NRC-10-0055, Notification Letter Designating Fermi 2 Balance of Plant Systems within the Cyber Security Rule Scope

Notification Letter Designating Fermi 2 Balance of Plant Systems within the Cyber Security Rule Scope

ML102730180
Person / Time
Site:	Fermi
Issue date:	09/29/2010
From:	Plona J DTE Energy
To:	Office of Nuclear Reactor Regulation, Document Control Desk, Office of Nuclear Security and Incident Response
References
NRC-10-0055
Download: ML102730180 (3)

Text

Joseph I. Plona Site Vice President 6400 N.Dixie Highway, Newport, MI 48166 Tel: 734.586.5910 Fax: 734.586.4172 DTE Ene gy*

September 29, 2010 NRC-10-0055 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Reference:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43

2) Letter from Jim Hughes (NERC) to Kent Kujala, Detroit Edison, "Request for Data or Information: Nuclear Power Plant 'Bright-Line' Survey," dated June 15, 2010

3) Letter from Michael Moon (NERC) to Kent Kujala, Detroit Edison, "NERC's Response to the Completed Bright Line Survey," dated August 30, 2010

4) Detroit Edison Letter to NRC, "Request for Approval of Revised Fermi 2 Cyber Security Plan," NRC-10-0050, dated July 27, 2010

Subject:

Notification Letter Designating Fermi 2 Balance of Plant Systems within the Cyber Security Rule Scope By Order dated March 19, 2009, 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 2) 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.

USNRC NRC-10-0055 Page 2 In Reference 3, NERC is requiring that the Fermi 2 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 Detroit Edison'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 in Reference 4 with the Fermi 2 Cyber Security Plan. This identification of SSCs will be available for inspection upon completion and will contain those SSCs as identified in of the Bright-Line Survey. Providing the requested information in this alternate matter satisfies the intent of the NERC letter.

In Reference 3, NERC is also requiring that each nuclear power plant submit a revised cyber security plan to the NRC for its review and approval. Therefore, Detroit Edison intends to supplement the Cyber Security Plan in Reference 4 by November 30, 2010, 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.

Should you have any questions or require additional information, please contact Mr.

Rodney W. Johnson of my staff at (734) 586-5076.

Sincerely, 4d + ( %iel

USNRC NRC-10-0055 Page 3 cc: NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 4, Region III Regional Administrator, Region III Supervisor, Electric Operators, Michigan Public Service Commission Michael Moon Director of Compliance Operations North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, NJ 08540 Jim Hughes North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, NJ 08540 Jim T. Wiggins Director, Office of Nuclear Security and Incident Response Two White Flint North (MS: 4D22A) 11555 Rockville Pike Rockville, MD 20852-2738 Eric Leeds Director, Office of Nuclear Reactor Regulation One White Flint North (MS: 13H16M) 11555 Rockville Pike Rockville, MD 20852-2738