I thought I'd send this to the PWR folks as well. I believe we may have
similar concerns on this issue.
Ed McVey
Exelon Nuclear Fuels
________________________________
From: McVey, Edward A.:(GenCo-Nuc)
Sent: Thursday, February 11, 2010 12:29 PM
To: rcrc(a)retaqs.com
Cc: Tusar, James J:(GenCo-Nuc); Donell, Adam C.:(GenCo-Nuc); Spooner,
Seth J.:(GenCo-Nuc); Hsiao, Ming-yuan:(GenCo-Nuc);
Roger.thomas(a)pgnmail.com; Fisher, Jill T:(GenCo-Nuc)
Subject: FW: FOR RELEASE: Questions to Reactor Engineering Community
Regarding Cyber Security
We discussed Cyber Security Issues at our last RCRC meeting. I'd
appreciate responses to these questions. I know it's a long survey, but
Exelon had our experts on the 3 vendors' Core Monitoring Systems put
this together in order to help our fleet make a decision, and I would
like to attempt to get the entire industry somewhat consistent on this
as well. When we get responses accumulated, we'll send it out to
everyone for your use. Thanks
Ed McVey
Questions to Reactor Engineering Community Regarding Cyber Security:
Background:
With the issuance of 10CFR73.54 and the associated Regulatory Guide (RG
5.71), NRC licensees are now required to provide high assurance that
digital computer systems, communications, and networks are adequately
protected against cyber attack. These documents require that the
following systems be protected from such cyber attack:
* Safety-related and important-to-safety functions
* Security functions
* Emergency preparedness functions
* Support systems that if compromised could adversely impact
safety, security, or emergency preparedness
The NRC has suggested the following cyber security defense architecture
would be acceptable.
(See Attached Picture)
Where:
* Level 4 would protect control and safety systems (e.g. digital
feedwater systems)
* Level 3 would protect data acquisition systems (e.g. plant
process computer)
* Level 2 would protect the site network
* Level 1 would protect the greater corporate network
* Level 0 would represent the internet
In the NRC's defensive model, communication would not be permitted from
less secure levels to the more secure levels for Levels 3 and 4.
This issue could have considerable impact on the manner in which Reactor
Engineers interact with the core monitoring systems. As such, your
responses to the following questions would be greatly appreciated.
Questions:
1. What safety classification (Safety Related, Non-Safety
Related, Other) does your site consider its core monitoring system?
2. Does your site permit access to the core monitoring system
from the following locations:
* From non-corporate off-site locations (e.g. home)?
* From corporate off-site locations (e.g. corporate
headquarters)?
* From on-site but outside of the control room or computer
room?
3. If you have access to any of the locations in Question 2,
what would be the impact to your organization if this was no longer
permitted?
4. If you have access to any of the locations in Question 2 and
this was removed, would any immediate or urgent actions be no longer
possible for your Reactor Engineers in support of Operations?
5. Do you feel that the core monitoring system must be
considered as a system that falls within any of the following?
* Safety-related and important-to-safety functions
* Security functions
* Emergency preparedness functions
* Support systems that if compromised could adversely impact
safety, security, or emergency preparedness
6. Has your organization considered locating the core monitoring
system in Level 2? What is the basis of this decision?
7. Has your organization considered replicating the core
monitoring system in Level 2 with a secure CMS in Level 3? Would you
feel that predictions run in Level 2 would need to be repeated on the
secure system?
8. Do you feel that a reactor engineering working group should
be developed to address cyber security impacts on core monitoring
systems?
9. Would you like to actively participate in such a working
group? If so, please provide a contact name, phone number, and e-mail.
-----------------------------------------
**************************************************
This e-mail and any of its attachments may contain Exelon
Corporation proprietary information, which is privileged,
confidential, or subject to copyright belonging to the Exelon
Corporation family of Companies.
This e-mail is intended solely for the use of the individual or
entity to which it is addressed. If you are not the intended
recipient of this e-mail, you are hereby notified that any
dissemination, distribution, copying, or action taken in relation
to the contents of and attachments to this e-mail is strictly
prohibited and may be unlawful. If you have received this e-mail
in error, please notify the sender immediately and permanently
delete the original and any copy of this e-mail and any printout.
Thank You.
**************************************************