ML110540732

E-mail, Request for Additional Information, Round 2, License Amendment Request for Cyber Security Plan

ML110540732
Person / Time
Site:	Arkansas Nuclear
Issue date:	02/23/2011
From:	Kalyanam N Plant Licensing Branch IV
To:	Mosher N, David Bice Entergy Operations
Kalyanam N, NRR/DORL/LPL4, 415-1480
References
TAC ME4424, TAC ME4425
Download: ML110540732 (4)

Text

From: Kalyanam, Kaly Sent: Wednesday, February 23, 2011 4:49 PM To: MOSHER, NATALIE B; BICE, DAVID B Cc: CLARK, ROBERT W; Burkhardt, Janet; Lent, Susan

Subject:

Request for Additional Information (RAI) on the Cyber Security Plan License Amendment Request (LAR)

Plant: Arkansas Nuclear One, Unit 1 and Unit 2 Docket No.: 50-313 and 50-368

Subject:

RAI on License Amendment Request, Cyber Security Plan TAC Nos.: ME4424 and ME4425 SUNSI Review Done: Yes. Publicly Available, Normal Release, Non-sensitive, From: N. Kalyanam To: Natalie Mosher / Robert Clark Attached is the second set of Cyber Security Plan (CSP) RAIs that the NRC staff has prepared. These RAIs apply to LAR submitted by Entergy Operations Inc. (the licensee) for Arkansas Nuclear One, Unit 1 and Unit 2, on July 9, 2010. A brief background on each RAI is provided below:

RAI-1 Records Retention This RAI addresses the apparent difference between the NRC staffs and the industrys interpretation of the CSP records retention regulation (10 CFR 73.54(h)). NSIR has been interacting with industrys Nuclear Security Working Group (NSWG) on this aspect of the rule over the past few months. Licensees are being asked to explain further how their submittal (based on NEI 08-09 Rev. 6) complies with the regulation.

RAI-2 Implementation Schedule This RAI requests licensees to resubmit their proposed implementation schedules to align with certain key milestones determined by the staff to be important in the implementation of the CSP. In addition, the staff is informing the licensee of its intention to develop a license condition incorporating the revised CSP implementation schedule. NSIR has been interacting with the NSWG on this issue for some time.

RAI-3 Scope of Systems This RAI requests licensees to clarify the scope of their CSP, in light of a recent Commission policy decision concerning the structures, systems, and components considered important-to-safety in the balance of plant systems. This issue has had much visibility in the industry, in part because multiple parties (NRC, FERC, NERC) are affected by this. The RAI identifies the key publicly available documents that have been issued by the Commission/staff.

Please advise the staff if you can provide the response in 30 days from the time of the receipt of this request.

Thanks Kaly Generic Request for Additional Information (RAI)

RAI 1: Records Retention Title 10 of the Code of Federal Regulations (10 CFR) Paragraph 73.54(c)(2) requires licensees to design a cyber security program to ensure the capability to detect, respond to, and recover from cyber attacks. Furthermore, 10 CFR 73.54(e)(2)(i) requires licensees to maintain a cyber security plan that describes how the licensee will maintain the capability for timely detection and response to cyber attacks. The ability for a licensee to detect and respond to cyber attacks requires accurate and complete records and is further supported by 10 CFR 73.54(h), which states that the licensee shall retain all records and supporting technical documentation required to satisfy the requirements of 10 CFR Section 73.54 as a record until the commission terminates the license for which the records were developed, and shall maintain superseded portions of these records for at least 3 years after the record is superseded, unless otherwise specified by the Commission.

The licensees Cyber Security Plan (CSP) in Section [4.13] states that Critical Digital Asset (CDA) audit records and audit data (e.g., operating system logs, network device logs) are retained for a period of time that is less than what is required by 10 CFR 73.54(h).

Explain the deviation from the 10 CFR 73.54(h) requirement to retain records and supporting technical documentation until the Commission terminates the license (or to maintain superseded portions of these records for at least 3 years) and how that meets the requirements of 10 CFR 73.54.

RAI 2: Implementation Schedule The regulation at 10 CFR 73.54, Protection of digital computer and communication systems and networks, requires licensees to submit a CSP that satisfies the requirements of this section for Commission review and approval. Furthermore, each submittal must include a proposed implementation schedule and the implementation of the licensees cyber security program must be consistent with the approved schedule. Paragraph 73.54(a) of 10 CFR requires licensees to provide high assurance that digital computer and communication systems and networks are adequately protected against cyber attacks, up to and including the design basis threat.

The completion of several key intermediate milestones (Items (a) through (g) below) would demonstrate progress toward meeting the requirements of 10 CFR 73.54. The Nuclear Regulatory Commission (NRC) staffs expectation is that the key intermediate milestones will be completed in a timely manner, but no later than December 31, 2012. The key CSP implementation milestones are as follows:

(a) Establish, train and qualify Cyber Security Assessment Team, as described in Section 3.1.2, Cyber Security Assessment Team, of the CSP.

(b) Identify Critical Systems and CDAs, as described in Section 3.1.3, Identification of Critical Digital Assets, of the CSP.

(c) Implement cyber security defense-in-depth architecture by installation of [deterministic one-way] devices, as described in Section 4.3, Defense-In-Depth Protective Strategies of the CSP.

(d) Implement the management, operational and technical cyber security controls that address attacks promulgated by use of portable media, portable devices, and portable equipment as described in Appendix D Section 1.19 Access Control for Portable and Mobile Devices, of Nuclear Energy Institute (NEI) 08-09, Revision 6.

(e) Implement observation and identification of obvious cyber related tampering to existing insider mitigation rounds as described in Appendix E Section 4.3, Personnel Performing Maintenance and Testing Activities, and Appendix E Section 10.3, Baseline Configuration of NEI 08-09, Revision 6.

(f) Identify, document, and implement cyber security controls to physical security target set CDAs in accordance with Section 3.1.6, Mitigation of Vulnerabilities and Application of Cyber Security Controls, of the CSP.

(g) Ongoing monitoring and assessment activities will commence for those target set CDAs whose security controls have been implemented, as described in Section 4.4, Ongoing Monitoring and Assessment, of the CSP (h) Full implementation of the CSP for all safety, security, and emergency preparedness functions.

Provide a revised CSP implementation schedule that identifies the appropriate milestones, completion dates, supporting rationale, and level of detail to allow the NRC to evaluate the licensees proposed schedule and associated milestone dates which include the final completion date. It is the NRCs intention to develop a license condition incorporating your revised CSP implementation schedule containing the key milestone dates.

RAI 3: Scope of Systems Paragraph 73.54(a) of 10 CFR requires licensees to provide high assurance that digital computer and communication systems and networks are adequately protected against cyber attacks, up to and including the design basis threat as described in 10 CFR 73.1. In addition, 10 CFR 73.54(a)(1) states that the licensee shall protect digital computer and communication systems and networks associated with:

(i) Safety-related and important-to-safety functions; (ii) Security functions; (iii) Emergency preparedness functions, including offsite communications; and (iv) Support systems and equipment which, if compromised, would adversely impact safety, security, or emergency preparedness functions.

Subsequent to the issuance of the cyber security rule, the NRC stated that 10 CFR 73.54 should be interpreted to include structures, systems, and components (SSCs) in the balance of plant (BOP) that have a nexus to radiological health and safety (Agencywide Documents Access and Management System (ADAMS) Accession No. ML103490344, dated November 19, 2010). The SSCs in the BOP are those that could directly or indirectly affect reactivity of a nuclear power plant and could result in an unplanned reactor shutdown or transient and are therefore, within the scope of important-to-safety functions described in 10 CFR 73.54(a)(1).

Furthermore, the NRC issued a letter to NEI dated January 5, 2011 (ADAMS Accession No. ML103550480) that provided licensees with additional guidance on one acceptable approach to comply with the Commissions policy determination.

Explain how the scoping of systems provided by [site/licensee]s CSP meets the requirements of 10 CFR 73.54 and the additional guidance provided by the NRC.