ML12325A914
| ML12325A914 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/20/2012 |
| From: | Geoffrey Miller NRC/RGN-IV/DRS/EB-2 |
| To: | Peter Dietrich Southern California Edison Co |
| References | |
| IR-13-405 | |
| Download: ML12325A914 (9) | |
See also: IR 05000361/2013405
Text
UNIT E D S TATE S
NUC LEAR RE GULATOR Y C OM MI S SI ON
R E G IO N I V
1600 EAST LAMAR BLVD
AR L I NGTON , TEXAS 7 60 1 1 - 4511
November 20, 2012
Mr. Peter Dietrich
Senior Vice President and
Chief Nuclear Officer
Southern California Edison Company
San Onofre Nuclear Generating Station
P.O. Box 128
San Clemente, CA 92674-0128
SUBJECT: SAN ONOFRE NUCLEAR GENERATING STATION - NOTIFICATION TO
PERFORM INSPECTION OF TEMPORARY INSTRUCTION 2201/004,
INSPECTION OF IMPLEMENTATION OF INTERIM CYBER SECURITY
MILESTONES 1-7, AND REQUEST FOR INFORMATION (05000361/2013405,
Dear Mr. Dietrich:
On February 25, 2013, the U.S. Nuclear Regulatory Commission (NRC) will begin an inspection
of Southern California Edison Companys cyber security program (CSP) implementation for
San Onofre Nuclear Generating Station, Units 2 and 3, using the guidance in Temporary
Instruction 2201/004, Inspection of Implementation of Interim Cyber Security Milestones 1-7.
The inspection will be performed to assess and verify your ability to meet the interim milestone
requirements of the NRCs Cyber Security Rule, Title 10, Code of Federal Regulations (CFR),
Part 73, Section 54, Protection of Digital Computer and Communication Systems and
Networks.
In accordance with 10 CFR 73.54, each nuclear power plant licensee was required to submit a
proposed cyber security plan and implementation schedule for NRC approval. On
December 14, 2009, by letter (ML093080517) to the Nuclear Energy Institute (NEI), the NRC
provided their expectations for the proposed implementation schedule. On January 5, 2011, by
letter (ML110060093) to the NRC, NEI issued an initial Template for the Cyber Security Plan
Implementation Schedule (ML110060097). On February 28, 2011, by letter (ML110600206) to
the NRC, NEI provided a revised, Template for the Cyber Security Plan Implementation
Schedule. The purpose of the letters attachment was to provide licensees with a generically
written template to develop their proposed CSP implementation schedule. Utilization of the
generic template required the licensee to make conforming changes to ensure the submitted
schedule accurately accounted for site-specific activities. Based on an NRC technical review
(ML110070348), the template was found acceptable to develop the licensees CSP
implementation schedule (i.e., Milestones 1 through 8).
Southern California Edison -2-
On July 22, 2010, as supplemented by letters, dated September 29, 2010, November 30, 2010,
and March 31, 2011, Southern California Edison submitted a cyber security plan for the
San Onofre Nuclear Generating Station, Units 2 and 3, following the template in NEI 08-09,
Revision 6, Cyber Security Plan for Nuclear Power Reactors, dated April 2010.
On March 31, 2011, Southern California Edison supplemented their cyber security plan to
address scope of systems in response to the October 21, 2010, Commission decision, records
retention issues, and implementation schedule concerns (ML11112A028). The NRC staff
considers the March 31, 2011, supplement as the approved schedule as required by 10 CFR 73.54.
The inspection of the interim cyber security program at San Onofre Nuclear Generating Station,
Units 2 and 3, will be limited to the verification of implementation of Milestones 1 through 7.
Temporary Instruction 2201/004, Inspection of Implementation of Interim Cyber Security
Milestones 1-7 provides a programmatic level review and verification of the site-specific
implementation of these milestones.
The schedule for the onsite inspection for Milestones 1 through 7 is as follows:
- Information Gathering Visit: February 12 - 14, 2013
- Milestone Inspection: February 25 - March 1, 2013
The purpose of the information gathering visit is to: (1) obtain information and documentation
needed to support the TI inspection; (2) become familiar with the San Onofre Nuclear
Generating Station Cyber Security Program, personnel, and plant layout; and (3) arrange
logistical details, such as office space, availability of knowledgeable staff, and to ensure
unescorted site access privileges.
In order to assure an efficient inspection, we have enclosed a request for information describing
documents needed to aid the inspectors in preparing for and conducting the temporary
instruction inspection. These documents have been divided into four groups. The first group
lists information necessary to aid the inspectors in planning for the TI inspection. It is requested
that this information be provided to the lead inspector via mail or electronically no later than
January 22, 2013. The second group also lists information and possible areas for discussion
necessary to assist the inspectors during the TI inspection. It is requested this information be
available during the information gathering visit (February 12 - 14, 2013). The third group of
requested documents consists of those items that the inspectors will review, or need access to,
during the TI inspection. Please have this information available by the first day of the onsite
inspection week (February 25, 2013). The fourth group lists the information necessary to aid
the inspectors in tracking questions and answers identified as a result of the TI inspection. It is
requested that this information be provided to the lead inspector as the information is generated
during the TI inspection. It is important that all of these documents are up to date and complete
in order to minimize the number of additional documents requested during the preparation
and/or the onsite portions of the TI inspection.
The lead inspector is Sam Graves. We understand that our contact for this inspection is
Ryan Pettus. If there are any questions about the inspection or the material requested, please
contact the lead inspector at (817) 200-1102, or via e-mail at samuel.graves@nrc.gov.
Southern California Edison -3-
This letter does not contain new or amended information collection requirements subject to the
Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection
requirements were approved by the Office of Management and Budget, control number 3150-
0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a
request for information or an information collection requirement unless the requesting document
displays a currently valid Office of Management and Budget control number.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document system
(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Geoffrey Miller, Chief
Engineering Branch 2
Division of Reactor Safety
Dockets: 50-361; 50-362
Enclosure:
Cyber Security Temporary Instruction (TI) 2201/004 (Milestones 1 - 7)
Request for Information
Electronic Distribution to San Onofre
Southern California Edison -4-
Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Art.Howell@nrc.gov)
DRP Director (Kriss.Kennedy@nrc.gov)
Acting DRP Deputy Director (Barry.Westreich@nrc.gov)
Acting DRS Director (Tom.Blount@nrc.gov)
Acting DRS Deputy Director (Jeff.Clark@nrc.gov)
Senior Resident Inspector (Greg.Warnick@nrc.gov)
Resident Inspector (John.Reynoso@nrc.gov)
Administrative Assistant (Heather.Hutchinson@nrc.gov)
Branch Chief, DRP/D (Ryan.Lantz@nrc.gov)
Senior Project Engineer (Nick.Taylor@nrc.gov)
Project Engineer, DRP/D (Brian.Parks@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Randy.Hall@nrc.gov)
Branch Chief, DRS/TSB (Ray.Kellar@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Technical Support Assistant (Loretta.Williams@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
OEMail Resource
RIV/ETA: OEDO (Cayetano.Santos@nrc.gov)
DRS/TSB STA (Dale.Powers@nrc.gov)
R:\ ADAMS ML12325A914
ADAMS: No Yes SUNSI Review Complete Reviewer Initials: GBM
Publicly Available Non-Sensitive
Non-publicly Available Sensitive
SRI::DRS/EB2 C: DRP/PBD C:DRS/EB2
STGraves RELantz GBMiller
11/19/12 11/20/12 11/20/12
/RA/ /RA/ /RA/
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
CYBER SECURITY TEMPORARY INSTRUCTION (TI) 2201/004 (MILESTONES 1 - 7)
REQUEST FOR INFORMATION
Inspection Report: 05000361/2013405, 05000362/2013405
Onsite Dates: February 12 - February 14, 2013 (Information Gathering Visit)
February 25 - March 1, 2013 (Cyber Security TI Inspection)
Procedure: Temporary Instruction 2201/004, Inspection of Implementation of Interim
Cyber Security Milestones 1 - 7
NRC Inspectors: Samuel Graves, Lead Inspector
(817) 200-1102
samuel.graves@nrc.gov
(817) 200-1384
nestor.makris@nrc.gov
Security Contractor, To Be Determined
I. Information Requested Prior to the Information Gathering Visit
The following information is requested by January 22, 2013. Electronic media is preferred.
Where information is provided that includes tables and/or lists of data or other such information,
please do not scan such tables and/or lists as images. The preferred file format is a searchable
portable document format (pdf) file on transportable media (CD/DVD). The information should
be indexed and hyperlinked to facilitate use. Please provide three copies of each CD submitted
(one for each inspector and for a cyber security contractor).
A. Cyber Security TI Documentation
1. Please provide a list of all documents necessary to support verification of the TI
requirements for each of the Cyber Security Milestones (1 through 7) identified in
Enclosure 3 - SONGS Cyber Security Plan Proposed Implementation Schedule. Identify
and describe each milestone in a separate folder on the media (e.g., Milestone 1,
Milestone 2, etc.). If the milestone description differs from those described in the
Temporary Instruction, provide a cross-reference between them. Provide each
milestone in a separate folder on the media (e.g., Milestone 1, Milestone 2, etc.). Each
milestone document shall be listed in a table as follows:
MILESTONE X (where X equals 1 through 7)
Document Title Description Revision Status
Number
No. 1
No. 2
No. 3
etc
-1- Enclosure
Based on the list of documents identified in I. A.1 above, for each milestone document
where the Status is identified as completed, place the completed document in its
associated folder and hyperlink the associated document number to the completed
document. For each document, the Status should be identified as not started, in-
progress or completed.
Please ensure the documents identified in I.A.1 above include the documents identified
below (I.A.2 - I.A.8) for MILESTONES 1 - 7 and are included in the I.A.1 table.
2. MILESTONE 1 - Provide the following documentation for the Cyber Security
Assessment Team (CSAT):
a. Procedures establishing the CSAT team.
b. List of CSAT members noting primary areas of responsibility.
c. Procedures detailing qualification requirements for CSAT members.
d. Supporting documentation that demonstrates each CSAT member meets the
requirements to fulfill their respective position on the team. For example, member
resumes; evaluation of previous education and experience; training required by your
implementing procedures and supporting documentation which shows training was
completed; or industry certifications).
3. MILESTONE 2 - Provide the following documentation:
a. List of plant systems noting which systems have been identified as critical systems
(CSs).
b. Procedure documenting the process by which CSs and Critical Digital Assets (CDAs)
are identified in accordance with your CSP.
4. MILESTONE 3 - Provide the following documentation:
a. Procedures establishing your cyber defensive architecture. Explain any variances
from your CSP and tracking documents for their correction.
b. Provide an overview of your cyber defensive architecture, preferably with overview
level diagrams showing the various levels and location of the subject deterministic
one-way device.
c. Provide details of the implementation of the subject deterministic one-way device.
5. MILESTONE 4 - Provide the following documentation:
Procedures implementing the security control Access Control for Portable and
Mobile Devices. Include any training material or promotional literature distributed to
staff associated with the control.
6. MILESTONE 5 - Provide the following documentation:
a. Procedures implementing the requirements described in Milestone 5.
-2- Enclosure
b. Training materials associated with the changes to plant programs associated with
Milestone 5
7. MILESTONE 6 - Provide the following documentation:
Procedures documenting the process by which technical cyber security controls have
been identified for those CDAs which require the implementation of technical security
controls for Milestone 6.
8. MILESTONE 7 - Provide the following documentation:
Procedures implementing the ongoing monitoring and assessment activities as
described in your CSP.
B. Cyber Security Supporting Documentation
1. Provide a copy of the current version of the updated safety analysis report (USAR),
Technical Specifications (TS), and technical requirements manual (TRM) or
equivalent.
2. Provide a copy of the current cyber security Health Report, if available.
3. Provide a copy of the current plant drawings used for operator training that provide
additional information on system operation, system operating parameters, setpoints,
etc. (e.g., some licensees refer to these drawings as Horse Notes) for identified
cyber security CSs, if available.
4. Provide operator training lesson plans and/or operator training aids for identified
cyber security CSs, if available.
II. Information Requested During the Information Gathering Visit (February 12 - 14,
2013)
The following information is requested to be provided to the inspectors during the onsite
information gathering visit. It is requested that the following information be provided on three
sets of searchable CD/DVDs.
A. General Information:
1. A listing of abbreviations and/or designators for plant systems;
2. Organizational chart for corporate and site personnel involved in establishing,
overseeing, and maintaining the Cyber Security Program and;
3. A phone list for licensee personnel.
-3- Enclosure
B. Facility Information:
1. Provide a presentation/discussion of your CSP, existing cyber security CSs, and
associated CDAs.
2. Provide a list and discussion of currently scheduled or planned cyber security related
modifications to be installed in the plant.
C. Specific Information Associated with the Milestones:
1. Provide a presentation/discussion of your CSP, existing cyber security CSs, and
associated CDAs.
2. MILESTONE 3 - Be prepared to provide an overview walkdown of the cyber
architecture within the plant including safety, security and emergency preparedness
related CDAs.
3. MILESTONE 6 - Be prepared to present information for target set CDAs including a
list of target set CDAs, and documentation of the process for identifying them.
4. MILESTONE 6 - For selected CDAs, be prepared to provide documentation for
each of the technical controls in Appendix D of NEI 08-09, Revision 6, the results of
reviews required under your CSP.
(a) For controls that are implemented, provide the procedures implementing the
control. Common controls for all CDAs may be provided in a separate list with the
procedures implementing each of them.
(b) For alternate controls that have been implemented, provide the documented
basis for employing alternative countermeasures, and the procedures implementing
the alternative measures.
(c) Where controls have been deemed unnecessary, provide the threat vector
analysis supporting the conclusion that the threat vector does not exist.
5. MILESTONE 7 - For the CDAs selected above, be prepared to provide
documentation for each of the technical controls in Appendix D of NEI 08-09,
Revision 6, and the results of immediate activities required under your CSP.
(a) For all controls that are implemented, provide the objective evidence that the
control is effective IAW your CSP. This may be combined with the documentation
provided for Milestone 6.
(b) Documentation for common controls for all CDAs may be provided in a separate
list with the procedures implementing each of them.
(c) Provide governing procedures and results of vulnerability scans performed to
comply with your CSP.
-4- Enclosure
III. Information Requested to be Available on First Day of the Onsite Inspection Week
(February 25, 2013)
Any updates to information previously provided.
IV. Information Requested to be Provided Throughout the Temporary Instruction
Inspection Assessment
Copies of the list of questions/documents requested identified by the inspector and the
status/resolution of the information requested (provided daily during the TI inspection to each
inspector).
If you have questions regarding the information requested, please contact the lead inspector,
Sam Graves, (817) 200-1102, or by email to samuel.graves@nrc.gov.
-5- Enclosure