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1 Proposed cyber-physical security system design for a new LNG plant USC PTE 519 December 2016 Cyrus Ashayeri

Proposed cyber-physical security system design for a new · PDF filethe plant receives its natural gas in form of mini LNG, purchased from Tipu Sultan LNG plant on a monthly basis

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1

Proposed cyber-physical security

system design for a new LNG plant

USC PTE 519

December 2016

Cyrus Ashayeri

2

OUTLINE

SECTION PAGE

Executive summary …………………………………………. 3

Imaginary cyber-attack scenarios …………………………. 4

Introduction …………………………...…………………….. 8

LNG plant overview ………………………………………… 8

Process control of key units in LNG plants ………………. 14

Security assessment ……………………………………….... 18

Security design ……………………………………………… 23

Lessons learned and defense …………………………….…. 26

References …………………………………………………... 29

3

Executive summary

Although the majority of LNG plants across the world share similar fundamentals, there are no

two identical plants. Therefore, every industrial control system is unique in its own right.

Designing a one-size-fits-all cybersecurity system for critical infrastructure is an impossible task,

and any attempt in using this approach is doomed to fail.

In this research, rather than designing a security system for an integrated physical-cyber system, a

methodology is proposed. The approach here is identification of main components in the LNG

operation and breaking those down onto key processes. In the meantime, based on the available

literature, major categories of cyberattacks on industrial systems have been introduced and their

targets are briefly explained. The workflow proposed on page 24 of this report can be used as a

tool to hypothetically impose various magnitudes of cyberattacks on key components of the system

and predict the outcomes.

While a large portion of the report focuses on the LNG plant layout and processes, pages 20 - 22

provide necessary information on industrial scale cyberattacks. This information can be used as

the tool to examine all possible attack consequences in various units of the LNG process.

To help better understanding the procedure, this report begins with three imaginary attack

scenarios. This section aims at inspiring the reader to see less obvious aspects of vulnerabilities in

such cases. Finally, the report ends with a brief section on lessons learned from the proposed

scenarios and basic suggestions on defense mechanisms.

Needless to say, a complete cyber-physical security design as above the scope of this research and

the information provided aim at creating basic thinking tools in tackling such projects.

4

Imaginary cyber-attack scenarios

Cyber-physical systems (CPS) are broadly used in critical infrastructures today. They integrate

sensors, controllers, actuators, computers, communication systems, and physical operations.

Technological advancements in the area of sensing and wireless communication have resulted in

large scale utilization of sensor nodes in industrial plants. In the meantime, the ever growing threat

of cyber-attacks could lead to severe damages to critical infrastructure, financial loss, and above

all, loss of human lives. Needless to say, it is impossible to develop complete immunity towards

such potential attacks, however, by identifying them, we can take major steps in detection and

prevention areas.

Based on the Confidentiality-Integrity-Availability model, cyberattacks target key components in

a system to compromise one, or more, of the mentioned categories. In this section, before starting

the introductions, 3 hypothetical cyberattack scenarios are provided to set background.

Scenario 1. Financial fraud via attack on Measurement System

Iran holds the 2nd largest gas natural gas reserves in the world and currently is the 3rd largest

producer of natural gas in the world. However, almost all of their natural gas production is

consumed domestically and the negligible amounts are exported. However, after the removal of

international nuclear related sanctions they are planning to bring online multiple development

phases in the South Pars gas field (largest non-associated natural gas field in the world) in the

Persian Gulf. Iran does not have any LNG plant, therefore they are planning to sign a 20-year

contract with Qatar to utilize their spare LNG capacity and ship their natural gas to Asian Market.

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Contractor X which is in charge of constructing the subsea pipeline and deliver the gas to Qatari

side is planning a cyberattack on the LNG plant flow meter systems to manipulate the readings on

received volumes. An error of 1 % in measurements can result in $12 million per year gain to the

company.

Company X has learned, through a leaked vendors’ list, that the Qatari LNG plant has installed

Honeywell’s Experion® Process Knowledge System (PKS), MeterSuite™. The mentioned system

has integrated wireless remote control capabilities that can access the data collection/storage

system.

Figure 1. Honeywell Experion® Mobile Access

The adversary company X has managed to access default authorization codes for the Experion

portable devices (shown above) to access the measurement system and feed false measurement

data into the system. The attacker is implanting malware to inject falsified information into both

receiving and loading (export) measurement devices to completely hide the measurement error

from the LNG facility control system.

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Scenario 2. Attack through supply chain through ERP System corruption

This scenario focuses on the possibility of LNG plant being used as means to attack a target which

is in the LNG supply chain (in this case a buyer). Detecting such attacks could be extremely

challenging since usually an LNG buyer, and the regasification destination are thousands of limes

away.

As part of energy diversification plans, India has constructed a solar power plant in a remote desert

area. This solar power plant is an integrated combined cycle which uses natural gas and provides

500 MW to the national power grid. Based on the remote location and lack of natural gas pipeline,

the plant receives its natural gas in form of mini LNG, purchased from Tipu Sultan LNG plant on

a monthly basis.

A new set of temperature sensors have been recently ordered and installed to detect leaks in the

plant pipeline system. New sensors have an automated diagnostic system which communicates

with the vendor. This connection is established through the LNG plant’s business network.

A group of political opposition backed by Pakistani extremists are planning a cyber-attack to shut

down parts of the Indian national power grid. The hacker group have managed to plant their

malware in the sensors and once the sensors access the business network to transmit diagnostics

report to the vendor, corruption of the ERP financial network occurs. The national power company

is connected to the LNG plant’s corporate network for monthly payments and restricted access to

purchase history data. The next data batch to be downloaded by the national power grid company.

7

Scenario 3. Compliance with regulation via attack on Flare Stack Valves

Due to oversupply in global LNG market an Algerian LNG plant is downsizing. An ex-engineer

who has been involved in the design and selection of valves for the new LNG plant has been fired

recently. He is trying to revenge the company. This employee had access to the automated control

system in Fisher Emerson flare stack valves.

Figure 2. Fisher™ 8532 High Performance Butterfly Valve

He has reprogrammed the PLC and has limited the valve’s opening to 50% during the plant startup

creating significant pressure differential, therefore causing supersonic velocity of 1.2 mach. The

operators have not been able to detect the source of vibration yet due to the manipulation and the

resulting vibration and noise have exceeded the national regulation levels and caused legal troubles

for the company with fines up to $500,000.

The motivation behind this attack was simply revenge, however the vulnerability exploited in this

scenario could be used to conduct terrorist attacks since failure to flow gas through flare system

could result in over-pressurized system and serious damages.

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Introduction

It is important to obtain basic familiarity with physical and chemical properties of LNG. This

section provides some information to help better understand different processes in an LNG plant,

and how the physical and chemical properties of LNG can result in an accident.

The composition of LNG depends on the composition of the field of origin’s natural gas

composition. It consists mostly of methane, with minor fractions of C2 to C4 and trace amounts

of CO2, Sulfur, and Nitrogen. LNG is colorless, odorless, and noncorrosive. LNG on its own is

nontoxic, but in a confined area can be harmful in many ways which will be discussed in following

sections. LNG has an average boiling point of -260 F, and density of 430-470 kg/m3 based on its

composition (Mokhatab, 2013) and the cooling process is done by Joule-Thompson effect. LNG

is a cryogenic liquid that is not flammable in liquid form.

After the arrival of natural gas to the plant, it needs to be purified from water and all other particles

such as Mercury. Different adsorption processes are utilized for removal of water and trace

amounts of other particles. Many other heavy HC molecules such as butane and pentane are also

removed by amine filters. The cooling process to such low levels requires extreme amounts of

energy.

LNG plant overview

An LNG plant, like any other chemical plant consists of thousands of components. In this study a

simplistic approach has been used to identify the general key components of the plant and focus

on their performance to design the appropriate security system. The image below depicts a typical

LNG plant with main components highlighted.

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Figure 3. Typical LNG facility layout

Physical plant specification Infrastructure

Gas Gate Station

LNG Trains

Flare Stack

LNG production

LNG storage tanks

Pipeline systems

Power

Communication systems

Export facilities

Control room

Maintenance building/Workshop

Administrative building

Physical perimeter

Table 1. Major components in a typical LNG plant

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For better preparation of the defense system it is beneficial to have an overall understanding of

the financial value of each section in the LNG plant. The chart below illustrates the value chain

breakdown in a typical LNG plant.

Figure 4. LNG value chain cost breakdown (from: Lim, 2013, I & EC Research)

As seen above, the liquefaction process is the most important and valuable part of the plant to be

defended against cyber or physical damage.

The core of the LNG plant is the process of cooling and liquefying the natural gas feed. Two of

the common methods globally used for the LNG process are Cascade Liquefaction Process and

Mixed Refrigerant Liquefaction Process. ConocoPhillips Optimized Cascade Process and Air

Products (AP-C3MR) are some famous commercial examples of these two methods.

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Diagrams below are simplified illustrations of the mentioned processes:

Figure 5. ConocoPhillips Optimized cascade LNG Process

Figure 6. Air Products’ Single Mixed Refrigerant Process

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Figure 7. AP-C3MR Process

Many large scale LNG plants across the world are operating using the above mentioned methods.

Idku LNG plant in Egypt with 2 trains and 7.2 MTPA capacity, Darwin LNG plant in Australia

with 1 train and 3.7 MTPA capacity, and Malabo LNG plant in Equatorial Guinea with 1 train and

3.7 MTPA capacity are among the examples using ConocoPhillips Cascade process. There are

several examples of Single Mixed Refrigerator such as AP-SMR and Propane Precooled Mixed

Mixed Refrigerant, such as AP-C3MR. Examples of the AP plants are found in Abu Dhabi, Algeria,

Indonesia, and China, utilizing 1 to 6 trains with capacities as high as 12 MTPA.

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Figure 8. Typical Cascade Liquefaction Process and Important valves

Figure 9. Typical Mixed Refrigerant Liquefaction Process and important valves

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Process control of key units in LNG plants

Liquefaction system

The liquefaction system is the heart of any LNG plant. Cooling down and condensing the

pretreated natural gas to produce LNG is the main operation here. Heat exchangers have very high

energy consumption, multiple temperature points require constant measurement, turbo-machinery

are used to compress the refrigerants in the system, and many disturbances such as flow rate and

feed gas composition fluctuation can significantly the process.

As mentioned earlier, there are several commercial liquefaction process technologies available on

the market, including APCI mixed refrigerant process (C3MR), Cascade refrigeration process, and

Shell DMR process. Diagram illustrating the flow chart in the first two systems have been provided

in the previous section. Key components of the system that have high security and safety risk and

therefore must be allocated high priority during defense design are briefly described here.

Control of refrigeration processes

A typical single stage refrigeration process normally consists of a chiller, compressor, condenser,

and surge tank. The diagram below is a simplified illustration of the process.

The main item to be controlled in this unit is the cooled outgoing stream’s temperature. The

temperature itself is maintained by controlling the pressure in the chiller, and this property is

controlled by manipulation of the compressor speed.

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Figure 10. Control scheme for a typical single-stage refrigeration process. (Mokhatab, 2013)

Control of liquefaction unit

The main item to be controlled at this unit is to ensure that the condensing of natural gas to form

LNG and sub cooling of LNG. Maintaining the optimal plant capacity is another equally crucial

objective at this unit. The two mentioned are achieved by rejecting disturbances such as ambient

temperature and feed composition fluctuations.

For the Mixed Refrigerant processes, the LNG temperature is controlled by the manipulation of

production rate, and the unit capacity is controlled by adjusting the compressor speeds and JT

valve positions (Mandler, 1998).

Compressor and gas turbine control

As discussed above, the capacity control for refrigeration is conducted by this unit. It is either done

by the plant DCS system or by embedded compressor control package available from different

vendors. The second option interacts with the anti-surge control and helps improve the process.

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Figure 11.Typical compressor-gas turbine string control scheme (Mokhatab, 2013)

Aside from the capacity control, several important capabilities that are required in a well-designed

compressor-driver such as: Antisurge control, Load balancing, Loop-decoupling, Override control,

and Load-limiting control.

Anti-surge control systems

This unit is of great importance from both safety and operation efficiency point of view.

Compressor operation in the marginal surge region can lead to severe damages such as flow

reversals. Also, Operating the compressor within the acceptable speed range helps avoiding

unplanned shutdowns which cause financial loss. The control system must be designed, based on

the physical properties of the system, to ensure flow rates higher than the surge line, and maintain

the designed surge margin as well. The simplified diagram below depicts the required capabilities

in this unit’s control system.

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Storage and loading

The main objective of the process control system in the storage unit is to maintain the storage tank

pressure at safe levels to prevent any flaring due to over-pressuring of the tank. The vapors from

the tank are fed to the BOG compressor, to be used again in the liquefaction process. The tank

pressure has to be controlled by manipulating the flow of BOG vapors.

LNG storage is either underground or above the ground. Multiple design variations such as single

containment tank, double containment tank, and full containment tank exist based on the plant

specification and each type have their own safety criteria. Design specification items to look for

here are: maximum design pressure, Vacuum design pressure, Norman operating pressure,

minimum operating pressure, and maximum operating pressure.

Anti-surge control system

Normal Proportional-

Integral (PI) controlDerivative response

Recycle trip response

Surge counter reset.

Figure 12. Required control capabilities in an Anti-surge unit

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Security assessment

Methodology

Digital risk identification and classification for the proposed LNG plant is conducted in the

following steps. First, the key physical process in the plant are identified. The selection criteria

here is both cost value of the units, their role in the plant operation, and their contribution in

production. Once these top priority components are identified, their function is studied to discover

physical or digital vulnerabilities.

Figure 13.Physical and security design steps

Cyber-attacks come in various forms and target different sections in an industrial plant. Based on

the attackers’ motivation, different degrees of damage can occur to the control systems, IT

network, physical devices, computers, or even further damages such is human safety are also

possible. In this research main forms of cyberattacks have been introduced and some of the top

frequent target in the industrial infrastructures are listed to facilitate the security assessment and

design.

For ICS security risk assessments, it is important to understand the interdependency of physical

and cyber security. The physical impacts of a cyber-attack can result in large scale damage to the

control system itself, the physical components of the facility, and potential human safety and

environmental damages. A security assessment must investigate the possible impacts of

Introduction to major control components

Priority protection

layers Defense strategy

Cost & value analysis

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cyberattacks on the performance of digital and physical components of the operation such as

sensors, actuators, valves, pumps, etc. Such damages can lead to short term or long term outage in

the plant process.

Business Case for Security

After conducting the security risk assessment at different levels, a business case must be prepared

for the organization which addresses the management concerns. Financial justification of the

security program is a key component in the successful implementation of an integrated cyber-

physical security design. In this research, four stages have been proposed to consider while

presenting a cyber security plan to upper management:

1) In case of LNG plants, based on the long term nature of the contracts and the level of

international competitiveness, it is crucial to include benefits of security systems in the

improvement of reliability and availability of the operation.

2) Damage scenarios in case of information or digital security breach.

3) Overview of the process for assessment, design, implementation, monitoring, maintaining

and updating the security system.

4) Costs and resources imposed on the management to develop the security plan.

Detailed study of physical, economic, and social impacts of cyberattacks helps evaluating and

defining the organization’s risk tolerance.

Cost has a big impact on management decision-making, however in case

of LNG infrastructure, investments needs to be considered as insurance

for a 25-year project. The long lifetime of the plant justifies significant

investment in utilization and constant upgrades in security systems.

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The table below shows various impacts of cyberattacks on industrial control systems (both tables

from Handbook of liquefied natural gas, Mokhatab, 2013).

Incident Type Potential Impact

Change in a system, operating

system, or application configuration

• Command and control channels introduced into otherwise secure

systems

• Suppression of alarms and reports to hide malicious activity

• Alteration of expected behavior to produce unwanted and

unpredictable results

Change in programmable logic in

PLCs, RTUs, or other controllers

• Damage to equipment and/or facilities

• Malfunction of the process (shutdown)

• Disabling control over a process

Misinformation reported to operators • Inappropriate actions taken in response to misinformation that could

result in a change to operational parameters

• Hiding or obfuscating malicious activity, including the incident itself

or injected code

Tampering with safety systems or

other controls

Preventing expected operations, fail safes, and other safeguards with

potentially damaging consequences

Malicious software (malware)

infection

• Initiation of additional incident scenarios

• Production impact resulting from assets taken offline for forensic

analysis, cleaning, and/or replacement

• Assets susceptible to further attacks, information theft, alteration, or

infection

Information theft Leakage of sensitive information such as a recipe or chemical formula

Information alteration Alteration of sensitive information such as a recipe or chemical formula in

order to sabotage or otherwise adversely affect the manufactured product

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The next table, has a more detailed approach and specifically shows the main targets of

cyberattacks on different control system components and the consequences of each category of

such attacks.

Target Attack Vectors Possible Attack Methods Possible Consequences

SCADA servers - Non-SCADA client

applications

- Application integration

communication channels

- Data historian

- Engineering Workstation

- Control network

- Software vendor support

portal

- Exploitation of unpatched applications

- Installation of malware via unvalidated

vendor software

- Remote access via “interactive” accounts

- Installation of malware via removable

media

- Exploitation of trusted connections within

control network

- Authorization to ICS applications without

sufficient access control mechanisms

- Plant upset / shutdown

- Delay plant startup

- Mechanical damage / sabotage

- Unauthorized manipulation of operator

graphics - inappropriate response to

process action

- Unauthorized modification of ICS

database(s)

- Unauthorized modification of critical

status / alarms

- Unauthorized startup / shutdown of ICS

devices

Controller (PLC) - Engineering workstation

- Operator HMI

- Standalone engineering

tools

- Rogue device in Control

Zone

- USB / removable media

- Controller network

- Controller (device)

network

- Engineer / technician misuse

- Network exploitation of industrial protocol -

known vulnerability

- Network exploitation of industrial protocol -

known functionality

- Network replay attack

- Network DoS via communication buffer

overload

- Direct code / malware injection via USB

- Direct access to device via rogue network

(local / remote) PC with appropriate tools /

software

- Manipulation of controlled process(es)

- Controller fault condition

- Manipulation / masking of input / output

data to / from controller

- Plant upset / shutdown

- Command-and-control

Engineering

workstations

- Engineering tools and

applications

- Exploitation of unpatched applications

- Installation of malware via unvalidated

vendor software

- Plant upset / shutdown

- Delay plant startup

- Mechanical damage / sabotage

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- Non-engineering client

applications

- USB / Removable media

- Elevated privileges

(engineer / administrator)

- Control network

- Software vendor support

portal

- Installation of malware via removable

media

- Installation of malware via keyboard

- Exploitation of trusted connections across

security perimeters

- Authorization to ICS applications without

sufficient access control mechanisms

- Unauthorized manipulation of operator

graphics - inappropriate response to

process action

- Unauthorized modification of ICS

database(s)

- Unauthorized modification of critical

status / alarms

- Unauthorized distribution of faulty

firmware

- Unauthorized startup / shutdown of ICS

devices

Fire detection and

suppression system

- Fire alarm / evaluation

- Fire suppressant system

- Building management

network

- Software vendor support

portal

- Exploitation of unpatched application

(building management system)

- Installation of malware via unvalidated

vendor software

- Network access through unprotected access

points

- Network pivoting through unregulated

network boundaries

- Unauthorized release of suppressant

- Equipment failure / shutdown

Perimeter protection

(firewall/IPS)

- Trusted connections

(Business-to-Control)

- Local user account

database

- Signature / rule updates

- Untested/unverified rules

- Exploitation of unnecessary / excessive

openings on perimeter defense (firewall)

- Insecure office and industrial protocols

allowed to cross security perimeter

- Reuse of credentials across boundary

- Unauthorized access to business network

- Unauthorized access to DMZ network

- Unauthorized access to control network

- Local credential leakage

- Unauthorized modification of rulesets /

signatures

- Communication disruption across

perimeter / boundary

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Security design

Security zones

Zoning and segregation is one of the most effective defense mechanisms in protecting industrial

networks. In the assessment of the potential zones for an LNG plant, all physical assets (equipment,

devices, computers, etc.), systems (controllers, sensors, logical devices, software), human interface

users, and all other components must be included. It is important to understand that there will be

overlaps in different zones, either in physical form or data network. Another issue is

implementation of zoning without influencing the efficient functionality of sub-systems.

Considering different means and protocols of communication among control systems and other

components help in dividing zones with minimal impact on process flow.

Zone 0: Field process zone

Zone 1: Basic control zone

Zone 2: Supervisory control zone

Zone 3: Plant operational control zone

Zone 4: Corporate and business zone

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WHAT CAN GO WRONG?

Control of refrigeration

processes

Control of liquefaction

unit

Compressor and gas turbine

control

Anti-surge control systems

Storage and loading

Change in a system, operating system, or application configuration

Change in programmable logic in PLCs, RTUs, or other controllers

Misinformation reported to operators

Malicious software (malware) infection

Tampering with safety systems or other controls

Information theft or alteration

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The design below (diagram created using the free version of Edraw software) show segregation of

major filed units, control systems, business network, emergency systems and their connection.

This is an over-simplification of the LNG plant operation and networks. Numerous types of

architecture in both operation and control process could impact the defense layers and priorities.

However, the detailed design of such system is not the goal of this research, and the proposed

methodology provides the tools to approach large scale designs.

Figure 14. Plant zoning design

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Lessons learned from hypothetical attack scenarios

The methodology explained in the previous section could be applied two different sectors of the

LNG plant. By listing the key control functions in each unit’s process, and imposing the impacts

of potential cyber-attacks, the security manager can first predict the failures created in the system

as a result of cyberattack, and then design defense mechanisms for prevention. Based on the three

different imaginary attack scenarios, and identified vulnerabilities, some basic defense

mechanisms are suggested here:

Scenario 1.

Remote access problem

Remote access to control system devices, if it is provided, should be controlled via specialized

virtual private networks (VPNs) or remote access servers (RAS), and should only allow explicitly

defined, point-to-point connections from known entities, over secure and encrypted channels.

User access problem

For human interaction, such as an operator accessing an HMI to control a process, it is just as

important to define which users should legitimately be communicating with which devices. This

requires a degree of Identity and Access Management (IAM), which defines users, their devices,

and their roles. Role-based access control (RBAC) on the other side, allows segregating employees

by allocating different groups. For example, upon termination of some employee’s contact which

included control system access, the plant is at risk. By placing a human operator in a functional

group with limited devices that he/she should be using, further suspicious activity could be

detected and potentially prevented. In the similar manner users from a business network endpoint

27

may require access to field data coming from within a SCADA system. Needless to say, such

behavior could expose the integrity and confidentiality of the system to great danger. Hence, the

use of demilitarize zone (DMZ) is recommended, as well as utilization of conduits such as one-

way communications between field and business users. Then assessment must be conducted for

all users within each security level zone (or layer).

Scenario 2.

Firewall/Network security problem

At a basic level, some sort of network firewall is required when field systems are connecting to a

network which has access to internet. Additional security such as Unified Threat Management

(UTM) devices, Network Whitelisting devices, Application Monitors, and Industrial Protocol

Filters, depending on the specific situation and budget can improve the reliability. The security

level of the zone in which control systems are operating dictates the degree of security that is

required, but in this scenario, the ultimate goal was corrupting the ERP system and eventually

attack some remote facility. In such cases, limited encryption of communication data helps

preventing unmonitored communication between field devices and business network.

Embedded corruption in purchased devices

Having a trusted internationally reputable vendor list eliminates many risks related to installing

pre-corrupted devices in the critical infrastructure. However, usually such risks are unknown to

the vendors as well. Therefore, having a 3rd party partner testing control devices prior to large scale

field implementation helps detecting some level of anomaly in the system.

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Scenario 3.

The human (employee) role problem

This scenario shares the human interaction component in the first scenario. The role of human

operators is by far the most important link in the cyberattack chain. A large portion of such attacks

include direct or indirect interference of an insider employee. This could be an intentional act of

sabotage, or in many cases, employees unintentionally cause severe damage to a critical system.

Therefore, constant training and education of the organization is one of the most crucial aspects of

defense mechanism. The certificate and standards listed below are some of the available means of

improving the employee knowledge:

- Certificate 1: ISA/IEC 62443 Cybersecurity Fundamentals Specialist

- Certificate 2: ISA/IEC 62443 Cybersecurity Risk Assessment Specialist

- Certificate 3: ISA/IEC 62443 Cybersecurity Design Specialist

- Certificate 4: ISA/IEC 62443 Cybersecurity Maintenance Specialist

- ISA/IEC 62443 Cybersecurity Expert: Individuals who achieve Certificates 1, 2, 3,

and 4 are designated as ISA/IEC 62443 Cybersecurity Experts.

While such training is extremely helpful, it is not enough and defense must be embedded in various

components of the physical and cyber systems.

Monitoring and detection problem

In the critical operation areas, application-layer session monitoring provides a valuable level of

protection, as it is able to detect low level protocol anomalies and application policy violations

(such as an unauthorized attempt to write a new configuration to a PLC).

29

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