ML102730183

(SONGS) Units 2 and 3 - Notification Letter Designating Balance of Plant Systems within the Cyber Security Rule Scope

ML102730183
Person / Time
Site:	San Onofre
Issue date:	09/29/2010
From:	Onge R, St.Onge R Southern California Edison Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
Download: ML102730183 (2)

Text

~\J SOUTHERN CALIFORNIA Richard J. St. Onge i'$ EDISON Director Nuclear Regulatory Affairs An EDISON INTERNATIONAL Company September 29, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 Facility Operating License Nos. NPF-10 and NPF-15 Docket Nos. 361 and 50-362

Subject:

Notification Letter Designating San Onofre Nuclear Generating Station (SONGS)

Units 2 and 3 Station Balance of Plant Systems within the Cyber Security Rule Scope

References:

(1) Letter from Jim Hughes (NERC) to Kenya Streeter, dated June 15, 2010,

Subject:

San Onofre Nuclear Generating Station Units 2 and 3, "Request for Data or Information: Nuclear Power Plant 'Bright-Line' Survey" (2) Letter from Michael Moon (NERC) to Kenya Streeter, dated August 27, 2010;

Subject:

"NERC's Response to the Completed Bright Line Survey" (3) Letter from R. T. Ridenoure (SCE) to Document Control Desk (NRC), dated July 22, 2010;

Subject:

San Onofre Nuclear Generating Station (SONGS)

Units 2and 3, "Withdrawal and Resubmittal of the SONGS Units 2 and 3 Cyber Security Plan, Docket Nos. 50-361 and 50-362" 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 e-quipment 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 "Brlqht-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.

In the Reference (2) letter, NERC is requiring that San Onofre Nuclear Generating Station 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, 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 1 Mandatory Reliability Standards for Critical Infrastructure Protection, order on clarification, Order No. 706-B, 126 FERC ~ 61,229 (2009).

P.O. Box 128 San Clemente, CA 92674

Document Control Desk September 29, 2010 SSCs subject to the requirements of 10 CFR 73.54 will be developed during the implementation of the Cyber Security Program.. The program will be implemented in accordance with the schedule submitted to the NRC by letter dated July 22, 2010 with San Onofre Nuclear Generating Station (SONGS) Units 2 arid 3 Cyber Security Plan (Reference 3). This identification of SSCs will be available for inspection upon completion and will contain those SSCs as identified in Attachment l' 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 each nuclear power plant submit a revised cyber security plan to the NRC for its review and approval. On or before November 30, 2010, Southern California Edison (SCE) will supplement our Cyber Security Plan 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 concerning this letter, or require additional information, please contact Linda Conklin at (949) 368-9443.

Sincerely,

~

cc: E. E. Collins, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, San Onofre Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 Michael Moon, Director of Compliance Operations, North American Electric Reliability Corporation Jim Hughes, North American Electric Reliability Corporation Jim T. Wiggins, Director, NRC Office of Nuclear Security and Incident Response Eric Leeds, Director, Office of Nuclear Reactor Regulation