ML110610522
| ML110610522 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/04/2011 |
| From: | Mahesh Chawla Plant Licensing Branch III |
| To: | Entergy Operations |
| chawla M, ADRO/DORL, 415-8371 | |
| References | |
| TAC ME4355 | |
| Download: ML110610522 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 4, 2011 Vice President, Operations Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
SUBJECT:
PALISADES NUCLEAR PLANT - REQUEST FOR ADDITIONAL INFORMATION
- CYBER SECURITY PLAN (TAC NO. ME4355)
Dear Sir:
By letter dated July 26,2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102110090), as supplemented by letters dated September 27,2010 (ADAMS Accession No. ML102710641) and November 30,2010 (ADAMS Accession No. ML103340386), Entergy Nuclear Operations, Inc. (ENO, the licensee), resubmitted a request to amend the Renewed Facility Operating License (RFOL) No. DPR-20 for Palisades Nuclear Plant (PNP).
In the letter dated July 26,2010, ENO submitted a new request for an amendment to the RFOL for PNP in accordance with provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.4 and 10 CFR 50.90. The proposed amendment requests Nuclear Regulatory Commission (NRC) approval of the PNP Cyber Security Plan (CSP), provides an implementation schedule, and revises the existing RFOL Physical Protection license condition to require ENO to fully implement and maintain in effect all provisions of the NRC-approved CSP for PNP.
On January 7, 2011, the NRC staff sent plant-specific requests for additional information (RAls) required for completing its technical review (ADAMS Accession No. ML110030661). In addition to this RAI, the NRC staff has determined that generic additional information is needed to complete the review of PNP CSP. This generic supplemental RAI, sent to the licensee via e mail on February 24,2011 (ADAMS Accession No. ML110590754) is enclosed and was reviewed in accordance with the guidance provided in 10 CFR Section 2.390. The NRC staff has determined that no security related or proprietary information is contained therein.
It is our understanding that the Nuclear Energy Institute and the Industry Cyber Security Task Force are working to ensure that the operating reactor licensees will submit consistent responses to these generic RAls to the NRC. On March 2, 2011, the Entergy staff indicated that a response to the RAI would be provided by April 4, 2011.
- 2 The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-8371.
Sincerely,
~ML--
Mahesh L. Chawla, Project Manager Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-255
Enclosure:
Request for Additional Information cc w/encl: Distribution via ListServ
REQUEST FOR ADDITIONAL INFORMATION (RAn REGARDING APPROVAL OF THE CYBER SECURITY PLAN ENTERGY NUCLEAR OPERATIONS, INC.
PALISADES NUCLEAR PLANT DOCKET NO. 50-255 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 licensee's 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 licensee's 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) staff's 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:
Enclosure
- 2 (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 licensee's proposed schedule and associated milestone dates which include the final completion date. It is the NRC's 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;
- 3 (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 Commission's policy determination.
Explain how the scoping of systems provided by licensee's CSP meets the requirements of 10 CFR 73.54 and the additional guidance provided by the NRC.
ML110610522 IRIISCPB/BC*
OFFICE LPL3-1/PM LPL3-1/LA BTuily CErlanger*
NAME MChawla 03/04/11 02/18/11 DATE 03/04111
- via memo dated 02/18/11
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