NL-10-096, Notification Letter Designating Balance of Plant Systems within the Cyber Security Rule Scope

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

ML102780434
Person / Time
Site:	Indian Point
Issue date:	09/23/2010
From:	Joseph E Pollock Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-10-096
Download: ML102780434 (4)

Text

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 SEntergy Buchanan, N.Y. 10511-0249 Tel (914) 734-6700 J.E. Pollock Site Vice President Administration September 23, 2010 NL-1 0-096 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Notification Letter Designating Indian Point Energy Center Balance of Plant Systems within the Cyber Security Rule Scope Indian Point Unit Numbers 2 and 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

REFERENCE:

1. Letter from Jim Hughes (NERC) to Indian Point, "Request for Data or Information: Nuclear Power Plant 'Bright-Line' Survey," dated June 14, 2010.

2. Letter from Michael Moon (NERC) to Gurunath Bijoor, "NERC's Response to the Completed Bright Line Survey: Indian Point Generating Unit 2 and 3," 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.

1 Mandatory Reliability Standards for CriticalInfrastructureProtection,order on clarification, Order No. 706-B, 126 FERC ¶ 61,229 (2009).

MLL_

NL-10-096 Docket Nos. 50-247 and 50-286 Page 2 of 2 In the Reference 2 letter, NERC is requiring that each Nuclear Power Plant 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 July 8, 2010 (NL-1 0-064) with the proposed Indian Point Energy Center 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. identifies commitments made in this letter. Should you have any questions concerning this letter, or require additional information, please contact Mr. Robert Walpole, Manager, Licensing at (914) 734-6710.

Respectfully, JEP/sp

Attachment:

1. Commitments cc: Mr. Michael Moon, Director of Compliance Operations, North American Electric Reliability Corporation Mr. John P. Boska, Senior Project Manager, NRC NRR DORL Mr. Theodore Smith, Project Manager, NRC FSME DWMEP DURLD Mr. Marc Dapas, Regional Administrator, NRC Region 1 NRC Resident Inspectors Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Mr. Paul Eddy, New York State Dept. of Public Service

ATTACHMENT 1 TO NL-10-096 COMMITTMENTS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNITS NO. 2 and 3 DOCKET NOs. 50-247, and 50-286

NL-1 0-096 Docket Nos. 50-247 and 50-286 Attachment 1 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED COMMITMENT (Check One) COMPLETION ONE-TIME CONTINUING DATE ACTION COMPLIANCE (If Required)

Entergy will supplement the IPEC X November 30, 2010 Cyber Security 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 X September 30, 2014 of 10 CFR 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 Attachment 1 of the Bright-Line Survey.