0CAN091002, Notification Letter Designating ANO Balance-of-Plant Systems within the Cyber Security Rule Scope (Cover Letter Only)
| ML11206A768 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 09/23/2010 |
| From: | David Bice Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 0CAN091002 | |
| Download: ML11206A768 (3) | |
Text
Entergy Entergy Operations, Inc.
1448* R. 333 Russellville, AR 72802 Tel 479-858-4710 David B. Bice Acting Manager, Licensing Arkansas Nuclear One OCAN091002 September 23, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Reference:
Notification Letter Designating ANO Balance-of-Plant Systems within the Cyber Security Rule Scope Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6
- 1. Letter from Jim Hughes (NERC) to Entergy, "Request for Data or Information: Nuclear Power Plant 'Bright-Line' Survey," dated June 15, 2010
- 2. Letters from Michael Moon (NERC) to ANO-1 and ANO-2, "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.
1 Mandatory Reliability Standards for Critical Infrastructure Protection, order on clarification, Order No. 706-B, 126 FERC 61,229 (2009).
OCAN091002 Page 2 of 3 In the Reference 2 letters, NERC is requiring that Arkansas Nuclear One (ANO) 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 Entergy's 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 9, 2010 (OCAN071 001) with ANO's 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 letters, 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 ANO 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. Should you have any questions concerning this letter, or require additional information, please contact me.
Sincerely, DBB/nbm
Attachment:
List of Regulatory Commitments
OCAN091002 Page 3 of 3 cc:
Mr. Elmo Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS 0-8 B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Michael Moon Director of Compliance Operations North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, NJ 08540