ML102670641

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

ML102670641
Person / Time
Site:	Millstone, Kewaunee, Surry, North Anna
Issue date:	09/23/2010
From:	Hartz L Dominion, Dominion Energy Kewaunee, Dominion Nuclear Connecticut, Dominion Resources Services, Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
10-349B
Download: ML102670641 (5)

Text

Dominion Resources Services, Inc.

Innsbrook Technical Center 5000 Dominion Boulevard, 25E, Glen Allen, VA 23060 September 23, 2010 U.S. Nuclear Regulatory Commission Serial No.: 10-349B Attention: Document Control Desk NL&OS/MAE: R4 Washington, D.C. 20555-0001 Docket Nos.: 50-305 50-336/423 50-338/339 50-280/281 License Nos.: DPR-43 DOMINION ENERGY KEWAUNEE, INC. DPR-65 DOMINION NUCLEAR CONNECTICUT, INC. NPF-49 VIRGINIA ELECTRIC AND POWER COMPANY NPF-4/7 KEWAUNEE POWER STATION DPR-32/37 MILLSTONE POWER STATION UNITS 2 AND 3 NORTH ANNA POWER STATION UNITS 1 AND 2 SURRY POWER STATION UNITS 1 AND 2 NOTIFICATION LETTER DESIGNATING BALANCE OF PLANT SYSTEMS WITHIN THE CYBER SECURITY RULE SCOPE

Reference:

(1) Letters from Jim Hughes (NERC) to the subject stations, "Request for Data or Information: Nuclear Power Plant "Bright-Line" Survey," dated June 15, 2010.

(2) Letters from Michael Moon (NERC) to the subject stations, "NERC's Response to the Completed Bright-Line Survey," dated August 27, 2010 and September 2, 2010.

(3) E-mail datedJuly15.2010fromJ.N.BaileytoJimHughes.Bright-Line Survey Results.

1 By Order dated March 19, 2009 , 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 the Reference (2) letters, NERC required that Dominion Energy Kewaunee, Inc. (DEK),

Dominion Nuclear Connecticut, Inc. (DNC), and Virginia Electric and Power Company (Dominion) 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 for Kewaunee, Millstone, North Anna, and Surry Power Stations. As documented in our response to the Bright-Line survey (Reference 3), balance 1 Mandatory Reliability Standards for Critical Infrastructure Protection, order on clarification, Order No. 706-B, 126 PERC ~ 61,229 (2009).

Serial No. 10-349B Page 2 of 5 of plant SSCs in Table 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. This program will be implemented in accordance with the schedule submitted to the NRC by letter dated August 5, 2010 (Serial No. 10-349A). The 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 matter satisfies the intent of the NERC letter.

In the Reference (2) letters, NERC required 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, DEK, DNC, and Dominion will supplement our 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.

Should you have any questions concerning this letter, or require additional information, please contact Ms. Margaret A. Earle at (804) 273-2768.

~~7_

L.N.Hartz ~

Vice President - Nuclear Support Services Dominion Energy Kewaunee, Inc.

Dominion Nuclear Connecticut, Inc.

Virginia Electric and Power Company COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Leslie N. Hartz, who is Vice President - Nuclear Support Services, of Dominion Energy Kewaunee, Inc., Dominion Nuclear Connecticut, Inc., and Virginia Electric and Power Company.

She has affirmed before me that she is duly authorized to execute and file the foregoing document in behalf of these Companies, and that the statements in the document are true to the best of her knowledge and belief.

Acknowledged before me this ~Yolday of September, 2010.

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My Commission Expires: __Lf..:...L../..:...3_0-l-J..:...J....

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GINGER LYNN MELTON ~taryPUbliC Notary Public -:r: Wet' COf'nt"Y\iS'~ION 0\ 0-. .J Commonwealth of Virginia t'\O-t-CA.Y~ (;\.5 Gt,*~ L-. A \ \1 5c:c:o"*

310847 My Comlllillion Expire. Apr 30, 2013

Serial No. 10-349B Page 3 of 5 Commitments made in this letter: On or before November 30, 2010, DEK, DNC, and Dominion will supplement our Cyber Security Plan submittal to amend Section 2.1.

cc: Mr. Jim Hughes North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, NJ 08540 Mr. Michael Moon Director of Compliance Operations North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, NJ 08540 Mr. Jim T. Wiggins Director, Office of Nuclear Security and Incident Response U. S. Nuclear Regulatory Commission Mail Stop T-4 D22A Two White Flint North 11545 Rockville Pike Rockville, MD 20852-2738 Mr. Eric Leeds Director, Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-13 H16M One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region I Regional Administrator 475 Allendale Road King of Prussia, PA 19406-1415 U. S. Nuclear Regulatory Commission, Region II Regional Administrator 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 U. S. Nuclear Regulatory Commission, Region III Regional Administrator 2443 Warrenville Road Suite 210 Lisle, Illinois 60532-4352

Serial No. 10-349B Page 4 of 5 State Health Commissioner Virginia Department of Health James Madison Building - t h floor 109 Governor Street Room 730 Richmond, VA 23219 Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, Connecticut 06106-5127 Public Service Commission of Wisconsin Electric Division P. O. Box 7854 Madison, WI 53707 Mr. K. D. Feintuch NRC Senior Project Manager Kewaunee U. S. Nuclear Regulatory Commission Mail Stop 0-8 H4A One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Ms. C. J. Sanders NRC Project Manager Millstone Units 2 & 3 U. S. Nuclear Regulatory Commission Mail Stop 0-8-B 3 One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Ms. K. R. Cotton NRC Project Manager Surry U. S. Nuclear Regulatory Commission Mail Stop 0 8 G-9A One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Dr. V. Sreenivas NRC Project Manager North Anna U. S. Nuclear Regulatory Commission Mail Stop 0 8 G-9A One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738

Serial No. 10-3498 Page 5 of 5 NRC Senior Resident Inspector Millstone Power Station NRC Senior Resident Inspector Kewaunee Power Station NRC Senior Resident Inspector North Anna Power Station NRC Senior Resident Inspector Surry Power Station