special cirumstances regarding each exemption are identified in the referenced section of the Safety" Evaluation Report and the supplements thereto. The exernptons in -H) through vi) are granted pursuant to 10 CFR 50.12.&U With these exemptions, the faciity 41 operate to the extent authorized.

herein, in O conform*t with the application, as amended, the provisions of the Act, and Mhe rules and regulations of the Commission.E. Nine Mile. Point Nuclear Station, LLC shall fully.Implement and maintain in effect all provisions of te Commission-approved physical security, training and qualificawon, and safeguards contingency plans, including amendrents made pursuant to pMvisionsof the Msellanus Amendments and. Search S Requirements revisions to' 10 CFR 73.55 (51 FR 27817 and 27822) and to the of 10 CFR 50.90 and 10 CFR 50.54(p).

The combined set of p(ans, which contain Safeguards Information protected under 10 CFR 73.21 is entitled 5 'Nine Mile Point Nuclear Station, LLC Physical Securty, Safeguards 3 -Contingency, and Security Training and Qualificaton Plan, Revision 1,' and was_

by letter dated April 26,2006. Changes made in accordance with 10< CFR 73.55 shall be Implemented in accordance with the schedule set forth therein.= -- " F. Nine Mile Point Nuclear Station, LLC 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 through Amendment No. 27 and as=ý9 described in submittals dated March 25, May7 and 9, June 10 and 25, JUly 11 a. and 16, August 19 and 22, September 5, 12, and 23, October 10, 21, and 22, and December 9, 1986, and April 10 and May 20, 1987, and as approved in the SER dated February 1985 (and Supplements 1 through 6) subject to the following provision:

Renewed 1eer.e Oen. NPF 69 Re*.Qd by 19#0o dutod August 23, 2007 Ame ndm$4t120

.It-ATTACHMENT (4)CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 LICENSE MARKUPS Constellation Energy Nuclear Group, LLC July 1, 2011 c. Identification of process sampling points;d. Procedure for recording and management of data;e. Procedures defining corrective actions for off control point chemistry conditions; and f. A procedure identifying the authority responsible for the interpretation of the data and the sequence and timing of administrative events required to initiate corrective action.(5) Mitigation Strategy The Calvert Cliffs Nuclear Power Plant, LLC, shall develop and maintain strategies for addressing large fires and explosions that include the following key areas: (a) Fire fighting response strategy with the following elements:ý5 E 1. Pre-defined coordinated fire response strategy and guidance 2. Assessment of mutual aid fire fighting assets 3. Designated staging areas for equipment and materials 4, 4. Command and control 5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

2 1. Protection and use of personnel assets c 2. Communications

3. Minimizing fire spread 4. Procedures for implementing integrated fire response E Jstrategy 5. Identification of readily available pre-staged equipment a 6. Training on integrated fire response strategy Z 7. Spent fuel pool mitigation measures 00='.M (c) Actions to minimize release to include consideration of:Water spray scrubbing 2. Dose to onsite responders U , 0 D. The licensee shall fully implement and maintain in effect all provisions of theCommission-approved physical security, training and qualification, and=

The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, is entitled: "Calvert Cliffs Nuclear Power Plant Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 1" submitted May 19, 2006.Amendment No. 295 4. Procedures for implementing integrated fire response strategy 5. Identification of readily available pre-staged equipment 6. Training on integrated fire response strategy 7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of: 1. Water spray scrubbing 2. Dose to onsite responders D. 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 FR 27817 and 27822) and 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: "Calvert a. >. Cliffs Nuclear Power Plant Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 1" submitted dated May 19, 2006..E. The Calvert Cliffs Nuclear Power Plant, LLC, shall implement and maintain in$ ~effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report for the facility and as approved in the SER dated September 14,1979, and Supplements dated October 2,1980; March 18, 1982; and September 27, 1982; and Exemptions dated August 16, 1982;April 21, 1983; March 15, 1984; August 22, 1990; and April 7, 1999 subject to the following provision:

The Calvert Cliffs Nuclear Power Plant, LLC may make SCLchanges to the approved fire protection program without prior approval of the I- Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.'- 2 F. At the time of the next scheduled update to the FSAR required pursuant to 10 CFR 50.71(e)(4) following the issuance of this renewed license, the licensee shall update the FSAR to include the FSAR supplement submitted pursuant to r- 10 CFR 54.21(d), as amended and supplemented by the program descriptions in.- Appendix E to the Safety Evaluation Report, NUREG-1705.

Until that FSAR update is complete, the licensee may make changes to the programs described in Appendix E without prior Commission approval, provided that the licensee evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.G. Any future actions listed in Appendix E to the Safety Evaluation Report, NUREG-1705, shall be included in the FSAR. The licensee shall complete these~actions by August 13, 2016.Amendment No. 271

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