ML20169A428

Jun 10 SR ITS Public Meeting Summary 6 17 2020

ML20169A428
Person / Time
Issue date:	06/17/2020
From:	Eric Lee NRC/NSIR/DPCP/CSB
To:	Jim Beardsley NRC/NSIR/DPCP/CSB
Lee E, 301-287-3461
References
NEI 10-04, NEI-13-10
Download: ML20169A428 (5)

Text

June 17, 2020 MEMORANDUM TO: James Beardsley, Branch Chief Cyber Security Branch Division of Physical and Cyber Security Policy Office of Nuclear Security and Incident Response FROM: Eric Lee, Senior Cyber Security Specialist /RA/

Cyber Security Branch Division of Physical and Cyber Security Policy Office of Nuclear Security and Incident Response

SUMMARY

OF CATEGORY 2 PUBLIC MEETING ON JUNE 10, 2020 WITH INDUSTRY STAKEHOLDERS AND THE NUCLEAR ENERGY INSTITUTE WHITE PAPER, "CHANGES TO NEI 10-04 AND NEI 13-10 GUIDANCE FOR IDENTIFYING AND PROTECTING DIGITAL ASSETS ASSOCIATED WITH SAFETY-RELATED AND IMPORTANT-TO-SAFETY FUNCTIONS,"

DATED MAY 2020 On June 10, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a two-hour Category 2 public meeting with the Nuclear Energy Institute (NEI) and other stakeholders. The meeting was conducted virtually. The purpose of the meeting was to provide an opportunity for the public and stakeholders to provide feedback regarding NEI's white paper entitled, Changes to NEI 10-04 and NEI 13-10 Guidance for Identifying and Protecting Digital Assets Associated with Safety-Related and Important-to-Safety Functions, Dated May 2020 (ML20139A190). The attendees who wished to be included in the meeting summary were instructed to send their names and respective organizations to eric.lee@nrc.gov. The enclosure provides the list of attendees.

Following introductory remarks by the NRC staff and industry, Stephen Flickinger from Exelon provide an overview of the white paper for industry.

Following the industry brief on the NEI white paper, staff provided the following four comments were provided for NEI consideration:

1. The white paper proposed to delete Appendices A and B from the current version of NEI 10-04. The appendices include examples of safety-related and important-to-safety systems and equipment. These examples provided helpful and useful information. NEI should consider revising the appendices rather than deleting them.

2. The white paper defined the term support system. However, the definition of support system is beyond the scope of this white paper, which provides clarification on the systems and equipment associated with safety-related and important-to-safety functions.

Therefore, if the industry wants to define the term support system, the industry should do so separately from this effort.

3. Revise the following two terms:

a. Identification Step 5 on Pages 6 and 16 - Replace the term a failure with the term a compromise by cyber attack. This is to be consistent with the Rule.

b. Identification Step 7 on Pages 6 and 17 - Replace the term i.e., with the term e.g., The current term limits potential changes in the future.

4. The term important-to-safety is not defined in the NRC regulation. Thus, the paper should consider adding a sentence that states that this guidance document does not define the term important-to-safety, rather it references how the term was used previously.

Following the staff feedback, the meeting was opened for public questions and answers and no additional comments or questions were raised. Following the meeting, the staff identified on additional comment. The white paper could be interpreted to eliminate any balance of plant (BOP) digital assets including the BOP digital assets that are regulated by the NRC per the Memorandum of Agreement (MOA) with the Federal Energy Regulatory Commission and the Memorandum of Understanding (MOU) with the North American Electric Reliability Corporations as described in NEI 10-04. Therefore, the paper should address the inclusion of BOP systems.

Following the public comment period, the Richard Magavero from NEI stated that the NEI evaluate staff feedback following issuance of the meeting summary.

CONTACT: Eric Lee, NSIR/DPCP/CSB 301-287-3461

Enclosure:

Attendees List

ML20169A428 *via e-mail OFFICE NSIR/DPCP/CSB NSIR/DPCP/CSB/BC NAME ELee* JBeardsley*

DATE 06/17/2020 06/17/2020 List of Public Meeting Attendees Name Organization Charity Pantalo NRC Brian Yip NRC Mario Fernandez NRC Richard A. Skokowski NRC Daniel Warner NRC Eric Lee NRC Juris Jauntirans NRC George M. Hausman NRC Ismael Garcia NRC James Beardsley NRC Russell Felts NRC Glenn Dentel NRC Sam Graves NRC George Hausman NRC Kim Holloway NRC Kim Lawson-Jenkins NRC Blake Purnell NRC Scott Shaeffer NRC Dariusz Szwarc NRC Nick Taylor NRC Shakur Walker NRC Michael Water NRC William Johns OASIS (NRC Contractor)

Kimberlee Edwards OASIS (NRC Contractor)

Cynthia DeBisschop OASIS (NRC Contractor Alan Konkal OASIS (NRC Contractor Mac Carey OASIS (NRC Contractor)

Stephen Flickinger Exelon Nathan Faith Exelon David Neff Exelon William Gross NEI Richard Mogavero NEI Jim Shank PSEG Chad Davis Talen Energy, Susquehanna Nuclear, LLC Lincoln M Goede Xcel Energy Jan A. Geib, Dominion Energy Jason Castro Nuclear Cyber Security Jamie Christian FPL Ralph Branscomb FPL Barry Westreich Westreich Group LLC Tony W. Martin BWX Technology Inc.

Kathy Paez St. Lucie Nuclear Power Plant Kevin Deyette Nuscale Jesse E. Smith Utilities Service Alliance Enclosure

Jana Bergman Curtiss-Wright Adam Goodman Duke Energy Gary B. Locklear Kinectrics Dave Feitl Xcel Energy Amy Altman Westinghouse Pamela Frey Susquehanna Nuclear Station, LLC Eugene Keller Susquehanna Nuclear Station, LLC Don Robinson Dominion Energy, Inc