Pipeline Security Guidelines March 2018 with Change 1 April 2021 Table of Contents 1 Introduction 1 1 1 1 2 Background and Purpose 1 Scope 1 2 Corporate Security Program 2 3 Corporate Security Plan 4 3 1 3 2 Introduction 4 Security Plan Elements 4 4 Risk Analysis 6 4 1 4 2 4 3 Introduction 6 Criticality Assessment 6 Security Vulnerability Assessment 7 5 Criticality 8 5 1 5 2 Introduction 8 Facility Criticality 8 6 Facility Security Measures 16 6 1 6 2 6 3 Introduction 16 Baseline and Enhanced Security Measures 16 Site-Specific Security Measures 16 7 Pipeline Cyber Asset Security Measures 22 7 1 7 2 7 3 7 4 Introduction 22 Pipeline Cyber Assets Identification 22 Security Measures for Pipeline Cyber Assets 22 Cyber Security Planning and Implementation Guidance 27 8 Protective Measures for National Terrorism Advisory System NTAS Alerts 28 Appendix A – Recurring Actions 29 Appendix B – TSA Notification Criteria 31 Appendix C – Acronyms 32 Appendix D – Reference Documents 33 Record of Changes 1 Change Number April 2021 Date Comment Replaced Section 5 Criticality TSA Pipeline Security Guidelines Introduction 1 INTRODUCTION Under the provisions of the Aviation and Transportation Security Act Public Law 107-71 the Transportation Security Administration TSA was established on November 19 2001 with responsibility for civil aviation security and “security responsibilities over other modes of transportation that are exercised by the Department of Transportation ” On September 8 2002 TSA initiated its pipeline security efforts Those responsibilities now reside within the Office of Security Policy and Industry Engagement’s Surface Division 1 1 Background and Purpose In executing its responsibility for national pipeline security TSA originally utilized the Pipeline Security Information Circular issued on September 5 2002 by the Department of Transportation’s DOT Office of Pipeline Safety as the primary Federal guideline for industry security Complementing this document and also adopted by TSA was the DOT-issued Pipeline Security Contingency Planning Guidance of June 2002 Recognizing that the Security Circular required updating TSA initiated a process to amend the Federal security guidance The 2010 Pipeline Security Guidelines were developed with the assistance of industry and government members of the Pipeline Sector and Government Coordinating Councils industry association representatives and other interested parties This document was soon revised resulting in the 2011 Pipeline Security Guidelines The advancement of security practices to meet the ever changing threat environment in both the physical and cyber security realms required that the guidelines be updated again Utilizing a similar industry and government collaborative approach TSA developed this document which supersedes the 2011 version of the Pipeline Security Guidelines The security measures in this guidance provide the basis for TSA’s Pipeline Security Program Corporate Security Reviews and Critical Facility Security Reviews This document is guidance and does not impose requirements on any person or company The term “should” means that TSA recommends the actions described Nothing in this document shall supersede Federal statutory or regulatory requirements 1 2 Scope These guidelines are applicable to operational natural gas and hazardous liquid transmission pipeline systems natural gas distribution pipeline systems and liquefied natural gas facility operators Additionally they apply to operational pipeline systems that transport materials categorized as toxic inhalation hazards TIH TIH materials are gases or liquids that are known or presumed on the basis of tests to be so toxic to humans as to pose a health hazard in the event of a release during transportation See the Hazardous Materials Regulations 49 CFR parts 171-180 1 TSA Pipeline Security Guidelines Corporate Security Program Operators of pipeline systems not included in the descriptions above are encouraged to implement the security measures contained herein to the extent appropriate to their particular system 2 CORPORATE SECURITY PROGRAM A risk-based corporate security program should be established and implemented by each pipeline operator to address and document the organization’s policies and procedures for managing security related threats incidents and responses In addition each operator should • Develop a corporate security plan as described in Section 3 • Ensure sufficient resources to include trained staff and equipment are provided to effectively execute the corporate security program • Ensure identified security deficiencies have appropriate financial resources allocated in the corporate budgeting and purchasing processes • Assign a qualified primary and alternate staff member to manage the corporate security program • Develop and maintain a cyber Supervisory Control and Data Acquisition SCADA security plan or incorporate cyber SCADA security measures in the corporate security plan • Develop and maintain security elements within the corporate incident response and recovery plan • Implement appropriate threat level protective measures upon receipt of a pertinent National Terrorism Advisory System NTAS Bulletin or Alert and • Notify TSA of security incidents meeting the criteria provided in Appendix B by phone or email as soon as possible Figure 1 identifies the major steps that each pipeline operator should take in creating and implementing a corporate security program and the relevant sections in the guidelines where specific details are provided 2 TSA Pipeline Security Guidelines Corporate Security Program Figure 1 Corporate Security Program Overview Corporate Security Program Overview Critical Facility Pipeline operators should adopt baseline security measures at all facilities Sections 6 and 7 Pipeline operators should conduct a SVA for each critical facility Section 4 3 Pipeline operators should adopt baseline and enhanced security measures at each critical facility Sections 6 and 7 3 TSA Pipeline Security Guidelines Corporate Security Plan 3 CORPORATE SECURITY PLAN 3 1 Introduction Operators should develop and implement a security plan customized to the needs of the company The corporate security plan should be comprehensive in scope systematic in its development and risk-based reflecting the security environment At a minimum the plan should • Identify the primary and alternate security manager or officer responsible for executing and maintaining the plan • Document the company’s security-related policies and procedures to include but not limited to methodologies used and timelines established for conducting criticality assessments risk assessments and security vulnerability assessments SVAs if applicable • Reference other company plans policies and procedures such as insider threat business continuity incident response and recovery plans • Be reviewed on an annual basis and updated as required based on findings from assessments major modifications to the system or any of its facilities substantial changes to the environment in which it operates or other significant changes • Be protected from unauthorized access based on company policy and • Be provided to TSA for review upon request 3 2 Security Plan Elements This section identifies and provides a brief description of the recommended elements of a corporate security plan In developing their plan operators should incorporate these elements in a format that is most suitable to their organization • System s Description - Identify the pipeline system s to which the plan applies • Security Administration and Management Structure - Identify the person s primarily responsible for the corporate security program and describe the responsibilities and duties of personnel assigned to security functions • Risk Analysis and Assessments - Describe the methodology used to conduct security risk analysis to include criticality assessments and SVAs • Physical Security and Access Control Measures - Describe the corporate policies and procedures employed to reduce security risks throughout the company • Equipment Maintenance and Testing - Discuss policies and procedures for ensuring security systems and equipment are maintained and function properly 4 TSA Pipeline Security Guidelines Corporate Security Plan • Personnel Screening - Describe policies and procedures for conducting employee background checks including criteria for disqualification and process for appeal in compliance with Federal and state laws Describe company policies for contractor personnel background checks • Communications - Describe the policies and procedures employed to ensure effective communication is maintained on both a routine and emergency basis The description should include but not be limited to types of equipment used communication methods between personnel facilities off-site responders and procedures for notification of government and law enforcement agencies • Personnel Training - Describe security training requirements to include training in security equipment operation security awareness and security incident recognition and reporting procedures for company personnel and contractors • Drills and Exercises - Describe company policies and procedures for conducting security drills and exercises Establish requirements for after-action reports communication of lessons learned and implementation of security improvement efforts based on exercise results • Security Incident Procedures - Describe procedures for responding to security incidents and emergencies Define the types of events that constitute a breach of security describe the procedures for investigating security incidents and who should be notified In addition the emergency response plan may be referenced in this section • NTAS Response Procedures - Describe the operator’s additional protective measures for periods of heightened threat corresponding to the duration of Department of Homeland Security DHS NTAS Bulletins or Alerts • Plan Reviews - Describe policies and procedures for the review validation and updating of the corporate security plan • Recordkeeping - Describe security-related recordkeeping requirements such as for criticality assessments SVAs and other company sensitive security information as well as measures to prevent unauthorized disclosure • Cyber SCADA System Security Measures - Describe the corporate policies and procedures employed to reduce security risks to cyber SCADA systems and assets throughout the company If a separate cyber SCADA security plan is maintained it should be incorporated by reference • Essential Security Contact Listings - List internal and external emergency contact information for reporting and responding to a security incident or suspicious activity • Security Testing and Audits - Describe policies and procedures for auditing and testing of the effectiveness of the company's security plan and procedures to include documentation of results • Outreach - Describe policies and procedures for company security awareness outreach efforts to neighbors law enforcement media and the public 5 TSA Pipeline Security Guidelines Risk Analysis 4 RISK ANALYSIS 4 1 Introduction The intent of these guidelines is to bring a risk-based approach to the application of the security measures throughout the pipeline industry As stated in the National Infrastructure Protection Plan DHS assesses risk as a function of threats vulnerabilities and consequences With this in mind the most effective security programs employ a risk management process that facilitates planning and decision making to mitigate risks for pipeline assets General elements include • Assessments used to determine facility criticality • Threat assessments identifying known or potential adversaries • Vulnerability assessments identifying security weaknesses • Risk assessments based on threat vulnerability and consequence considering facility criticality assessment findings • Risk mitigation to determine and implement appropriate risk reduction countermeasures and • Ongoing risk management to monitor reassess and modify the program Recognizing that there are multiple risk assessment methodologies each operator should determine the process and methodology most appropriate for implementation of the corporate security plan at the facilities comprising their pipeline system TSA may ask to review the operator’s risk assessment methodology 4 2 Criticality Assessment Determining facility criticality is an essential first step in the security risk management process Information and findings gathered in the criticality assessment assist operators with prioritizing assets and implementing risk reduction countermeasures Operators should evaluate each operating facility within their system using the criteria outlined in Section 5 2 to determine or validate criticality Operators should • Conduct facility criticality assessments on a periodic basis not to exceed 18 months for all facilities • Document the methodology used and retain the criticality assessment until no longer valid • Conduct an SVA or the equivalent as outlined in Section 4 3 of this document for facilities determined to be critical and • Maintain and secure the company’s list of critical facilities The operator’s list of critical facilities is subject to review and evaluation by TSA Operators and TSA will work together towards concurrence on the facilities listed 6 TSA Pipeline Security Guidelines Risk Analysis 4 3 Security Vulnerability Assessment A security vulnerability assessment SVA is one of the risk assessment methodologies pipeline operators may choose The SVA serves as a planning and decision support tool to assist security managers with identifying evaluating and prioritizing risks and determining effective security measures to mitigate threats and vulnerabilities to their critical facilities Common steps performed while conducting an SVA include • Asset Characterization - identification of hazards and consequences of concern for the facility its surroundings and its supporting infrastructure and identification of existing layers of protection • Threats Assessment - description of possible internal and external threats • Security Vulnerability Analysis - identification of potential security vulnerabilities and existing countermeasures and their level of effectiveness in reducing identified vulnerabilities • Risk Assessment - determination of the relative degree of risk to the facility in terms of the expected effect on each asset and the likelihood of success of an attack and • Countermeasures Analysis – comparison of strategies that reduce the probability of a successful attack or reduce the possible degree of success strategies that enhance the degree of risk reduction the capabilities and effectiveness of mitigation options and the feasibility of the options Operators of critical pipeline facilities should • Conduct an SVA or the equivalent on a periodic basis not to exceed 36 months and within 12 months after completion of a significant enhancement or modification to the facility • Conduct an SVA or the equivalent for newly identified or constructed critical facilities within 12 months of designation or after achieving operational status • Document findings from each assessment and retain them until no longer valid • Implement appropriate findings from the SVA in a timely fashion but no later than 24 months after SVA completion and • Document the assessment methodology used and make the documentation available for TSA review upon request 7 TSA Pipeline Security Guidelines Criticality 5 CRITICALITY 5 1 Introduction Change 1 April 2021 The objective in determining which pipeline facilities are critical is to ensure that reasonable appropriate security risk reduction measures are implemented thereby reducing the impact of service disruptions to critical infrastructure and the public 5 2 Facility Criticality The designation of critical pipeline facilities is a challenging task considering the diverse operational and market environments spanning the pipeline industry Pipeline operators are uniquely positioned to understand the criticality of their operations and the infrastructure necessary to serve those functions Pipeline companies should develop a written policy and procedure to identify critical facilities in accordance with their enterprise risk management process and the TSA guidance below To aid operators in applying the guidance the criteria are differentiated for each of the three major pipeline subsectors • natural gas distribution • natural gas transmission to include LNG peak shaving and satellite plants • hazardous liquid transmission Determination of pipeline critical facilities • • • • • TSA is responsible for notifying pipeline operators of TSA-designated critical pipeline systems Operators should pay particular attention to identifying critical facilities on these systems A pipeline facility is considered critical if it provides primary service to designated critical infrastructure and is determined by the operator to be a “single point of failure” i e does not have redundancy or systematic backup TSA defines a single point of failure as a facility that if rendered inoperable would degrade service to critical infrastructure to the point that the infrastructure would not be able to satisfactorily perform its critical mission Operators are responsible for conducting an operational assessment and identifying specific pipeline facilities that are necessary for critical pipeline systems as designated by TSA to function System redundancies contingency plans and available mitigations may be considered when evaluating the criticality of a facility If requested operators should provide TSA documentation including how identified redundancies are evaluated This documentation is protected from unauthorized disclosure as sensitive security information As external mutual aid is not under the control of the operator it should not be considered as a contingency or mitigation factor when identifying critical facilities Operators should coordinate with the appropriate internal company business functions e g sales marketing and rates tariffs to identify pipeline feeds to potentially critical 8 TSA Pipeline Security Guidelines Criticality • • • • • Change 1 April 2021 infrastructure including large volume customers such as natural gas-fired power generation plants military bases and defense industrial base manufacturers Operators may take into consideration whether firm or interruptible contracts are in place In general contracts for interruptible service may indicate the dependency on a fuel source is not vital to that critical infrastructure however this assumption should be validated with owners of said critical infrastructure Operators may consider adjustments based on the severity of consequences as a result of the loss of a facility or disruption in service e g climate conditions restart capability and life-safety Operators may consider their ability to continue operations e g product free flow or alternate or redundant prime-mover capacity as an adequate facility backup as long as they demonstrate no impact to deliverability TSA in consultation with pipeline operators may designate specific pipeline facilities as critical in accordance with this guidance Operators may set more stringent criteria and designate facilities as critical in addition to those meeting the guidance below A pipeline facility is defined as new and existing pipelines rights of way and any equipment facility or building used in the transportation of gas or hazardous liquids or in the treatment of gas or hazardous liquids during the course of transportation 1 Critical facilities may include but are not limited to • pipeline interconnections • metering and or regulating stations • pump stations • compressor stations • operational control facilities • main line valves • tank farms terminals If damage or destruction of a facility has the potential to meet at least one of the following criteria the facility or facilities should be designated as critical 1 Consistent with definitions in 49 CFR § 192 3 193 2007 and 195 2 9 TSA Pipeline Security Guidelines Criticality Change 1 April 2021 Table 1 Critical Facility Criteria Criteria 1 Disrupt or significantly reduce required service or deliverability to installations identified as critical to national defense 2 Disrupt or significantly reduce required service or deliverability to key infrastructure such as power plants or major airports resulting in major operational disruption Subsector Guidance TSA will notify pipeline operators who directly serve installations or defense industrial base DIB manufacturers deemed critical to national defense and who rely on the pipeline commodity to perform a critical mission at that location Natural Gas Distribution Natural gas distribution operators should designate as critical those facilities that must function to provide service to critical defense installations or DIB manufacturers with a firm contract Natural Gas Transmission Natural gas transmission operators should designate as critical those facilities that must function to provide service to critical defense installations or DIB manufacturers with a firm contract Hazardous Liquid Transmission Hazardous liquid transmission operators should designate as critical those facilities that must function to provide service to critical defense installations or DIB manufacturers Natural Gas Distribution Natural Gas Transmission TSA will notify pipeline operators of key infrastructure they serve e g “black start” electric power generation plants Category X airports and service to the Strategic Petroleum Reserve Service to Natural Gas-Fired Power Generation Plants Natural gas distribution operators should designate as critical those facilities that must function to provide service to power generation facilities that • Directly serve as Defense Critical Electric Infrastructure as identified by Department of Energy DOE and with firm contract • Receive natural gas in excess of 30 000 MMcf annually per a firm contract as listed on Energy Information Administration EIA Form 923 Power Plant Operations Report Annual • Serve as a “black start” electric generation plant with firm contract Service to Natural Gas-Fired Power Generation Plants Natural gas transmission operators should designate as critical those facilities that must function to provide service to power generation facilities that • Directly serve as Defense Critical Electric Infrastructure as identified by DOE and with firm contract 10 TSA Pipeline Security Guidelines Criticality Criteria 2 Disrupt or significantly reduce required service or deliverability to key infrastructure such as power plants or major airports resulting in major operational disruption Cont Subsector Natural Gas Transmission Cont Change 1 April 2021 • • Hazardous Liquid Transmission Guidance Receive natural gas in excess of 30 000 MMcf annually per a firm contract as listed on EIA Form 923 Power Plant Operations Report Annual Serve as a “black start” electric generation plant with firm contract Service to Category X Airports Hazardous liquid transmission operators should designate as critical those facilities that must function to provide service to TSA designated Category X airports Service to the Strategic Petroleum Reserve SPR Hazardous liquid transmission operators should designate as critical those facilities that must function to provide service to or within the SPR sites 3 Cause mass injuries casualties or significant health or environmental effects 2 Natural Gas Distribution Operator-Generated Methodology In addition to guidance below natural gas distribution operators should use their own methodology to designate additional critical facilities which may cause mass casualty or significant health effects Operators should consider variation in service territory and facility siting differences in regional weather extremes and distinctions among risk profiles Facilities Operating Near Occupied Buildings or Areas Natural gas operators should evaluate their facilities through their Distribution Integrity Management Program DIMP 3 or comparable risk methodology and designate as critical those facilities that • • • Operate at pressures above 125 PSIG Operate in a Class 4 location regardless of operating pressure as defined in the Dept of Transportation DOT 49 Code of Federal Regulations 4 Operate in a Class 3 location regardless of operating pressure and do not have service regulators installed or redundant overpressure protection systems For these guidelines a mass casualty incident is defined as an event that overwhelms the local healthcare system where the number of casualties vastly exceeds the local resources and capabilities in a short period of time 3 49 CFR Part 192 Subpart P Gas Distribution Pipeline Integrity Management IM 4 49 CFR § 192 5 2 11 TSA Pipeline Security Guidelines Criticality Criteria 3 Cause mass injuries casualties or significant health or environmental effects Cont Change 1 April 2021 Subsector Natural Gas Distribution Cont Guidance High Risk Tiered Facilities under DHS CFATS Natural gas distribution operators should review and consider as critical all facilities designated as high risk under the DHS Chemical Facility Anti-Terrorism Standards CFATS program Natural Gas Transmission Facilities Operating in HCAs Natural gas transmission operators should designate as critical all facilities operating in High Consequence Areas HCAs as defined in Dept of Transportation DOT 49 Code of Federal Regulations 5 HCAs could include designated human health-safety structure or human occupancy impact zones from a release of natural gas High Risk Tiered Facilities under DHS CFATS Natural gas transmission operators should review and consider as critical all facilities designated as high risk under the DHS Chemical Facility Anti-Terrorism Standards CFATS program Hazardous Liquid Transmission Facilities Operating in HCAs Hazardous liquid transmission operators should designate as critical all facilities operating in High Consequence Areas HCAs as defined in Dept of Transportation DOT 49 Code of Federal Regulations 6 HCAs can include commercially navigable waterways high population areas other populated areas or unusually sensitive areas High Risk Tiered Facilities under DHS CFATS Hazardous liquid transmission operators should review and consider as critical all facilities designated as high risk under the DHS Chemical Facility Anti-Terrorism Standards CFATS program 4 Disrupt or significantly reduce required service or deliverability resulting in a state or local government's inability to provide essential public services and emergency response for an 5 6 Natural Gas Distribution Natural gas distribution operators should designate as critical those facilities that directly support essential public services and emergency response and which rely on natural gas to perform their critical mission Consideration should be given to • government complexes or hubs that function as a state’s primary government facility including executive legislative and judicial complexes • state emergency response headquarters 49 CFR § 192 903 and Appendix E to Part 192 Guidance on Determining High Consequence Areas and on Carrying Out Requirements in the Integrity Management Rule 49 CFR § 195 450 195 452 and Appendix C to Part 195 Guidance for Implementation of an Integrity Management Plan 12 TSA Pipeline Security Guidelines Criticality Criteria extended period of time Subsector Natural Gas Distribution Cont Change 1 April 2021 • Guidance complexes that provide essential public service or emergency response capability7 Operators should coordinate with the appropriate state office e g State Office of Emergency Management to identify essential public service and emergency response facilities In the case that state offices are nonresponsive to operator requests TSA will work with DHS to facilitate this coordination For this criterion an extended period of time is defined as the inability to provide essential public services and emergency response for seven or more consecutive days due to a disruption of natural gas distribution service Natural Gas Transmission Not applicable Hazardous Liquid Transmission Hazardous liquid transmission operators should designate as critical those facilities that directly support essential public services and emergency response and which rely on hazardous liquids to perform their critical mission Consideration should be given to • government complexes or hubs that function as a state’s primary government facility including executive legislative and judicial complexes • state emergency response headquarters • complexes that provide essential public service or emergency response capability8 Operators should coordinate with the appropriate state office e g State Office of Emergency Management to identify essential public service and emergency response facilities In the case that state offices are nonresponsive to operator requests TSA will work with DHS to facilitate this coordination For this criterion an extended period of time is defined as the inability to provide essential public services and emergency response for seven or more consecutive days due to a disruption of hazardous liquid transmission service 7 8 See FEMA Continuity Guidance Circular February 2018 and particularly National Essential Functions 6 – Provide Emergency Services 7 – Maintain Economic Stability and 8 – Provide Basic Essential Services See FEMA Continuity Guidance Circular February 2018 and particularly National Essential Functions 6 – Provide Emergency Services 7 – Maintain Economic Stability and 8 – Provide Basic Essential Services 13 TSA Pipeline Security Guidelines Criticality Criteria 5 Disrupt or significantly reduce the intended usage of major rivers lakes or waterways for example public drinking water for large populations or disruption of major commerce or public transportation routes Change 1 April 2021 Subsector Natural Gas Distribution Not applicable Guidance Natural Gas Transmission Not applicable Hazardous Liquid Transmission Hazardous liquid transmission operators should designate as critical all pipeline facilities that could significantly impact public drinking water sources if state or local advisories are issued Hazardous liquid transmission operators should designate as critical all pipeline facilities subject to Oil Pipeline Response Plans9 impacting a PHMSA-defined Major River-High Volume Area or Other Navigable Waters 10 Hazardous liquid transmission operators are encouraged to consult with environmental risk specialists with expertise in this area 6 Disrupt or significantly reduce required service or deliverability to a significant number of customers or individuals for an extended period of time Natural Gas Distribution Natural gas distribution operators should designate as critical all facilities that if disrupted for more than seven consecutive days would experience reduced service or deliverability to 100 000 or more meters Natural Gas Transmission Not applicable Hazardous Liquid Transmission Not applicable 7 Significantly disrupt pipeline system operations for an extended period of time Natural Gas Distribution Natural gas distribution operators should designate as critical all pipeline facilities where the loss or disruption of facility operations lasting more than seven days would significantly impact overall deliverability and system safety Factors to consider in determining criticality of a facility include • whether a facility contains components not readily available to the operator due to long lead times or limited geographic sourcing • if a facility contains critical pipeline cyber assets11 Natural gas distribution operators should identify as critical operational control rooms without a hot site backup i e a backup control room that is continuously running and where all hardware and software are run concurrently with the primary site 49 CFR Part 194 – Response Plans for Onshore Oil Pipelines 49 CFR Part 194 – Response Plans for Onshore Oil Pipelines Appendix B 11 Section 7 2 TSA Pipeline Security Guidelines March 2018 9 10 14 TSA Pipeline Security Guidelines Criticality Criteria 7 Significantly disrupt pipeline system operations for an extended period of time Cont Subsector Natural Gas Transmission Change 1 April 2021 Guidance Natural gas transmission operators should designate as critical all pipeline facilities where the loss or disruption of facility operations lasting more than 14 days would significantly impact overall deliverability and system safety Factors to consider in determining criticality of a facility include • whether a facility contains components not readily available to the operator due to long lead times or limited geographic sourcing • if a facility contains critical pipeline cyber assets12 Natural gas transmission operators should identify as critical operational control rooms without a hot site backup i e a backup control room that is continuously running and where all hardware and software are run concurrently with the primary site Hazardous Liquid Transmission Hazardous liquid transmission operators should designate as critical all pipeline facilities where the loss or disruption of facility operations lasting more than seven days would significantly impact overall deliverability and system safety Factors to consider in determining criticality of a facility include • whether a facility contains components not readily available to the operator due to long lead times or limited geographic sourcing • if a facility contains critical pipeline cyber assets13 Hazardous liquid transmission operators should identify as critical operational control rooms without a hot site backup i e a backup control room that continuously running and where all hardware and software are run concurrently with the primary site 12 13 Section 7 2 TSA Pipeline Security Guidelines March 2018 Section 7 2 TSA Pipeline Security Guidelines March 2018 15 TSA Pipeline Security Guidelines Facility Security Measures 6 FACILITY SECURITY MEASURES 6 1 Introduction Upon completion of the risk analysis process operators should determine the appropriate mitigation measures for both critical and non-critical facilities 6 2 Baseline and Enhanced Security Measures Pipeline operators should develop and implement baseline security measures at all of their facilities Operators should develop and implement both baseline and enhanced security measures at each of their critical facilities Table 2 identifies the baseline and enhanced security measures for operators to implement at appropriate pipeline facilities Recurring actions are summarized in Appendix A 6 3 Site-Specific Security Measures Operators should develop document and implement site-specific security measures for each of their critical facilities These measures should be tailored explicitly for each facility and address specific actions to be taken in response to pertinent NTAS Bulletins or Alerts On a periodic basis not to exceed 18 months these site-specific security measures should be reviewed and updated as necessary 16 TSA Pipeline Security Guidelines Facility Security Measures Table 2 Baseline and Enhanced Security Measures BASELINE SECURITY MEASURES ENHANCED SECURITY MEASURES Fencing Barriers Employ measures to impede unauthorized access to facilities Create a security perimeter that impedes unauthorized vehicles from entering the facility perimeter or critical areas by installing and maintaining barriers e g fences bollards jersey barriers or equivalent Physical Security and Access Control Maintain fences if used without gaps around gates or underneath the fence line Ensure that there is a clear zone for several feet on either side of the fence free of obstructions vegetation or objects that could be used for concealment or to scale the fence Access Controls Employ measures to impede unauthorized persons from gaining access to a facility and restricted areas within a facility Implement procedures such as manual or electronic sign in out for controlling access to the facility and restricted buildings or areas within the facility Close and secure perimeter gates or entrances when not in use Monitor and escort visitors at critical facilities Post “No Trespassing” or “Authorized Personnel Only” signs at intervals that are visible from any point of potential entry Gates Install and maintain gates of an equivalent quality to the barrier to which they are attached Locks and Key Control Establish and document key control procedures for key issuance tracking collection loss and unauthorized duplication Use patent keys to prevent unauthorized duplication Conduct key inventories every 24 months 17 TSA Pipeline Security Guidelines Facility Security Measures Table 2 Baseline and Enhanced Security Measures and Access Control Physical Security BASELINE SECURITY MEASURES ENHANCED SECURITY MEASURES Facility Lighting Provide sufficient illumination for human or technological recognition of intrusion into the facility perimeter or critical areas Intrusion Detection Monitoring Provide critical facilities or critical areas within a facility with security measures to monitor detect and assess unauthorized access 24 hours a day 7 days a week Personnel Identification and Badging Develop identification and badging policies and procedures for personnel who have access to secure areas or sensitive information These policies should address Ensure that company or vendor identification is available for examination by being visibly displayed or carried by personnel while on-site Personnel Security • Lost or stolen identification cards or badges • Temporary badges and • Personnel termination Ensure personnel identification cards or badges are secure from tampering and contain the individual’s photograph and name Background Investigation Establish policies and procedures for applicant pre-employment screening and behavioral criteria for disqualification of applicants and employees Conduct pre-employment background investigations of applicants for positions that are • Authorized regular unescorted access to control systems or sensitive areas • Authorized access to sensitive information • Assigned security roles • Assigned to work at or granted access rights to critical facilities At a minimum investigations should • Verify and validate identity • Check criminal history and • Verify and validate legal authorization to work NOTE Operators should consider using the Federally-established list of disqualifying crimes see 49 CFR 1572 103 to assess the suitability of their personnel for these positions 18 TSA Pipeline Security Guidelines Facility Security Measures Table 2 Baseline and Enhanced Security Measures ENHANCED SECURITY MEASURES Security Verify that contractors have background investigation policies and procedures at least as rigorous as the pipeline operator’s Conduct recurring background investigations on a regular basis as labor laws or bargaining unit contracts allow not to exceed 10 years for employees occupying security positions or who have access to sensitive information or areas and Testing Equipment Maintenance and Testing Design Construction Equipment Maintenance Personnel BASELINE SECURITY MEASURES Develop and implement a maintenance program to ensure security systems are in good working order Through routine use or quarterly examination verify the proper operation and or condition of all security equipment Identify and respond to security equipment malfunctions or failures in a timely manner Provide an equivalent level of protective security measures to mitigate risk during power outages security equipment failure or extended repair of security systems Design and Construction Integrate security risk mitigation measures during the design construction or renovation of a facility Conduct an SVA for newly identified or constructed critical facilities within 12 months of designation or after achieving operational status Update the facility SVA within 12 months following significant modifications Communication Communication Develop internal and external notification requirements and procedures for security events Ensure primary and alternate communication capabilities exist for internal and external reporting of appropriate security events and information Document and periodically update contact who and communication how information for Federal state and local homeland security law enforcement agencies See Appendix B for TSA contact information Establish a defined process for receiving handling disseminating and storing security and threat information 19 TSA Pipeline Security Guidelines Facility Security Measures Table 2 Baseline and Enhanced Security Measures Personnel Training BASELINE SECURITY MEASURES ENHANCED SECURITY MEASURES Personnel Training Provide security awareness briefings to include security incident recognition and reporting procedures for personnel with unescorted access upon hiring and every 3 years thereafter Provide security training to include incident response training to personnel assigned security duties upon hiring and annually thereafter Document security training and maintain records in accordance with company record retention policy Security Incident Procedures Drills and Exercises Drills and Exercises Conduct periodic security drills or exercises to include announced or unannounced tests of security and incident plans These can be conducted in conjunction with other required drills or exercises Conduct or participate in an annual security drill or exercise Multiple facilities may participate in a common drill or exercise NOTE Response to an actual security incident can satisfy this measure Develop and implement a written post-event report assessing security drills or exercises and documenting corrective actions Security Incident Procedures Implement procedures for responding to security incidents or emergencies and to pertinent National Terrorism Advisory System NTAS Bulletins or Alerts These procedures should include the appropriate reporting requirements Post bomb threat checklists by telephones at staffed facilities 20 TSA Pipeline Security Guidelines Facility Security Measures Table 2 Baseline and Enhanced Security Measures BASELINE SECURITY MEASURES ENHANCED SECURITY MEASURES Recordkeeping Recordkeeping Develop and document recordkeeping policies and procedures for security information Protection of SSI in accordance with the provisions of 49 CFR Parts 15 and 1520 should be specifically addressed The following documents as appropriate should be retained until superseded or replaced • Corporate Security Plan • Criticality assessment s • Training records • Security drill or exercise reports • Incident response plan s • Security testing and audits In addition to the documents specified for non-critical facilities the following documents applicable to critical facilities should be retained until superseded or replaced • SVA s • Site-specific measures Make security information records available to TSA upon request Make security information records available to TSA upon request Outreach Outreach Conduct outreach to nearby law enforcement agencies to ensure awareness of the facility’s functions and significance Conduct outreach to neighboring businesses to coordinate security efforts Also conduct outreach to neighboring residences to provide facility security awareness 21 TSA Pipeline Security Guidelines Pipeline Cyber Asset Security Measures 7 PIPELINE CYBER ASSET SECURITY MEASURES 7 1 Introduction The operational technology used by the operators to manage their infrastructure and products are vital to the pipeline system's safe and efficient operation “Operational technologies” OT are the systems that detect or cause a change through the direct monitoring and or control of physical devices processes and events in the pipelines OT systems include control systems SCADA process control systems PCS distributed control systems DCS measurement systems and telemetry systems which are collectively referred to as “pipeline cyber assets ” The National Institute of Standards and Technology NIST has developed the Framework for Improving Critical Infrastructure Cybersecurity a set of standards and best practices to assist organizations in managing cybersecurity risks and to promote the protection of critical infrastructure To implement an effective cybersecurity strategy pipeline operators should consider the approach outlined in the NIST Framework and the guidance issued by DHS and the Department of Energy along with industry-specific or other established methodologies standards and best practices see Section 7 4 7 2 Pipeline Cyber Assets Classification Operators should evaluate pipeline cyber assets and classify them using the following criteria • Critical pipeline cyber assets are OT systems that can control operations on the pipeline Baseline and enhanced security measures should be applied to these assets • Non-critical pipeline cyber assets are OT systems that monitor operations on the pipeline Baseline security measures should be applied to these assets 7 3 Security Measures for Pipeline Cyber Assets Table 3 shows the baseline and enhanced cybersecurity measures that pipeline operators should apply to pipeline cyber assets based on their criticality designation These measures incorporate updates to the previous TSA Pipeline Security Guidelines as well as recommendations and practices from the government and industry documents listed in Section 7 4 The cybersecurity guidelines that follow are organized according to the relevant functions and categories presented in the NIST Framework 22 TSA Pipeline Security Guidelines Pipeline Cyber Asset Security Measures Table 3 Baseline and Enhanced Cyber Security Measures Enhanced Security Measures Baseline Security Measures Asset Management Establish and document policies and procedures for assessing and maintaining configuration information for tracking changes made to the pipeline cyber assets and for patching upgrading operating systems and applications Ensure that the changes do not adversely impact existing cybersecurity controls Employ mechanisms to maintain accurate inventory and to detect unauthorized components Develop and maintain a comprehensive set of network system architecture diagrams or other documentation including nodes interfaces remote and third party connections and information flows Review network connections periodically including remote and third party connections Develop a detailed inventory for every endpoint Review and assess pipeline cyber asset classification as critical or non-critical at least every 12 months Identify Business Environment Ensure that any change that adds control operations to a non-critical pipeline cyber asset results in the system being recognized as a critical pipeline cyber asset and enhanced security measures being applied Governance Establish and distribute cybersecurity policies plans processes and supporting procedures commensurate with the current regulatory risk legal and operational environment Review and assess all cybersecurity policies plans processes and supporting procedures regularly not to exceed 36 months or when there is a significant organizational or technological change Update as necessary Review and assess all cybersecurity policies plans processes and supporting procedures regularly not to exceed 12 months or when there is a significant organizational change Update as necessary Risk Management Strategy Develop an operational framework to ensure coordination communication and accountability for information security on and between the control systems and enterprise networks 23 TSA Pipeline Security Guidelines Pipeline Cyber Asset Security Measures Table 3 Baseline and Enhanced Cyber Security Measures Enhanced Security Measures Baseline Security Measures Identify Risk Assessment Establish a process to identify and evaluate vulnerabilities and compensating security controls Ensure threat and vulnerability information received from information sharing forums and sources are made available to those responsible for assessing and determining the appropriate course of action Access Control Establish and enforce unique accounts for each individual user and administrator establish security requirements for certain types of privileged accounts and prohibit the sharing of these accounts Restrict user physical access to control systems and control networks through the use of appropriate controls Employ more stringent identity and access management practices e g authenticators passwordconstruct access control In instances where systems do not support unique user accounts then implement appropriate compensating security controls e g physical controls Ensure that user accounts are modified deleted or de-activated expeditiously for personnel who no longer require access or are no longer employed by the company Protect Establish and enforce access control policies for local and remote users Procedures and controls should be in place for approving and enforcing policy for remote and third-party connections Monitor physical and remote user access to critical pipeline cyber assets Ensure appropriate segregation of duties is in place In instances where this is not feasible apply appropriate compensating security controls Change all default passwords for new software hardware etc upon installation In instances where changing default passwords is not technically feasible e g a control system with a hard-coded password implement appropriate compensating security controls e g administrative controls Employ mechanisms to support the management of accounts 24 TSA Pipeline Security Guidelines Pipeline Cyber Asset Security Measures Table 3 Baseline and Enhanced Cyber Security Measures Enhanced Security Measures Baseline Security Measures Awareness and Training Ensure that all persons requiring access to the organization’s pipeline cyber assets receive cybersecurity awareness training Provide role-based security training on recognizing and reporting potential indicators of system compromise prior to obtaining access to the critical pipeline cyber assets Establish and execute a cyber-threat awareness program for employees This program should include practical exercises testing Data Security Information Protection Protect Establish and implement policies and procedures to ensure data protection measures are in place including identifying critical data and establishing classification of different types of data establishing specific handling procedures and protections and disposal Protective Technology Segregate and protect the pipeline cyber assets from enterprise networks and the internet using physical separation firewalls and other protections Regularly validate that technical controls comply with the organization’s cybersecurity policies plans and procedures and report results to senior management Implement technical or procedural controls to restrict the use of pipeline cyber assets for only approved activities Detect Anomalies and Events Implement processes to generate alerts and log cybersecurity events in response to anomalous activity Review the logs and respond to alerts in a timely manner Security Continuous Monitoring Monitor for unauthorized access or the introduction of malicious code or communications Conduct cyber vulnerability assessments as described in your risk assessment process Utilize independent assessors to conduct pipeline cyber security assessments 25 TSA Pipeline Security Guidelines Pipeline Cyber Asset Security Measures Table 3 Baseline and Enhanced Cyber Security Measures Enhanced Security Measures Baseline Security Measures Detect Detection Processes Establish technical or procedural controls for cyber intrusion monitoring and detection Perform regular testing of intrusion and malware detection processes and procedures Respond Response Planning Establish policies and procedures for cybersecurity incident handling analysis and reporting including assignment of the specific roles tasks to individuals and teams Conduct cybersecurity incident response exercises periodically Establish and maintain a cyber-incident response capability Establish and maintain a process that supports 24 hours a day cyber incident response Communications Report significant cyber incidents to senior management appropriate federal state local tribal and territorial SLTT entities and applicable ISAC s Pipeline operators should follow the notification criteria in Appendix B Mitigation Ensure the organization’s response plans and procedures include mitigation measures to help prevent further impacts Recover Recovery Planning Establish a plan for the recovery and reconstitution of pipeline cyber assets within a timeframe to align with the organization’s safety and business continuity objectives Improvements Review the organization's cyber recovery plan annually Update as necessary 26 TSA Pipeline Security Guidelines Pipeline Cyber Asset Security Measures 7 4 Cyber Security Planning and Implementation Guidance The following is a list of planning and implementation guidance developed by industry or Federal government entities Operators should consult the current edition of these and other cyber security references on a frequent basis in developing and reviewing their company’s cyber security program • American Chemistry Council Guidance for Addressing Cyber Security in the Chemical Industry • American Gas Association AGA Report Number 12 Cryptographic Protection of SCADA Communications Part 1 Background Policies and Test Plan • American National Standards Institute ANSI International Society of Automation ISA – 99 00 01 – 2007 Security for Industrial Automation and Control Systems Terminology Concepts and Models • ANSI ISA – 99 02 01 – 2009 Security for Industrial Automation and Control Systems Establishing an Industrial Automation and Control System Security Program • American Petroleum Institute API Standard 1164 Pipeline SCADA Security • ANSI API Standard 780 Security Risk Assessment Methodology for the Petroleum and Petrochemical Industries • U S Department of Commerce National Institute of Standards and Technology NIST Framework for Improving Critical Infrastructure Cybersecurity • U S Department of Commerce NIST Special Publication 800-82 Guide to Industrial Control Systems ICS Security • U S Department of Homeland Security Office of Infrastructure Protection Risk-Based Performance Standards Guidance Chemical Facility Anti-Terrorism Standards May 2009 • U S Department of Energy Office of Electricity Delivery and Energy Reliability Energy Sector Cybersecurity Framework Implementation Guidance January 2015 • U S Department of Homeland Security Transportation Systems Sector Cybersecurity Framework Implementation Guidance June 2015 27 TSA Pipeline Security Guidelines Protective Measures for National Terrorism Advisory System NTAS Alerts 8 PROTECTIVE MEASURES FOR NATIONAL TERRORISM ADVISORY SYSTEM NTAS ALERTS The Department of Homeland Security’s NTAS provides a framework to disseminate information via Bulletins or Alerts regarding the threat of terrorist acts to the nation TSA has developed a supplement to this document containing recommended security measures to reduce vulnerabilities to pipeline systems and facilities during periods of heightened threat and to establish a consistent security posture within the pipeline industry This supplement is unclassified but sensitive and is marked as Sensitive Security Information SSI The password- protected document may be obtained by email request to pipelinesecurity@dhs gov 28 TSA Pipeline Security Guidelines Appendix A – Recurring Actions APPENDIX A – RECURRING ACTIONS RECURRING ACTIONS 12 Months 18 Months Perform an annual review of the corporate security plan and update as required Section 3 1 Conduct facility criticality assessments on a periodic basis not to exceed 18 months Section 4 2 24 Months 36 Months Other Periodically update contact and communications information for government agencies Table 2 Communication Baseline Conduct security drills or exercises on a periodic basis Table 2 Drills and Exercises Review and assess pipeline cyber asset classification as critical or non-critical at least every 12 months Table 3 Cyber Asset Management Review the organization's cyber recovery plan annually Table 3 Cyber Improvements Review and assess all cybersecurity policies plans processes and supporting procedures regularly not to exceed 36 months Table 3 Cyber Governance Perform regular testing of intrusion and malware detection processes and procedures Table 3 Cyber Detection Processes Conduct cybersecurity incident response exercises periodically Table 3 Cyber Response Planning Periodically review facility staffing requirements for implementing additional security measures NTAS Supplement p 1 Provide notification of a pipeline incident in accordance with Appendix B 29 TSA Pipeline Security Guidelines Appendix A – Recurring Actions RECURRING ACTIONS 12 Months 18 Months Conduct a SVA within 12 months of significant modification to a critical facility a newly identified critical facility or a newly constructed facility identified as critical Section 4 3 Enhanced Review sitespecific security measures periodically not to exceed 18 months Section 6 3 24 Months 36 Months Implement appropriate findings NLT 24 months after SVA completion Section 4 3 Conduct periodic SVAs not to exceed 36 months Section 4 3 Conduct key inventories every 24 months Table 2 Locks and Key Control Verify the proper operation and or condition of all security equipment through routine use or quarterly examination Table 2 Equipment Maintenance and Testing Conduct recurring background investigations not to exceed 10 years for employees occupying security positions or in sensitive positions Table 2 Background Investigation Conduct or participate in an annual security drill or exercise Table 2 Exercises and Drills Provide security training to personnel assigned security duties upon hiring and annually thereafter Table 2 Personnel Training Other Provide security awareness briefings for personnel with unescorted access upon hiring and every 3 years thereafter Table 2 Personnel Training Review and assess all cybersecurity policies plans processes and supporting procedures regularly not to exceed 12 months Table 3 Cyber Governance Note 1 Baseline measures apply to all pipeline operators Enhanced measures apply to operators’ critical facilities 2 All baseline and enhanced security measures are detailed in Section 6 of this document 30 TSA Pipeline Security Guidelines Appendix B - TSA Notification Criteria APPENDIX B - TSA NOTIFICATION CRITERIA As the lead Federal agency for pipeline security TSA requests to be notified of security incidents that are indicative of a deliberate attempt to disrupt pipeline operations or activities that could be considered precursors to such an attempt Pipeline operators should notify the Transportation Security Operations Center TSOC via phone at 866-615-5150 or email at TSOC ST@dhs gov as soon as possible if any of the following incidents occurs or if there is other reason to believe that a terrorist incident may be planned or may have occurred • Explosions or fires of a suspicious nature affecting pipeline systems facilities or assets • Actual or suspected attacks on pipeline systems facilities or assets • Bomb threats or weapons of mass destruction WMD threats to pipeline systems facilities or assets • Theft of pipeline company vehicles uniforms or employee credentials • Suspicious persons or vehicles around pipeline systems facilities assets or right-of-way • Suspicious photography or possible surveillance of pipeline systems facilities or assets • Suspicious inquiries from people asking about pipeline system facility or asset operations vulnerabilities or security practices • Suspicious individuals applying for security-sensitive positions in the pipeline company • Theft or loss of sensitive security information detailed pipeline maps security plans etc When contacting the TSOC provide as much of the following information as possible • Name and contact information • The time and location of the incident as specifically as possible • A description of the incident or activity involved • Which entities have been notified and what actions have been taken • The names and or descriptions of persons involved or suspicious parties and license plates as appropriate Actual or suspected cyber-attacks that could impact pipeline industrial control systems SCADA PCS DCS measurement systems and telemetry systems or enterprise associated IT systems should be reported to the National Cybersecurity and Communications Integration Center NCCIC at 888-282-0870 For questions or concerns email the TSA Pipeline Security staff at pipelinesecurity@dhs gov 31 APPENDIX C – LIST OF ACRONYMS AGA ANSI APGA API CFR DCS DHS DOT FEMA HSEEP HSIN ICS INGAA ISA IT NIST NTAS PCS SCADA SSI SVA TIH TSA TSOC WMD American Gas Association American National Standards Institute American Public Gas Association American Petroleum Institute Code of Federal Regulations Distributed Control System U S Department of Homeland Security U S Department of Transportation Federal Emergency Management Agency Homeland Security Exercise and Evaluation Program Homeland Security Information Network Industrial Control System Interstate Natural Gas Association of America International Society of Automation Information Technology National Institute of Standards and Technology National Terrorism Advisory System Process Control System Supervisory Control and Data Acquisition Sensitive Security Information Security Vulnerability Assessment Toxic Inhalation Hazard Transportation Security Administration Transportation Security Operations Center Weapons of Mass Destruction 32 APPENDIX D – REFERENCE DOCUMENTS Operators should consult the current edition of these and other security references on a frequent basis in developing and reviewing their company’s security program Cyber planning and implementation guidance appears in Section 7 4 American Gas Association AGA Interstate Natural Gas Association of America INGAA American Public Gas Association APGA Security Guidelines Natural Gas Industry Transmission and Distribution American Petroleum Institute API National Petrochemical Refiners Association NPRA Security Vulnerability Assessment Methodology for the Petroleum and Petrochemical Industries API Security Guidelines for the Petroleum Industry Homeland Security Presidential Directive 7 Critical Infrastructure Identification Prioritization and Protection Presidential Policy Directive 7 National Terrorism Advisory System NTAS U S Department of Homeland Security Federal Emergency Management Agency FEMA Homeland Security Exercise and Evaluation Program HSEEP Vols 1 - 4 U S Department of Homeland Security National Infrastructure Protection Plan U S Department of Homeland Security National Cyber Security Division Catalog of Control Systems Security Recommendations for Standards Developers U S Department of Homeland Security Transportation Security Administration TSA Pipeline Security Smart Practices U S Department of Homeland Security TSA Transportation Systems Sector-Specific Plan Pipeline Modal Annex 33