ML102720411

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

ML102720411
Person / Time
Site:	Pilgrim
Issue date:	09/22/2010
From:	Jeffery Lynch Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
2.10.042
Download: ML102720411 (5)

Text

SEn tergy Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 September 22, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 Notification Letter Designating Pilgrim Nuclear Power Station Balance-of-Plant Systems within the Cyber Security Rule Scope

Reference:

1. Letter from Jim Hughes (NERC) to Entergy, Pilgrim Nuclear Power Station, "Request for Data or Information: Nuclear Power Plant

'Bright-Line' Survey," dated June 14, 2010

2. Letter from Michael Moon (NERC) to Pilgrim Nuclear Power Station,

"'NERO's Response to thc Completed Bright-Line Survey,"

dated August',27,.2010 -.

LETTER NUMBER: 2.10.042

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.CI.P R.eliability 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'Standardsfor CriticalInfrastructureProtection, order on clarification, Order No. 706-B, 1,26 FERC ¶ 61,229 (2009).

Entergy Nuclear Operations, Inc. Letter Number: 2.10.042 Pilgrim Nuclear Power Station Page 2 In the Reference 2 letter, NERC is requiring that Pilgrim Nuclear Power Station (Pilgrim) 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 15, 2010 (Ltr. No. 2.10.034) with Pilgrim'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 letter, NERC is also requiring that eachnuclear 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 Pilgrim Cyber Security Plant 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 at 508-830-8403.

Sincerely, Joseph R. Lynch Manager, Licensing

Attachment:

List of Regulatory Commitments

Entergy Nuclear Operations, Inc. Letter Number: 2.10.042 Pilgrim Nuclear Power Station Page 3 cc:

Regional Administrator, Region 1 Mr. Richard Guzman, Project Manager U.S. Nuclear Regulatory Commission Plant Licensing Branch I-1 475 Allendale Road Division of Operator Reactor Licensing King of Prussia, PA 19406-1415 Office of Nuclear Reactor Regulation (w/o Attachments) U.S. Nuclear Regulatory Commission One White Flint North O-8C2 11555 Rockville Pike Rockville, MD 20852 Mr. Michael Moon Sr. Resident Inspector, Pilgrim Station Director of Compliance Operations North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, NJ 08540

Attachment to Letter No. 2.10.042 List of Regulatory Commitments

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

Entergy will supplement our Cyber X November 30, 2010 Security Plan submittal to clarify the scope of systems described in Section 2.1, "Scope and Purpose" to include the following language, "The scope of 10 CFR 73.54 includes, in part, balance-of-plant equipment that, if compromised, could cause a reactivity event."

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.

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