NLS2010089, Notification Letter Designating Balance of Plant Systems within the Cyber Security Rule Scope
| ML102770094 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/27/2010 |
| From: | O'Grady B Nebraska Public Power District (NPPD) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NLS2010089 | |
| Download: ML102770094 (4) | |
Text
N Nebraska Public Power District Always there when you need us NLS2010089 September 27, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001
Subject:
Notification Letter Designating Cooper Nuclear StationBalance of Plant Systems within the Cyber Security Rule Scope Cooper Nuclear Station, Docket No. 50-298, License No. DPR-46
Reference:
- 1. Letter from Jim Hughes (NERC) to Tony Eddleman (Nebraska Public Power District), "Request for Data or Information: Nuclear Power Plant 'Bright-Line' Survey," dated June 15, 2010
- 2. Letter from Michael Moon (NERC) to Tony Eddleman (Nebraska Public Power District), "NERC's Response to the Completed Bright Line Survey:
Cooper Nuclear Station," dated August 27, 2010
Dear Sir or Madam:
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 Nuclear Regulatory Commission (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.
In the Reference (2) letter, NERC is requiring that Cooper Nuclear 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.
Mandatory Reliability Standards for Critical Infrastructure Protection, order on clarification, Order No. 706-B, 126 FERC ¶ 61,229 (2009).
COOPER NUCLEAR STATION
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r4 P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5217 wwwnppd~com
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NLS2010089 Page 2 of 3 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 20, 2010, with the Cooper Nuclear Station Cyber Security Plan. This identification of SSCs will be available for inspection upon completion and will contain 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 each nuclear power plant submit a revised cyber security plan to the NRC for its review and approval. On or before November 30, 2010, Cooper Nuclear Station will supplement our Cyber Security Plan 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.
Should you have any questions concerning this letter, or require additional information, please contact David Van Der Kamp, Licensing Manager, at (402) 825-2904.
.. t ectfully, Brian J. O'Grady Vice President - Nuclear and Chief Nuclear Officer
/lb cc:
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
NLS2010089 Page 3 of 3 Eric Leeds Director, Office of Nuclear Reactor Regulation One White Flint North (MS: 13H 16M) 11555 Rockville Pike Rockville, MD 20852-2738 Regional Administrator USNRC - Region IV Cooper Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC - CNS NPG Distribution CNS Records
ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© 4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS@4 Correspondence Number: NLS2010089 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE On or before November 30, 2010, Cooper Nuclear Station will supplement our Cyber Security Plan submittal to clarify the scope of systems described in Section 2.1, "Scope and NLS2010089-01 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.
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 6/30/2011 implementation of the cyber security program.
NLS2010089-02 This identification of SSCs will be available for inspection upon completion and will contain those SSCs as identified in Attachment 1 of the Bright-Line Survey.
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