ML19284A626

NEI Fee Waiver Request Changes to NEI 10-04 and NEI 13-10 Regarding EP

ML19284A626
Person / Time
Site:	Nuclear Energy Institute
Issue date:	10/10/2019
From:	Gross W Nuclear Energy Institute
To:	Maureen Wylie NRC/OCFO
smh
References
NEI 10-04, Rev 2, NEI 13-10, Rev 6
Download: ML19284A626 (2)

Text

WILLIAM R. GROSS Director, Incident Preparedness 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8123 wrg@nei.org nei.org October 10, 2019 Ms. Maureen E. Wylie Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Fee Exemption Request for NEI White Paper, Changes to NEI 10-04 and NEI 13-10 Guidance for Identifying and Protecting Digital Assets Associated with Emergency Preparedness Functions, Dated October 2019 Project Number: 689

Dear Ms. Wylie:

The Nuclear Energy Institute (NEI) 1, on behalf of its members, will be submitting for the Nuclear Regulatory Commissions (NRC) review and endorsement a White Paper revising two currently endorsed NEI technical reports. The submittal will contain proposed changes to NEI 10-04, Identifying Systems and Assets Subject to the Cyber Security Rule, Revision 2, dated July 2012; and to NEI 13-10, Cyber Security Control Assessments, Revision 6, dated August 2017. This submittal revises guidance for identifying and protecting Emergency Preparedness (EP) Critical Digital Assets (CDAs). Lessons learned through the implementation of cyber security programs indicate that the specified clarifications are necessary to enhance clarity, support efficient and consistent implementation, and to support NRC oversight activities. The changes are intended to improve the effectiveness and efficiency of licensee cyber security programs while maintaining adequate protection against the radiological sabotage cyber attack.

NEI requests that the NRC's review of the document and any future submissions of the guidance documents be granted a fee waiver pursuant to the provisions of 10 CFR 170.11. The document meets the exemption requirement in 10 CFR 170.11(a)(1)(ii) in that it will assist the NRC in generic regulatory improvements or efforts (e.g., rules, regulatory guides, regulations, policy statements, generic letters, or bulletins). In this case, NRC review and endorsement of NEI White Paper, Changes to NEI 10-04 and NEI 13-10 Guidance for Identifying and Protecting Digital Assets Associated with Emergency Preparedness Functions, dated 1

The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.

Ms. Maureen E. Wylie October 10, 2019 Page 2 October 2019, by December 20, 2019, will improve the effectiveness and efficiency of licensee cyber security programs and the NRC oversight function. In addition, the NRC staff can use the information as it develops and implements its Cyber Security Action Plan as described in its Power Reactor Cyber Security Program Assessment (ADAMS ML19175A210), dated July 12, 2019.

If you have any questions or require additional information, please contact Richard Mogavero, at (202) 739-8174 or rm@nei.org, or me.

Sincerely, William R. Gross c: Mr. James D. Beardsley, NSIR/CSD, NRC Mr. Doug Huyck, NSIR/DSO, NRC NRC Document Control Desk