ULNRC-05732, Notification Letter Designing Callaway Balance-of-Plant Systems within the Cyber Security Rule Scope

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

ML102710118
Person / Time
Site:	Callaway
Issue date:	09/27/2010
From:	Sandbothe S AmerenUE
To:	Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
ULNRC-05732
Download: ML102710118 (4)

Text

AmerenUE PO Box 620 Cal/away Plant Fulton, MO 65251 September 27,2010 ULNRC-05732 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 73.54 Ladies and Gentlemen:

~~ DOCKET NUMBER 50-483 wAmeren CALLAWAY PLANT UNIT 1 UE UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 NOTIFICATION LETTER DESIGNATING CALLAWAY BALANCE-OF-PLANT SYSTEMS WITHIN THE CYBER SECURITY RULE SCOPE

References:

1) Letter from Jim Hughes (NERC) to Kirit Shah, "Request for Data or Information: Nuclear Power Plant 'Bright-Line' Survey," dated June 15, 2010

2) Letter from Michael Moon (NERC) to Kirit Shah, "NERC's Response to the Completed Bright Line Survey," dated August 27,2010 By Order dated March 19, 2009 1, 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.

Per the Reference (2) letter, NERC is requiring AmerenUE (Union Electric Company) to provide the NRC with a letter identifying all Callaway Plant balance-of-1 Mandatory Reliability Standards for Critical Infrastructure Protection, order on clarification, Order No. 706-B, 126 FERC, 61,229 (2009).

a subsidiary of Ameren Corporation

ULNRC-05732 September 27,2010 Page 2 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, the 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 that was submitted along with the Callaway Cyber Security Plan to the NRC by letter dated August 12, 2010.

This identification of SSCs will be available for inspection upon completion and will contain those SSCs identified in Attachment 1 of the Bright-Line Survey. Providing the requested information in this alternate manner satisfies the intent of the NERC letter.

As noted in the Reference (2) letter, NERC is also requiring each nuclear power plant licensee to submit a revised cyber security plan to the NRC for its review and approval. Accordingly, on or before November 30,2010, AmerenUE (Union Electric) will supplement the Cyber Security Plan for Callaway Plant to clarify the scope of systems described in Section 2.1, "Scope and Purpose." Specifically, 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.

No commitments are being made to the NRC by this letter. Should you have any questions concerning this letter, or require additional information, please contact Scott Maglio at (573) 676-8719.

Sincerely,

~~~

Scott Sandbothe Manager, Plant Support EMF/nls

ULNRC-05732 September 27,2010 Page 3 cc: Mr. Elmo E. Collins, Jr.

Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Senior Resident Inspector Callaway Resident Office U. S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)

Senior Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8G 14 Washington, DC 20555-2738 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

ULNRC-05732 September 27,2010 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed. )

Electronic distribution for the following can be made via Responses and Reports ULNRC Distribution:

A. C. Heflin F. M. Diya L. S. Sandbothe C. O. Reasoner III S.M.Maglio T. B. Elwood S. L. Gallagher A. M. Lowry T. L. Woodward (NSRB)

Mr. Ron Reynolds, Director (SEMA)

Mr. Edward Gray, Senior REP Planner (SEMA)

Mr. John Campbell, REP Planner (SEMA)

Ms. Diane M. Hooper (WCNOC)

Mr. Tim Hope (Luminant Power)

Mr. Ron Barnes (APS)

Mr. Tom Baldwin (pG&E)

Mr. Wayne Harrison (STPNOC)

Ms. Linda Conklin (SCE)

Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Mr. Dm Buntin (DNR)