ML13030A269
| ML13030A269 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/29/2013 |
| From: | Geoffrey Miller NRC/RGN-IV/DRS/EB-2 |
| To: | Reddemann M Energy Northwest |
| References | |
| IR-13-406 | |
| Download: ML13030A269 (8) | |
See also: IR 05000397/2013406
Text
January 29, 2013
Mr. Mark E. Reddemann
Chief Executive Officer
Energy Northwest
P.O. Box 968 (Mail Drop 1023)
Richland, WA 99352-0968
SUBJECT:
COLUMBIA 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 (05000397/2013406)
Dear Mr. Reddemann:
On April 22, 2013, the U.S. Nuclear Regulatory Commission (NRC) will begin an inspection of
Energy Northwest cyber security program implementation for Columbia Generating Station
using the guidance in Temporary Instruction 2201/004, Inspection of Implementation of Interim
Cyber Security Milestones 1-7. As previously discussed with members of your staff, the
inspection will be performed to assess and verify that the cyber security program interim
implementation milestones have been implemented in accordance with the regulatory
requirements of 10 CFR 73.54 and NRC-approved cyber security plans and implementation
schedules.
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 February 28, 2011, NEI provided a revised Template for the Cyber Security Plan
Implementation Schedule, for the purpose of providing licensees with a generic template to aid
in the development of their cyber security plan and implementation schedule. Based on NRC
review (ML110070348), the template was found acceptable to develop cyber security plans and
implementation schedules.
With a variety of valid operational and technical issues, full implementation dates varied among
the operating fleet of nuclear power reactors. The NRC staff worked with the nuclear industry to
devise seven interim implementation milestones to ensure a level of protection against cyber
security threats at each power reactor until full implementation of 10 CFR 73.54 is achieved. In
its NRC-approved implementation schedule, each licensee committed to meet these seven
interim milestones by December 31, 2012. These seven milestones are: (1) establishment of a
Cyber Security Assessment Team (CSAT); (2) identification and documentation of critical
systems (CSs) and critical digital assets (CDAs); (3) installation of protective devices between
UNITED STATES
NUCLEAR REGULATORY COMMI SSI ON
RE G IO N I V
1600 EAST LAMAR BLVD
ARL INGTON, TEXAS 76011-4511
M. Reddemann
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lower and higher security levels as described in the CSP; (4) implementation of access control
for portable mobile devices; (5) observation for and identification of obvious cyber related
tampering; (6) implementation of cyber security controls for CDAs that could adversely impact
the design function of target set equipment; and (7) implementing and commencing on-going
monitoring and assessment activities.
By letter dated July 22, 2010 (ML102150367), supplemented by letters dated September 27,
2010, (ML102780398), November 30, 2010 (ML103420058), and March 31, 2011
(ML111020378), Energy Northwest submitted a license amendment request, in part, for
approval of the Cyber Security Plan and Implementation Schedule for the Columbia Generating
Station as required by Title 10 of the Code of Federal Regulations (10 CFR) 73.54. Additionally,
on March 31, 2011 the licensee supplemented their Cyber Security Plan to address: 1) scope of
systems in response to the October 21, 2010, Commission decision; 2) records retention; and 3)
implementation schedule. The inspection of the interim cyber security program at Columbia
Generating Station will be limited to the verification of implementation of milestones one through
seven. 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. Milestone 8 will be inspected on a future date.
The schedule for the onsite inspection for Milestones 1 through 7 is as follows:
Information Gathering Visit: April 9 - 11, 2013
Milestone Inspection: April 22 - 26, 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 Columbia 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
March 18, 2013. The second group also lists information and possible areas for discussion
necessary to assist the inspectors during the inspection. It is requested this information be
available during the information gathering visit (April 9 - 11, 2013). The third group of requested
documents consists of those items that the inspectors will review, or need access to, during the
inspection. Please have this information available by the first day of the onsite inspection week
(April 22, 2013). The fourth group lists the information necessary to aid the inspectors in
tracking questions and answers identified as a result of the inspection. It is requested that this
information be provided to the lead inspector as the information is generated during the
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.
M. Reddemann
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The lead inspector is Sam Graves. We understand that our contact for this inspection is Dean
Kovacs of your organization. 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.
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 will be
available electronically for public inspection in the NRC Public Document Room or from the
Publicly Available Records (PARS) component of the NRCs Agencywide Document Access
and Management System (ADAMS). ADAMS is accessible from the NRC Website 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: 50-397
Licenses: NPF-21
Enclosure:
Cyber Security Temporary Instruction (TI) 2201/004
(Milestones 1 - 7) Request for Information
Electronic Distribution to Columbia Generating Station
M. Reddemann
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Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Stephen.Reynolds@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 (Jeremy.Groom@nrc.gov)
Resident Inspector (Mahdi.Hayes@nrc.gov)
Administrative Assistant (Crystal.Myers@nrc.gov)
Branch Chief, DRP/A (Wayne.Walker@nrc.gov)
Senior Project Engineer (Matt.Young@nrc.gov)
Project Engineer, DRP/D (Jason.Dykert@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Lauren.Gibson@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 (John.Cassidy@nrc.gov)
DRS/TSB STA (Dale.Powers@nrc.gov)
R:\\REACTORS\\COL\\CGS 2013406 RFI (TI 2202-004)
ADAMS: No Yes
SUNSI Review Complete
Reviewer Initials: STG
Publicly Available
Non-Sensitive
Non-publicly Available
Sensitive
SRI:DRS/EB2
C:DRS/EB2
STGraves
GBMiller
/RA/
/RA/
1/29/13
1/29/13
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
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Enclosure
CYBER SECURITY TEMPORARY INSTRUCTION (TI) 2201/004 (MILESTONES 1 - 7)
REQUEST FOR INFORMATION
Inspection Report: 05000397/2013406
Onsite Dates:
April 9 - 11, 2013 (Information Gathering Visit)
April 22 - 26, 2013 (Cyber Security TI Inspection)
Procedure:
Temporary Instruction 2201/004, Inspection of Implementation of Interim
Cyber Security Milestones 1 - 7
NRC Inspectors:
Sam Graves, Lead Inspector
(817) 200-1102
samuel.graves@nrc.gov
(817) 200-1507
Shiattin.makor@nrc.gov
Security Contractor: To Be Determined
I.
Information Requested Prior to the Information Gathering Visit
The following information is requested by March 18, 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 - Cyber Security Plan 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
Number
Title
Description
Revision
Status
No. 1
No. 2
No. 3
etc
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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.
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.
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Enclosure
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 (April 9 - 11,
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.
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. 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.
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Enclosure
(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.
4.
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.
III.
Information Requested to be Available on First Day of the Onsite Inspection
Week (April 22, 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.