ML22259A084

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Enclosure 1 - NRC Staff Comment Table
ML22259A084
Person / Time
Issue date: 09/30/2022
From: Dan Warner
NRC/NSIR/DPCP/CSB
To:
Warner D
Shared Package
ML22259A076 List:
References
Download: ML22259A084 (3)


Text

Enclosure NRC Staff Comments on NEI 15-09, Cyber Security Event Notifications, Revision 1, Dated May 2022 NEI 15-09 Location NEI 15-09 Text Revised Text for Consideration NRC Staff Comment and Technical Basis Section 1.4, Related Guidance U.S. Department of Homeland Securitys website provides a vast amount of information related to cyber security and cyber security event reporting (www.dhs.gov).

N/A Recommend including a link to DHS/CISAs website for reporting cyber events, https://www.cisa.gov/report.

Executive Summary Summary of Changes N/A The summary of changes should address changes made to Section 2.1.1 regarding 1-hour reportable events.

Section 2.1.1 Therefore, it is the CDAs identified by the licensees Cyber Security Plan that are subject to the reporting requirements in 10 CFR 73.77 Therefore, it is the CDAs identified by the licensees Cyber Security Plan that are subject to the reporting requirements in 10 CFR 73.77(a)(1)

This statement should specify that it pertains to 1-hour reports under 10 CFR 73.77(a)(1). Malicious activity against non-CDA devices that provide protection to CDAs or perform support functions are reportable under 10 CFR 73.77(a)(3).

Appendix C Eight-hour Notifications Malicious cyber actors routinely target devices that provide real-time detection and alerting as part of their pre-operational activities against critical targets.

Actions by malicious cyber actors against devices from which a CDA inherits

Enclosure security controls (e.g.,

portable media scanning kiosks, intrusion detection/prevention systems, security information and event management systems) are examples of such activity.

This activity is reportable under 10 CFR 73.77(a)(3) as, observed behavior, activities, or statements that may indicate intelligence gathering or pre-operational planning related to a cyber attack against digital computer and communication systems and networks within the scope of 10 CFR 73.54.

NEI 15-09 should provide guidance and examples to this effect.

Appendix C Eight-hour Notifications Malicious cyber activity observed against or impacting non-CDA digital systems located on the same network as a CDA would indicate potential pre-operational activity that could affect CDAs.

Enclosure This activity is reportable under 10 CFR 73.77(a)(3) as, observed behavior, activities, or statements that may indicate intelligence gathering or pre-operational planning related to a cyber attack against digital computer and communication systems and networks within the scope of 10 CFR 73.54.

NEI 15-09 should provide guidance and examples to this effect.