WM 10-0026, Notification Letter Designating Balance of Plant Systems within the Cyber Security Rule Scope
| ML102780414 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/24/2010 |
| From: | Matthew Sunseri Wolf Creek |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response |
| References | |
| WM 10-0026 | |
| Download: ML102780414 (9) | |
Text
WG@LF CREEK NUCLEAR OPERATING CORPORATION Matthew W. Sunseri President and CEO September 24, 2010 WM 10-0026 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Reference:
- 1)
Letter dated June 15, 2010, from J. Hughes, NERC, to M.
Gammon, KCPL, "Request for Data or Information: Nuclear Power Plant 'Bright-Line' Survey"
- 2)
Letter WO 10-0048, dated July 19, 2010, from S. E. Hedges, WCNOC, to USNRC
- 3)
Letter dated August 27, 2010, from M. Moon, NERC, to M.
Gammon, KCPL, "NERC's Response to the Completed Bright Line Survey: Wolf Creek Generating Station"
Subject:
Docket No. 50-482:
Notification Letter Designating Wolf Creek Generating Station Balance of Plant Systems within the Cyber Security Rule Scope Gentlemen:
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 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.
'Mandatory Reliability Standards for Critical Infrastructure Protection, order on clarification, Order No. 706-B, 126 FERC ¶ 61,229 (2009).
P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET
WM 10-0026 Page 2 of 3 In Reference 3, NERC is requiring that Wolf Creek Nuclear Operating Corporation (WCNOC) provide the NRC with a letter identifying all balance of plant Systems, Structures, and Components (SSCs) considered important to safety at Wolf Creek Generating Station (WCGS) with respect to the NRC's cyber security regulation.' Enclosed is a copy of WCNOC Letter WM 10-0021, dated July 16, 2010, from M. Sunseri, WCNOC, to B. Jones, Westar, which provided WCNOC's "Bright-Line" Survey Response, and includes an attachment that identifies all of the balance of plant SSCs at WCGS that are important to safety, and thus, are within the scope of 10 CFR 73.54. Providing a copy of WCNOC Letter WM 10-0021 and its attachment satisfies the intent of the NERC letter (Reference 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 will be implemented in accordance with the schedule submitted to the NRC by Reference 2, which submitted a request for an amendment to Renewed Facility Operating License No. NPF-42 for the Wolf Creek Generating Station (WCGS) and requested Commission review and approval of a cyber security plan in accordance with 10 CFR 73.54. This identification of SSCs will be available for inspection upon completion and will contain those SSCs as identified in the attachment of WCNOC's "Bright-Line" Survey Response, WM 10-0021 (Enclosed).
Providing the requested information in this alternate manner satisfies the intent of the NERC letter.
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, WCNOC will supplement the WCGS 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.
The Attachment provides a List of Regulatory Commitments made in this submittal.
If you have any questions concerning this matter, please contact me at (620) 364-4008, or Mr.
Richard D. Flannigan at (620) 364-4117.
Sincerely, Matthew W. Sunseri MWS/rlt Attachment Enclosure
WM 10-0026 Page 3 of 3 cc:
E. E. Collins (NRC), w/a, w/e G. B. Miller (NRC), w/a, wie B. K. Singal (NRC), w/a, w/e Senior Resident Inspector (NRC), w/a, wie Mark Barbee, (KepCo), w/a, w/e Vice President of Engineering Kansas Electric Power Cooperative 600 SW Corporate View Topeka, KS 66615 Michael Gammon, (KCP&L), w/a, w/e Kansas City Power & Light Mail Code 801-2A PO Box 418679 Kansas City, MO, 64141 Jim Hughes, (NERC), w/a, w/e North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, NJ 08540 Bo Jones, (Westar), w/a, w/e Director, NERC Compliance Westar Energy 818 S. Kansas Avenue - 10th Floor Topeka, KS 66612 Eric Leeds, (NRC), w/a, w/e Director, Office of Nuclear Reactor Regulation One White Flint North (MS: 13H16M) 11555 Rockville Pike Rockville, MD 20852-2738 Michael Moon, (NERC), w/a, w/e Director of Compliance Operations North American Electric Reliability Corporation 116-390 Village Boulevard Princeton, NJ 08540 Jim T. Wiggins, (NRC), w/a, w/e Director, Office of Nuclear Security and Incident Response Two White Flint North (MS: 4D22A) 11555 Rockville Pike Rockville, MD 20852-2738
Attachment to WM 10-0026 Page 1 of 1 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by WCNOC in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
Please direct questions regarding these commitments to Mr.
Richard Flannigan at (620) 364-4117.
Regulatory Commitments Due Date / Event Wolf Creek Nuclear Operating Corporation (WCNOC) will November 30, 2010 supplement the Wolf Creek Generating Station (WCGS) 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 Systems, Structures, and Components (SSCs) that will be included in the scope of the cyber security program.
Enclosure to Letter WM 10-0026 4 Pages
W LF CREEK
'NUCLEAR OPERATING CORPORATION Matthew W. Sunseri President and Chief Executive Officer July 16, 2010 WM 10-0021 Mr. Bo Jones Director of NERC Compliance Westar Energy Inc.
818 S. Kansas Ave.
P.O. Box 889 Topeka, Kansas 66601
Reference:
- 1. NEI Letter dated June 18, 2010, from M. S. Fertel, NEI to G. B.
Jaczko, NRC, & J. Wellinghoff, FERC
- 2. Letter dated June 15, 2010 from J. Hughes, NERC, to M.
Gammon KCPL
Subject:
Wolf Creek Nuclear Operating Corporations Endorsement of NEI position and Corresponding "Bright-Line" Survey Response Mr. Jones, This letter is to inform you of Wolf Creek Nuclear Operating Corporation's (WCNOC) official position with respect to the North American Electric Reliability Corporation's (NERC) "Bright Line" survey provided by reference 2, and reference 1 the Nuclear Energy Institute (NEI) letter to the Chairmen of the Nuclear Regulatory Commission. (NRC) and Federal Energy Regulatory Commission (FERC).
WCNOC fully endorses the NEI position described in reference 1 and has completed the corresponding "Bright Line" survey consistent with the discussion in that letter. This response is in alignment with all other nuclear utilities.
WCNOC has attached the survey response for Wolf Creek Generating Station (WCGS),
including site-by-site-items listed -in-the-miscellaneous and-power sections of the-System-List, that is consistent with the position described in reference 1.
P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 An Equal Opportunity Employer M/F/HCNET
WMAO--0021 Page 2 of 2 If you have any questions concerning this matter, please contact me at (620) 364-4008, or Mr.
Richard D. Flannigan, Manager Regulatory Affairs at (620) 364-4117.
Sincerely, Matthew W. Sunseri MWS/rlt
Attachment:
WCNOC Response to NERC "Bright Line" Survey
Attachment to WM 10-0021 Page 1 of 2 Survey Question 1: Does Attachment I, as written, include all SSCs in the balance of plant of your power plant that could impact the reliable delivery of electricity to the Bulk Power System, but do not impact safety functions, security functions, or emergency response functions as defined in 10 C.F.R. Section 73?
YES NO0-If the answer to this question is "no", please make any corrections to the existing systems list in Attachment I to include all applicable systems. Additionally, please identify those components that should be excluded from the systems identified in Attachment I that would have functions as defined in 10 C.F.R. Section 73. Please include an explanation justifying your changes.
The following proposed Nuclear Industry Response provides the justification for excluding the identified components or systems:
The NRC Cyber Security Rule, 10 CFR 73.54, requires, in part:
(a)(1)
The licensee shall protect digital computer and communication systems and networks associated with:
(i)
Safety-related and important-to safety functions; And (iv)
Support systems and equipment which, if compromised, would adversely impact safety, security, or emergency preparedness functions.
(2)
The licensee shall protect the systems and networks identified in paragraph (a)(1) of this section from cyber attacks...
We interpret these provisions to include all systems that could impact reactivity (i.e., cause a reactor shutdown or change in reactor power).
The majority of the systems in Table I may support the reliability of the bulk-power system, but could also directly or indirectly impact reactivity. These systems would therefore fall under the scope of the NRC Rule. Additionally, 10 CFR 73.54 (a)(2) requires licensees to protect systems, not components. As such, if a plant system contains one or more components that could impact reactivity, then the system falls under the scope of 10 CFR 73.54.
We have not identified systems in the Balance of Plant that could impact bulk-power reliability that do not also have an impact on reactivity.
Comment on the systems provided in Attachment 2 is not necessary as this identification of systems will be performed during the implementation of the NRC approved cyber security plan. The cyber security plan is executed in accordance with the implementation schedule submitted to the NRC in compliance with the requirements of 10 CFR 73.54.
t, Attachment to WM 10-0021 Page 2 of 2 NERC Survey System List Impact Reactivity - Subject to 10 CFR 73.54 Water Systems
" Heater/Drain System Yes
" Condensate System Yes
" Water Cleanup System, Chemical Treatment No
" Circulating Water.
Yes
. Non-Safety Cooling Water Yes
" Extraction Steam Yes
" Gland Steam Yes Generator
" Generator Exciter and Control Systems Yes
" Generator and Support System Yes
" Electro-hydraulic System - (Excluding Fast Acting Solenoid Valve)
Yes No - for C02 and Nitrogen systems, except, Yes -
- Nitrogen, C02, and Hydrogen Systems for Hydrogen system.
- Isophase Bus Duct Cooling Yes
- Lube Oil System Yes Miscellaneous
" Air Removal System (Pressurized Water Reactor)
Yes
- Station and Service Air System Yes
" Computer systems and SSCs feeding Energy Management System (EMS)
No Power No - for all equipment except, Yes - for all equipment downstream of the main transformers
" Switchyard out to the first breaker.
" Non-Safety Related Power Distribution (AC/DC)
Yes