ML101470262

Acceptance Review Approval Cyber Security Plan License Amendment Request

ML101470262
Person / Time
Site:	Susquehanna
Issue date:	05/27/2010
From:	Richard Guzman Plant Licensing Branch 1
To:	Rausch T Susquehanna
Guzman R, NRR/DORL, 415-1030
References
TAC ME2649, TAC ME2650
Download: ML101470262 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 27,2010 Mr. Timothy S. Rausch Senior Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603-0467

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNIT NOS. 1 AND 2 - PPL SUSQUEHANNA, LLC RE: CYBER SECURITY PLAN LICENSE AMENDMENT REQUEST (TAC NOS. ME2649 AND ME2650)

Dear Mr. Rausch:

By letter dated November 16, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093290097), PPL Susquehanna, LLC (the licensee) submitted a license amendment request (LAR) for the Renewed Facility Operating Licenses for Susquehanna Steam Electric Station, Unit Nos. 1 and 2 (SSES 1 and 2). The proposed LAR includes the cyber security plan, proposed changes to Section 2 of the Renewed Facility Operating License, and a proposed Cyber Security Plan 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.

The purpose of this letter is to inform you that the U.S. Nuclear Regulatory Commission (NRC) staff has completed an initial review of the LAR. In accordance with the Office of Nuclear Reactor Regulation Office Instruction L1C-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 SSES 1 and 2 is based on an earlier version of Nuclear Energy Institute (I\lEI) 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 generic concerns.

Through numerous interactions, the NRC staff has communicated their 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).

T. Rausch -2 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 staff's concerns with the requested LAR, the licensee is requested to review the list of generic issues provided to the industry cyber security writing team and forwarded to all licensees via e-mail dated March 9, 2010, and provide a revised submittal.

For those generic issues that will not be addressed in the revised submittal, please provide additional information or justification 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, and a potentially less resource intensive method than addressing the individual issues, the licensee may submit a revised Cyber Security Plan consistent with Regulatory Guide (RG) 5.71 1 or submit a revised Cyber Security Plan consistent with I\IEI 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.

1 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.

T. Rausch -3 If you have any questions regarding this matter, please contact me at (301) 415-1030.

Sincerely, Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388 cc: Distribution via Listserv

ML101470262 OFFICE LPL 1-1/PM LPL1-'I/LA LPL 1-1/BC NAME RGuzman SUttle NSalgado DATE 5/27/10 5/27/10 5/27/10