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Cyber Security and Other Realities of Our Digital World Andy Dickson IT Director – Nuclear Fleet Operations
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Page 1: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Cyber Security and Other Realities of Our Digital WorldAndy DicksonIT Director – Nuclear Fleet Operations

Page 2: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

What Changes Are We Facing?

Cyber Security Regulation and Threats

Changing IT Landscape and Expectations

Changing Industry

Page 3: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

3

Exelon Overview

Generation Retail & Wholesale

Exelon

Power Generation Constellation ComEd, PECO & BGE

Competitive Business Regulated Business

Exelon is the largest competitive integrated energy company in the U.S.

• Largest merchant fleet in the nation (~35 GW of capacity), with unparalleled upside

• One of the largest and best managed nuclear fleets in the world (~19 GW)

• Significant gas generation capacity (~10 GW)

• Renewable portfolio (~1 GW), mostly contracted

• Leading competitive energy provider in the U.S.

• Customer-facing business, with ~1.1 M competitive customers and large wholesale business

• Top-notch portfolio and risk management capabilities

• Extensive suite of products including Load Response, RECs, Distributed Solar

• One of the largest electric and gas distribution companies in the nation ~6.6 M customers

• Diversified across three utility jurisdictions – Illinois, Maryland and Pennsylvania

• Significant investments in Smart Grid technologies

• Transmission infrastructure improvement at utilities

Exelon Generation Exelon Utilities

Page 4: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Exelon Nuclear and My IT World

10 Nuclear Sites17 Reactors (12 BWRs, 5 PWRs)3 EOFs2 Corporate Campuses9 EP offsite staging facilities21 Scientech R*Time PPCs6 Legacy PPCs

10000 PCs300 Business Servers180 Real Time Servers25 Firewalls40 Routers500 Switches/Routers40 Data Diode Pairs

By the Numbers…

Page 5: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Is the glass half empty or half full?

Challenges AND

Opportunities!

Page 6: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

What Changes Are We Facing?

Cyber Security Regulation and Threats

Changing IT Landscape and Expectations

Changing Industry

Page 7: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Current Activity and Threats

Question: What is the average time to infection of an unprotected Windows PC connected to the internet?Answer: 20 Minutes (SANS Internet Storm Center)

Question: How many pieces of New Malware are created every day?Answer: >1 Million (Symantec)

Page 8: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Most targeted critical infrastructure sectors

Source: ICS-CERT

Incidents October 2012 to May 2013

You Are HERE

Page 9: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Brief History of Nuclear Cyber Security (10CFR73.54)

2005-07

•NEI 04-04, “Cyber Security Program for Power Reactors”, NEI -NERC MOA on CIP •Cyber Attack Added to Design Basis Threat

2005-07

•NEI 04-04 Implemented and New NRC Cyber Rule Issued – “SSEP Systems”•2009 NRC Decides Program Must be DETERMINISTIC•NRC Endorses NEI 08-09, Cyber Plan Template – Standard for the Industry

2011-12

•NRC Approves Cyber Security Plans•NRC Approved Interim Milestone Approach (1-7) Implemented Across Industry

2013•NRC Interim Inspections Begin

2014 – 16•Program Fully Implemented

Page 10: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Data CentersProtected by Firewalls

Site Business LAN protected by Firewalls

Control and Data Acquisition Systems protected by Data Diodes

Nuclear Plant Cyber SecurityNuclear Plant Cyber Security

Nuclear Industry Has Isolated all Plant Control and Data Acquisition System by One-Way Deterministic Devices (Milestone 3)

Page 11: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

This Leaves…

• Thank You Stuxnet• Scanning• Control• Sanitization• Security/Employee

Awareness• (Milestone 4)

With Data Diodes in Place, Focus Shifts Swift Quickly to Portable Media

Page 12: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Current State

• 137 Controls, broken into 698 Sub-Controls Must Be Assessed for EACH Critical Digital Asset – Do the Math!

• 14 of the 22 Scheduled NRC Interim Milestone Inspections have been conducted

• Inspection Team’s interpretation of Milestones 1-7 differs from the industries

• Current Deterministic Approach Treats EP Assets in the EOF the Same as Target Set

• Indications from NRC that they would consider moving to a “Consequence-based” Approach – Industry must Seize the Opportunity

• Program can Conflict with Technology Improvements like Wireless Monitoring - Cost/Controls

Page 13: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Example of Evolution in Interpretations

Issue Original Approach Current Approach

AntivirusScanning Kiosks for Removable Media

LeverageEnterprise Antivirus (AV) Solution

Use Hardened, Multi –AV, Network-DetachedSolution

Digital Test Equipment

Scan if Able Must be scanned, hardened, and controlled

EngineeringConfiguration Control

For Plant Systems For Plant Systems and EP Facilities

EP Assets (Business LAN)

Take Credit for Existing Enterprise Cyber Controls

Need to Isolate and Provide Separate Controls

Page 14: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Cyber Security

Challenges• Threats are Real• Nuclear Industry Cannot Tolerate Even Perception

of a Breach• Current Regulatory Interpretations and Lack of

Graded Approach Stand to Drive Significant Up Front and Ongoing Costs and Complexity

Opportunities• Data Diodes and Removable Media Practices

Have Fortified our Plants Significantly• Program has Driven Better Documentation,

control, and Disaster Recovery for Important Systems

• NRC Listening to Industry on Graded Approach

Page 15: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

What Changes Are We Facing?

Cyber Security Regulation and Threats

Changing IT Landscape and Expectations

Changing Industry

Page 16: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Changing Technology Landscape ORWhat’s going on beyond the Data Diode?

Source: Intel Inside Scoop 3/13/2012

Page 17: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

17

Today’s Challenges...the explosion of Digital Technologies has significantly increased requirements to improve efficiencies

Enabling Operational Efficiencies & Emerging Technologies Overview

Page 18: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Social Media

Source: Forbes Website

Page 19: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

NEI.org Post-Fukushima Page View

Source: NEI

Page 20: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Cloud Computing

• Security a barrier to adoption• Beware of 10CFR810 for Nuclear• Pay attention to new demands on Internet pipe

Gartner predicts that by 2015, 35% of Enterprise IT Expenditures for most organizations will be managed outside of IT Departmental Budgets.

Source: NIST Cloud Model

Page 21: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

BYOD Rationale: Consumerization & Anytime Access Trends

7.5B Smartphones by 2015 from 4.6B in 20112

149M Tablets by 2015 from 17M in 20103

250-300M M2M Connections by 2015 from 80M in 20104

2 Ovum, 2010 3 Current Analysis, 2011 4 Current Analysis, 2011

Diversification and Proliferation

998.1M Mobile Cloud App Subscribers in 2014 from 42.8M in 20088

788M Mobile-Only Internet Users by 20159

8ABI Research, 2009 9ARS Technica, 2011

Acceleration andIntegration

Virtualization and Ubiquity

Device Adoption

AcceleratingUsage

Ubiquitous Access

Consumer Behavior

IT Consumerization

Next Generation Employees want to work with technology and functionalitythat they can readily get in the marketplace

Rise of Mobile “Elite” workers Mobility and flexibility are the focus of consumer technology

40% of devices being used for business purposes are personally owned. 10% increase between 2010-20111

1 IDC, 2011

76.9B Mobile Apps downloaded in 2014 from 10.9B in 20105

155M Mobile Video Users by 2015 from 3.4M in 20106

Over 100M views a day via YouTube mobile in 20117

5IDC, 2010 6In-Stat, 2010 7YouTube, 2011

Page 22: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

BYOD Rationale: Benefits To Employees & Exelon

Effective Controls & Management Oversight

Consistent BYOD policy and approach to determining employee stipend amounts

Automated portal for onboarding employees Accurate tracking & reporting for management

One Culture

Consolidate multiple programs with different policies Enable ease of use and self service Encourage collaboration and advancement of an culture

Employee Satisfaction

Single device to carry Employees empowered to choose device and plans Increased mobility

Workforce Productivity

Increased remote workforce productivity with any time, any where, any device access

Improved cycle time for approval tasks & issue resolution Improved communications and business efficiency

Page 23: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Changing IT Landscape

Challenges• Social Media is Here – Control Your Message or

Someone Else Will • Cloud-sourcing – present Technical And Nuclear-

Specific Challenges• BYOD is Happening Today - Must Deal with It

Opportunities• Embrace Social Media to Get You Message Out

Directly to Customer and with Great Speed• Leverage “Cloud” as A Part of your IT Strategy to

Speed Deployments, Reduce Internal Complexity and Provide Anytime-Anywhere Access where the Fit is Right

• Seize the Advantages of BYOD

Page 24: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

What Changes Are We Facing?

Cyber Security Regulation and Threats

Changing IT Landscape and Expectations

Changing Industry

Page 25: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

What’s Going on in our industry• Shale Gas Disruption• Nuclear Plant Closings

• Keewaunee - Wisconsin• Crystal River - Florida• SONGS – California

• Post-Fukushima Mitigations• Changing Workforce Demographics

Page 26: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

What’s Going on in our industry

• New Nuclear Construction• Southern Company Vogtle 3 &4• SCANA/SCE&G Summer 2&3• TVA Watts Bar 2

Source: SCANA Corporation “INSIGHTS” Spring 2013

Page 27: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Changing Industry

Opportunities• Leverage Emerging Technology to:− Automate and Improve Ineffective Processes− Develop Optimal Solutions to Address Regulations − Facilitate Knowledge Transfer and Retentions− Attract Best Talent

• Promote Benefits of New Nuclear Technology

Challenges• Gas Prices will Continue To Challenge the

Economics of US Nuclear Fleet and Lead to Potential Additional Plant Closings

• Regulations like for Fukushima and Cyber Security will Apply Additional Financial Challenges

• Retaining Critical Knowledge and Skills as the Work Force Changes – Particularly for Legacy Systems

Page 28: Andy Dickson IT Director – Nuclear Fleet Operations · 2020-01-29 · Brief History of Nuclear Cyber Security (10CFR73.54) 2005-07 •NEI 04-04, “Cyber Security Program for Power

Closing

So, Is the Glass Half Empty or Half Full?

• Technology Creates Both the Challenge and the Opportunity

• We Can Embrace Change, Seize Opportunities or Be Overwhelmed by the Challenges

• Its Up to Us!


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