ML110610761

Request for Additional Information Regarding Approval of Cyber Security Plan

ML110610761
Person / Time
Site:	Seabrook
Issue date:	03/04/2011
From:	Geoffrey Miller Plant Licensing Branch 1
To:	Freeman P, O'Keefe M NextEra Energy Seabrook
Miller G, NRR/DORL/LPL1-2, 415-2481
References
TAC ME4453
Download: ML110610761 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 4, 2011 Mr. Paul Freeman Site Vice President clo Michael O'Keefe Seabrook Station NextEra Energy Seabrook, LLC P.O. Box 300 Seabrook, NH 03874

SUBJECT:

SEABROOK STATION UNIT NO.1 - REQUEST FOR ADDITIONAL INFORMATION REGARDING APPROVAL OF CYBER SECURITY PLAN (TAC NO. ME4453)

Dear Mr. Freeman:

By letter to the Nuclear Regulatory Commission (NRC) dated July 26,2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102140177 (non public>>, NextEra Energy Seabrook, LLC submitted its Cyber Security Plan (CSP) as supplemented by letters dated September 28,2010, and November 16, 2010 (ADAMS Accession Nos. ML102780426 and ML103270036, respectively (some enclosures non-public>>.

The July 26,2010, CSP is based on Nuclear Energy Institute (NEI) 08-09, Revision 6 which the NRC staff stated, in its letter dated May 5,2010 (ADAMS Accession No. ML101190371), would be acceptable for use by licensees to comply with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 73.54 with the exception of the definition of "cyber attack."

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with Mr. Michael O'Keefe of your staff on March 2, 2011, it was agreed that you would provide a response 30 days from the date of this letter. It should be noted that the response to RAI 2 will be used to support a license condition at each facility concerning the revised CSP implementation schedule containing the key milestone dates as discussed in 10 CFR 73.54.

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

P. Freeman -2 efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me before the response date at (301) 415-2481.

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G. Edward Miller, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-443

Enclosure:

As stated cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION RELATED TO CYBER SECURITY PLAN REQUEST SEABROOK STATION UNIT NO.1 DOCKET NOS. 50-443 Records Retention Title 10 of the Code of Federal Regulations (10 CFR) Section 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 (CSP) 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 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 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 req uired by 10 CFR 73. 54(h).

RAI-01: 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.

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. 10 CFR 73.54(a) 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 (DBT).

The completion of several key intermediate milestones, listed 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:

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

Enclosure

-2 Identify Critical Systems and CDAs, as described in Section 3.1.3, "Identification of Critical Digital Assets," of the CSP.

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.

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.

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.

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.

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.

Full implementation of the CSP for all safety, security, and emergency preparedness functions.

It is the NRC's intention to develop a license condition incorporating the revised CSP implementation schedule containing the key milestone dates.

RAI-02: 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.

Scope of Systems Section 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 DBT 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:

Safety-related and important-to-safety functions; Security functions; Emergency preparedness functions, including offsite communications; and

- 3 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.

RAI-03: Explain how the scoping of systems provided by the CSP meets the requirements of 10 CFR 73.54 and the additional guidance provided by the NRC, as referenced above.

ML110610761 OFFICE LPLI-2/PM NAME DATE