ML102360486

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Comment (1) of W. Martin, on Behalf of VC Summer, Comments Regarding DG-1249
ML102360486
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 08/18/2010
From: Martin W
SCANA Corp
To:
Rulemaking, Directives, and Editing Branch
References
75FR35508 00001, DG-1249
Download: ML102360486 (1)


Text

Rullemaking Resource From: wmartin@scana.com Sent: Wednesday, August 18, 2010 11:04 AM To: Rulemaking Resource

Subject:

Response from "Contact Us About Rulemaking-Ruleforum" Below is the result of your feedback form. It was submitted by

~{L (wmartin(cscana.com) on Wednesday, August 18, 2010 at 11:04:28

/

comments: VC Summer comments regarding DG-1 249:

1. The draft DG relies heavily on the Vendor having a secure development environment. The draft regulatory guide should recommend developing a procurement specification for Digital Safety Systems that meet the regulatory guide.
2. Section 2.1 Concepts Phase, last sentence states that the NRC has positions and guidance on data communication between non-safety and safety digital systems. The documents associated with these NRC positions and guidance should be listed.
3. RG 5.71 Security Control, C.12.5 Developer Security Testing, provides criteria for system developers and integrators of acquired CDAs to create, implement, and document a security test and evaluation plan. DG-1249 should align with the criteria in RG 5.71.

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