ML110540461

Request for Additional Information on Cyber Security Program

ML110540461
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	02/25/2011
From:	Martin R E Plant Licensing Branch II
To:	Ajluni M Southern Nuclear Operating Co
martin re, NRR/DORL, 415-1493
References
TAC ME4356, TAC ME4357, TAC ME4358, TAC ME4359, TAC ME4360, TAC ME4361
Download: ML110540461 (6)

Text

UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 February 25, 2011 Mr. M. J. Ajluni Nuclear Licensing Director Southern Nuclear Operating Company, Inc. 40 Inverness Center Parkway Post Office Box 1295, Bin -038 Birmingham, AL 35201-1295 JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2; EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2; VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2-REQUEST FOR ADDITIONAL INFORMATION ON CYBER SECURITY PROGRAM (TAC NOS. ME4356, ME4357, FARLEY; ME4358, ME4359, HATCH; AND ME4360, ME4361, VOGTLE)

Dear Mr. Ajluni:

By letter dated July 16, 2010 (Agencywide Documents Access and Management System (ADAMS), Accession No. ML 102000158), Southern Nuclear Operating Company, Inc. (SNC), submitted license amendment requests for U.S. Nuclear Regulatory Commission (NRC) review and approval of the facility cyber security program (CSPs) and proposed implementation schedules for the plants named above. The NRC staff has determined that additional information is required to address the issues of records retention, implementation schedules and the scoping of systems in the CSPs, as discussed in further detail in the Enclosure.

The NRC staff has determined that no security-related or proprietary information is contained therein. We understand that the Nuclear Energy Institute and the industry Cyber Security Task Force are working to ensure that operating reactor licensees will submit consistent responses to the NRC for these generic RAls. The NRC staff believes that consistency in the implementation of NRC regulations across the licensed power reactor fleet supports the protection of the public health and safety.

M. Ajluni We request that a response be provided within 30 days of the date of this Sincerely, /t6-+{1, r))Robert E. Martin, Senior Project Plant Licensing Branch Division of Operating Reactor Office of Nuclear Reactor Docket Nos. 50-348, 50-364, 50-366, 50-424, and

Enclosure:

RAI cc w/encl: Distribution via Listserv REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE AMENDMENT REQUEST TO IMPLEMENT A CYBER SECURITY PROGRAM AT SOUTHERN NUCLEAR OPERATING COMPANY, INC. (SNC)' PLANTS JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-348, 50-364, 50-321, 50-366, 50-424, AND 50-425 RAt 1: Records Retention Title 10 of the Code of Federal Regulations (10 CFR), Part 73, Paragraph 73.54(c)(2) requires licensees to design a cyber security program (CSP) to ensure the capability to detect, respond to, and recover from cyber attacks. Furthermore, 10 CFR 73.54(e)(2)(i) requires licensees to maintain a CSP that describes how the licensee will maintain the capability for timely detection and response to cyber attacks. The ability for a licensee to detect and respond to cyber attacks requires accurate and complete records and is further supported by 10 CFR 73.54(h), which states that the licensee shall retain all records and supporting technical documentation required to satisfy the requirements of 10 CFR 73.54 as a record until the Commission terminates the license for which the records were developed, and shall maintain superseded portions of these records for at least 3 years after the record is superseded, unless otherwise specified by the Commission.

The licensee's CSP in Section 4.13 states that critical digital asset (CDA) audit records and audit data (e.g., operating system logs, network device logs) are retained for a period oftime that is less than what is required by 10 CFR 73.54(h).

Explain the deviation from the 10 CFR 73.54(h) requirement to retain records and supporting technical documentation until the Commission terminates the license (or to maintain superseded portions of these records for at least 3 years) and how that meets the requirements of 10 CFR 73.54. RAI 2: Implementation Schedule The regulation at 10 CFR 73.54, "Protection of digital computer and communication systems and networks," requires licensees to submit a CSP that satisfies the requirements of this section for Commission review and approval.

Furthermore, each submittal must include a proposed implementation schedule and the implementation of the licensee's cyber security program must be consistent with the approved schedule.

Paragraph 73.54(a) of 10 CFR requires licensees to provide high assurance that digital computer and communication systems and networks are adequately protected against cyber attacks, up to and including the design basis threat. Enclosure

-2 The completion of several key intermediate milestones (Items (a) through (g) below) would demonstrate progress toward meeting the requirements of 10 CFR 73.54. The Nuclear Regulatory Commission (NRC) staff's expectation is that the key intermediate milestones will be completed in a timely manner, but no later than December 31,2012. The key CSP implementation milestones are as follows: (a) Establish, train and qualify a Cyber Security Assessment Team, as described in Section 3.1.2, "Cyber Security Assessment Team," of the CSP. (b) Identify Critical Systems and CDAs, as described in Section 3.1.3, "Identification of Critical Digital Assets," of the CSP. (c) Implement cyber security defense-in-depth architecture by installation of, for example, deterministic one-way devices, as described in Section 4.3, In-Depth Protective Strategies" of the CSP. (d) Implement the management, operational and technical cyber security controls that address attacks promulgated by use of portable media, portable devices, and portable equipment as described in Appendix D, Section 1.19, "Access Control for Portable and Mobile Devices," of Nuclear Energy Institute (NEI) 08-09, Revision 6. (e) Implement observation and identification of obvious cyber related tampering to existing insider mitigation rounds as described in Appendix E, Section 4.3, "Personnel Performing Maintenance and Testing Activities," and Appendix E Section 10.3, "Baseline Configuration," of NEI 08-09, Revision 6. Identify, document, and implement cyber security controls to phYSical security target set CDAs in accordance with Section 3.1.6, "Mitigation of Vulnerabilities and Application of Cyber Security Controls," of the CSP. (g) Ongoing monitoring and assessment activities will commence for those target set CDAs whose security controls have been implemented, as described in Section 4.4, "Ongoing Monitoring and Assessment," of the CSP (h) Full implementation of the CSP for all safety, security, and emergency preparedness functions.

Provide a revised CSP implementation schedule that identifies the appropriate milestones, completion dates, supporting rationale, and level of detail to allow the NRC to evaluate the licensee's proposed schedule and associated milestone dates which include the final completion date. It is the NRC's intention to develop a license condition incorporating your revised CSP implementation schedule containing the key milestone dates.

-RAI 3: Scope of Systems Paragraph 73.54(a) of 10 CFR requires licensees to provide high assurance that digital computer and communication systems and networks are adequately protected against cyber attacks, up to and including the design basis threat as described in 10 CFR 73.1. In addition, 10 CFR 73.54(a)(1) states that the licensee shall protect digital computer and communication systems and networks associated with: (i) Safety-related and important-to-safety functions; (ii) Security functions; (iii) Emergency preparedness functions, including offsite communications; and (iv) Support systems and equipment which, if compromised, would adversely impact safety, security, or emergency preparedness functions.

Subsequent to the issuance of the cyber security rule, the NRC stated that 10 CFR 73.54 should be interpreted to include structures, systems, and components (SSCs) in the balance of plant (BOP) that have a nexus to radiological health and safety (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 103490344, dated November 19, 2010). The SSCs in the BOP are those that could directly or indirectly affect reactivity of a nuclear power plant and could result in an unplanned reactor shutdown or transient and are therefore within the scope of important-to-safety functions described in 10 CFR 73.54(a)(1).

Furthermore, the NRC issued a letter to NEI dated January 5,2011 (ADAMS Accession No. ML 103550480), that provided licensees with additional guidance on one acceptable approach to comply with the Commission's policy determination.

Explain how the scoping of systems provided by the licensee's CSP meets the requirements of 10 CFR 73.54 and the additional guidance provided by the NRC.

M. Ajluni -2 We request that a response be provided within 30 days of the date of this letter. Sincerely, IRA! Robert E. Martin, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348, 50-364, 50-321, 50-366, 50-424, and 50-425

Enclosure:

RAI cc w/encl: Distribution via Listserv DISTRIBUTION PUBLIC LPL2-1 RtF RidsNrrDorlLpl2-1 Resource RidsAcrsAcnw_MailCTR Resource RidsNrrDoriDpr Resource RidsRgn2MailCenter Resource RidsNrrLAMOBrien Resource RidsOgcRp Resource PPederson, NSIR CErlanger, NSIR RidsNrrPMFarley Resource RidsNrrPMHatch Resource RidsNrrPMVogtle Resource ADAMS Accession No.: ML110540461 NSIRtDSP/BC NAME n MO'Brien OFFICE -1/PM LPL2-1/LA CErlanger*

DATE 02/24/11 2/18111 OFFICIAL RECORD COPY *b LPL2-lIBC GKulesa (JStang for) 02125/11