NOC-AE-10002602, Notification Letter Designating Balance of Plant Systems within the Cyber Security Rule Scope

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

ML102770095
Person / Time
Site:	South Texas
Issue date:	09/23/2010
From:	Bowman C South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-10002602, STI: 32747953
Download: ML102770095 (3)

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Nuclear Operating Company South Texas Pro/ect ElectricGeneatingStation PO Box 289 Wadsworth, Teas 77483 /

September 23, 2010 NOC-AE-1 0002602 STI: 32747953 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Docket Nos. STN 50-498, STN 50-499 Notification Letter Designating South Texas Project Balance of Plant Systems within the Cyber Security Rule Scope

Reference:

(1) Letters from Jim Hughes (NERC) to Mike Berg, South Texas Project, Unit 1 and Unit 2 "Request for Data or Information: Nuclear Power Plant 'Bright-Line' Survey," dated June 15, 2010 (2) Letter from Michael Moon (NERC) to Mike Berg, South Texas Project, Units 1 and 2, "NERC's Response to the Completed Bright Line Survey," dated August 27, 2010 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 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 ClP Reliability Standards.

In the Reference (2) letter, NERC is requiring that South Texas Project 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 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 1 Mandatory Reliability Standardsfor Critical InfrastructureProtection, order on clarificaition, Order No. 706-B, 126 FERC ¶ 61,229 (2009).

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NOC-AE-1 0002602 Page 2 of 3 of the cyber security program. The program is implemented in accordance with the schedule submitted to the NRC by letter dated July 27, 2010 with the South Texas Project 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 matter 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, STP Nuclear Operating Company 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.

There are no commitments in this letter.

Should you have any questions concerning this letter, or require additional information, please contact me at (361) 972-7454 or Marilyn Kistler at (361) 972-8385.

Charles T. Bowman General Manager, Oversight mk/

NOC-AE-1 0002602 Page 3 of 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 612 East Lamar Blvd, Suite 400 Arlington, Texas 76011-4125 Mohan C. Thadani U. S. Nuclear Regulatory Commission Mohan C. Thadani John Ragan Senior Project Manager Catherine Callaway U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8 G14) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Ed Alarcon Senior Resident Inspector Kevin Polio U. S. Nuclear Regulatory Commission Richard Pena P.O. Box 289, Mail Code: MNI16 City Public Service Wadsworth, TX 77483 C. M. Canady Peter Nemeth City of Austin Crain Caton & James, P.C.

Electric Utility Department 721 Barton Springs Road C. Mele Austin, TX 78704 City of Austin Michael Moon Richard A. Ratliff Director of Compliance Operations Texas Department of State Health North American Electric Reliability Corporation Services 116-390 Village Boulevard Princeton, NJ 08540 Alice Rogers Texas Department of State Health Services Jim Hughes Jim T. Wiggins North American Electric Reliability Corporation Director, Office of Nuclear Security and 116-390 Village Boulevard Incident Response Princeton, NJ 08540 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