GO2-10-143, 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

ML102780398
Person / Time
Site:	Columbia
Issue date:	09/27/2010
From:	Atkinson D Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
GO2-10-143
Download: ML102780398 (2)

Text

ENERGY Dale K. Atkinson Vice President, Operational Support P.O. Box 968, PE03 NORTHW ESTPh. Richland, WA 99352-0968 509.377.4302 509.377.4098 dkatkinson @energy-northwest.corn September 27, 2010 G02-10-143 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 NOTIFICATION LETTER DESIGNATING COLUMBIA GENERATING STATION BALANCE OF PLANT SYSTEMS WITHIN THE CYBER SECURITY RULE SCOPE

References:

1) Mandatory Reliability Standards for Critical Infrastructure Protection, order on clarification, Order No. 706-B, 126 FERC T 61,229 (2009)

2) Letter from Jim Hughes (NERC) to Douglas W. Coleman (Energy Northwest), "Request for Data or Information: Nuclear Power Plant

'Bright-Line' Survey," dated June 15, 2010

3) Letter from Michael Moon (NERC) to Don Gregoire (Energy Northwest),

"NERC's Response to the Completed Bright Line Survey, Columbia Generating Station," dated August 27, 2010

4) Columbia Generating Station Response to "Request-for Data or Information: Nuclear Power Plant 'Bright-Line' Survey," dated July 15, 2010

Dear Sir or Madam:

By Order dated March 19, 2009 (Reference 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 2) 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.

SooIA

NOTIFICATION LETTER DESIGNATING COLUMBIA GENERATING STATION BALANCE OF PLANT SYSTEMS WITHIN THE CYBER SECURITY RULE SCOPE Page 2 In Reference 3, NERC is requiring that Columbia Generating Station (CGS) 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 (Reference 4), 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 submitted to the NRC by letter dated July 22, 2010 with the CGS 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. By providing the requested information in this alternate matter, the intent of the NERC letter is satisfied.

In Reference 3, 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, Energy Northwest will supplement the CGS 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 DW Gregoire, Licensing Supervisor, at (509) 377-8616.

Respectfully, DK Atkinson Vice President, Operational Support cc: NRC Region IV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C RN Sherman - BPA/1 399 WA Horin - Winston & Strawn JT Wiggins - NRC NRR EJ Leeds - NRC NRR M Moon - NERC J Hughes - NERC