IR 05000277/2024401
| ML23278A018 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/05/2023 |
| From: | Glenn Dentel NRC/RGN-I/DORS |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2024401 | |
| Download: ML23278A018 (1) | |
Text
October 5, 2023
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 -
INFORMATION REQUEST FOR THE CYBERSECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM INSPECTION 05000277/2024401 AND 05000278/2024401
Dear David Rhoades:
On February 5, 2024, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline inspection in accordance with Inspection Procedure (IP) 71130.10, Cyber Security, dated December 14, 2021, at Peach Bottom Atomic Power Station, Units 2 and 3. The inspection will be performed to evaluate and verify your ability to meet the requirements of the NRCs Cyber Security Rule, Title 10 of the Code of Federal Regulations (10 CFR) Part 73, Section 54, Protection of Digital Computer and Communication Systems and Networks. The onsite portion of the inspection will take place February 5 through 9, 2024.
Experience has shown that baseline inspections are extremely resource intensive, both for the NRC inspectors and the licensee staff. In order to minimize the inspection impact on the site and to ensure a productive inspection for both parties, we have enclosed a request for documents needed for the inspection. These documents have been divided into four groups.
The first group specifies information necessary to assist the inspection team in choosing the focus areas (i.e., sample set) to be inspected by IP 71130.10. This information should be made available either on an online repository (preferred) or digital media (CD/DVD) no later than October 27, 2023. The inspection team will review this information and, by December 1, 2023, will request the specific items that should be provided for review.
The second group of additional requested documents will assist the inspection team in the evaluation of the critical systems and critical digital assets (CSs/CDAs), defensive architecture, and the areas of the licensees Cyber Security Program selected for the cybersecurity inspection. This information will be requested for review in the regional office prior to the inspection by December 29, 2023, as identified above. The third group of requested documents consists of those items that the inspection team will review, or need access to, during the inspection. Please have this information available by the first day of the onsite inspection, February 5, 2024.
The fourth group of information is necessary to aid the inspection team in tracking issues identified as a result of the inspection. It is requested that this information be provided to the lead inspector as the information is generated during the inspection. It is important that all of these documents are up to date and complete in order to minimize the number of additional documents requested during the preparation and/or the onsite portions of the inspection.
The lead inspector for this inspection is Louis Dumont. We understand that our regulatory contact for this inspection is Angel Castro Hernadez of your organization. If there are any questions about the inspection or the material requested, please contact the lead inspector at (610) 337-5183 or via email at louis.dumont@nrc.gov.
This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, control number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.
In accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely, Digitally signed by Glenn Glenn T. T. Dentel Date: 2023.10.05 Dentel 10:04:37 -04'00'
Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket Nos. 05000277 and 05000278 License Nos. DPR-44 and DRP-56 Enclosure:
Cybersecurity Inspection Document Request cc w/encl: Distribution via ListServ
ML23278A018 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE RI/DORS RI/DORS NAME LDumont GDentel DATE 10/4/2023 10/5/2023
PEACH BOTTOM ATOMIC POWER STATION CYBER SECURITY INSPECTION DOCUMENT REQUEST Inspection Report: 05000277/2024401 AND 05000278/2024401 Inspection Dates: February 5 - 9, 2024 Inspection Procedure: IP 71130.10, Cyber Security, dated December 14, 2021 (ADAMS Accession Number: ML21271A106)
Reference: Guidance Document for Development of the Request for Information (RFI) and Notification Letter for IP 71130.10, Cyber Security (ML21330A088)
NRC Inspectors: Louis Dumont, Lead Brandon Pinson 610-337-5183 610-337-5091 Louis.Dumont@nrc.gov Brandon.Pinson@nrc.gov Timothy Hennessey 610-337-5135 Timothy.hennessey@nrc.gov NRC Contractors: TBD I. Information Requested for In-Office Preparation The initial request for information (i.e., first RFI) concentrates on providing the inspection team with the general information necessary to select appropriate components and Cyber Security Program (CSP) elements to develop a site-specific inspection plan.
The first RFI is used to identify the list of critical systems and critical digital assets (CSs/CDAs) plus operational and management (O&M) security control portions of the CSP to be chosen as the sample set required to be inspected by the cybersecurity inspection procedure. The first RFIs requested information is specified below in Table RFI #1. The Table RFI #1 information is requested to be provided to the regional office by October 27, 2023, or sooner, to facilitate the selection of the specific items that will be reviewed during the onsite inspection weeks.
The inspection team will examine the returned documentation from the first RFI and identify/select specific systems and equipment (e.g., CSs/CDAs) to provide a more focused follow-up request to develop the second RFI. The inspection team will submit the specific systems and equipment list to your staff by December 1, 2023, which will identify the specific systems and equipment that will be utilized to evaluate the CSs/CDAs, defensive architecture, and the areas of the licensees CSP selected for the cybersecurity inspection. We request that the additional information provided from the second RFI be made available to the regional office prior to the inspection by December 29, 2023.
Enclosure
PEACH BOTTOM ATOMIC POWER STATION CYBERSECURITY INSPECTION DOCUMENT REQUEST The required Table RFI #1 information shall be provided on an online repository (preferred) or digital media (CD/DVD) to the lead inspector by October 27, 2023. The preferred file format for all lists is a searchable Excel spreadsheet file. The information should be indexed and hyper-linked to facilitate ease of use. If you have any questions regarding this information, please call the inspection team leader as soon as possible.
Table RFI #1 Section 3, Paragraph Number/Title: IP Ref A list of all Identified Critical Systems and Critical Digital Assets -
highlight/note any additions, deletions or reclassifications due to new 1 Overall guidance from white papers, changes to NEI 10-04, 13-10, etc. since the last cybersecurity inspection 2 A list of EP and Security onsite and offsite digital communication systems Overall Network Topology Diagrams to include information and data flow for 3 Overall critical systems in levels 2, 3 and 4 (If available)
4 Ongoing Monitoring and Assessment program documentation 03.01(a)
5 The most recent effectiveness analysis of the Cyber Security Program 03.01(b)
6 Vulnerability screening/assessment and scan program documentation 03.01(c)
Cybersecurity Incident response documentation, including incident detection, response, and recovery documentation as well as contingency 03.02(a)
7 plan development and implementation, including any program and documentation that requires testing of security boundary device 03.04(b)
functionality 8 Device Access and Key Control documentation 03.02(c)
9 Password/Authenticator documentation 03.02(c)
10 User Account/Credential documentation 03.02(d)
Portable Media and Mobile Device control documentation, including kiosk 11 03.02(e)
security control assessment/documentation Design change/modification program documentation and a list of all design changes that affected CDAs that have actually been installed and completed 12 03.03(a)
since the last cybersecurity inspection, including either a summary of the design change or the 50.59 documentation of the change 03.03(a),
Supply Chain Management documentation including any security impact 13 (b) and analysis for new acquisitions (c)
Configuration Management documentation including any security impact 03.03(a)
analysis performed due to configuration changes since the last inspection and (b)
Cybersecurity Plan and any 50.54(p) analysis to support changes to the plan 15 03.04(a)
since the last inspection 16 Cybersecurity Metrics tracked (if applicable) 03.06 (b)
Provide documentation describing any cybersecurity changes to the access 17 Overall authorization program since the last cybersecurity inspection Provide a list of all procedures and policies provided to the NRC with their 18 Overall descriptive name and associated number (if available)
19 Performance testing report (if applicable) 03.06 (a)
PEACH BOTTOM ATOMIC POWER STATION CYBERSECURITY INSPECTION DOCUMENT REQUEST In addition to the above information please provide the following:
(1) Electronic copy of the UFSAR and technical specifications.
(2) Name(s) and phone numbers for the regulatory and technical contacts.
(3) Current management and engineering organizational charts.
Based on this information, the inspection team will identify and select specific systems and equipment (e.g., CSs/CDAs) from the information requested by Table RFI #1 and submit a list of specific systems and equipment to your staff by December 1, 2023, for the second RFI (i.e., RFI #2).
II. Additional Information Requested to be Available Prior to Inspection.
As stated in Section I above, the inspection team will examine the returned documentation requested from Table RFI #1 and submit the list of specific systems and equipment to your staff by December 1, 2023, for the second RFI (i.e., RFI #2). The second RFI will request additional information required to evaluate the CSs/CDAs, defensive architecture, and the areas of the licensees CSP selected for the cybersecurity inspection. The additional information requested for the specific systems and equipment is identified in Table RFI #2.
The Table RFI #2 information shall be provided to the lead inspector by December 29, 2023. The preferred file format for all lists is a searchable Excel spreadsheet. The information should be indexed and hyper-linked to facilitate ease of use. If you have any questions regarding this information, please call the inspection team leader as soon as possible.
Table RFI #2 Section 3, Paragraph Number/Title: Items For the system(s) chosen for inspection provide:
1 Ongoing Monitoring and Assessment activity performed on the system(s) 03.01(a)
2 All Security Control Assessments for the selected system(s) 03.01(a)
All vulnerability screenings/assessments associated with or scans 3 performed on the selected system(s) since the last cybersecurity 03.01(c)
inspection Documentation (including configuration files and rules sets) for Network-based Intrusion Detection/Protection Systems (NIDS/NIPS), Host-based 4 03.02(b)
Intrusion Detection Systems (HIDS), and Security Information and Event Management (SIEM) systems for system(s) chosen for inspection)
Documentation (including configuration files and rule sets) for intra-5 security level firewalls and boundary devices used to protect the selected 03.02(c)
system(s)
Copies of all periodic reviews of the access authorization list for the 6 03.02(d)
selected systems since the last inspection 7 Baseline configuration data sheets for the selected CDAs 03.03(a)
PEACH BOTTOM ATOMIC POWER STATION CYBERSECURITY INSPECTION DOCUMENT REQUEST Documentation on any changes, including Security Impact Analyses, 8 03.03(b)
performed on the selected system(s) since the last inspection Copies of the purchase order documentation for any new equipment 9 03.03(c)
purchased for the selected systems since the last inspection Copies of any reports/assessment for cybersecurity drills performed since 03.02(a)
the last inspection 03.04(b)
Copy of the individual recovery plan(s) for the selected system(s) including 03.02(a)
documentation of the results the last time the backups were executed 03.04(b)
Corrective actions taken as a result of cybersecurity incidents/issues to 12 include previous NRC violations and Licensee Identified Violations since 03.05 the last cybersecurity inspection For the selected systems, provide design change/modification packages 13 03.03(a)
including completed work orders since the last cybersecurity inspection III. Information Requested to be Available on First Day of Inspection For the specific systems and equipment identified in Section II above, provide the following RFI (i.e., Table 1ST Week Onsite) to the team by February 5, 2024, the first day of the inspection.
Table 1ST Week Onsite Section 3, Paragraph Number/Title: Items Any cybersecurity event reports submitted in accordance with 10 CFR 1 03.04(b)
73.77 since the last cybersecurity inspection Updated Copies of corrective actions taken as a result of cybersecurity incidents/issues, to include previous NRC violations and Licensee 2 03.05 Identified Violations since the last cybersecurity inspection, as well as vulnerability-related corrective actions In addition to the above information please provide the following:
(1) Copies of the following documents do not need to be solely available to the inspection team as long as the inspectors have easy and unrestrained access to them.
a. Updated Final Safety Analysis Report, if not previously provided; b. Original Cybersecurity Safety Evaluation Report and Supplements; c. Quality Assurance (QA) Plan; d. Technical Specifications, if not previously provided; and e. Latest individual plant examination/probabilistic Risk assessment report.
PEACH BOTTOM ATOMIC POWER STATION CYBERSECURITY INSPECTION DOCUMENT REQUEST (2) Vendor Manuals, Assessment and Corrective Actions:
a. The most recent Cybersecurity QA audit and/or self-assessment; and b. Corrective action documents (e.g., condition reports, including status of corrective actions) generated as a result of the most recent Cybersecurity QA audit and/or self-assessment.
IV. Information Requested To Be Provided Throughout the Inspection (1) Copies of any corrective action documents generated as a result of the inspection teams questions or queries during the inspection.
(2) Copies of the list of questions submitted by the inspection team members and the status/resolution of the information requested (provided daily during the inspection to each inspection team member).
If you have any questions regarding the information requested, please contact the inspection team leader.
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