ML14338A910
| ML14338A910 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/10/2014 |
| From: | Miksa J Entergy Nuclear Operations |
| To: | Jennivine Rankin Plant Licensing Branch III |
| References | |
| MF3303 | |
| Download: ML14338A910 (9) | |
Text
1 NRR-PMDAPEm Resource From:
MIKSA, JAMES P [jmiksa@entergy.com]
Sent:
Monday, November 10, 2014 10:58 AM To:
Rankin, Jennivine Cc:
ERICKSON, JEFFREY S; Hardy, Jeffery A; GUSTAFSON, OTTO W
Subject:
FW: Draft Safety Evaluation for LAR for Approval of Revised Cyber Security Plan Implementation Schedule (TAC No MF3303)
Attachments:
New Draft SE for SR review.docx Follow Up Flag:
Follow up Flag Status:
Flagged
- Jennie, Palisades has reviewed the attached draft Safety Evaluation for the subject License Amendment Request and agrees with the NRC staffs determination that none of the information contained in the attached Draft SE is security-related information. Palisades is also in agreement with the 30 day implementation time. Palisades has no further comments in the Draft SE.
Jim Miksa, Regulatory Assurance Engineer Entergy Palisades Plant Work: (269) 764-2945 Cell: (269) 767-2337 From: ERICKSON, JEFFREY S Sent: Friday, November 07, 2014 11:47 AM To: MIKSA, JAMES P; Hardy, Jeffery A
Subject:
FW: Draft Safety Evaluation for LAR for Approval of Revised Cyber Security Plan Implementation Schedule (TAC No MF3303) fyi From: Rankin, Jennivine [1]
Sent: Friday, November 07, 2014 9:53 AM To: ERICKSON, JEFFREY S
Subject:
Draft Safety Evaluation for LAR for Approval of Revised Cyber Security Plan Implementation Schedule (TAC No MF3303)
THE ATTACHMENT MAY CONTAIN SECURITY-RELATED INFORMATION AND SHOULD BE PROCESSED ACCORDINGLY.
- Jeff, Please see the attached copy of the Draft Safety Evaluation (SE) for the subject License Amendment Request. The information in section 3.1 of the Draft SE as well as the Milestone 8 implementation date was identified as security-related information in your application dated December 30, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13364A328). The NRC staff does not consider this information to be security-related and the information is likely to be included in the final staff
2 SE which will be publically available. Please review the Draft SE and confirm by e-mail that you agree with the NRC staffs determination and none of the information contained in the attached Draft SE is security-related information.
As discussed with you previously, I understand that a implementation time was not specifically requested. I have inserted a 30 day implementation time. Please let me know if this is problematic.
- Thanks, Jennie Jennie Rankin, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Hearing Identifier:
NRR_PMDA Email Number:
1740 Mail Envelope Properties (1177E005471F6A45B7EE5747CC3DE9BB36192004)
Subject:
FW: Draft Safety Evaluation for LAR for Approval of Revised Cyber Security Plan Implementation Schedule (TAC No MF3303)
Sent Date:
11/10/2014 10:58:03 AM Received Date:
11/10/2014 10:58:52 AM From:
MIKSA, JAMES P Created By:
jmiksa@entergy.com Recipients:
"ERICKSON, JEFFREY S" <JERICKS@entergy.com>
Tracking Status: None "Hardy, Jeffery A" <jhardy@entergy.com>
Tracking Status: None "GUSTAFSON, OTTO W" <ogustaf@entergy.com>
Tracking Status: None "Rankin, Jennivine" <Jennivine.Rankin@nrc.gov>
Tracking Status: None Post Office:
JDCXMETSP002.etrsouth.corp.entergy.com Files Size Date & Time MESSAGE 2316 11/10/2014 10:58:52 AM New Draft SE for SR review.docx 33000 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
Follow up
DRAFT SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 253 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-20 ENTERGY NUCLEAR OPERATIONS, INC.
PALISADES NUCLEAR PLANT DOCKET NO. 50-255
1.0 INTRODUCTION
By letter dated December 30, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13364A328), as supplemented by letter dated May 22, 2014 (ADAMS Accession No. ML14142A296), Entergy Nuclear Operations, Inc. (ENO, the licensee) requested a change to the renewed facility operating license for Palisades Nuclear Plant (PNP).
The proposed change would revise the date of Cyber Security Plan (CSP) Implementation Schedule Milestone 8 and Paragraph 2.E in the renewed facility operating license. Milestone 8 of the CSP implementation schedule concerns the full implementation of the CSP. Portions of the letter dated December 30, 2013, contain sensitive unclassified non-safeguards (security-related) information and, accordingly, those portions are withheld from public disclosure.
The supplement dated May 22, 2014, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on April 15, 2014 (79 FR 21297).
2.0 REGULATORY EVALUATION
The U.S. Nuclear Regulatory Commission (NRC) staff approved the licensees existing CSP implementation schedule for PNP by letter dated July 28, 2011, Amendment No. 243 (ADAMS Accession No. ML111801243), concurrent with the incorporation of the CSP into the facilitys current licensing basis. By letter dated December 30, 2013, the licensee requested to change Milestone 8 of the CSP implementation schedule. The NRC staff considered the following regulatory requirements and guidance in its review of the license amendment request (LAR) to modify the existing CSP implementation schedule:
Title 10 of the Code of Federal Regulations (10 CFR), Section 73.54, Protection of digital computer and communication systems and networks, which states, in part, Each [CSP] submittal must include a proposed implementation schedule.
Implementation of the licensees cyber security program must be consistent with the approved schedule.
The licensees renewed facility operating license includes a license condition that requires the licensee to fully implement and maintain in effect all provisions of the Commission-approved CSP.
Review criteria provided by the NRC staffs internal memorandum, Review Criteria for Title 10 of the Code of Federal Regulations Part 73.54, Cyber Security Implementation Schedule Milestone 8 License Amendment Requests, dated October 24, 2013 (ADAMS Accession No. ML13295A467), to be considered for evaluating licensees requests to postpone their cyber security program implementation date (commonly known as Milestone 8).
3.0 TECHNICAL EVALUATION
3.1 Licensees Requested Change The NRC staff issued Amendment No. 243 to Renewed Facility Operation License DPR-20 for PNP by letter dated July 28, 2011. This amendment approved the CSP and associated implementation schedule. The implementation schedule was based on a template prepared by the Nuclear Energy Institute (NEI), which was transmitted to the NRC by letter dated February 28, 2011 (ADAMS Accession No. ML110600206). By letter dated March 1, 2011, the NRC staff found the NEI template acceptable for licensees to use to develop their CSP implementation schedules (ADAMS Accession No. ML110070348). The licensees proposed implementation schedule for the Cyber Security Program identified completion dates and bases for the following eight milestones:
- 1) Establish the Cyber Security Assessment Team (CSAT);
- 3) Install deterministic one-way devices between lower level devices and higher level devices;
- 4) Implement the security control Access Control For Portable And Mobile Devices;
- 5) Implement observation and identification of obvious cyber related tampering to existing insider mitigation rounds by incorporating the appropriate elements;
- 6) Identify, document, and implement technical cyber security controls in accordance with Mitigation of Vulnerabilities and Application of Cyber Security Controls for CDAs that could adversely impact the design function of physical security target set equipment;
- 7) Ongoing monitoring and assessment activities for those target set CDAs whose security controls have been implemented;
- 8) Fully implement the CSP.
Currently, Milestone 8 of the PNP CSP requires the licensee to fully implement the CSP by December 15, 2014. By letter dated December 30, 2013, the licensee proposed to modify the Milestone 8 completion date to June 30, 2016.
By letter dated December 30, 2013, the licensee provided the following information pertinent to each of the criteria identified in the NRC guidance memorandum dated October 24, 2013.
- 1.
Identification of the specific requirement or requirements of the cyber security plan that the licensee needs additional time to implement.
The licensee stated that the requirements of the CSP needed additional time to implement Section 3, Analyzing Digital Computer Systems and Networks and Section 4, Establishing, Implementing and Maintaining the Cyber Security Program. It further noted that these sections describe requirements for application and maintenance of cyber security controls and described the process of addressing security controls. The licensee described specific requirements needing additional time including determining the need for a specific security features to provide for audit and accountability; monitoring tools and techniques; analyzing security alerts and advisories; and to assist personnel performing maintenance and testing activities. It also described a need for additional physical security controls for CDAs outside the security protected area and significant programmatic change management associated with approximately 40 procedure revisions related to operational and management cyber security controls.
- 2.
Detailed justification that describes the reason the licensee requires additional time to implement the specific requirement or requirements identified.
By letter dated December 30, 2013, the licensee stated the following:
ENO is using a robust full-time team of approximately 20 personnel to perform and document the detailed analysis (cyber security assessment process)
However, even with that level of resource commitment, the analysis which began in 2011 is presently projected to be completed by the second quarter of 2014.
Since the number of CDAs and existing procedures is in the hundreds and the number of individual cyber security control attributes is also in the hundreds the total of physical, logical and programmatic changes required constitutes a significant project involving plant components and systems and substantial planning. Additionally, changes to CDAs and procedures must be integrated into the plant operational schedule including on-line operations, maintenance and testing, as well as planning and execution of refueling outages. With this analysis concluding in the second quarter of 2014, it is expected that insufficient time will remain in 2014 to conduct modification and change management planning activities and execution.
Planning [for the specific security feature mentioned in Section 1 above] is expected to occur in 2014 and implement it in the following 18 months.
- 3.
A proposed completion date for Milestone 8 consistent with the remaining scope of work to be conducted and the resources available.
The licensee proposed a Milestone 8 completion date of June 30, 2016, and stated the revised Milestone 8 date will provide a six month contingency for the security features mentioned in Section 1 above.
- 4.
An evaluation of the impact that the additional time to implement the requirements will have on the effectiveness of the licensees overall cyber security program in the context of milestones already completed.
By letter dated December 30, 2013, the licensee stated the following:
The impact of the requested additional implementation time on the effectiveness of the overall cyber security program is considered to be very low, because the milestones already completed have resulted in a high degree of protection of safety-related, important-to-safety, and security CDAs against common threat vectors. Additionally, extensive physical and administrative measures are already in place for CDAs because they are plant components, pursuant to the Physical Security Plan and Technical Specification Requirements.
The NRC staff was concerned the LAR did not address all seven milestones and provided a request for additional information (RAI) to the licensee by email dated April 30, 2014 (ADAMS Accession No. ML14121A017). The licensee responded by letter May 22, 2014 (ADAMS Accession No. ML14142A296). The licensees response indicated that the milestone of concern had been implemented and the extension request had no effect on the milestones mentioned in the response.
- 5.
A description of the licensees methodology for prioritizing completion of work for critical digital assets associated with significant safety consequences and with reactivity effects in the balance of plant.
The licensee stated its methodology for prioritizing CDA activities is centered on considerations for safety, security, and emergency preparedness (SSEP) and BOP (continuity of power) consequences. By letter dated December 30, 2013, the licensee stated the following:
Because CDAs are plant components, prioritization follows the normal work management process that places the highest priority on apparent conditions adverse to quality in system, structure, and component design function and related factors such as safety risk and nuclear defense-in-depth, as well as threats to continuity of electric power generation in the balance-of-plant.
This prioritization enabled completion of cyber security Interim Milestones 3 and 4 in 2012. High focus continues to be maintained on prompt attention to any emergent issue with these CDAs that would potentially challenge the established cyber protective barriers. Additionally it should be noted that these CDAs encompass those associated with physical security target sets.
- 6.
A discussion of the licensees cyber security program performance up to the date of the license amendment request.
By letter dated December 30, 2013, the licensee stated that there has been no identified compromise of SSEP functions by cyber means at any ENO plant. These actions provide a high degree of protection against cyber attacks while full program actions are in progress. The licensee also noted a formal Quality Assurance audit in the last quarter of 2013 that included review of the cyber security program implementation and that there were no significant findings related to overall cyber security program performance and effectiveness.
- 7.
A discussion of cyber security issues pending in the licensees corrective action program.
By letter dated December 30, 2013, the licensee stated the following:
There are presently no significant nuclear cyber security issues pending in the
Corrective Action Program (CAP) that constitute a threat to a CDA via cyber means or calling into question program effectiveness. Several non-significant issues identified during the Quality Assurance audit described above have been entered into CAP. Additionally, when the Reference 3 internal NRC memorandum was shared with ENO, the actions described regarding cyber security Interim Milestone 4 were entered into CAP for evaluation by the CSAT.
Final actions regarding some program activities are pending.
- 8.
A discussion of modifications completed to support the cyber security program and a discussion of pending cyber security modifications.
By letter dated December 30, 2013, the licensee discussed completed modifications and pending modifications.
3.2
NRC Staff Evaluation
The NRC staff has evaluated the licensees application using the regulatory requirements and guidance above. The NRC staff concludes that the actions the licensee noted as being required to implement from the CSP, Section 3, Analyzing Digital Computer Systems and Networks and Section 4, Establishing, Implementing and Maintaining the Cyber Security Program are reasonable as discussed below.
The licensee indicated that completion of the activities associated with the CSP, as described in Milestones 1 through 7 were completed prior to December 31, 2012, and provide a high degree of protection to ensure that the most significant digital computer and communication systems and networks associated with SSEP functions are protected against cyber attacks. The NRC staff concludes that the licensees site is more secure after the implementation of Milestones 1 through 7 because the activities the licensee has completed mitigate the most significant cyber attack vectors for the most significant CDAs. The licensee has stated that the scope of actions and resources required to fully implement its CSP were not anticipated when the implementation schedule was originally determined. The NRC staff has had extensive interaction with the nuclear industry since licensees first developed their CSP implementation schedules. Based on this interaction, the NRC staff recognizes that CDA assessment work to include application of controls is much more complex and resource intensive than originally anticipated and that the licensee has a large number of additional tasks not originally considered when developing its CSP implementation schedule. The NRC staff concludes that the licensees request for additional time to implement Milestone 8 is reasonable given the unanticipated complexity and scope of the work required to come into full compliance with its CSP.
The licensee proposed a Milestone 8 completion date of June 30, 2016. The licensee stated that changing the completion date of Milestone 8 allows for the application of changes to CDAs, procedures and cyber security controls and provides the necessary time to methodically plan, implement, and test the required additions or changes and allows those additions or changes that require a design change to be performed. The licensee stated its methodology for prioritizing Milestone 8 activities is centered on considerations for SSEP and BOP (continuity of power) consequences. The methodology is based on defense-in-depth, installed configuration of the CDA and susceptibility to commonly identified threat vectors. Prioritization for CDA assessment begins with safety related CDAs and continues through lower priority non-safety and EP CDAs. The NRC staff concludes that based on the large number of digital assets described above and the limited resources with the appropriate expertise to perform these
activities, the licensees methodology for prioritizing work on CDAs is appropriate. The NRC staff further concludes that the licensees request to delay final implementation of the CSP until June 30, 2016, is reasonable given the complexity of the remaining unanticipated work.