LR-N10-0354, Stations - Notification Letter Designating Balance of Plant Systems within the Cyber Security Rule Scope

Stations - Notification Letter Designating Balance of Plant Systems within the Cyber Security Rule Scope

ML102810304
Person / Time
Site:	Salem, Hope Creek
Issue date:	09/28/2010
From:	Neely C Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
LR-N10-0354
Download: ML102810304 (5)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 0 PSEG Nuclear LLC SEP 2 8 2010 LR-N10-0354 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 SALEM GENERATING STATION - UNIT 1 and UNIT 2 FACILITY OPERATING LICENSE NOS. DPR 70 and DPR-75 NRC DOCKET NOS. 50-272 and 50-311 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 NRC DOCKET NO. 50-354

Subject:

Notification Letter Designating Salem and Hope Creek Generating Stations Balance of Plant Systems within the Cyber Security Rule Scope

References:

(1) Letter from Jim Hughes (NERC) to Jeffrey Mueller, Salem Nuclear Generating Station, Unit 1 [sic], "Request for Data or Information:

Nuclear Power Plant 'Bright-Line' Survey," dated June 15, 2010 (2) Letter from Jim Hughes (NERC) to Jeffrey Mueller, Hope Creek Generating Station, Unit 1, "Request for Data or Information: Nuclear Power Plant 'Bright-Line' Survey," dated June 15, 2010 (3) Letter from Michael Moon (NERC) to Jeffrey Mueller, "NERC's Response to the Completed Bright Line Survey: Hope Creek Generating Station, Unit 1" dated August 27, 2010 (4) Letter from Michael Moon (NERC) to Jeffrey Mueller, "NERC's Response to the Completed Bright Line Survey: Salem Nuclear Generating Station, Unit 1 and 2" dated August 27, 2010 K91R7 95-2168 REV. 7/99

Document Control Desk SEP 28 2010 LR-N 10-0354 By Order dated March 19, 20091, the Federal Energy Regulatory Commission (FERC) clarified that the "balance of plant" equipment within a nuclear power plant is subject to compliance with the FERC approved Critical Infrastructure Protection (CIP) Reliability Standards. Paragraph 50 of the Order provides for an exception from the CIP Reliability Standards for equipment in the balance of plant that is subject to the NRC cyber security regulations. Pursuant to paragraph 50 of the Order, the North American Electric Reliability Corporation (NERC) has been engaging in a "Bright-Line" determination process (References 1 & 2) to clarify the systems that would be subject to the NRC cyber security rule (10 CFR 73.54), and those that would be subject to the CIP Reliability Standards.

In the Reference (3) and (4) letters, NERC is requiring that the Hope Creek and Salem Nuclear Power Plants provide the NRC with a letter identifying all balance of plant Systems, Structures, and Components (SSCs) considered important to safety with respect to the NRC's cyber security regulation. As documented in our response to the Bright Line survey, balance of plant SSCs in Attachment 1 of the Survey are important to safety, and thus, are within the scope of 10 CFR 73.54.

In accordance with the requirements of 10 CFR 73.54 (b)(1), a comprehensive identification of SSCs subject to the requirements of 10 CFR 73.54 will be developed during the implementation of the cyber security program. The program is implemented in accordance with the schedule submitted to the NRC by letter dated July 14, 2010 with the Salem-Hope Creek Cyber Security Plan. This identification of SSCs will be available for inspection upon completion and will contain those SSCs as identified in of the Bright-Line Survey. Providing the requested information in this alternate manner satisfies the intent of the NERC letter.

In the Reference (3) and (4) letters, NERC is also requiring that each nuclear power plant submit a revised cyber security plan to the NRC for its review and approval. On or before November 30, 2010, PSEG Nuclear will supplement our Salem-Hope Creek Cyber Security Plan to clarify the scope of systems described in Section 2.1, "Scope and Purpose." Section 2.1, will be amended to clarify the balance of plant SSCs that will be included in the scope of the Cyber Security Program.

There is one new regulatory commitment contained in this letter. It is listed in .

1 Mandatory Reliability Standardsfor CriticalInfrastructureProtection, order on clarification, Order No. 706-B, 126 FERC ¶ 61,229 (2009).

2

Document Control Desk LR-N10-0354 :SEP s8 2010 Should you have any questions concerning this letter, or require additional information, please contact Lee Marabella at (856) 339-1208 or James Shank at (856) 339-1834.

Respectfully, Dii ctor, Regulatory Affairs CC: Michael Moon Director of Compliance Operations North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, NJ 08540 Mr. S. Collins, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U. S. Nuclear Regulatory Commission Mr. R. Ennis, Project Manager - Salem Unit 1 and Unit 2 and Hope Creek Mail Stop 08C2 Washington, DC 20555-0001 USNRC Senior Resident Inspector - Hope Creek Generating Station USNRC Senior Resident Inspector - Salem Generating Station Mr. P. Mulligan, Manager IV Bureau of Nuclear Engineering P. 0. Box 415 Trenton, NJ 08625 Corporate Commitment Tracking Coordinator 3

Document Control Desk SEP 2 8 2010 LR-N10-0354 Mr. Jim Hughes NERC 116-390 Village Boulevard Princeton, NJ 08540 Mr. Jim T. Wiggins Director, Office of Nuclear Security & Incident Response Two White Flint North (MS: 4D22A) 11555 Rockville Pike Rockwell, MD 20852-2738 Mr. Eric Leeds Director, Office of Nuclear Reactor Regulation One White Flint North (MS: 13H16M) 11555 Rockville Pike Rockwell, MD 20852-2738 4

Document Control Desk LR-N10-0354 "The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)"

Attachment 1 Salem-Hope Creek Cyber Security Plan Supplement Submittal Commitment COMMITMENT TYPE COMMITMENT COMMITTED DATE ONE-TIME PROGRAM OR "OUTAGE" ACTION -MATIC (YES/NO) (YES/NO)

PSEG Nuclear will PENulawilNovember 30, 2010 Yes No supplement its Salem-Hope Creek Cyber Security Plan submittal to clarify the scope of systems described in Section 2.1, "Scope and Purpose."

I