ML101160422
| ML101160422 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Peach Bottom, Oyster Creek, Byron, Braidwood, Limerick, Clinton, Quad Cities, LaSalle, Crane |
| Issue date: | 06/04/2010 |
| From: | Nicholas Difrancesco Plant Licensing Branch III |
| To: | Pardee C Exelon Nuclear |
| DiFrancesco N, NRR/DORL/LPL3-2, 415-1115 | |
| References | |
| TAC ME2585, TAC ME2684, TAC ME2686, TAC ME2687, TAC ME2688, TAC ME2689, TAC ME2690, TAC ME2691, TAC ME2692, TAC ME2693, TAC ME2694, TAC ME2695, TAC ME2696, TAC ME2697, TAC ME2698, TAC ME2699 | |
| Download: ML101160422 (4) | |
Text
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~O Mr. Charles G. Pardee President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
BRAIDWOOD STATION, UNITS 1 AND 2; BYRON STATION, UNIT NOS. 1 AND 2; CLINTON POWER STATION, UNIT NO.1; DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; LASALLE COUNTY STATION, UNITS 1 AND 2; LIMERICK GENERATING STATION, UNITS 1 AND 2; OYSTER CREEK NUCLEAR GENERATING STATION; PEACH BOTTOM ATOMIC POWER STATION, UNITS 2, AND 3; QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2; AND THREE MILE ISLAND NUCLEAR STATION, UNIT 1 LICENSE AMENDMENT REQUEST FOR APPROVAL OF THE CYBER SECURITY PLAN (TAC NOS. ME2684, ME2684, ME2685, ME2686, ME2687, ME2688, ME2689, ME2690, ME2691, ME2692, ME2693, ME2694, ME2695, ME2696, ME2697, ME2698, ME2699)
Dear Mr. Pardee:
By letter dated November 23, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093280234 (non-public)), as supplemented by letter dated January 15,2010 (ADAMS Accession No. ML100150629 (publicly available)), Exelon Generation Company, LLC (EGC, the licensee), submitted a license amendment request (LAR) for Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Clinton Power Station, Unit No.1; Dresden Nuclear Power Station, Units 2 and 3; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Oyster Creek Nuclear Generating Station; Peach Bottom Atomic Power Station, Units 2, and 3; Quad Cities Nuclear Power Station, Units 1 and 2; and Three Mile Island Nuclear Station, Unit 1. The proposed LAR includes the Cyber Security Plan, proposed changes the Facilities Operating License Physical Protection license condition, and provides a proposed Implementation Schedule. The proposed cyber security plan has been submitted in accordance with Title 10 of the Code of Federal Regulations (10 CFR),
Section 73.54 "Protection of digital computer and communication systems networks." The purpose of this letter is to inform you that the U.S. Nuclear Regulatory Commission (NRC) staff has completed an initial review of this LAR. In accordance with the Office of Nuclear Reactor Regulation Office Instruction LlC-109, "Acceptance Review Procedures" (ADAMS Accession No. ML091810088), Section 3.1.3, the NRC staff has decided to forgo the traditional acceptance review due to the complexity and "first-of-a-kind" nature of this application. While the NRC staff has docketed your application, we are not rendering a judgment as to the acceptability of the submittal within the context of an acceptance review.
The cyber security plan submittal prepared for the subject facilities is based on an earlier version of Nuclear Energy Institute (NEI) guidance. The NRC staff had significant generic concerns with this guidance. As a result of NRC staff discussions with NEI and the Executive Task Force of the industry Nuclear Security Working Group (NSWG), NEI and NSWG committed to representing operating power reactor licensees in resolving these concerns.
C. Pardee
- 2 Through numerous interactions, the NRC staff has communicated its generic concerns with the NEI guidance. The security-related nature of the information required these interactions to be conducted in closed meetings not open to the public. A publicly available list of the specific issues discussed with NEI and NSWG was communicated to the licensees via e-mail dated March 9, 2010 (ADAMS Accession No. ML100680284).
By letter dated April 28, 2010 (ADAMS Accession No. ML101180434), NEI submitted Revision 6 to NEI 08-09, "Cyber Security Plan for Nuclear Power Reactors" (ADAMS Accession No. ML101180437), which contains changes that address the NRC staff concerns associated with previous versions. Based on a technical review of the document, the Office of Nuclear Security and Incident Response, in its letter dated May 5, 2010 (ADAMS Accession No. ML101190371),
concluded that submission of a cyber security plan using the template provided in NEI 08-09, Revision 6, dated April 2010, would be acceptable for use by licensees to comply with the requirements of 10 CFR 73.54, with the exception of the definition of "cyber attack."
Therefore, to resolve the NRC staffs concerns with the previously submitted LAR, the licensee is requested to review the list of generic issues provided via e-mail dated March 9, 2010, and provide a revised submittal. Please provide justification for any generic issues that will not be addressed in the revised submittal.
For any changes to the Cyber Security Plan proposed in the LAR, the licensee is requested to indicate that the revised submittal supersedes, in its entirety, the previous submittal or indicate what portions are superseded.
As an alternative to addressing the individual generic issues, the licensee may submit a revised Cyber Security Plan consistent with NRC Regulatory Guide (RG) 5.71* or submit a revised Cyber Security Plan consistent with NEI 08-09, Revision 6. However, if this option is exercised, the NRC staff expects that the existing application will be withdrawn and the revised application resubmitted at the same time.
The NRC staff requests that the licensee's response or revised application be submitted within 60 days of the date of this letter. Please contact me if circumstances result in the need to revise the requested response date.
Following receipt and review of your response, you will be advised by separate correspondence if any further information is needed to support the NRC staff's detailed technical review.
- In January 2010, the NRC staff issued RG 5.71, "Cyber Security Programs for Nuclear Facilities" (ADAMS Accession No. ML090340159). This guidance provides an approach that the NRC staff deems acceptable for complying with the Commission's regulations regarding the protection of digital computers, communications systems, and networks from a cyber security attack.
C. Pardee
- 3 If you have any questions regarding this matter, I may be reached at (301) 415-1115 or via email at nicholas.difrancesco@nrc.gov.
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Nicholas J. DiFrancesco, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454, STN 50-455,50-461,50-237, 50-249, 50-373, 50-374, 50-352, 50-353, 50-219, 50-277, 50-278, 50-254, 50-265, and 50-289 cc: Distribution via Listserv
C. Pardee
-3 If you have any questions regarding this matter, I may be reached at (301) 415-1115 or via email at nicholas.difrancesco@nrc.gov.
Sincerely, IRA!
Nicholas J. DiFrancesco, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. SIN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-461, 50-237, 50-249,50-373,50-374,50-352,50-353,50-219, 50-277, 50-278, 50-254, 50-265, and 50-289 cc: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsRgn3MailCenter Resource RidsOgcRp RidsNrrPMClinton RidsNrrPMQuadCities RidsNrrPMPBamford RidsNrrDorlDpr RidsNrrDorlLpl1-2 Resource LPL3-2 R/F RidsNrrDorlLpl3-2 Resource RidsN rrPMBraidwood RidsNrrLaSalie RidsNrrPM"IHughey RidsNrrPMEMilier RidsNrrLAABaxter C. Erlanger, NSIR LPL 1-2 RlF C. Grattton, NRR RidsNrrPMByron RidsNrrPIVIDresden RidsAcrsAcnw_mMailCenter RidsNrrLA THarris RidsRgn 1 MailCenter P. Pederson, NSIR ADAMS Accession No. ML101160422 NRR-088 OFFICE LPL3-2/PM LPL3-2/LA LPL1-2/BC LPL3-21BC LPL3-2/PM NAME NDiFrancesco THarris HChernoff CGoodwin for SCampbeli NDiFrancesco DATE 6/4/10 6/4/10 6/3/10 6/3/10 6/4/10 OFFICIAL RECORD COpy