GNRO-2010/00065, Notification Letter Designating Grand Gulf Nuclear Station Balance of-Plant Systems within the Cyber Security Rule Scope
| ML102670030 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/23/2010 |
| From: | Perino C Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GNRO-2010/00065 | |
| Download: ML102670030 (5) | |
Text
~Entergy GNRO-2010100065 September 23, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Entergy Operations, Inc.
7003 Bald Hill Road PO. Box 756 Port Gibson, MS 39150 Tel 601 437 6299 Christina L. Perino Manager Licensing
SUBJECT:
Notification Letter Designating Grand Gulf Nuclear Station Balance of-Plant Systems Within the Cyber Security Rule Scope Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
REFERENCES:
1.
Letter from Jim Hughes (NERC) to Entergy, "Request for Data or Information: Nuclear Power Plant 'Bright-Line' Survey," dated June 14,2010 2.
Letter from Michael Moon (NERC) to Grand Gulf Nuclear Station, Unit 1, "NERC's Response to the Completed Bright-Line Survey,"
dated August 27,2010
Dear Sir or Madam:
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 (Reference 1) 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 Reference 2, NERC is requiring that Grand Gulf Nuclear Station (GGNS) provide the NRC with a letter identifying all balance-of-plant structures, systems, 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 (Reference 1),
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.
1 Mandatory Reliability Standards for Critical Infrastructure Protection, order on clarification, Order No. 706-8, 126 FERC 61,229 (2009)
GNRO-2010/00065 Page 2 of 3 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 22,2010 (GNRO-2010100047) with the GGNS Cyber Security Plan. This identification of SSCs will be available for inspection upon completion and will contain, at a minimum, those SSCs as identified in Attachment 1 of the Bright-Line Survey. Providing the requested information in this alternate manner satisfies the intent of the NERC letter.
In Reference 2, 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, Entergy will supplement the GGNS Cyber Security Plan submittal 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.
The new commitments contained in this submittal are summarized in the attachment.
If you have any questions regarding this submittal, please contact Peggy R. Rescheske at 601-437-1781.
Sincerely, CLP/PRR
Attachment:
List of Regulatory Commitments
GNRO-2010100065 Page 3 of 3 cc:
NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 u.s. Nuclear Regulatory Commission ATTN: Mr. Elmo E. Collins, Jr. (w/2)
Region Administrator, Region IV 612 East Lamar Blvd, Suite 400 Arlington, TX 76011-4125
- u. S. Nuclear Regulatory Commission ATTN: Mr. Carl F. Lyon, NRRlDORL (w/2)
Mail Stop OWFN/8 B1 Washington, DC 20555-0001 Michael Moon Director of Compliance Operations North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, NJ 08540
Attachment GNRO-2010/00065 List of Regulatory Commitments
Attachment to GNRO-2010/00065 Page 1 of 1 List of Regulatory Commitments The table below identifies actions discussed in this letter for which Entergy commits to perform.
Any other statements or actions discussed in this submittal are for information purposes and are not considered commitments.
TYPE ONE-TIME CONTINUING SCHEDULED COMMITMENT COMPLETION DATE ACTION COMPLIANCE (If Required)
Entergy will supplement the GGNS Cyber Security X
November 30,2010 Plan submittal to clarify the scope of systems described in Section 2.1, Scope and Purpose, to clarify the balance-of-plant SSCs that will be included in the scope of the cyber security program.
In accordance with the requirements of 10 CFR X
September 30,2014 73.54 (b)(1), a comprehensive identification of systems, structures, and components (SSCs) subject to the requirements of 10 CFR 73.54 will be developed during the implementation of the cyber security program. This identification of SSCs will be available for inspection upon completion and will contain, at a minimum, those SSCs as identified in of the Bright-Line Survey.