ML18071A067
ML18071A067 | |
Person / Time | |
---|---|
Issue date: | 03/12/2018 |
From: | NRC/OCIO |
To: | Santos R FOIA Group |
References | |
FOIA, NRC-2018-000257 | |
Download: ML18071A067 (42) | |
Text
NRC FORM 464 Part I U.S. NUCLEAR REGULATORY COMMISSION FOIA RESPONSE NUMBER (03-2017) ~RAEac,l..r
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INFORMATION ACT (FOIA) REQUEST
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TYPE D INTERIM [ZJ FINAL REQUESTER: DATE:
IRose Santos 03/12/2018 11 I DESCRIPTION OF REQUESTED RECORDS:
Copy of the contract title page (1st page only) and the current Statement of Work/Performance Work Statement (SOW/
PWS), no pricing [Reference FGI #18-55788G] Relevant to NRCHQI014T0001 PART I. - INFORMATION RELEASED You have the right to seek assistance from the NRC's FOIA Public Liaison. Contact information for the NRC's FOIA Public Liaison is available at httgs://www.nrc.gov/reading-rm/foia/contact-foia.html D Agency records subject to the request are already available on the Public NRC Website, in Public ADAMS or on microfiche in the NRC Public Document Room.
[Z] Agency records subject to the request are enclosed.
Records subject to the request that contain information originated by or of interest to another Federal agency have been D referred to that agency (see comments section) for a disclosure determination and direct response to you.
D We are continuing to process your request.
D See Comments.
PART I.A - FEES NO FEES AMOUNT" D You will be billed by NRC for the amount listed.
D Minimum fee threshold not met.
II II D You will receive a refund for the amount listed.
[Z] Due to our delayed response, you will
- see Comments for details D Fees waived. not be charged fees.
PART I.B -- INFORMATION NOT LOCATED OR WITHHELD FROM DISCLOSURE D We did not locate any agency records responsive to your request. Note: Agencies may treat three discrete categories of law enforcement and national security records as not subject to the FOIA ("exclusions"). 5 U.S.C. 552(c). This is a standard notification given to all requesters; it should not be taken to mean that any excluded records do, or do not, exist.
0 We have withheld certain information pursuant to the FOIA exemptions described, and for the reasons stated, in Part II.
Because this is an interim response to your request, you may not appeal at this time. We will notify you of your right to D appeal any of the responses we have issued in response to your request when we issue our final determination.
You may appeal this final determination within 90 calendar days of the date of this response by sending a letter or e-mail to the FOIA Officer, at U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001, or FOIA.Resource@nrc.gov. Please be
[Z] sure to include on your letter or email that it is a "FOIA Appeal." You have the right to seek dispute resolution services from the NRC's Public Liaison, or the Office of Government Information Services (OGIS). Contact information for OGIS is available at httgs://ogis.archives.gov/about-ogis/contact-information.htm PART I.C COMMENTS ( Use attached Comments continuation page if required)
Sianafhre - Freedom of Information Act Officer or Desi~mee
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NRC FORM 464 Part II U.S. NUCLEAR REGULATORY COMMISSION FOIA (03-2017)
RESPONSE TO FREEDOM OF I NR.C-2018-000257 I INFORMATION ACT (FOIA) REQUEST DATE:
1 03112,201s PART II.A ** APPLICABLE EXEMPTIONS Records subject to the request are being withheld in their entirety or in part under the FOIA exemption(s) as indicated below (5 U.S.C. 552(b)).
D Exemption 1: The withheld information is properly classified pursuant to an Executive Order protecting national security information.
D Exemption 2: The withheld information relates solely to the internal personnel rules and practices of NRG.
D Exemption 3: The withheld information is specifically exempted from public disclosure by the statute indicated.
D Sections 141-145 of the Atomic Energy Act, which prohibits the disclosure of Restricted Data or Formerly Restricted Data (42 U.S.C. 2161-2165).
D Section 147 of the Atomic Energy Act, which prohibits the disclosure of Unclassified Safeguards Information (42 U.S.C. 2167).
41 U.S.C. 4702{b), which prohibits the disclosure of contractor proposals, except when incorporated into the contract between the agency and the D submitter of the proposal.
Exemption 4: The withheld information is a trade secret or confidential commercial or financial information that is being withheld for the reason(s)
D indicated.
The information is considered to be proprietary because it concerns a licensee's or applicant's physical protection or material control and D accounting program for special nuclear material pursuant to 10 CFR 2.390(d)(1).
D The information is considered to be another type or confidential business (proprietary) information.
D The information was submitted by a foreign source and received in confidence pursuant to 1 O CFR 2.390(d)(2).
D Exemption 5: The withheld information consists of interagency or intraagency records that are normally privileged in civil litigation.
D Deliberative process privilege.
D Attorney work product privilege.
D Attorney-client privilege.
Exemption 6: The withheld information from a personnel, medical, or similar file, is exempted from public disclosure because its disclosure would result D in a clearly unwarranted invasion of personal privacy.
[{J Exemption 7: The withheld information consists of records compiled for law enforcement purposes and is being withheld for the reason(s) indicated.
D (A) Disclosure could reasonably be expected to interfere with an open enforcement proceeding.
D (C) Disclosure could reasonably be expected to constitute an unwarranted invasion of personal privacy.
(D) The information consists of names and other information the disclosure of which could reasonably be expected to reveal identities of confidential D sources.
(E) Disclosure would reveal techniques and procedures for law enforcement investigations or prosecutions, or guidelines that could reasonably be 0 expected to risk circumvention of the law.
D (F) Disclosure could reasonably be expected to endanger the life or physical safety of an individual.
D PART 11.B ** DENYING OFFICIALS In accordance with 10 CFR 9.25(g) and 9.25(h) of the U.S. Nuclear Regulatory Commission regulations, the official(s) listed below have made the determination to withhold certain information responsive to your request APPELLATE OFFICIAL DENYING OFFICIAL TITLE/OFFICE RECORDS DENIED EDD SECY IStephanie Blaney I IFOIA Officer/OCIO 11 Testing tools, Op Systems & Application [Z] D 11 I D D I
11 I D D Appeals must be made in writing within 90 calendar days of the date of this response by sending a letter or email to the FOIA Officer, at U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001, or FOIA.Resource@nrc.gov. Please be sure to include on your letter or email that it is a "FOIA Appeal."
NRC Form 464 Part II (03-2017) Page 1 of 1
ORDER FOR SUPPLIES_ OR SERVICES I PAGE OF PAGES IMPORTANT: Mark aU packages and papers with contract and/or order numbers.
I, DATE OF ORDER 2 CONTRACT NO. (If any} 6.SHIPTO:
I 1 I ~6 GS06F0641Z a. NAME OF CONSIGNEE 02/19/2014 3.0RDERNO. ,4. REQUISITION/REFERENCE-NO.
NRC-HQ-10-14~T-0001 See Schedule. , US NUCLEAR REGULATORY COMMISSION-
- 5. ISSUING OFFICE /Addross concspondanoo lo} b. STREET ADDRESS US NRC - HQ MAIL PROCESSING CENTER DIVISION OF CO~TRACTS 4930 BOILING BROOK PARKWAY MAIL STOP 3Wrn-05-C64MP WASHING'l'ON DC 20555-0001 c.CITY Id. STATE I o. ZIP CODE ROCKVILLE MD 20852
- 7. TO: DANIEL HACKENBERG f. SHIPVIA
- o. NAME OF CONTRACTOR MAR INCORPORATED 8. TYPE OF ORDER
- b. COMPANY NAME OaPURCHASE IKJ b_ DELIVERY
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1803 RESEARCH BOULEVARD Exoopt f<<r billing instructions on lho reverse, !his dolivory Ofder is subject SUITE 204 to in,tructions contained on this sido only ol Utis form and is issued Flaase-fumish the fallowing an lhe,lorms subject ta lho torms and condilions and condition< specified an boUt sides of of tho '1bovo-numborod conlract.
- d. CITY ROCKVILLE I MD I208506106 ,
- e. STATE f. ZIP CODE
!his ardor and on Uto attached sheel. ~ eny, including delivery as lndlceted.
- 9. ACCOUNTING ANO APPROPRIATION DATA 10. REQUISITIONING OFFICE See Schedule COMPUTER SECURITY OFFICE
- 11. BUSINESS CLASSIFICATION (Check appropriate box/es 12- F.0.B. POINT
[I a_ SMALL lJ b. OTHER THAN SMALL D C. DISADVANTAGED 0d WOMEN-OWNED 0 e.HUBZone [j f. SERVICE-OiSABLED D g. VVOMEN-OWNED SM!\LL BUSINESS (WOSBi ! :J h. eowpse VETERAN-OWNED ELIGIBLE UNDER THE WOSB PROGRAM
- 13. PLACE OF 14. GOVERNMENT Bil NO.. 15. DELIVER TO F.O.B. POINT 16. DISCOUNTTERMS
- a. INSPECTION Destination Ib. ACCEPTANCE Destination ON OR BEFORE~Dale}
02/20/201
- 17. SCHEDULE (Soo rovcr.;o tor Rojecl/ons) ,
QUANTITY UNIT QUANTITY ITEM NO. SUPPLIES OR SERVICES ORDERED UNIT PRICE AMOUNT ACCEPTED (a) (b) <e> (d) (o). (f) (g) Accounting Info: 2014-X0200-FEEBASED-7S-7SD00l-5l-J-l45-N7343
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Period of Performance: 02/21/2014 to 05/20/2022 Continued ... .
- 18. SHIPP!NG POINT 119, GROSS SHIPPING V.'EIGHT 20. INVOICE NO. 1,1n1 TOTAL (Cent.
- ,,ages}
- 21. MAIL INVOICE TO:
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a.NAME $3,979,466.13 SEEBIUJNG us NUCLEAR REGULATORY C01".MISSI0N INSTRUcnONS b. STREET ADDRESS ONE WHITE FLU:IT NORTH ON REVERSE (01 P.O. Box) 11555 ROCKVILLE PIKE 17(1) GRAND MAILSTOP 03-E17A T-OTAL C. 1,11 T r* 'MD
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- 23. NAME (Typod)
- 22. UNITED STATES OF 02/19/2014 ... '
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JOSEPH L. WIDDUP AMERICA BY (Signature} 9,,,,,,~ 1 i,J,:O..,,f TITLE: CONTRACTIN,GIORDERING OFFICER AUTHORIZED FOR LOCAL REPROOI.ICTION OPTIONAL FORM 347 (RN Vl<l12J PREVIOUS EDITION NOT USABl.E F':N-~tyGSNF'AR4:SCf:R SJ213(J}
Attachment 1.1 Revised Statement of Work (SOW) OBJECTIVE I ( The Federal Information Security Management Act (FISMA) of 2002 requires agencies to develop, document, and implement an agency wide (includes NRC headquarters facilities, regions, etc.) program for the security of information and information systems that support the operations of the agency. These information systems include those provided or managed by (1) the agency, (2), another agency, (3) Contractor, or (4) other source. Agencies must perform periodic assessments of the risk and magnitude of the harm that could result from the unauthorized use, access, disclosure, disruption, modification, or destruction of information and information systems that support the operations and assets of the agency. The Contractor will assist the NRC in establishing and maintaining a robust Cyber Security Program. The Contractor shall ensure the program operates in compliance with the applicable federal and NRC Cyber Security regulations, policy, standards, and guidance. The Contractor shall support the NRC as follows:
- Project Management:
- Maintain a Quality Assurance Plan. - Develop and maintain a Project Management Plan.
- Special Projects:
- Report on cyber security risks across the NRC infrastructure quarterly. - Evaluating new technologies to understand their security impact and how they could be used to enhance the NRC Cyber Security Program. - Analyze Cyber Security best practices and make recommendations on how those practices s:ould be used at the NRC.
- FISMA Compliance and Oversight:
- Assist the NRC in authorizing each of its information systems to operate. - Support the NRG in establishing and maintaining a robust Cyber Security continuous monitoring program. - Assist the NRC with Cyb er Security related data calls from other government agencies and the NRC Office of Inspector General. - Assess planned or completed remediation actions to ensure they meet federally mandated and NRC defined cyber security requirements.
- Cyber Situational Awareness:
- Support the NRC's computer security incident response efforts. - Perform Computer Security Vulnerability Assessments. - Develop and establish and maintain a Cyber Security Laboratory. - Verify and validate the agency's use of the Security Content Automation Protocol (SCAP).
- Assist the NRG in establishing a software quality assurar:ice program to verify and validate information systems are resistant to cyber security attacks. - Perform computer security penetration testing. - Evaluate system security designs and configurations. - E)evelop and implement and maintain an in depth Security Architecture that follows the Federal Segment Architecture Methodology. - Pilot systems that support the NRG Cyber Security Program.
Perform Security Impact Assessments (SIAs).
- Policy, Standards, and Training:
- Assist the NRG in developing, establishing, and maintaining Cyber Security Policy that adheres to federally mandated requirements and industry best practices. - - Assist the NRG in developing processes, procedures, templates, checklists, standards, and guidance that support the NRG Cyber Security program. - Analyze business solutions to ensure they meet federally mandated and NRG defined cyber security requirements. - Establish, conduct, and maintain IT Security Awareness Training, Role-based Training, and other specialized Cyber Security training. - Assist the NRG in effectively communicating Cyber Security information to the NRG user community.
2 CONTRACT TYPE This task order will utilize the firm-fixed-price (FFP) and labor-hour (LH) contract types. 3 SCOPE The Contractor shall provide all personnel and other direct costs necessary to accomplish the work as specified in this Statement of Work (SOW). 4 FACILITY ACCESS The following sections provide details on Contractor access to NRG facilities. 4.1 Hours of Operation The Contractor shall have access to all NRG facilities five (5) days per week, Monday through Friday, except when these facilities are closed due to local or national emergencies, administrative closings, or similar Government directed facility closings. If the Contractor is supporting a critical function (e.g., incident response) their access may be expanded to the weekends. This shall be addressed on a case by case basis. 4.2 Place of Performance The NRG shall provide onsite physical space for up to four (4) Contractor full time equivalents at NRG headquarters and the NRG shall supply desktops for those individuals to access NRC's Local Area Network (LAN). The remaining Contractor personnel working on this task order shall 2
operate remotely using a workstation or laptop that has been approved by the primary or alternate COR in writing to process NRG information. 5 TRAVEL The task order contains the following travel requirements: (a.) Local travel expenses will not be reimbursed by the NRG. On-site parking at NRG is not available. Parking is available at the White Flint Metro Station. (b.)Occasional travel to the NRG Regional locations and remote NRG facilities including State and Local Government facilities and external commercial and government application service providers and application hosting facilities may be required. (c.) Total expenditures for domestic travel (does not include travel to any NRG Headquarters facilities) may not exceed $80,000.00 for each year of the period of performance, without the prior written modification of the task order to obligate additional funds. Travel costs may include an applicable G&A burden but shall not include profit/fee. - (d.) The Contractor will be reimbursed for reasonable travel costs incurred directly and specifically in the performance of this task order. The cost limitations for travel costs are determined in accordance with Federal Acquisition Regulation (FAR) 31.205-46. (e.) If the Contractor exceeds obligated funds for travel costs, it does so at its own risk. 5.1 Special Access Requirements The Contractor may need to be contacted outside of normal duty hours. The Contractor shall respond to all inquiries, both during and outside of normal duty hours, within four (4) hours of being contacted by the primary or alternate Contracting Officer's Representative (COR). Historically, this has occurred only a couple of times a year. 6 GOVERNMENT FURNISHED INFORMATION The Contractor shall have access to information (e.g. StandardOperational Procedures, regulations, manuals, texts, briefs and the other materials associated with this project) and tools located on the NRG infrastructure. All information, regardless of media, provided by the Government and/or generated for the Government in the performance of this task order is Government property and shall be maintained and disposed of by the Government. At the time of disposition, this information shall be boxed up, its contents labeled, and delivered to the Contracting Officer. Also, the Contractor shall completely remove all electronic copies of the information from Contractor equipment (e.g., computers, copiers, printers, faxes). The government reserves the right to verify and validate how this has been done. All equipment/media that has ever contained electronic copies of SGI or classified information must be provided to the government for destruction. 7 TASKS AND DELIVERABLES The Contractor shall support the NRG in its efforts to establish and maintain a robust Cyber Security Program. The following tasks shall be performed by the Contractor during the, execution of this Statement of Work. All data that is first produced under this task order is subject to clause 52.227-17, Rights in Data-Special Works (Dec 2007). 3
All deliverables must be provided to the primary COR and their alternate COR (s) in the NRG Computer Security Office (CSO). The primary and alternate COR (s), in consultation with the NRG CISO, will provide overarching technical direction on the manner and method used to perform and report on all cyber security activities and shall resolve any differences in technical direction provided by different office CORs. Note: This task order cannot be awarded to a Contractor that constructs, operates, or maintains NRG information systems. This would be considered a conflict of interest. Also the Contractor will not be allowed to act as an Information System Security Officer (ISSO) for any NRG system. 7.1 Project Management The Contractor shall comply with, and provide the following services as required by, NRG Management Directive 2.8, Project Management Methodology (PMM). 7.1.1 Quality Assurance Plan The Contractor shall provide a Quality Assurance Plan for this task order. This plan must be approved in writing by the primary or alternate GOR (s) prior to submission of the first deliverable. The plan shall address the following:
- 1) Deficiency Prevention: A description of the methods to be used for identifying and preventing deficiencies and their causes in the quality of service performed before the level of performance becomes unacceptable.
- 2) Resolution: Documents the corrective .or preventive actions that were taken during the execution of this task order. These records shall be made readily available to the primary and alternate CORs.
7.1.2 Project Plan (includes Level 4 Work Breakdown Structure) The Contractor shall develop and maintain a Project Plan for this task order and provide that project plan electronically to the primary and alternate CORs. At a minimum, the project plan shall contain a Level 4 Work Breakdown Structure (WBS) and shall use the project plan template from NRC's PMM web site. The WBS shall include a definition of the work to be conducted decomposed into distinct discrete manageable tasks or groups of tasks (work packages) with decisive outputs and specific measurable entry and exit criteria. Each work package shall have a short duration (not to exceed 80 hours), or can be divided into a series of milestones whose status can be objectively measured. Each work package shall be assigned a start and finish date, a budget value, and shall be constructed such that it can be integrated with higher-level schedules. Levels one through three of the WBS shall be organized as follows:
- Level one of the WBS shall represent the NRG Office that is allocating funds on this task order. The Contractor must be able to track costs and earned value management at this level.
Level two of the WBS shall be broken down into various activities that are being performed for that NRC Office. For example: Continuous Monitoring, Authorization, Software Quality Assurance, Policy Support, Standards Support, etc. 4
- Level three of the WBS shall represent the tasks that are needed to perform each activity under this task order. For example under Authorization: Security Categorization, System Security Plan, Standards Test & Evaluation Plan, Testing, etc.
The project plan shall specify, at the task level, a schedule and ceiling price to accomplish the work and identify the resources needed to complete the work. Resources include manpower, hardware, software, equipment, travel, etc. The Contractor shall ensure the WBS laid out in the project plan adequately defines all work necessary to meet the requirements of this task order. The Contractor shall utilize Microsoft Project and other resources to develop and maintain the project plan. The project plan shall be provided to the primary and alternate CORs on a monthly basis and shall be delivered in conjunction with the Monthly Status Report. 7.2 Special Projects The following Special Projects shall be implemented under this task order. 7.2 ..1 Assessment of Residual Risk The Contractor shall develop and implement a process for determining cyber security risks that affect the NRG IT infrastructure. The Contractor shall place greater emphasis on risks that occur at an enterprise level or impact multiple NRG information systems. The Contractor shall develop a reporting template (Quarterly Residual Risk Report) and brief the primary and alternate CORs on current residual risks as well as risk trends on a quarterly basis. Assessment of risks shall be based upon supported evidence. The Contractor shall use the following sources to determine these risks: audits, the Enterprise Risk Assessment, Cyber Security incidents,: NRG Strategic Plans, Inspector General Reports, Plan of Action & Milestone items, vendor reported vulnerabilities & exploits, and observations. The Contractor shall identify, prioritize, and map these risks to NRC's mission and business functions. The Contractor shall document all risks that were found during this assessment in a formalized report that is delivered to the primary and alternate CORs. The Contractor shall give a quarterly risk briefing to the primary and alternate CORs that communicates the results of this assessment to NRG management. 7.2.2 Classified Processing Support The Contractor shall provide the following security engineering support for classified information processing:
- Support the NRG efforts to obtain an authorization to operate for systems that process classified information.
Assist the NRG in developing and maintaining a continuous monitoring program for its
, information systems that process classified information.
- Work with the NRG to ensure that classified information is properly protected and secured.
All classified processing must comply with CNSS publications, except where the information and systems are governed by the Director of National Intelligence issuances. 5
7.2.3 Evaluation of New Technologies The Contractor may be requested to assist the primary and alternate CORs in evaluating new technologies so the impact these technologies have on NRC's information systems and the NRG Cyber Security Program can be fully understood. ' 7.2.4 Analysis of Best Practices The Contractor shall analyze security best practices to determine how those practices can be applied to the NRG Cyber Security Program. After the analysis has been completed, the Contractor shall develop recommendations and document those recommendations in white papers that will be delivered to the primary and alternate CORs. Once the primary or alternate COR has reviewed the white papers and decided upon a course of action, the Contractor m primary and alternate CORs may be asked to assist the NRG in incorporating selected recommendations into the NRG Cyber Security Program., 7.3 System Authorization The Contractor shall assist the NRG with the following: authorizing its information systems, developing accurate and high-quality system security documentation, testing systems to determine risk, supporting continuous monitoring activities, and assisting with data calls from other government agencies and the NRG Office of Inspector General (OIG). 7.3.1 Obtaining NRG Information Systems Authorization to Operate The Contractor shall assist the NRG in developing authorization packages for its unclassified information systems. The Contractor may support the system owner in the development of the entire authorization package or just a portion of it. For example, the Contractor may only act as an independent assessor during the testing and evaluation of the system. In this instance the Contractor would only be testing the system.
- The Contractor shall assist the NRG in annually authorizing NRG information systems. An authorization package must include but is not limited to the following:
E-Authentication Risk Assessment Electronic authentication (e-authentication) is the process of establishing confiqence in user identities electronically presented to an information system. The focus is on remote authentication of individual people over a network, for the purpose of electronic government or commerce. The 0MB M-04-04 memorandum guidance applies to systems that have remote authentication of users of Federal agency information technology systems for the purposes of conducting Government business electronically ,(ore-government). The guidance does not apply to internal only systems or the authentication of servers, or other machines and network devices. E-Authentication Risk Assessments shall be consistent with 0MB M04-04, NIST SP 800-30, NIST SP 800-60, and NIST SP 800-63. The Contractor must develop the E-Authentication Risk Assessments according to NRG requirements. It will be the responsibility of the Contractor at the start of each assessment to ensure the latest requirements are adhered to.
- Security Categorization Package Security categorization for information and information systems provides a common framework and understanding for expressing security that, for the federal government, promotes: (i) effective management and oversight of inform?tion security programs; (ii) 6
consistent reporting to the 0MB and Congress on the adequacy and effectiveness of cyber security policies, procedures, and practices. N RC's Security Categorization Package contains the following deliverables: Security Categorization Memo, Security Categorization Document, Privacy Impact Assessment (PIA), etc. The Security Categorization document must follow federally mandated requirements found in NIST FIPS 199 Standards for Security Categorization of Federal Information and Information Systems and NIST SP 800-60 Guide for Mapping Types of Information and Information Systems to Security Categories. In addition, the Contractor must develop the Security Categorization Package according to NRG defined cyber security requirements. It will be the responsibility of the Contractor at the start of each categorization package to ensure the latest requirements are adhered to.
- Security Risk Assessment (SRA)
The SRA is an important activity in the NRC's information security program that directly supports security authorization and is required by the FISMA and 0MB Circular A-130, Appendix Ill. This assessment influences the development of the security controls for an information system and generates much of the information needed for the system's security plan. The assessment shall ensure compliance with NRC's Cyber Security policy, ensure compliance with federally mandated security requirements, and include but is not limited to the following:
- Identification of user types and associated roles and responsibilities; - Identification of risk assessment team members and their associations; - A description of the risk assessment approach and techniques, where the techniques include documentation review, interviews, observation, and system configuration assessments, security scans and penetration tests; - A description of the risk scale used, including at a minimum, the potential impact as defined in FIPS 199, and likelihood as defined in NIST SP 800-30, Risk Management Guide for Information Technology Systems; - A list of potential system vulnerabilities; - A list of potential threat-sources applicable to the system, including natural, human, and environmental threat-sources; - A table of vulnerability and threat-source pairs and observations about each; - Detailed findings for each vulnerability and threat-actions discussing the possible outcome if the vulnerability was exploited; existing controls to mitigate the pair; the likelihood determination as high, moderate, or low; the impact determination expressed as high, moderate, or low; the overall risk rating based upon the risk scale; and the recommended controls to mitigate the risk; and, - A summary that includes the number of high, moderate, and low findings and provides a list of prioritized action items based upon the findings.
The assessment shall be documented in a report according federally mandated and NRG defined cyber security requirements. It will be the responsibility of the Contractor at the start of each assessment to ensure the latest requirements are adhered to. 7
All findings that are discovered during the SRA shall be incorporated into the system's Plan of Action and Milestones (POA&M) Report.
- System Security Plan (SSP)
The SSP shall be developed in accordance with NRC .Cyber Security policy and federally mandated requirements (NIST Special Publications, Federal Information Processing Standards, etc.). The SSP identifies the necessary security controls that are required, citing the security controls that are in place, those that are planned, those that are not planned, and those that are not applicable. When an NRC information system inherits a security control being provided by another information system, what is being inherited shall be noted along with the name of the system providing that control. The Contractor shall trace the security controls to specific documented guidance, NRC policy (e.g., Management Directives), infrastructure policy or procedures, and federally mandated security requirements. The SSP shall be documented and updated to reflect security testing, control implementation, and changes to the system. Once the certifier enters his/her information . into the SSP it cannot be changed without CSO's approval. The final SSP shall reflect validated in-place and planned controls.
- Preliminary Assessment Report The Contractor shall perform a preliminary assessment of the system to ensure the system is compliant with federally mandated and NRC defined cyber security requirements. The following is a sample of what must be checked:
- All National Institute of Standards and Technology (NIST) Federal Information Processing Standards. Especially NIST FIPS 140-2. When checking NIST FIPS 140-2, the Contractor must ensure that all cryptography used in the system has been validated, has a current FIPS 140-2 certificate, and the configuration of that cryptography complies with the security policy specified by the certificate for the cryptographic module. - All NIST Special Publications. Especially NIST 800-53. The Contractor must ensure the system complies with the technical, managerial, and procedural controls found in this standard. - All NRG Management Directives. - All NRG Cyber Security Standards. For a complete list of Cyber Security standards please see "http://www.internal.nrc.gov/CSO/standards.html".
Note: If a configuration standard has not been identified, DISA standards, checklists, and guidance shall be used. In the absence of CSO and DISA configuration information, CIS benchmarks shall be used. In the absence of CSO, DISA, and CIS configuration the vendor's security guide shall be used.
- Currency of Cyber Security relevant patches, service packs, and versions. - Mitigation of known vulnerabilities - All Committee on National Security Systems (CNSS) issuances The Contractor shall identify any operational risks found that may affect the system's ability to perform its mission and protect its data (stored and transmitted). The Contractor shall 8
assist developers, project managers, engineers, etc. to identify vulnerabilities during the initial stages of the System Development Life Cycle (SDLC). Preliminary Testing includes automated and manual testing of the different system platforms to ensure they have been configured, operated, and maintained correctly and in accordance with NRC policy and standards. An operating system and application scan against required configuration standards and assessing vulnerability patching is required. The Contractor shall document the results and observations of this process in a Vulnerability Assessment Report (VAR). Each finding identified in the VAR shall include the risk number, a description of each risk, the type of risk (i.e., impacting the confidentiality, integrity, or availability), the level of risk (i.e., low, moderate, or high), the associated controls, and the action(s) required or actually performed to eliminate or minimize each risk. The Contractor shall coordinate and execute all applicable site access and non-disclosure agreements and authority to scan forms with parties other than the NRG prior to commencement of the above mentioned activities, ensuring that project schedules are not impacted. Finally, all deficiencies found in the system that are exploitable must be reported to the primary and alternate CORs immediately in writing.
- Systems Test and Evaluation (ST&E) Plan The ST&E plan exercises the system's security controls and ensures those controls are operating as intended and have been implemented in accordance with federally mandated requirements/ NRG defined surety requirements. The following lists some of the guidance that should be considered when developing the ST&E Plan:
- NIST SP 800-53A Guide for Accessing the Security Controls in Federal Information Systems - NIST SP 800-53 Recommended Security Controls for Federal Information Systems - NIST SP 800-37 Guide for Applying the Risk Management Framework to Federal Information Systems - NRC System Security Test and Evaluation Plan Template The ST &E plan provides detailed test procedures to ensure all federally mandated and NRG defined cyber security requirements are fully tested. These procedures contain sufficient detail that a technically trained individual not familiar with the system can successfully follow the procedures.
The following criteria shall be utilized during testing:
- Examine - The Contractor shall observe random individuals to verify that activities on the system follow the documented procedure or process as the activity is performed. For example, examine visitors upon computer room entry in order to verify that all visitation procedures are followed. The Contractor shall examine all processes, procedures, and documents associated with the system to ensure they are in compliance with established requirements.
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- Interview - The Contractor shall interview personnel to verify the security policies and procedures are understood as implemented and prescribed by governing policies and regulations. - Inspection - The Contractor shall ensure security controls have been properly implemented and maintained. For example, the Contractor shall verify that the visitor's name, signature, organization, reason of visit, arrival and departure date, time, and the escort's name, initials, or signature are included on the log sheets. - Test - The Technical Test verification method shall be used to verify that each implemented control is functioning as intended. For example, the Contractor shall attempt to access the system by logging on to the system from an end user workstation (or other device) using an incorrect password to see if the system responds with an error message stating an incorrect password has been entered or denies access after exceeding the maximum threshold for logon attempts.
If a control is inherited, the Contractor shall review the inherited system's security documentation to determine if the control is in place and operating as intended. If it is not, this shall be factored in when the system's risks are determined. If the control is not inherited, the Contractor shall ensure that the security control meets all federally mandated and NRG defined cyber security requirements and provides the appropriate level of protection based on the sensitivity of the system. This shall be determined through interviews, documentation reviews, or testing.
- Security Control Testing The system shall be reviewed, yerified, and validated using the system's security test plans and procedures to ensure the accuracy and adequacy of documented test procedures for all system security controls and associated technical resolutions, risk mitigation, and implementations contained within various NRG security and systems development documentation such that confirmation that the system and associated controls are operating as intended. The Contractor shall evaluate common controls used throughout the agency.
Once testing has been completed, the ST&E Report, the Vulnerability Assessment Report, and the Project Objectives and Milestones (POA&M) Report shall be developed to document the results. All findings that are not immediately remediated must be documented. cl System testing includes automated and manual testing of the different system platforms and applications to ensure security controls have been configured, operated, and maintained correctly. This shall be accomplished through interviews, documentation reviews, or testing depending on the security control being assessed. The Contractor shall be responsible for coordinating and executing all applicable site access, and authority to scan forms with other parties for the commencement of the above mentioned activities. Examples of some of the standards that must be checked:
- National Institute of Standards and Technology (NIST) Federal Information Processing*
(FIPS) 140-2. When checking NIST FIPS 140-2, the Contractor must ensure that all cryptography used in the system has been validated, has a current FIPS 140-2 10
certificate, and the configuration of that cryptography complies with the security policy specified by the certificate for the cryptographic module.
- NIST 800-53A. The Contractor must ensure the system complies with the technical, managerial, and procedural controls found in this standard. - NRG Cyber Security Standards. NRC Cyber Security standards ensure a consistent application of security across NRG information systems and provide a minimally acceptable level of security for devices, operating systems and applications. NRC Cyber Security Standards are used as system baseline configurations for any information system that stores, transmits/receives, or processes NRG information.
f Please note: Individual Contractors working with the system owner to develop the system's E-Authentication Risk Assessment, Security Categorization Package, or SSP cannot be involved in system testing. This would be considered a conflict of interest. POA&M Report The POA&M Report identifies the risks or findings that were found during the authorization process. POA&Ms document the risk number; a description of each risk; the type of risk (i.e., impacting the confidentiality, integrity, or availability); the level of risk (i.e., low, moderate, or high); the associated controls; and the action(s) required or actually performed to eliminate or minimize each risk. The POA&M report is a tool that is used to track the system's remaining findings to ensure remediation occurs over an agreed upon period of time. The format and data required in quarterly POA&M reports is determined by the 0MB and is subject to change on an annual basis.
- Contingency Plan (CP)
The Contractor shall assist the NRG in developing a CP, disaster recovery procedures, and business impact assessment that supports the system's contingency planning process. The CP shall be documented according to the current NRG CP Template. The GP shall be developed in accordance with federally mandated requirements, NRG defined cyber security requirements and contingency approach, National Institute of Standards & Technology (NIST) Special Publication (SP) 800-34 "Contingency Planning Guide for Information Technology Systems", NIST SP 800-37 "Guide for Applying the Risk Management Framework to Federal Information Systems", and the NRG Contingency Plan (CP) Template. The Contractor shall document detailed procedures for the Notification/Activation Phase, Recovery Operations, and Return to Normal Operations. The procedures shall contain sufficient detail that a technically trained individual not familiar with the system can successfully follow the procedures. The system CP shall contain but will not be limited to the following:
- Sufficient contact information (personnel and vendor) - Equipment (hardware and software) - Specification information to enable reconstitution of the system from scratch, all service level agreements, memoranda of understanding 11
- IT standard operating procedures for the system - Identification of any systems that this system is dependent upon along with references for th$ applicable contingency plans - References to the emergency management plan and occupant evacuation plan - References to the appropriate continuity of operations plan.
- Contingency Plan Test Report The Contractor shall provide expert advice and support during the Contingency Plan Test to ensure the test is documented in accordance with the system's CP, federally mandated requirements (NIST SP 800-34 "Contingency Planning Guide for Information Technology Systems", NIST SP 800-37 "Guide for Applying the Risk Management Framework to Federal Information Systems", etc.), and NRG defined cyber se9urity requirements.
The test shall be documented using a template approved by the primary or alternate CORs. The Contractor shall update the system's CP once the CP Test Report has been completed to reflect validated information. The primary or alternate CORs must approve the final version of the system's CP and Contingency Plan Test Report.
- Authorization Package The Authorization package provides the authorizing official with the essential information needed to make a credible risk-based decision on whether to authorize operation of the information system. The Authorization Package contains the following deliverable~:
Security Categorization Document, SRA, SSP, ST&E Plan, ST&E Report, Vulnerability Assessment Report, POA&M Report, and an Approval to Operate Request Memo. The ST&E Execution Report, VAR, and Contingency Plan Test Report shall be delivered in a file format that canhot be changed. The SSP, SRA, ST&E Plan, ST&E Report, and VAR must be current (within 2 months). If the system has a risk that cannot be mitigated or captured on the POA&M report, the risk must be captured in a Deviation Request. Some findings cannot be remediated because they will break the system or impact its business objectives. For these findings a deviation request is developed that justifies why this finding has not been addressed, what is the risk to the system and NRG infrastructure, and what are the mitigating controls in place that protect the system from this risk. *
- Supporting Documentation The Contractor shall develop documentation that supports the system's authorization package (standard operating procedures, service level agreements, memorandums of understanding, interconnection agreements, etc.). The Contractor shall ensure all supporting documentation has been identified, properly developed, and has addressed all federally mandated and NRG defined cyber security requirements.
7.3.2 Obtaining Laptop Authorization to Operate The contactor shall conduct Laptop System Authorizations for NRG system owners. 12
Laptops must comply with all federally mandated and NRG defined cyber security requirements. Once properly configured, the system owner (NRC office director or Office of Information Systems division director) certifies the laptop system and sends a memo to the CISO notifying them that the laptop system is ready to be evaluated. CSO reviews the system owner's submittal, all supporting documentation, and provides a recommendation to the DAA if the laptop should be authorized. 7.4 Continuous Monitoring Support The Contractor shall assist the primary and alternate CORs in establishing and maintaining a continuous monitoring process that addresses federally mandated and NRC defined cyber security requirements. Currently, the NRG performs Continuous Monitoring activities on 30 systems. The continuous monitoring process shall consist of but is not limited to the following:
- Coordinate Continuous Monitoring Efforts
- Coordinate the continuous monitoring efforts. - Assist the system owner's representatives in establishing their continuous monitoring schedules. - Apply knowledge, skills, tools, and techniques to ensure continuous monitoring activities are performed effectively, on schedule, and within budget.
Perform Annual Security Controls Testing The Contractor shall conduct annual security controls testing of the organization's information systems according to NIST SP 800-53 "Guide for Assessing the Security Controls in Federal Information Systems" and NRC Cyber Security requirements. The Contractor shall work with the NRC to develop selection criteria to determine which security controls shall be tested to include common controls and inherited controls. At a minimum, the selection criteria shall be based upon: the sensitivity level of the system; the requirement to annually test volatile controls; controls called out for annual testing in 0MB guidance; CSO specified controls; and those associated with each system's POA&M items. This assessment shall be performed on all NRG Information Systems each fiscal year. The Contractor shall perform a comprehensive assessment of the selected programmatic, management, operational, and technical security controls for each system. The assessment shall determine the extent to which each system's controls are implemented correctly, operating as intended, and producing the desired outcome with respect to meeting federally mandated and NRC defined cyber security requirements. Upon completion of testing, the Contractor shall develop an Annual Security Controls Test Report for each system and incorporate any findings into that system's POA&M Report. The draft Annual Security Controls Test Report and the updates made to the system's POA&M Report shall be submitted to NRC review and comment. The Contractor shall revise and update each deliverable as appropriate and provide final versions. Conduct Quarterly Scanning The Contractor shall conduct quarterly vulnerability scanning of NRC's systems. Quarterly scanning shall establish if the system's security controls are operating as intended and 13
ensure systems continually meet federally mandated and NRG defined cyber security requirements. All risks/ deficiencies shall be measured according to NIST SP 800-30 "Risk Management Guide for Information Technology Systems" .
............................._r shall use a variety of testing tool~(b)(l)(E) .
manual and automatic, including proprietary and modmed open source, to I
~=IT'l'ffl~e""""'*ssessment. All hardware and software used to support this task order must be approved in writing by the primary or alternate CORs.
Scanning shall consist of the following phases:
- Phase 1: Preparation - The Contractor shall ensure all testing devices that are going to be used during the assessment are loaded with the latest patches, security updates, device drivers, and plug-ins. - Phase 2: Information Gathering - The Contractor shall conduct scans, review documentation, and interview personnel to gather the needed information to perform a risk analysis of the organization's systems. - Phase 3: Draft Assessment Reports - The Contractor shall develop System Assessment Reports that identify the risks each system poses to itself, its data, and the NRG infrastructure. - Phase 4: Validate Findings - The Contractor shall validate findings, ensure risks have been properly assessed, and develop mitigation strategies that will address deficiencies in consultation with the System Owner, ISSOs and System Administrators. - Phase 5: Finalize Assessment Reports - The Contractor shall incorporate NRC's comments into the Assessment Reports and deliver the final version of the Assessment Reports to the primary and alternate CORs. * - Phase 6: Plan of Action and Milestone (POA&M) Reports - The Contractor shall incorporate any findings into each system's POA&M Report.
The Contractor shall submit Assessment Reports and Updated POA&M Reports to the primary and alternate CORs for review and comment. The Contractor shall revise and update each deliverable as appropriate based on written feedback from the primary and alternate CORs and provide final versions to the primary and alternate CORs.
- Update POA&M Reports The Contractor shall update system level POA&M reports quarterly. When updating POA&M reports, the Contractor shall utilize the CSO POA&M Quality Checklist and review the report with the CSO to ensure the report is in accordance with the CSO POA&M process.
The Contractor shall collect information so the POA&Ms can be updated to reflect the current situation. Any new vulnerability that is discovered shall be added and assigned to the appropriate system. All POA&M Reports shall be submitted for review and comment. The Contractor shall revise and update each deliverable as appropriate and provide final versions to the primary and alternate CORs. Upon completion, the Contractor shall upload the POA&M Reports into the CSO FISMA Compliance automated tracking tool. 14
- Update Contingency Plan The Contractor shall update the system level CPs and ensure the GP is still valid and effective. The System GP shall be documented in a report that follows the NRG Template.
The GP shall be maintained in its hard copy form for contingency execution should the NRG Network Infrastructure be unavailable. Develop Contingency Plan Test Rep_orts The Contractor shall ensure the Contingency Planning Test is documented in accordance with the system's GP, federally mandated requirements (NIST SP 800-34 "Contingency Planning Guide for Information Technology Systems", NIST SP 800-37 "Guide for Applying the Risk Management Framework to Federal Information Systems", etc.), and NRG defined cyber security requirements.
- Update SRA and SSP Annually, the Contractor shall update the system's SRA and SSP. The draft documents shall be submitted to the organization for review and comment. The Contractor shall revise and update each deliverable as appropriate and provide final versions to the primary and alternate CORs.
This activity should be performed in conjunction with the Annual Security Controls Testing. Provide Security Engineering Support The Contractor shall provide security engineering support to verify and validate proposed architectures and implementations based on sound security engineering principles and practices. The Contractor shall ensure that all federally mandated and NRG defined cyber security requirements are met. The Contractor shall keep all supporting documentation up-to-date (memoranda, agreements, procedures, etc.) in consultation with the CSO. 7.4.1 Periodic System Cybersecurity Assessment (PSCA) The Contractor shall conduct a PSCA of the organization's information system according to National Institute of Standards and Technology (NIST) Special Publication (SP) 800-53 and Nuclear Regulatory Commission (NRG) Cyber Security requirements. The Contractor shall work with the NRG to develop selection criteria to determine which security controls shall be tested to include common controls and inherited controls. At a minimum, the selection criteria shall be based upon: the sensitivity level of the system; the requirement to annually test volatile controls; controls called out for annual testing in Office of Management and Budget (0MB) guidance; Computer Security Office (CSO) specified controls; and those associated with each system's Plan of Action and Milestone (POA&M) items. The number of controls should comprise no less than one-third of the total number of controls of the system's baseline. This information shall be used to develop a PSCA plan that shall be followed when performing the assessment. The draft PSCA plan shall be submitted to the NRG for review and comment. The Contractor shall revise and update the plan as appropriate and provide a final version. The Contractor shall perform a comprehensive assessment of the selected management, operational, and technical security controls for the system. The assessment shall determine the extent to which each control is implemented correctly, operating as intended, and producing the desired outcome with respect to meeting federally mandated 15
and NRG defined cyber security requirements. Upon completion of testing, the Contractor shall develop a PSCA Report and a Vulnerability Assessment Report (VAR) for the system using the NRG approved template. In addition, the contractor shall provide a POA&M spreadsheet reflecting new POA&Ms to be created. The draft PSCA Report, VAR, and POA&M spreadsheet shall be submitted to the NRC for review and comment. The Contractor shall update each of these deliverables as appropriate and provide final versions. The PSCA Report and VAR shall be provided in PDF format when delivered in their final versions. The following scanning activities shall be performed:
- One-time vulnerability scanning and configuration checks of the NRC approved sampling of components.
- Validation of fixes using automated tools.
Note: If the scope of the effort requires more than 50% of the controls to be tested, the effort should be performed as an Authorization task (as outlined in Section 7.3). I 7.5 Data Calls The Contractor shall assist the NRC's in its efforts to respond to Cyber Security related data calls from the NRG OIG and other government organizations. Data calls are usually unexpected and require a quick turnaround. 7.6 Cyber Situational Awareness The Contractor shall provide the fallowing services. 7.6.1 Incident Response Efforts The Contractor shall assist the NRG in developing, establishing, and maintaining an agency wide Incident Response Program that addresses federally mandated and NRG defined cyber security requirements (found in Management Directives and policy). At a minimum the Incident Response Program shall satisfy the following criteria: Incident Response Process And Procedures - Develop, disseminate, and review/update formal incident response procedures that address purpose, scope, roles, responsibilities, 16
management commitment, coordination among organizational entities, and compliance with federally mandated and NRC defined cyber security requirements. Incident Response Training - Train personnel in their incident response roles and responsibilities with respect to the information system; and provide refresher training annually. Incorporate simulated events into incident response training to facilitate effective response by personnel in crisis situations. Employ automated mechanisms to provide a more thorougl1 and realistic training environment. Ensure closed incidents are reviewed for lessons learned. Lessons learned should be incorporated into Incident Response processes, procedures, and plans. Incident Response Testing And Exercises - Test the incident response capability for the information system annually using defined tests and/or exercises to determine the incident response effectiveness and document the results. Employ automated mechanisms to more thoroughly and effectively test/exercise the incident response capability. Incident Handling - Implement an incident handling capability that includes: Preparation for security incidents.
- Verification and validation of the organization's detection, declaration, containment, remediation, and restoral capabilities.
Coordination of incident handling activities and contingency planning activities. Incorporation of lessons learned from historical incident handling activities to enable continuous improvement of the agency's incident handling program.
- Deployment of automated mechanisms to support the incident handling process. ,
Identify classes of incidents (e.g., targeted malicious attacks, untargeted malicious attacks, malfunctions due to design or implementation errors and omissions) and define appropriate actions to ens~re continuation of mission/business operations.
- Correlate incident information and individual incident responses to achieve an organization-wide perspective on incident awareness and response.
" Implement a configurable capability to automatically disable an information system if a set organization defined security violations are detected.
- Incident Monitoring - Track and document information system security incidents. Employ automated mechanisms to assist in the tracking of security incidents and in the collection and analysis of incident information.
- Incident Reporting. Employ automated mechanisms to assist in the reporting of security incidents. Report information system weaknesses, deficiencies, and/or vulnerabilities associated with reported security incidents to appropriate organizational officials.
Incident Response Assistance - Provide an incident response support resource that offers advice and assistance to users of NRG information systems for the handling and reporting of security incidents. . Incident Response Plan - Develop an incident response plan that provides the organization with a roadmap for implementing its incident response capability; describe the structure of the incident response capability; provide a high-level approach for how the incident response capability fits into the overall organization; meet the unique requirements of the NRC, which relate to mission, size, structure, and functions; define reportable incidents; provide metrics for measuring the incident response capability within the NRC; 17
and define the resources and management support needed to effectively maintain a mature incident response capability. Distribute copies of the incident response plan to specified personnel. Review the incident response plan annually. Revise the incident response plan to address system/organizational changes or problems encountered during plan implementation, execution, or testing. Communicate any changes to the incident response plan to specified personnel. 7.6.2 NRC Enterprise Security Architecture The NRC Enterprise Security Architecture (ESA) is envisioned to be an integral and critical component within ttie overall NRC Enterprise Architecture. Recent studies, by both the Government Accountability Office (GAO) and the Computer Security Institute found that the number of cyber security threats to both the government and the private sector continues to be on the rise. The potential for damage to both the physical critical infrastructure and the ability for the United States to effect continuity of government could be greatly impacted or denied by successful attacks. The NRG is not exempt from this continuing and persistent threat. The Contractor shall assist the NRC in building and sustaining the agency ESA. The NRG has acknowledged that cyber warfare applies to all systems. As a result, the Computer Security Office seeks to provide and build, a sustainable Enterprise Security Architecture, wherein the following principles drive the task deliverables:
- Security levels applied to resources should be commensurate to their value to the organization and sufficient to contain risk to an acceptable level.I
- The architecture must accommodate varying security needs.
- The architecture must provide integrated security services to enable the enterprise to conduct safe and secure business electronically.
- A single, accurate and consistent system date and time should be maintained across the enterprise architecture and security elements to enable service-wide root cause analysis, response and containment. Users will see the time local to their geographic location.
The objectives within the NRG ESA Program include, but are not limited to:
- Ensuring that the NRG IT Infrastructure, IT Services, system software and components as articulated in the ESA continually enable the appropriate risk based protection of NRG information and information systems.
- The target ESA, along with other NRC Computer Security Office solutions and deliverables will at a minimum, support the 201 O Federal Information Security Management Act Reporting Requirements for all executive agencies.
- The target ESA will support HSPD-12, 1Pv6, as well as the latest published, released version of the Federal CIO Council Information Security Line of Business and Security and Privacy Profile.
- The target ESA will support the cyber security requirements established by Federal and NRC regulations, statues, standards and guidance pertaining to NRC information 18
confidentiality, accessibility, availability and integrity.
- The "as-is" and target Enterprise Security Architectures shall enable rapid visibility into the current security posture of the NRG IT operational environment and provide insight into the desired security posture.
- The ESA shall enable the NRG to assess the maturity of the operational environment using the latest version of the SANS Institute Consensus Audit Guidelines.
- The ESA shall support the secure, efficient transaction of business and delivery of services.
The ESA shall support the Separation of Duties Principle.
- The Contractor shall develop and maintain the NRC Enterprise Security Architecture (ESA)
Principles and Framework to provide a continuing risk-based, defense-in-depth security architecture to protect the confidentiality, integrity and availability of the agency's sensitive information and information network(s) and systems.
- The Contractor shall ensure that the ESA is a subset of and maintains alignment with the NRG and the Federal Enterprise Architecture models.
- The Contractor shall develop and maintain the "as-is" architecture, the target or "to-be" architecture and the agency transition strategy to migrate from one to the other. The target architecture should project no more than 3 years into the future as technology continues an ever-tighter evolutionary cycle.
- The ESA shall be developed in conjunction with the NRC Strategic Plan, the NRG IT/ IM Roadmap and the current release of the NRC Technical Reference Model and IT Services Catalog.
- The Contractor shall use the current, published release of the Federal Enterprise Architecture and the Federal Segment Architecture Methodology in development of the NRG ESA.
The primary and alternate CORs will evaluate and measure Contractor progress and ESA capability maturity using, at a minimum, but not limited to, the most current, published release of the Government Accountability Office Document entitled "Organizational Transformation: A Framework for Assessing and Improving Enterprise Architecture Management". The most current release is Version 2.0. The Contractor is encouraged to incorporate this framework and their assessment for each of the deliverables as appropriate. Additionally, the Contractor shall meet with the primary and alternate CORs once per month to discuss status and challenges associated with this effort. The Contractor shall provide the following deliverables to the NRC in support of this work as follows: ESA Deliverable 1 - The Annual Enterprise Security Architecture (ESA) Project Plan - This plan shall describe the scope (requirements), time, cost, resources and risks associated with the development, sustainment and maturity of the ESA and all subsequent ESA task order deliverables. The Contractor shall use the NRC Management Directive 2.8 Project Management Methodology (PMM) to construct the Integrated Master Schedule. The NRC PMM leverages the IBM Rational Unified Process (RUP) four key life-cycle phases, inception, elaboration, construction and transition. The Integrated Master Schedule must provide sufficient 19
definition to track each sub-task against time, scope, resources, risks and quality. Each version of the annual plan will be reviewed and approved by the primary and alternate CORs, will be based-lined, and the Contractor shall provide updates to the primary and alternate CORs no less than once per quarter. ESA Deliverable 2 - The Enterprise Security Architecture (ESA) Charter and Communications Plan - The Contractor shall develop and update, with inputs from the primary and alternate CORs, those core NRG organizations that have a measurable requirement in the development, responsibility and communication of the Enterprise Security Architecture across the agency to facilitate its acceptance and institutionalization within each applicable NRC Office. . ESA Deliverable 3 - The Annual "as-is" Enterprise Security Architecture - The ESA shall use the Federal Segment Architecture Model to capture, articulate and report, at a minimum, but not limited to, the existing policies, security standards, standard operating procedures, services and components that form the agency's current cyber security infrastructure. The "as-is" ESA should be validated by the Contractor against the currently operational environment and the latest version of the NRC Technical Reference Model through manual and automated means available. ESA Deliverable 4 - The Annual Target Enterprise Security Architecture - Using the NRG Strategic Plan, the NRC IT Roadmap, the NRG Technical Reference Model, the CSO Residual Risk Reports, the NRG implementation maturity of the SANS Consensus Audit Guidelines as well as authoritative reports and information provided by NRG Offices, the NRC Office of the Inspector General, the Governmental Accounting Office, the Department of Homeland Security, the Department of Justice, the National Institute of Standards and Technology, the NRG Trusted Internet Connection (once operational), and the principles contained in this task and the ESA Charter, the Contractor shall use the Federal Segment Architecture Methodology to develop the Annual Target Enterprise Security Architecture. Each deliverable shall include a draft for comment and the Contractor shall meet with the primary and alternate CORs to discuss items that need improvement. 7.6.3 Vulnerability Assessments The Contractor shall conduct vulnerability assessments. A vulnerability assessment is an independent verification and validation of a system's security controls, cyber security requirements, technical resolutions, risk mitigations, and implementations that identifies the deficiencies and vulnerabilities that are present in the system. This helps the NRG determine levels of risk present in the system and if those risks are acceptable. The testing methodology, assumptions, constraints, and dependencies must be clearly stated up front so the results can be put into proper context. Also, the personnel, hardware, and tools used to perform the test must be identified. The Contractor shall ensure testing identifi~s any operational risks found that may affect the system's ability to perform its mission, protect its data (stored and transmitted), or make the NRC infrastructure vulnerable. The following test methods shall be used:
- Analysis - The "analysis" verification method shall be used to appraise a process, procedure, or document to ensure properly documented actions (e.g. risk assessments, 20
audit logs, organization level policies, etc.) are in compliance with established requirements. An example of "analysis" as an evaluation technique would be to review documented physical security policies and procedures to ensure compliance with established requirements. This verification method is often called a documentation review. Demonstration - The Contractor shall observe random individuals to verify that activities on the system follow the documented procedure or process as the activity is performed. For example, observe visitors upon computer room entry in order to verify that all visitation
- procedures are followed.
.. Interview - The Contractor shall interview personnel to verify the security policies and procedures are understood as implemented and prescribed by governing policies and regulations.
- Inspection - The Contractor shall ensure security controls have been properly implemented and maintained. For example, the Contractor shall verify that the visitor's name, signature, organization, reason of visit, arrival and departure date, time, and the escort's name, initials, or signature are included on the log sheets.
- Technical Test - The Technical Test verification method shall be used to verify that each implemented control is functioning as intended. For example, the Contractor shall attempt to access the system by logging on to the system from an end user workstation (or other device) using an incorrect password to see if the system responds with an error message stating an incorrect password has been entered or denies access after exceeding the maximum threshold for logon attempts.
Testing shall be accomplished using interviews, documentation reviews, or scanning depending on the security control being assessed. 7.6.4 Source Code Reviews The Contractor shall implement a program that gives the NRG the capability to s*can object files for vulnerabilities and deficiencies. Under this program two capabilities will be established:
- Developer Verification - The Contractor will evaluate auditing software used by NRC's IT system developers so flaws and inadequacies that exist in their source code can be identified, prioritized, and understood.
CSO Verification - NRG uses offsite software as service (SAAS) to provide code validation to ensure developed source code has been properly hardened and is resistant to known attacks. By utilizing these capabilities, the NRG will be able to develop a robust program that ensures customized source code is properly protected from attackers. 7.6.5 Penetration Testing The Contractor shall conduct external and internal ("red team" and "blue team") penetration tests and social engineering tests against the NRG infrastructure and its user community. The Contractor shall use a variety of testing tools, manual and automatic, including proprietary and modified open source, to attempt to penetrate NRG systems. The primary or alternate CORs must be present during all active penetration testing. The following steps shall be followed: 20
.J
- Phase 1: lnformation"Gathering - The Contractor shall gather information and perform an analysis identifying the touch points that need to be tested (for example: publically facing servers, routers, firewalls, gateways, remote access services, web applications, adherence to policies & standards, etc.).
- Phase 2: Testing Tools - The Contractor shall develop a Tools Report that identifies the automated tools that are going to be used for testing. The tools report must be approved by the primary or alternate CORs in writing before the Contractor can move on to the next phase.
The Contractor shall update all devices that are going to be used during the te,sts with the latest patches, security updates, device drivers, and plug-ins. The devices used during the tests will be wiped once the tests have been completed.
- Phase 3: Test Plan - The Contractor shall develop a detailed Test Plan that describes the penetration testing, and social engineering attacks that are going to be performed against the NRG. The Test Plan must be approved in writing by the primary or alternate CORs before any testing can be initiated. The Test Plan will answer the following questions:
- Who will be performing the test? - What tools are going to be used? - What tests are going to be run against the NRC's automated information systems and user community? - When are the tests going to be run (date and time)? - Where will the tests be conducted from? - How are NRG automated information systems and users going to be affected? - How is Contractor going to identify the risk?
- Phase 4: Testing - The Contractor shall perform external penetration testing, internal penetration testing, and social engineering attacks against the NRG under observation by a designated government official. All raw scans, observations, and testing results shall be captured and documented in the corrective action report.
- Phase 5: Test Result Report - The Test Result Report shall contain but will not be limited to the following:
- Summarize how each test was performed and how the risk was evaluated. - Identify each type of test that was run (external penetration test, internal penetration test, and social engineering attack). - Specify the hosts/users that were tested and the information systems/organizations they belonged to - Describe the vulnerabilities and deficiencies that were discovered during testing. - Identify the risks associated with these vulnerabilities and deficiencies. Risks will be organized with the most significant risk listed first. - Provide recommendations on how to mitigate these risks. A recommendation will be provided for every risk.
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.. Phase 6: Cleanup - The Contractor shall wipe all devices used during testing and certify in writing that the task was completed. All Contractors associated with this task order will sign non-disclosure agreements and not publish, discuss or otherwise communicate the test findings to individuals outside the NRG without rewritten authorization by the Government. All testing must be approved in writing by the primary or alternate CORs. The Contractor will not conduct any testing without written approval from the primary or alternate CORs and without being under the primary or alternate COR's observation. 7.6.6 Security Impact Assessments The Security Impact Assessment (SIA) process helps determine the necessary steps a system owner must take to incorporate a change into an NRG approved information system. The system owner must summarize the change by filling the SIA form, send that form to the CSO for review, and finally the CSO informs the system owner on what must be done to ensure the change does not negatively impact the security posture of the information system or NRG infrastructure. The Contractor will assist NRG system owners in gathering information, filling out the SIA forin, and interpreting guidance from the primary or alternate CORs on what needs to be done. Representative types of activities that may be required include: Updating Security Categorization Packages
- Updating Authorization documents
- Conducting a tailored ST&E that includes only the changes that are made to the system
- Developing a vulnerability assessment report that describes the technical risks associated with the change
- Assessing how the change impacts other NRC information systems or the NRG infrastructure 7.7 Policy, Standards, and Training The Contractor shall provide the following services.
7.7.1 Cyber Security Policy The Contractor shall support the NRC efforts to ensure that all aspects of Management Directive and Handbook (MD) 12.5 properly address Federally mandated requirements, (through gap analyses, vulnerability assessments, etc.), properly communicated to the NRC user community, and kept up-to-date as new exploits, vulnerabilities, and technologies are introduced. MD 12.5 utilizes the policy framework developed by the International Organization for Standardization (ISO)/lnternational Electrotechnical Commission (IEC) Standard 27002:2005(E). This framework is broken into 12 primary areas. Each area contains a number of main security categories, which are listed below:
- Access Control
- Business requirements for access controls - Access control policy. - User access managements - User registration, privilege management, user password management, and review of user access rights.
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- User responsibilities - Password use, unattended user equipment, and clear desk/
screen policy. Network access control - Policy on use of network services, user authentication for external connections, equipment identification in networks, remote diagnostic and configuration port protection, segregation in networks, network connection control, and network routing control.
- Operating system access control - Secure log-on procedures; user identification and authentication; password management system; use of system utilities; session time-out; and limitation of connection time. - Application and information access control - Information access restriction and sensitive system isolation. - Mobile computing and teleworking - Mobile computing and teleworking policy.
Asset Management
- Responsibility for assets - Inventory of assets, ownership of assets, and acceptable use of assets. - Information classification - Classification guidelines and information labeling and handling.
Business Continuity
- Security aspects of business continuity management - Including security in the business continuity management process; business continuity and risk assessment; developing and implementing continuity plans; business continuity planning framework; and testing, maintaining and re-assessing business continuity plans.
- Communications and Operations Management
- Operational procedures and responsibilities - Documented operating procedures; change management; segregation of duties; and separation of development, test, and operational facilities. - Third party service delivery management - Service delivery; monitoring and review of third party services; and managing changes to third party services. - System planning and acceptance - Capacity management and system acceptance. - Protection against malicious and mobile code- Controls against malicious code and controls against mobile code. - Backup - Information backup. - Network security management - Network controls, and security of network services. - Media handling - Management of removable media, disposal of media, information handling procedures, and security of system documentation. - Exchange of information - Information exchange policies and procedures; exchange agreements; physical media in transit; electronic messaging; and business information systems. -
- Electronic commerce services - Electronic commerce, on-line transactions, and publicly available information.
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- Monitoring - Audit logging; monitoring system use; protection of log information; administrator and operator logs; fault logging; and clock synchronization.
- Compliance
- Compliance with Legal Requirements - Identification of applicable legislation; intellectual property rights (IPR); protection of organizational records; data protection and privacy of personal information; prevention of misuse of information processing facilities; and regulation of cryptographic controls. - Compliance with Policies, Standards, and Guidance - Compliance with security policies and standards and technical compliance checking. - Information System Audit Considerations - Information systems audit <;:ontrols and protection of information systems audit tools.
- Human Resource Security ,
- Prior to employment - Roles and responsibilities; screening; and terms and conditions of employment. - During employment - Management responsibilities; security awareness; education and training; and disciplinary process. - Termination or change of employment - Termination responsibilities, return of assets, and removal of access rights.
- Incident Management
- Reporting security events and weaknesses - Reporting security events and reporting security weaknesses. - Management of security incidents and improvements - Responsibilities and procedures; learning from security incidents; and collection of evidence.
- Information Systems Acquisition, Development, and Maintenance
- Cyber security requirements for information systems - Cyber security requirements analysis and specification. - Correct processing in applications - Input data validation, control of internal processing, message integrity, and output data validation. - Cryptographic controls - Policy on the use of cryptographic controls and key management. - Security of system files - Control of operational software, protection of system test data, and access control to program source code. - Security in development and support processes - Change control procedures, technical review of applications after operating system changes, restrictions on changes to software packages, information leakage, and outsourced software development.
Technical vulnerability management - Control of technical vulnerabilities. Organization
- Internal - Management commitment to cyber security, cyber security coordination, allocation of cyber security responsibilities, authorization process for information 24
processing facilities, confidentiality agreements, contact with authorities, contact with special interest groups, and independent review of cyber security.
- External - Identification of risks related to external parties, addressing security when dealing with customers, and addressing security in third party agreements.
Physical and Environmental Security
- Secure areas - Physical security perimeter; securing offices, rooms, and facilities; protecting against external and environmental threats; working in secure areas; and public access, delivery, and loading areas. - Equipment security - Equipment siting and protection; supporting utilities; cabling security; equipment maintenance; security of equipment off-premises; secure disposal or re-use of equipment; and removal of property.
Risk Assessment
- Assessing security risks - Treating security risks
- Security Policy
- Security policy document Review security policy 7.7.2 Processes, Procedures, Templates, Checklists, Standards, and Guidance The Contractor shall develop processes, procedures, templates, checklists, standards, and guidance to support the establishment and maintenance of NRC's Cyber Security Program.
Each documentmust comply with the required format for the document type. The required format is provided on the applicable CSO internal web page. The Contractor is expected to establish and maintain documents that will focus on the following aspects of the program:
- Access Control
- Security Awareness and Training
- Auditing and Accountability Certification, Accreditation, and Security Assessments
- Configuration Management
- Contingency Planning Identification and Authentication Incident Response
- Maintenance
- Media Protection
- Physical and Environmental Protection
- Planning
- Personnel Security Risk Assessment
- System Services and Acquisition System and Communications Protection
'
- System and Information Integrity These documents must take into account the following:
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- Different types of information systems that the NRC utilizes:
- Publicly facing systems - Large enterprise systems - Small systems supporting specific business needs - Legacy systems that are beyond their life cycle - Systems supporting new technologies
- Information sensitivities for confidentiality, integrity, and availability (FIPS 199 for unclassified systems, CNSS and DNI levels for classified systems)
- Different types of information that the NRC must protect:
- Unclassified Non-Safeguards Information - SGI - Classified Information 7.7.3 Security Relevant Business Solutions The Contractor shall identify and document technical electronic processing solutions that enable secure NRC business processes. These technical solutions may include introduction of new technology or may alter current electronic processing methods for security reasons and may result in more efficient processing. The business solutions shall be documented as NRC Cyber Security standards, processes, procedures, templates, and/or checklists, and shall provide sufficient information for implementation by technically knowledgeable individuals.
7.7.4 Cyber Security Awareness Program In order to comply with FISMA, the NRC must provide Cyber Security awareness courses to all individuals who have access to NRC information systems or have access to NRC data., The NRC utilizes computer based security awareness courses to meet this federally mandated requirement. The NRC currently has a computer based security awareness course for general users that is updated annually by a Federal Information Systems Security Line of Business (LOB). The Contractor shall develop, maintain, and update Cyber Security awareness courses to supplement the LOB general awareness course using current electronic training methods to ensure that federally mandated and NRC defined cyber security requirements are satisfied. The courses shall use current technologies such as those used in the current Federal Information Systems Security LOB for security awareness training and shall operate within the NRC Learning Management System (LMS). All courses must be Sharable Content Object Reference Model (SCORM) compliant and may be customized to meet the needs of the NRC. An "Awareness" course should be completed by the user in an average time of 1 hour or less (excluding any test). Course completion tracking shall be maintained by the NRG LMS with reports available on-line and downloadable. 26
7.7.4.1 Course Descriptions _ The NRC General User Awareness course is comprised of federally provided general user awareness content and NRC provided SGI awareness content. Together these convey NRC's Cyber Security relevant requirements for electronic SGI information. The Contractor shall be responsible for ensuring that the NRC SGI content and the federally provided general user awareness content are properly integrated . . At a minimum, the SGI content shall address the following:
- User Authentication Methods End user responsibilities Electronic media Electronic handling, access and storage
- Use of E-Mail
- Use of mobile devices
- Malicious actor techniques, such as social engineering
- Social networking security considerations Note: Other topics may be added later as additional requirements become known.
7.7.5 Cyber Security Role-based Training Program In order to comply with FISMA, the NRC must provide Cyber Security role-based training to all fndividuals with significant security responsibilities. The Contractor will develop and deliver courses that address all FISMA requirements and ensure all course materials are kept up-to-date. The NRC role-based training program currently contains the following courses: Role-based Training for ISSOs This course is for system and office ISSOs and at a minimum covers the following topics:
- 1880 role in relation to other NRG roles and positions - Information technology initiatives - 1880 roles and responsibilities - Role separation - Procurement - Threats - Vulnerabilities - Risk management - Operational, management, and technical security controls - Planning 27
- Site/system security plans - Authorization to Operate - Continuous monitoring - Incident reporting - Continuity of operations Role-based Training for System Administrators of Windows-Based Systems This course is for Windows System Administrators and at a minimum covers the following *topics: - Security configuration guidelines - NRG policies and procedures - Authorization to Operate - Vulnerabilities - Threats - Auditing - Continuous Monitoring - Incident response Note: A portion of this class is devoted to hands-on exercises that guide students in implementing current security configuration requirements for Microsoft Windows servers and workstations.
- Role-based Training for System Administrators of Linux/Unix-Based Systems This course is for Linux/Unix System Administrators and at a minimum covers the following topics:
- Security configuration guidelines - NRG policies and procedures - Authorization to Operate - Vulnerabilities - Threats - Auditing - Continuous Monitoring - Incident response Note: A portion pf this class is devoted to hands-on exercises that guide students in implementing current security configuration requirements for Microsoft Windows servers and workstations.
- Role-based Training for Senior IT Managers and System Owners 28
This course is for Senior IT Managers and Systems Owners and at a minimum covers the following topics:
- Federal and NRG policies, guidance, regulations and requirements - NRG FISMA results - Office of Inspector General (OIG) audits and other NRG auditing or inspection reports - Planning - Procurement - Security in the life-cycle - Role separation - Risk management - System security plans - Vulnerabilities - Threats - Security Controls - Authorization to operate - Continuous monitoring
- Role-based Training for the DAA This course is for individuals with DAA responsibilities and must include information 1
that describes the role and responsibilities for all levels of systems. Note: The course topics must be related to NRC examples and designed at a high level to help senior level managers and executives ev~luate the components of an IT security program with regard to critical business functions and the NRC's specific IT requirements as well as understand their role as it relates to other NRC roles and positions.
- Role-based Training for Senior Level Managers and Executives This course is for Senior Level Managers and Executives and at a minimum covers the following topics:
- Federal and NRG policies, guidance, regulations and requirements - NRG FISMA results - Office of Inspector General (OIG) audits and other NRG auditing or inspection reports - Overview of the Authorization - Role separation
/ - Risk management
- Vulnerabilities - Threats 29
- Security Controls - Authorization to operate Note: The course topics must be related to NRC examples and designed at a high level to help senior level managers and executives evaluate the components of an IT security program with regard to critical business functions and the NRC's specific IT requirements as well as understand their role as it relates to other NRC roles and positions.
7.7.6 Cyber Security Conference Upon request of the primary or alternate CORs, the Contractor shall support them with the implementation of an annual Cyber Security conference, to include multiple tracks addressing both IT security awareness and in-depth role-based Cyber Security information. The attendees of the conference will be NRC staff and Contractors. Conference duration shall be no more than three (3) days in length. The objective of the conference will be to increase staff knowledge and understanding of Cyber Security. The Contractor shall provide the staff necessary to run three (3) possibly concurrent conference tracks, for example:
- IT Security for the general user, focusing on understanding the reason for Cyber Security IT Security for Cyber Security implementers (e.g., ISSOs, system administrators, developers)
- IT Security for Managers and Executives A variety of methods and techniques should be used to enable understanding of the message across the conference tracks.
Basic administrative functions for the conference (e.g., arrangement for physical space, physical conference set-up and tear-down) shall be provided using another NRG resource. 7.7.6.1 Place of Performance The primary or alternate CORs will identify the physical location where the Security Conference will be held at least 3 months in advance. 7.7.6.2 Provided Services The Contractor shall provide trainers in the field of Cyber Security who have experience supporting and providing training in the following areas:
- Operating Systems _,(b)(l)(E)
!(b)(7)(E)
- A lications (b)(l)(E)
(b)(7)(E) (b)(7)(E) Information Assurance - Network Engineering, Network Monitoring, Active Directory, Intrusion Detection Systems (IDS)/ Intrusion Prevention Systems (IPS), Firewalls, Virtual 30
Private Networking (VPN), Public Key Infrastructure (PKI), Wireless, Remote Access Systems (RAS), Malware, Spyware, and Penetration Testing. 7.7.7 Electronically Communicating Cyber Security Information The Contractor shall work with the primary and alternate CORs to enhance user knowledge of Cyber Security. This effort will focus on raising the level of Cyber Security understanding of all NRG staff and Contractors. The Contractor shall develop a monthly security newsletter that summarizes changes in policies and requirements and keeps the reader apprised of the current risks and threats that are being seen inside and outside the NRG. The Contractor shall review the security awareness program annually and provide recommendations to the NRG on how the program can be more effective and reach a wider audience. The Contractor shall assist the CSO in establishing and maintaining their web site. 8 IT CYBER SECURITY REQUIREMENTS - GENERAL 8.1 Basic Contract Cyber Security Requirements For unclassified information used for the effort, the Contractor shall provide an information security categorization document indicating the sensitivity of the information processed as part of this contract if the information security categorization was not provided in the statement of work. The determination shall be made using NIST SP 800-60 and must be approved by the primary or alternate COR in writing. The Contractor shall notify the primary and alternate CORs in writing immediately before the Contractor begins to process information at a higher sensitivity level. If the effort includes use or processing of classified information, the NRG Contracting Officer, primary and alternate CORs shall be notified beforerthe Contractor begins to process information at a more restrictive classification level. All work under this task order shall comply with the latest version of all applicable guidance and standards. These standards include, but are not limited to, NRG Management Directive (MD) volume 12 Security, Cyber Security policies issued until MD 12.5, NRG Cyber Security Program is updated, National Institute of Standards and Technology (NIST) guidance and Federal Information Processing Standards (FIPS), and Committee on National Security Systems (CNSS) policy, directives, instructions, and guidance. This information is available at the following links: NRG Policies, Procedures and Standards (CSO internal website): http://www.internal.nrc.gov/CSO/policies.html NRG Policy and Procedures for Handling, Marking and Protecting Sensitive Unclassified Non-Safeguards Information (SUNSI): http://www.internal.nrc.gov/sunsi/pdf/SUNSI-Policy-
- Procedures.pdf All NRG Management Directives (public website): http://www.nrc.gov/readinq-rm/doc-collections/manaqement-directives/
NIST SP and FIPS documentation is located at: http://csrc.nist.gov/ 31
CNSS documents are located at: http://www.cnss.gov/ The Contractor shall ensure compliance with the latest version of CNSS publications, NIST guidance, and FIPS standards available at contract issuance and continued compliance with the latest versions within one year of the release date. When e-mail is used, the Contractors shall only use NRG provided e-mail accounts to send and receive sensitive information (information that is not releasable to the public) or mechanisms to protect the information during transmission to NRC that have been approved by CSO. All Contractor personnel must sign the NRG Agency Rules of Behavior for Secure Computer Use prior to being granted access to NRG computing resources. The Contractor shall adhere to following NRG policies:
- NRC Management Directives
- NRG Sensitive Unclassified Non-Safeguards Information (SUNSI)
- Cyber Security Policy for Encryption of Data at Rest When Outside of Agency Facilities
- Policy for Copying, Scanning, Printing, and Faxing SGI & Classified Information
- Cyber Security Information Protection Policy
- Remote Access Policy
- Use of Commercial Wireless Devices, Services and Technologies Policy
- Laptop Security Policy
- Cyber Security Incident Response Policy Contractor shall adhere to NRG's prohibition of use of personal devices to process and store NRG sensitive information.
All electronic process of NRG sensitive information, including system development and operations and maintenance performed at non-NRG facilities shall be in facilities, networks, and computers that have been accredited by NRG for processing information at the highest sensitivity of the information that is processed or will ultimately be processed. 8.2 Contract Performance and Completion The Contractor shall ensure that the NRC data processed during the performance of this task order is purged from all data storage components of the Contractor's computer facility. Tools used to perform data purging shall be approved by the primary or alternate CORs in writing. The Contractor shall provide written certification to the NRC Contracting Officer that the Contractor does not retain any NRC data within 30 calendar days after contract completion. Until all data is purged, the Contractor shall ensure that any NRC data remaining in any storage component will be protected to prevent unauthorized disclosure. When Contractor personnel no longer require access to an NRC system, the Contractor shall notify the primary I and alternate CORs within 24 hours. 32
Upon task order completion, the Contractor shall provide a status list of all NRC system users and shall note if any users still require access to the system to perform work if a follow-on contract or task order has been issued by NRG. 8.2.1 Control of Information and Data The Contractor shall not publish or disclose in any manner, without the Contracting Officer's written consent, the details of any security controls or countermeasures either designed or developed by the Contractor under this task order or otherwise provided by the NRG. Any IT system used to process NRG sensitive information shall:
- 1) Include a mechanism to require users to uniquely identify themselves to the system before beginning to periorm any other actions that the system is expected to provide.
- 2) Be able to authenticate data that includes information for verifying the claimed identity of individual users (e.g., passwords)
- 3) Protect authentication data so that it cannot be accessed by any unauthorized user
- 4) Be able to enforce individual accountability by providing the capability to uniquely identify each individual computer system user
- 5) Report to appropriate security personnel when attempts are made to guess the authentication data whether inadvertently or deliberately.
8.3 Access Controls Any Contractor system being used to process NRG data shall be able to define and enforce access privileges for individual users. The discretionary access controls mechanisms shall be configurable to protect objects (e.g., files, folders) from unauthorized access. The Contractor system being used to process NRG data shall provide only essential capabilities and specifically prohibit and/or restrict the use of specified functions, ports, protocols, and/or services. The Contractors shall only use NRG approved methods to send and receive information considered sensitive or classified. Specifically, *
- 1) Classified Information - All NRC Classified data being transmitted over a network shall use National Security Agency (NSA) approved encryption and adhere to guidance in MD 12.2 NRG Classified Information Security Program, MD 12.5 NRG Automated Information Security Program and Committee on National Security Systems. Classified processing shall be only within facilities, computers, and spaces that have been specifically approved for classified processing.
- 2) SGI Information - All SGI being transmitted over a network'shall adhere to guidance in MD 12.7 NRC Safeguards Information Security Program and MD 12.5 NRC Automated Information Security Program. SGI processing shall be only within facilities, computers, and spaces that have been specifically approved for SGI processing. Cryptographic modules provided as part of the system shall be validated under the Cryptographic Module Validation Program to conform to NIST FIPS 140-2 overall level 2 and must be operated in FIPS mode.
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The Contractor shall provide the FIPS 140-2 cryptographic module certificate number and a brief description of the encryption module that includes the encryption algorithm(s) used, the key length, and the vendor of the product. The most restrictive set of rights/privileges or accesses needed by users (or processes acting on behalf of users) for the performance of specified tasks must be enforced by the system through assigned access authorizations. Separation of duties for Contractor systems used to process NRG information must be enforced by the system through assigned access authorizations. The mechanisms within the Contractor system or application that enforces access control and other security features shall be continuously protected against tampering and/or unauthorized changes. 8.4 Configuration Standards All systems used to process NRG sensitive information shall meet NRG configuration standards available at: http://www.internal.nrc.gov/CSO/standards.html. 8.5 Media Handling All media used by the Contractor to store or process NRC information shall be controlled in accordance with the sensitivity level. The Contractor shall not perform sanitization or destruction of media approved for processing NRC information designated as SGI or Classified. The Contractor must provide the media to the primary and alternate CORs for destruction. 8.6 Vulnerability Management The Contractor must adhere to NRC patch management processes for all systems used to process NRC information. Patch Management reports will made available to the NRC upon request for following security categorizations and reporting timeframes:
- Five (5) calendar days after being requested for a high sensitivity system
- 1O calendar days after being requested for a moderate sensitivity system 15 calendar days after being requested for a low sensitivity system For any Contractor system used to process NRC information, the Contractor must ensure that information loaded into the system is scanned for viruses prior to posting; servers are scanned for viruses, adware, and spyware on a regular basis; and virus signatures are updated at the following frequency:
- One ( 1) calendar day for a high sensitivity system
- Three (3) calendar days for a moderate sensitivity system
- Seven (7) calendar days for a low sensitivity system 9 CORRECTIVE ACTIONS 34
Issues requiring corrective action shall be identified in a Contract Discrepancy Report (CDR) issued by the primary or alternate CORs. Compliance will be monitored by the NRC through Draft Deliverables, Final Deliverables, Project Schedules, Progress Reports, and primary and alternate COR review of related NRG Customer Satisfaction Surveys.
- i. Target: Three (3) business days of the CDR issuance meeting ii. Data Source: Draft Deliverables, Final Deliverables, Project Schedules, Progress Reports, and NRG Project Officers reviews of related NRG Customer Satisfaction Surveys iii. Frequency: As needed upon issuance of a CDR iv. Exceptions: The duration will be determined from the time of CDR issuance meeting. The three (3) business day corrective action time will not include time in which the Contractor is waiting on the NRG for data necessary to perform the corrective action.
10 DELIVERABLE STANDARDS The following standards shall be enforced for all deliverables developed under this task order. 10.1 Deliverable File Formats The Contractor shall provide all documentation to the primary and alternate CORs electronically via electronic mail in all the following formats, except as specifically stated herein: Microsoft Word (version 2010), Microsoft Excel (version 2010), Microsoft Project (version 2010), and Adobe PDF. All electronic mail shall be transmitted using the Contractor's NRC electronic mail . account. Personal and corporate electronic mail accounts shall not be used to transmit or to receive sensitive NRG information. 10.2 Standard for Grammar and Mechanics All documentation submitted by the Contractor shall conform to the Chicago Manual of Style, as amended by any applicable NRG format templates and requirements. 10.3 Draft and Final Submission All task order deliverables submitted to the primary and alternate CORs must conform to the standards referenced in this SOW and will be reviewed by the primary and alternate CORs for acceptability. All documentation shall be submitted in draft form for comment to the primary and alternate CORs. The primary or alternate CORs will be given ten up to (10) business days to generate comments and submit them in writing to the Contractor. Once the Contractor receives the primary or alternate COR's written comments, the Contractor shall have three (3) business days to generate the final draft version of the document. Then, the final draft shall be sent to the primary or alternate CORs for review and approval. Once the final draft has been accepted by the primary or alternate CO Rs, the Contractor will be given one (1) business day to revise the document. This constitutes a revision cycle. The first revision cycle for a deliverable shall be acceptable to the Government when the Contractor submits a revised deliverable incorporating any comments and suggestions made by the primary or alternate CORs. 35
The following provisions also apply to all deliverables: Publication of Results: Prior to any dissemination, display, publication or release of articles, reports, summaries, data or related documents developed under the contract, the Contractor shall submit for review and approval by the Contracting Officer the proposed articles, reports, summaries, data and related documents that the Contractor intends to release, disseminate or publish to other persons, the public or any other entities. The Contractor shall not release, disseminate, display or publish articles, reports, summaries, data, and related documents or the contents therein that have not been reviewed and approved by the Contracting Officer for release, display, dissemination or publication. The Contractor agrees to conspicuously place any disclaimers, markings or notices directed by the NRG on any articles, reports, summaries, data and related documents that the Contractor intends to release, display, disseminate or publish to other persons, the public or any other entities.
- Identification/ Marking of Sensitive and SAFEGUARDS Information: The decision, determination or direction by the COR that information constitutes sensitive or SAFEGUARDS information remains exclusively a matter within the authority of the COR to make. In performing this task order, the Contractor shall clearly mark sensitive unclassified non-SAFEGUARDS information (SUNSI), sensitive, and SAFEGUARDS information to include for example Official Use Only and SAFEGUARDS Information on any reports, documents, designs, data, materials and written information as directed by the NRG. In addition to marking the information as directed by the COR, the Contractor shall use the applicable NRG cover sheet forms (e.g. NRG Form 461 SAFEGUARDS Information and NRG Form 1908 Official Use Only) in maintaining these records and documents. The Contractor shall ensure that sensitive and SAFEGUARDS information is handled appropriately, maintained and protected from unauthorized disclosure. The Contractor shall comply with the requirements to mark, maintain and protect all information including documents, summaries, reports, data, designs, and materials in accordance with the provisions of Section 147 of the Atomic Energy Act of 1954 as amended, its implementing regulations (10 CFR 73.21 ), and NRG Management Directive and Handbook 12.6.
- Remedies: In addition to any civil, criminal and contractual remedies available under the applicable laws and regulations, failure to comply with the above provisions and or COR's directions may result in suspension, withholding or offsetting of any payments invoiced or claimed by the Contractor. If the Contractor intends to enter into any subcontracts or other agreements to perform this contract, the Contractor shall include all the above provisions in this Section 11.3 of the SOW in any subcontract or agreements.
10.4 Deliverable Reviews Deliverable Reviews will be held to provide the Contractor with feedback related to improving the quality of deliverables, including feedback received from Customer Satisfaction Surveys. Such reviews will be coordinated by the primary or alternate CORs as required to supplement written comments provided on deliverable submissions. The written minutes of all deliverable review meetings shall be prepared by the Government. Should the Contractor not concur with the minutes, the Contractor shall so state any areas of non-concurrence in writing to the primary or alternate CO Rs in writing within 10 calendar days of receipt of the minutes. 11 REPORTING REQUIREMENTS The Contractor must meet the following reporting requirements. 36
11.1 B\-Weekly Funding Report The bi-Weekly Funding Reports must be submitted to the primary and alternate CORs no later than close of business Tuesday. Bi-Weekly Funding Reports shall cover all Contractor activity tha( occurred during the previous two (2) calendar weeks. Bi-Weekly Funding Reports shall identify spending at the 2nd level of the WBS. For each activity being performed under the contract, the following information will be reported.
- Office - Name of the sponsoring office.
- Activity- Name of the activity being performed.
- Budget - Funds obligated to support the activity.
- Money Spent - Amount of funds used to date.
Money Remaining - Amount of funds remaining.
- Remaining Labor - Amount of funds remaining for labor.
- Remaining ODC - Amount of funds remaining for other than direct cost items like travel 11.2 l\.'.lonthly Progress Report Monthly Progress Reports must be submitted to the primary and alternate CO Rs no later than close of business on the 5th business day of the month. Monthly Progress Reports shall cover all Contractor activity that occurred during the previous month. Monthly Progress Reports must be submitted on the Contractor's letterhead.
11.3 Other Reporting Requirements The Contractor shall bring problems or potential issues affecting performance to the attention of the primary and alternate CORs and Contracting Officer as soon as possible. Verbal reports shall be followed up with written reports and meetings. 12 MEETINGS The following meetings will be required under this task order: Post Award Conference The Government will schedule a kick-off meeting once the Contractor's designated personnel have received their security clearance authorization. The NRC will provide an agenda prior to the meeting. The Contractor shall participate in the meeting to establish processes, procedures, and priority of tasking. The Contracting Officer and the primary or alternate CORs will represent the Government. The Contractor shall have equivalent representation at the meeting. The Contractor will be responsible for taking the minutes of this meeting. The minutes will be documented using Microsoft Word. The Contractor must send the minutes to the primary and alternate CORs for their review and approval within three (3) business days.
- Bi-Weekly Meetings (first six (6) months)
During the first six (6) months of the contract, the Contractor shall meet with the primary or alternate CORs every two (2) weeks to discuss concerns or challenges that are currently being experienced on the contract. The primary and alternate CORs, and Contractor, shall 37
jointly develop the agenda to ensure issues are addressed, deadlines are known, and direction can be provided to resolve any known issues. The Contractor shall be responsible for taking the minutes of this meeting. The minutes will be documented using Microsoft Word. The Contractor must send the minutes to the primary and alternate CORs for their review and/or approval within three (3) business days.
- Monthly Meetings (monthly)
After six (6) months, the Contractor shall meet with the primary or alternate CORs monthly to discuss concerns or challenges that are currently being experienced on the contract. The primary or alternate CORs and the Contractor shall jointly develop the agenda to ensure issues are addressed, deadlines are known, and direction can be provided to resolve any known issues. The Contractor will be responsible for taking the minutes of this meeting. The minutes shall be documented using Microsoft Word. The Contractor must send the minutes to the primary and alternate CORs for review and/or approval within three (3) business days.
- Quarterly Meetings (quarterly)
After twenty four months, the monthly meetings shall be replaced with Quarterly Meetings. The Contractor shall meet with the primary or alternate CORs quarterly to discuss concerns or challenges that are currently being experienced on the contract. The primary or alternate CORs and the Contractor shall jointly develop the agenda to ensure issues are addressed, deadlines are known, and direction can be provided to resolve any known issues. The Contractor will be responsible for taking the minutes of this meeting. The minutes shall be documented using Microsoft Word. The Contractor must send the minutes to the primary and alternate CORs for review and/or approval within three (3) business days.
- Ad Hoc Meetings Either party may request an ad hoc meeting. The calling party must provide an agenda and a summary description of what is to be discussed 48 business hours before the meeting is held. The Contractor will be responsible for taking the minutes of this meeting. The minutes shall be documented using Microsoft Word. The Contractor must send the minutes to the primary and alternate CO Rs for their review and/or approval within three (3) business days.
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