IR 05000333/2023401

Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection 05000333/2023401

ML23152A004
Person / Time
Site:	FitzPatrick
Issue date:	06/01/2023
From:	Glenn Dentel NRC/RGN-I/DORS
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2023401
Download: ML23152A004 (1)

Text

June 1, 2023

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT-INFORMATION REQUEST FOR THE CYBER SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM INSPECTION 05000333/2023401

Dear David Rhoades:

On October 23, 2023, 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 FitzPatrick. 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 October 23 through 27, 2023.

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 July 14, 2023. The inspection team will review this information and, by August 18, 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 cyber security inspection. This information will be requested for review in the regional office prior to the inspection by September 15, 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, October 23, 2023.

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 Steven Juravich 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 website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely, Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety

Docket No. 05000333 License No. DPR-59

Enclosure:

Cyber Security Inspection Document Request

cc: Distribution via ListServ

Glenn T.

Dentel Digitally signed by Glenn T. Dentel Date: 2023.06.01 15:33:04 -04'00'

ML23152A004

SUNSI Review

Non-Sensitive Sensitive

Publicly Available Non-Publicly Available

OFFICE RI/DORS RI/DORS

NAME LDumont GDentel

DATE 5/31/2023 5/31/2023

JAMES A. FITZPATRICK NUCLEAR POWER PLANT CYBER SECURITY INSPECTION DOCUMENT REQUEST Enclosure Inspection Report:

05000333/2023401 Inspection Dates:

October 23 - 27, 2023 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 Tanvir Siddiky (610) 337-5183 Tanvir.siddiky@nrc.gov Louis.Dumont@nrc.gov

Timothy Hennessey (610) 337-5135 Timothy.hennessey@nrc.gov

NRC Contractors:

Balla Barro

Balla.barro@nrc.gov

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 security control portions of the CSP to be chosen as the sample set required to be inspected by the cyber security 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 July 14, 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 August 18, 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 cyber security inspection. We request that the additional information provided from the second RFI be made available to the regional office prior to the inspection by September 15, 2023.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT CYBER SECURITY 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 July 14, 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 guidance from white papers, changes to NEI 10-04, 13-10, etc. since the last cyber security inspection.

Overall

A list of EP and Security onsite and offsite digital communication systems Overall

Network Topology Diagrams to include information and data flow for critical systems in levels 2, 3 and 4 (If available)

Overall

Ongoing Monitoring and Assessment program documentation 03.01(a)

The most recent effectiveness analysis of the Cyber Security Program 03.01(b)

Vulnerability screening/assessment and scan program documentation 03.01(c)

Cyber Security Incident response documentation, including incident detection, response, and recovery documentation as well as contingency plan development and implementation, including any program documentation that requires testing of security boundary device functionality 03.02(a)

and 03.04(b)

8 Device Access and Key Control documentation 03.02(c)

Password/Authenticator documentation 03.02(c)

User Account/Credential documentation 03.02(d)

11 Portable Media and Mobile Device control documentation, including kiosk security control assessment/documentation 03.02(e)

Design change/modification program documentation and a list of all design changes that affected CDAs that have actually been installed and completed since the last cyber security 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 analysis for new acquisitions 03.03(a),

(b) and (c)

Configuration Management documentation including any security impact analysis performed due to configuration changes since the last inspection 03.03(a)

and (b)

Cyber Security Plan and any 50.54(p) analysis to support changes to the plan since the last inspection 03.04(a)

Cyber Security Metrics tracked (if applicable)

03.06 (b)

Provide documentation describing any cyber security changes to the access authorization program since the last cyber security inspection.

Overall

Provide a list of all procedures and policies provided to the NRC with their descriptive name and associated number (if available)

Overall

Performance testing report (if applicable)

03.06 (a)

JAMES A. FITZPATRICK NUCLEAR POWER PLANT CYBER SECURITY INSPECTION DOCUMENT REQUEST

In addition to the above information please provide the following:

(1) Electronic copy of the Updated Final Safety Analysis Report (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 August 18, 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 August 18, 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 cyber security 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 September 15, 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 performed on the selected system(s) since the last cyber security inspection 03.01(c)

Documentation (including configuration files and rules sets) for Network-based Intrusion Detection/Protection Systems (NIDS/NIPS), Host-based Intrusion Detection Systems (HIDS), and Security Information and Event Management (SIEM) systems for system(s) chosen for inspection)

03.02(b)

Documentation (including configuration files and rule sets) for intra-security level firewalls and boundary devices used to protect the selected system(s)

03.02(c)

6 Copies of all periodic reviews of the access authorization list for the selected systems since the last inspection 03.02(d)

7 Baseline configuration data sheets for the selected CDAs 03.03(a)

JAMES A. FITZPATRICK NUCLEAR POWER PLANT CYBER SECURITY INSPECTION DOCUMENT REQUEST

8 Documentation on any changes, including Security Impact Analyses, performed on the selected system(s) since the last inspection 03.03(b)

9 Copies of the purchase order documentation for any new equipment purchased for the selected systems since the last inspection 03.03(c)

10 Copies of any reports/assessment for cyber security drills performed since the last inspection.

03.02(a)

03.04(b)

11 Copy of the individual recovery plan(s) for the selected system(s) including documentation of the results the last time the backups were executed.

03.02(a)

03.04(b)

Corrective actions taken as a result of cyber security incidents/issues to include previous NRC violations and Licensee Identified Violations since the last cyber security inspection 03.05 13 For the selected systems, provide design change/modification packages including completed work orders since the last cyber security inspection 03.03(a)

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 October 23, 2023, the first day of the inspection.

Table 1ST Week Onsite Section 3, Paragraph Number/Title:

Items`

1 Any cyber security event reports submitted in accordance with 10 CFR 73.77 since the last cyber security inspection 03.04(b)

Updated Copies of corrective actions taken as a result of cyber security incidents/issues, to include previous NRC violations and Licensee Identified Violations since the last cyber security inspection, as well as vulnerability-related corrective actions 03.05 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 Cyber Security 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.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT CYBER SECURITY INSPECTION DOCUMENT REQUEST

(2) Vendor Manuals, Assessment and Corrective Actions:

a. The most recent Cyber Security 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 Cyber Security 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.