ML110630095

Generic Request for Additional Information Email, License Amendment Request to Revise License Condition and Approve Cyber Security Plan Based on NEI 08-09, Revision 3

ML110630095
Person / Time
Site:	Grand Gulf
Issue date:	03/04/2011
From:	Wang A Plant Licensing Branch IV
To:	Rolonda Jackson, Perino C Entergy Operations
Wang, A B, NRR/DORL/LPLIV, 415-1445
References
TAC ME4379
Download: ML110630095 (141)

Text

From: Wang, Alan Sent: Friday, March 04, 2011 9:07 AM To: Perino, Christina; JACKSON, RITA R Cc: ENGLAND, LESLEY A; Lent, Susan; Burkhardt, Janet

Subject:

Grand Gulf Nulclear Power Station Cyber Security Plan Request for Additional Information (ME4379}

Christina and Rita, By letter dated July 22, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102070558), Entergy Operations, Inc (Entergy, the licensee) submitted Entergy Letter GNRO-2010/00047, Operating License Amendment Withdrawal and Request - Grand Gulf Nuclear Station Cyber Security Plan, which superseded the previous submittal on May 24, 2010. Entergy submitted a request for revision to the Facility Operating License No. NPF-29 and review and approval of the Cyber Security Plan (CSP) for the Grand Gulf Nuclear Station, Unit 1 (GGNS), in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 73.54, Protection of digital computer and communication systems and networks.

The NRC staff has determined that the following additional information is needed to complete our review of this amendment. This request for additional information (RAI) was discussed with Mr. Les England of your staff on March 2, 2011, and it was agreed that a response would be provided by April 4, 2011. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1445 or via e-mail at Alan.Wang@nrc.gov. The NRC staff has determined that no security-related or proprietary information is contained therein.

1. Records Retention The regulations in 10 CFR 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 CSP 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 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).

Please 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.

2. Implementation Schedule The regulations in 10 CFR 73.54 require 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 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.

Please 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.

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 (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.

Please explain how the scoping of systems provided by CSP for GGNS, meets the requirements of 10 CFR 73.54 and the additional guidance provided by the NRC.