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MONTHYEARML1021101012010-07-30030 July 2010 Acceptance of LAR Application for Cyber Security Plan Project stage: Acceptance Review ML1036103512011-01-0505 January 2011 Request for Additional Information to Support the Review of PNPS Cyber Security Plan (Id: 2.10.034) Project stage: RAI ML1105403302011-02-15015 February 2011 Response to Request for Additional Information (Rai), Dated January 5, 2011 on the Cyber Security Plan Project stage: Response to RAI ML1106101872011-03-0303 March 2011 Request for Additional Information to Support the Review of Pilgrim Nuclear Power Station Cyber Security Plan (Id: 2.10.034) Project stage: RAI ML1110203732011-04-0404 April 2011 Response to Additional Requests for Additional Information (Rais) Dated March 3, 2011 and Revision to the PNPS Cyber Security Plan Project stage: Other ML11152A0432011-07-22022 July 2011 License Amendment, Cyber Security Plan Project stage: Other 2011-02-15
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Category:Letter
MONTHYEARL-24-002, Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G2024-02-0202 February 2024 Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G ML23342A1182024-01-0909 January 2024 Independent Spent Fuel Storage Installation Security Inspection Plan L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023 Proof of Financial Protection 10 CFR 140.15 ML23334A1822023-11-30030 November 2023 Biennial Report for the Defueled Safety Analysis Report Update, Technical Specification Bases Changes, 10 CFR 50.59 Evaluation Summary, and Regulatory Commitment Change Summary November 2021 Through October 2023 L-23-012, Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point2023-11-13013 November 2023 Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point ML23306A0992023-11-0202 November 2023 and Indian Point Energy Center, Notification of Changes in Schedule in Accordance with 10 CFR 50.82(a)(7) L-23-011, 10 CFR 72.48 Biennial Change Summary Report2023-10-27027 October 2023 10 CFR 72.48 Biennial Change Summary Report IR 05000293/20234012023-08-31031 August 2023 NRC Inspection Report No. 05000293/2023401 & 2023001 (Cover Letter Only) IR 05000293/20230022023-08-0404 August 2023 NRC Inspection Report No. 05000293/2023002 L-23-008, Correction to Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations Holtec Decommissioning International, LLC (HDI)2023-05-23023 May 2023 Correction to Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations Holtec Decommissioning International, LLC (HDI) ML23136A7792023-05-15015 May 2023 Annual Radiological Environmental Operating Report, January 1 Through December 31, 2022 ML23135A2152023-05-15015 May 2023 Annual Radioactive Effluent Release Report, January 1 Through December 31, 2022 L-23-004, HDI Annual Occupational Radiation Exposure Data Reports - 20222023-04-24024 April 2023 HDI Annual Occupational Radiation Exposure Data Reports - 2022 L-23-003, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-31031 March 2023 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations ML23088A0382023-03-29029 March 2023 Stations 1, 2, & 3, Palisades Nuclear Plant, and Big Rock Point - Nuclear Onsite Property Damage Insurance ML23069A2782023-03-13013 March 2023 Request for Scoping Comments Concerning the Environmental Review of Monticello Nuclear Generating Plant, Unit 1 Subsequent License Renewal Application ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities IR 05000293/20220042023-02-15015 February 2023 NRC Inspection Report No. 05000293/2022004 ML22356A0712023-01-31031 January 2023 Issuance of Exemption for Pilgrim Nuclear Power Station ISFSI Regarding Annual Radioactive Effluent Release Report - Cover Letter ML22347A2782022-12-21021 December 2022 Independent Spent Fuel Storage Installation Security Inspection Plan Dated December 21, 2022 L-22-042, Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.152022-12-14014 December 2022 Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.15 L-22-041, Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension2022-12-0909 December 2022 Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension IR 05000293/20220032022-11-18018 November 2022 NRC Inspection Report No. 05000293/2022003 L-22-036, Decommissioning Trust Fund Agreement2022-11-0808 November 2022 Decommissioning Trust Fund Agreement ML22276A1762022-10-24024 October 2022 Decommissioning International Proposed Revisions to the Quality Assurance Program Approval Forms for Radioactive Material Packages ML22266A1922022-09-23023 September 2022 and Pilgrim Nuclear Power Station - Request to Withdraw Prior Submissions from NRC Consideration ML22272A0352022-09-22022 September 2022 S. Lynch-Benttinen Letter Regarding U.S. Citizen Intent to Sue U.S. Fish and Wildlife and NOAA Fisheries Representing the Endangered Species (Na Right Whale) Which Will Be Adversely Affected by Holtec International Potential Actions ML22269A4202022-09-22022 September 2022 Citizen Lawsuit ML22241A1122022-08-29029 August 2022 Request for Exemption from 10 CFR 72.212(a)(2), (b)(2), (b)(3), (b)(4), (B)(5)(i), (b)(11), and 72.214 for Pilgrim ISFSI Annual Radioactive Effluent Release Report IR 05000293/20220022022-08-12012 August 2022 NRC Inspection Report No. 05000293/2022002 ML22215A1772022-08-0303 August 2022 Decommissioning International (HDI) Proposed Revisions to the Quality Assurance Program Approval Forms for Radioactive Material Packages ML22206A1512022-08-0101 August 2022 NRC Office of Investigations Case Nos. 1-2022-002 & 1-2022-006 ML22221A2592022-08-0101 August 2022 LTR-22-0217-1-NMSS - Town of Duxbury Letter Opposing the Irradiated Water Release from Pilgrim (Docket No. 05000293) ML22193A1662022-07-28028 July 2022 LTR-22-0154-1 - Heather Govern, VP, Clean Air and Water Program, Et Al., Letter Regarding Radioactive Wastewater Disposal from the Pilgrim Nuclear Power Station (Docket No. 05000293) ML22175A1732022-07-28028 July 2022 LTR-22-0153-1 - Response Letter to D. Turco, Cape Downwinders, from A. Roberts, NRC, Regarding Holtec-Pilgrim Plans to Dump One Million Gallons of Radioactive Waste Into Cape Cod Bay ML22154A4882022-06-0101 June 2022 Letter from Conservation Law Foundation Regarding Irradiated Water Release from Pilgrim ML22154A1622022-05-26026 May 2022 Letter and Email from Save Our Bay/Diane Turco Regarding Irradiated Water Release from Pilgrim ML22136A2602022-05-16016 May 2022 Submittal of Annual Radiological Environmental Operating Report for January 1 Through December 31, 2021 ML22136A2572022-05-16016 May 2022 Submittal of Annual Radioactive Effluent Release Report for January 1 Through December 31, 2021 ML22102A0932022-05-12012 May 2022 LTR-22-0067 Response to Matthew P. Levesque, President, Barnstable Town Council Regarding Irradiated Water Release from Pilgrim IR 05000293/20220012022-05-11011 May 2022 NRC Inspection Report No. 05000293/2022001 ML22104A0542022-04-30030 April 2022 LTR-22-0093 Response to Sheila Lynch-Benttinen, Regarding Irradiated Water Release from Pilgrim L-22-026, Occupational Radiation Exposure Data Report - 20212022-04-29029 April 2022 Occupational Radiation Exposure Data Report - 2021 ML22152A2592022-04-25025 April 2022 Zaccagnini Letter Dated 04/25/22 ML22152A2642022-04-19019 April 2022 Flynn Letter Dated 04/19/22 ML22091A1062022-04-0101 April 2022 Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) L-22-022, and Indian Point Nuclear Generating Stations 1, 2, & 3 - Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec.2022-03-25025 March 2022 and Indian Point Nuclear Generating Stations 1, 2, & 3 - Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec. ML22130A6762022-03-14014 March 2022 Decola Ltr Dtd 03/14/22 Re Potential Discharge of Radioactive Water from Pilgrim Nuclear Power Station ML22041B0762022-03-0707 March 2022 03-07-22 - Letter to the Honorable William R. Keating, Responds to Letter Regarding Proposed Release of Irradiated Water at Pilgrim Nuclear Power Station Into Cape Cod Bay ML22054A2962022-02-23023 February 2022 Annual ISFSI Radioactive Effluent Release Report for 2021 2024-02-02
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML21223A2422021-08-16016 August 2021 Enclosure - Pilgrim Nuclear Power Station - Request for Additional Information Regarding Pilgrim - License Amendment Request Independent Spent Fuel Storage Installation Only Emergency Plan ML21161A1072021-07-0909 July 2021 Request for Additional Information Regarding Pilgrim License Amendment Request ISFSI Only Emergency Plan ML21013A5232021-01-15015 January 2021 Request for Additional Information Regarding the Request to Change the Physical Security Plan - Alternative Measures ML20297A2382020-10-22022 October 2020 Fleet DQAP RAIs - Enclosure ML20297A2372020-10-22022 October 2020 Request for Additional Information - HDI Fleet Decommissioning Quality Assurance Program ML20142A2422020-05-26026 May 2020 Acceptance of Requested Licensing Action Physical Security Plan Revision and License Amendment Request to Incorporate Additional Independent Spent Fuel Storage Installation with Requests for Additional Information ML20280A1912020-04-17017 April 2020 Request for Additional Information- Clarifying Information for Pilgrim ISFSI Physical Security Amendment Application ML19207B3662019-07-26026 July 2019 NRR E-mail Capture - Pilgrim - RAI Direct and Indirect Transfer of Lic.; Conforming Lic. Amend.; Req. for Exemption 10 CFR 50.82(A)(8)(I)(A) for Holtec Decom. International, Llc ML19154A5242019-06-0303 June 2019 NRR E-mail Capture - RAI - Pilgrim Post-Decommissioning Technical Specifications (PDTS) License Amendment Request (LAR) ML19086A3492019-03-21021 March 2019 NRR E-mail Capture - Pilgrim Power Station - Request for Additional Information Application for Order Consenting to Direct and Indirect Transfers of Control of Licenses and Approving Conforming License Amendment (EPID: L-2018-LL0-0003) ML19036A6512019-02-0404 February 2019 NRR E-mail Capture - RAI - Pilgrim EP Exemption ML18320A1292018-11-16016 November 2018 NRR E-mail Capture - Request for Additional Information (RAI) - Pilgrim Post-Decommissioning Technical Specifications (PDTS) License Amendment Request (LAR) ML18323A1192018-11-15015 November 2018 CAL 5 Document Request #2 ML18317A2202018-11-11011 November 2018 NRR E-mail Capture - (External_Sender) Questions and Comments Regarding Pilgrim EP Exemption RAI, October 16, 2018 ML18317A2192018-11-0808 November 2018 NRR E-mail Capture - (External_Sender) RAI EP 11.06.18-Question ML18310A0212018-11-0606 November 2018 NRR E-mail Capture - RAI - Pilgrim EP Exemption ML18289A4072018-10-16016 October 2018 NRR E-mail Capture - RAIs - Pilgrim EP Exemption ML18285A8182018-10-12012 October 2018 NRR E-mail Capture - for Your Action: RAIs - Pilgrim - LAR - EP and EAL Scheme to Address Permanently Defueled Condition ML18124A1392018-05-0404 May 2018 NRR E-mail Capture - RAI - Pilgrim ERO Staffing License Amendment Request ML18094B0922018-04-0505 April 2018 Enclosurequest for Additional Information (Letter to B. S. Ford RAI Regarding Entergy Operations, Inc.'S Decommissioning Funding Plan Update for ISFSI Docket Nos.: 72-43, 72-51, 72-1044, 72-07, 72-12, and 72-59) ML18005A5422018-01-0505 January 2018 NRR E-mail Capture - Second Round of RAI for DAEC Fifth Inservice Inspection Interval Program Plan, Relief Request RR-03 - EPID: L-2017-LLR-0110 ML16347A0042016-12-0909 December 2016 NRR E-mail Capture - Pilgrim: Request for Additional Information for Relief Requests on Volumetric Exam Requirements, PNPS-ISI-001, 002 and 003 ML16013A0642016-01-13013 January 2016 NRR E-mail Capture - Request for Additional Information Entergy CNRO-2015-00023 - Revision to Entergy Quality Assurance Program Manual (Fleet Submittal CAC Nos. MF7086-MF7097) ML15341A1662015-12-0707 December 2015 NRR E-mail Capture - Entergy Fleet RR-EN-15-1, Request for Additional Information (CACs MF6341-MF6349) ML15211A6612015-07-30030 July 2015 Licensed Operator Positive Fitness-For-Duty-Test ML15051A0322015-02-25025 February 2015 Request for Additional Information Regarding the Safety Limit Minimum Critical Power Ratio License Amendment Request ML14342A0942014-12-17017 December 2014 Request for Additional Information Regarding Relief Request PRR-24, Nozzle-to-Vessel Welds and Nozzle Inner Radii Examinations ML14042A0432014-02-18018 February 2014 Request for Additional Information Regarding Safety Limits to Resolve Pressure Regulator Fail-Open Transient License Amendment Request ML13333A9102013-12-0505 December 2013 Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool ins ML13323B4702013-11-25025 November 2013 Request for Additional Information Regarding Relief Request PRR-22 ML13304B4182013-11-0101 November 2013 Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns ML13179A4622013-07-0505 July 2013 Entergy Nuclear Operations, Inc., Decommissioning Funding Status Report Request for Additional Information Regarding the Decommissioning Funding Status Report ML13182A4252013-07-0101 July 2013 Request for Additional Information E-mail from R.Guzman to W.Lobo PR-03 and PR-05 Fifth Ten-Year Inservice Testing (IST) Program ML13165A2762013-06-20020 June 2013 Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (NRC Order EA-12-051) ML12278A3862012-10-0404 October 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2, and 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford, Request for Additional Information, Round 2, Amendment Request to Revise QA Program Manual and Staff Qualification TSs ML1209604492012-04-0505 April 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2 & 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford - Request for Additional Information, Revise Quality Assurance Program Manual and Staff Qualification Technical Specificat ML1208601472012-03-26026 March 2012 Request for Additional Information - Pilgrim Nuclear Power Station Revision to Condensate Storage Tank Low Level Trip Setpoint ML12056A0512012-03-12012 March 2012 Enclosure 5 - Recommendation 9.3: Emergency Preparedness ML12056A0502012-03-12012 March 2012 Enclosure 4 - Recommendation 2.3: Flooding ML12056A0482012-03-12012 March 2012 Enclosure 2 - Recommendation 2.1: Flooding ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic ML12056A0472012-03-12012 March 2012 Enclosure 1 - Recommendation 2.1: Seismic ML1132502282011-11-22022 November 2011 Request for Additional Information, Relief Request No. PRR-21 ML1132202342011-11-21021 November 2011 Request for Additional Information 60-Day Response to Bulletin 2011-01, Mitigating Strategies, ML1114402342011-05-25025 May 2011 Request for Additional Information to Support the Review of 2011 Decommissioning Funding Status Report ML1108202082011-04-11011 April 2011 Summary of Telephone Conference Call Held on March 23, 2011, Between the USNRC and Entergy Nuclear Operations, Inc., Concerning the Pilgrim Nuclear Power Station License Renewal Application ML1106101872011-03-0303 March 2011 Request for Additional Information to Support the Review of Pilgrim Nuclear Power Station Cyber Security Plan (Id: 2.10.034) ML1105403302011-02-15015 February 2011 Response to Request for Additional Information (Rai), Dated January 5, 2011 on the Cyber Security Plan ML1100900272011-01-10010 January 2011 Request for Additional Information Revision to TS for Setpoint and Setpoint Tolerance Increase for Safety Relief Valves and Spring Safety Valves, and Related Changes (ME3543) ML1034105062011-01-0707 January 2011 December 1, 2010, Summary of Telephone Conference Call Held Between the U.S. Nuclear Regulatory Commission and Entergy Nuclear Operations, Inc., Concerning the Pilgrim Nuclear Power Station License Renewal Application 2021-08-16
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 March 3, 2011 Site Vice President Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION TO SUPPORT THE REVIEW OF PILGRIM NUCLEAR POWER STATION CYBER SECURITY PLAN (ID: 2.10.034) (TAC NO. ME4351)
Dear Sir or Madam:
By letter dated July 15, 2010 (Agencywide Documents Access and Management System, Accession No. ML101970359), as supplemented by letter dated February 15, 2011 (ADAMS Accession No. ML110540330), Entergy Nuclear Operations, Inc. (the licensee) resubmitted a request to amend the Facility Operating License (No. DPR-35) for Pilgrim Nuclear Power Station (PNPS). Per the proposed license amendment, the licensee requested approval of the PNPS Cyber Security Plan (CSP), provided a proposed CSP Implementation Schedule, and included a proposed revision to the Facility Operating License to incorporate the provisions for implementing and maintaining in effect the provisions of the approved CSP. The licensee's amendment request was based on a generic template developed by the Nuclear Energy Institute in concert with the industry.
The Nuclear Regulatory Commission (NRC) staff is reviewing the CSP and the proposed CSP Implementation Schedule and has determined that additional information is required to complete its technical review. A supplemental request for additional information is included as an Enclosure and was reviewed in accordance with the guidance provided in Title 10 of the Code of Federal Regulations Section 2.390, and the NRC staff has determined that no security-related or proprietary information is contained therein. A response to this RAI is requested to be provided by April 4, 2011.
Please contact me at (301) 415-1030 if you have any questions.
Sincerely, Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293
Enclosure:
As stated cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION (RAI)
REGARDING LICENSE AMENDMENT REQUEST FOR THE CYBER SECURITY PLAN ENTERGY NUCLEAR OPERATIONS, INC.
PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293 RAI 1: Records Retention Title 10 of the Code of Federal Regulations (10 CFR) Section 73.54(c)(2) requires licensees to design a cyber security program to ensure the capability to detect, respond to, and recover from cyber attacks. Furthermore, 10 CFR 73.54(e)(2)(i) requires licensees to maintain a Cyber Security Plan (CSP) that describes how. the licensee will maintain the capability for timely detection and response to cyber attacks. The ability for a licensee to detect and respond to cyber attacks requires accurate and complete records and is further supported by 10 CFR 73.54(h), which states that the licensee shall retain all records and supporting technical documentation required to satisfy the requirements of 10 CFR 73.54 as a record until the Commission terminates the license for which the records were developed, and shall maintain superseded portions of these records for at least 3 years after the record is superseded, unless otherwise specified by the Commission.
The licensee's CSP in Section 4.13 states that Critical Digital Asset (CDA) audit records and audit data (e.g., operating system logs, network device logs) are retained for a period of time that is less than what is required by 10 CFR 73.54(h).
Explain the deviation from the 10 CFR 73.54(h) requirement to retain records and supporting technical documentation until the Commission terminates the license (or to maintain superseded portions of these records for at least 3 years) and how that meets the requirements of 10 CFR 73.54.
RAI 2: Implementation Schedule The regulation at 10 CFR 73.54, " Protection of digital computer and communication systems and networks," requires licensees to submit a CSP that satisfies the requirements of this section for Commission review and approval. Furthermore, each submittal must include a proposed implementation schedule and the implementation of the licensee's cyber security program must be consistent with the approved schedule. 10 CFR 73.54(a) requires licensees to provide high assurance that digital computer and communication systems and networks are adequately protected against cyber attacks, up to and including the design-basis threat (DBT). The completion of several key intermediate milestones (Items (a) through (g) below) would demonstrate progress toward meeting the requirements of 10 CFR 73.54. The Nuclear Regulatory Commission (NRC) staff s expectation is that the key intermediate milestones will be completed in a timely manner, but no later than December 31, 2012. The key CSP implementation milestones are as follows:
Enclosure
-2 (a) Establish, train and qualify Cyber Security Assessment Team, as described in Section 3.1.2, "Cyber Security Assessment Team," of the CSP.
(b) Identify Critical Systems and CDAs, as described in Section 3.1.3, "Identification of Critical Digital Assets," of the CSP.
(c) Implement cyber security defense-in-depth architecture by installation of deterministic one-way devices, as described in Section 4.3, "Defense-In-Depth Protective Strategies" of the CSP.
(d) Implement the management, operational and technical cyber security controls that address attacks promulgated by use of portable media, portable devices, and portable equipment as described in Appendix D Section 1.19 "Access Control for Portable and Mobile Devices," of Nuclear Energy Institute (NEI) 08-09, Revision 6.
(e) Implement observation and identification of obvious cyber related tampering to existing insider mitigation rounds as described in Appendix E Section 4.3, "Personnel Performing Maintenance and Testing Activities," and Appendix E Section 10.3, "Baseline Configuration" of NEI 08-09, Revision 6.
(f) Identify, document, and implement cyber security controls to physical security target set CDAs in accordance with Section 3.1.6, "Mitigation of Vulnerabilities and Application of Cyber Security Controls," of the CSP.
(g) Ongoing monitoring and assessment activities will commence for those target set CDAs whose security controls have been implemented, as described in Section 4A, "Ongoing Monitoring and Assessment," of the CSP.
(h) Full implementation of the CSP for all safety, security, and emergency preparedness functions.
Provide a revised CSP implementation schedule that identifies the appropriate milestones, completion dates, supporting rationale, and level of detail to allow the NRC to evaluate the licensee's proposed schedule and associated milestone dates which include the final completion date. It is the NRC's intention to develop a license condition incorporating your revised CSP implementation schedule containing the key milestone dates.
RAI3: Scope of Systems Paragraph 73.54(a} of 10 CFR requires licensees to provide high assurance that digital computer and communication systems and networks are adequately protected against cyber attacks, up to and including the DBT as described in 10 CFR 73.1. In addition, 10 CFR 73.54(a}(1} states that the licensee shall protect digital computer and communication systems and networks associated with:
-3 (i) Safety-related and important-to-safety functions; (ii) Security functions; (iii) Emergency preparedness functions, including offsite communications; and (iv) Support systems and equipment which, if compromised, would adversely impact safety, security, or emergency preparedness functions.
Subsequent to the issuance of the cyber security rule, the NRC stated that 10 CFR 73.54 should be interpreted to include structures, systems, and components (SSCs) in the balance of plant (BOP) that have a nexus to radiological health and safety (Agencywide Documents Access and Management System (ADAMS) Accession No. ML103490344, dated November 19,2010). The SSCs in the BOP are those that could directly or indirectly affect reactivity of a nuclear power plant and could result in an unplanned reactor shutdown or transient and are therefore, within the scope of important-to-safety functions described in 10 CFR 73.54(a)(1). Furthermore, the NRC issued a letter to NEI dated January 5, 2011 (ADAMS Accession No. ML103550480) that provided licensees with additional guidance on one acceptable approach to comply with the Commission's policy determination.
Explain how the scoping of systems provided by licensee's CSP meets the requirements of 10 CFR 73.54 and the additional guidance provided by the NRC.
March 3, 2011 Site Vice President Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION TO SUPPORT THE REVIEW OF PILGRIM NUCLEAR POWER STATION CYBER SECURITY PLAN (lD: 2.10.034) (TAC NO. ME4351)
Dear Sir or Madam:
By letter dated July 15, 2010 (Agencywide Documents Access and Management System, Accession No. ML101970359), as supplemented by letter dated February 15, 2011 (ADAMS Accession No. ML110540330), Entergy Nuclear Operations, Inc. (the licensee) resubmitted a request to amend the Facility Operating License (No. DPR-35) for Pilgrim Nuclear Power Station (PNPS). Per the proposed license amendment, the licensee requested approval of the PNPS Cyber Security Plan (CSP), provided a proposed CSP Implementation Schedule, and included a proposed revision to the Facility Operating License to incorporate the provisions for implementing and maintaining in effect the provisions of the approved CSP. The licensee's amendment request was based on a generic template developed by the Nuclear Energy Institute in concert with the industry.
The Nuclear Regulatory Commission (NRC) staff is reviewing the CSP and the proposed CSP Implementation Schedule and has determined that additional information is required to complete its technical review. A supplemental request for additional information is included as an Enclosure and was reviewed in accordance with the guidance provided in Title 10 of the Code of Federal Regulations Section 2.390, and the NRC staff has determined that no security-related or proprietary information is contained therein. A response to this RAI is requested to be provided by February 15, 2011.
Please contact me at (301) 415-1030 if you have any questions.
Sincerely, Ira!
Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsNrrDorlLpl1-1 Resource RidsRgn1 MailCenter RidsOGCMailCenter RidsNrrLASLittle RidsNsirDsp Resource RidsNrrPMPilgrim RidsNrrDorlDpr PPederson RidsAcrsAcnw_MailCenter Resource ADAMSACCESSION NUMBER : ML110610187
- RAI provl'd ed by memo. No substantial changes made.
OFFICE LPL1-1/PM LPL1-1/LA NSIRfDSP/ISCPB/BC* LPL 1-1/BC NAME RGuzman SUttle CErlanger NSalgado DATE 3/2/11 3/2/11 02118/11 313/11 OFFICIAL RECORD COpy