ML102710641
| ML102710641 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/27/2010 |
| From: | Schwarz C Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response |
| Shared Package | |
| ML102710646 | List: |
| References | |
| Download: ML102710641 (3) | |
Text
Entergy September 27, 2010 u.S. Nuclear Regulatory Commissiqn Attn: Document Control Desk Washington, DC 20555 Entergy Nuclear Operations, Inc.
27780 Blue Star Memorial Highway Covert, MI 49043 Tel 269 7642000 Christopher J. Schwarz Site Vice President Palisades Nuclear Plant
SUBJECT:
Notification Letter Designating Palisades Balance-of-Plant Systems within the Cyber Security Rule Scope Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant Docket No. 50-255 License No. DPR-20
Reference:
- 1. NERC, "Request for Data or Information: Nuclear Power Plant 'Bright-Line' Survey," dated June 14, 2010
- 2. Letter from Michael Moon (NERC) to Jim Ellis, "NERC's Response to the Completed Bright-Line Survey, Palisades Nuclear Station" 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-planf' 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 Nuclear Regulatory Commission (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.
1 Mandatory Reliability Standards for Critical Infrastructure Protection, Order On Clarification, Order No. 706-B, 126 FERC 1161,229 (March 19,2009).
In the Reference 2 letter, NERC is requiring that Palisades Nuclear Plant (PNP) 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 J41y 26, 2010, with the PNP 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 the Reference 2 letter, 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 Nuclear Operations, Inc. 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.
The new commitments contained in this submittal are summarized in the attachment.
Sincerely, cjs/rbh of Commitments Regional Administrator, Region III, Project Manager, Palisades, Resident Inspector, Palisades, USNRC Designated Michigan Officials Michael Moon Director of Compliance Operations North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, NJ 08540 list