3.6.The operator should have a facility computer security risk management (CSRM) process to implement computer security to protect the functions performed by I&C systems. This process is used to identify the facility’s vulnerabilities1313 to cyber attack and to determine the consequence of successful compromise of one or more functions performed by I&C systems (which may include exploitation of vulnerabilities).
3.7.The outputs of the facility CSRM processes should include an identification of facility functions performed by I&C systems including supporting and complementary systems that, if compromised, could adversely affect safety, security of nuclear material or accident management. The facility safety analysis may be used as an input for the facility CSRM, but the safety analysis alone is not sufficient as it does not address all mal-operations. Mal-operations caused by cyber attacks might place the facility in conditions that have not been considered by the safety analysis.
3.8.The outputs of the facility CSRM processes should identify the potential consequences related to nuclear safety, nuclear security and nuclear material accounting and control resulting from system compromise due to a cyber attack on the I&C systems. When analysing the consequences of an attack on an I&C system, the possibility should be considered that the attack might be a component of a larger attack affecting multiple I&C systems or a combined cyber and physical attack. This analysis could then be used to assign the appropriate security levels to individual I&C systems and components based upon the potential consequences of their failure or mal-operation.
3.9.The security levels assigned to the I&C systems may be associated with a hierarchical list of potential safety or security consequences. For example, plant states, sabotage consequences, nuclear material categorization hierarchies or a combination of these might be used, as in the examples in paras 3.10–3.13 and 3.15.
3.10.For reasons of safety, plant states could be used to denote the potential safety consequences of a cyber attack on I&C systems. For example, plant states could be associated with security levels for I&C systems as follows, ordered from the situation with the lowest to the situation with the highest consequence:
Normal operation: A cyber attack on I&C systems cannot cause facility operation outside limits and conditions specified for normal operation.
Anticipated operational occurrence: A cyber attack on I&C systems may cause the plant state to deviate from normal operation in a way that is anticipated to occur, but which in view of appropriate design provisions does not cause any significant damage to items important to safety or lead to accident conditions.
Design basis accident1414: A cyber attack on I&C systems may cause accident conditions that remain within the facility design basis and for which the damage to the nuclear material (or other radioactive material) and the release of radioactive material are kept within authorized limits.
Design extension conditions: A cyber attack on I&C systems may cause accident conditions that are not considered for design basis accidents, but that are considered in the design process of the facility in accordance with best estimate methodology, and for which releases of radioactive material are kept within acceptable limits. Design extension conditions could include severe accident conditions.
3.11.The consequences of sabotage of functions performed by I&C systems could also be associated with security levels. Such an approach would involve the State defining the threshold for unacceptable radiological consequences (URC), as recommended in para. 3.44 of Ref. [2]. The definition of a threshold for URC may be based on quantitative or qualitative criteria, which may be expressed in terms of releases of radionuclides (e.g. a release exceeding some identified amount), doses (e.g. a release leading to a radiation dose exceeding some identified value to an individual located at some identified point, usually off-site) or facility conditions (e.g. sabotage that may result in significant core damage in a reactor). As stated in Ref. [11], paras 3.94 and 95:
“targets for which sabotage could potentially result in a substantial radiological release significantly affecting the population and environment beyond the boundaries of the nuclear facility need the highest level of protection. Such a severe event is referred to…[in Ref. [2]] as having high radiological consequences.
“Therefore, the State should also define the threshold for high radiological consequences.”
3.12.An example of a hierarchical list of potential consequences of sabotage is provided in Ref. [11] and summarized for I&C system functions as follows, ranked from the lowest to the highest consequences:
Radiological consequence below the URC threshold: Targets posing these low consequences need a correspondingly low level of protection.
URC can be graded into three categories ranked from the lowest to the highest consequences:
Consequence Level C: Sabotage that could result in doses to persons on-site that warrant urgent protective action to minimize on-site health effects.
Consequence Level B: Sabotage that could result in doses or contamination off-site that warrant urgent protective action to minimize off-site health effects (may also be considered high radiological consequences).
Consequence Level A: Sabotage that could give rise to severe deterministic health effects off-site (likely also to be considered high radiological consequences).
3.13.Security levels could also be associated with the possibility of the unauthorized removal of nuclear material. The potential consequences of cyber attacks on I&C systems performing physical protection or nuclear material accounting and control functions could be associated with security levels on the basis of the category of material that could be subject to unauthorized removal. Table I of Ref. [2] provides the criteria for the categorization of nuclear material and further identifies recommendations for physical protection based on this categorization.
3.14.There is currently no international consensus on a model for a completely integrated hierarchy of all safety and security consequences arising from accidents and nuclear security events resulting from cyber attacks. However, the operator or State should develop such a hierarchy at a national level.
3.15.Other consequences, such as loss of reputation, may also be considered when evaluating the combined consequences of a cyber attack on facility I&C systems. A listing of possible consequences can be found in Ref. [12].
3.16.Adversary tactics and techniques are constantly changing and nuclear facilities should foster a nuclear security culture that continually reviews computer security risks and allows for the adaptability of the facility computer security programme. Nuclear security culture is further explained in Ref. [13].
3.17.System configuration and activities associated with I&C systems enhanced with digital equipment should be analysed to identify changes to logical and physical pathways that could provide opportunities that an adversary could exploit. These activities associated with the I&C systems include temporary maintenance activities, procurement processes, vendor support, communication with field devices and manual software updates.
3.18.Facility CSRM is an iterative and cyclical process that could include an initial analysis, threat identification and assessment, definition of security levels, periodic review and updated analysis. There should be a defined acceptance process to review and verify the results of new or updated analyses.
3.19.For new facilities, the facility CSRM should be performed as part of the design process and accepted before completion of the initial commissioning phase.
3.20.For existing facilities, inputs to the new or updated facility CSRM may include safety analysis, details of safety and process architecture and previously accepted facility CSRM outputs.