IR 05000348/2024402

Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection 05000348/2024402 and 05000364/2024402

ML24233A137
Person / Time
Site:	Farley
Issue date:	08/26/2024
From:	Daniel Bacon Division of Reactor Safety II
To:	Dean E Southern Nuclear Operating Co
References
IR 2024402
Download: ML24233A137 (6)

Text

SUBJECT:

FARLEY NUCLEAR PLANT UNITS 1 & 2 - INFORMATION REQUEST FOR THE CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM INSPECTION 05000348/2024402 AND 05000364/2024402

Dear Edwin Dean:

On December 2, 2024, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline inspection in accordance with Inspection Procedure (IP) 71130.10 Cyber-Security, Revision 0, at your Farley Nuclear Plant Units 1 & 2. The inspection will be performed to evaluate and verify your ability to provide assurance that your digital computer and communication systems and networks associated with safety, security, or emergency preparedness (SSEP) functions are adequately protected against cyber-attacks in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 73.54 and the U.S. Nuclear Regulatory Commission (NRC)

approved cyber security plan (CSP). The onsite portion of the inspection will take place during the week of December 2, 2024.

Experience has shown that baseline inspections are extremely resource intensive, both for the NRC inspectors and the licensee staff. 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 the cyber-security IP. This information should be made available electronically no later than October 4, 2024. The inspection team will review this information and, by October 18, 2024, will request the specific items that should be provided for review. This 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 CSP selected for the cyber-security inspection. We request that the information provided from the second RFI be made available to the regional office prior to the inspection by November 22, 2024.

August 26, 2024 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, December 2, 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 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 Mr. William Monk. We understand that our regulatory contacts for this inspection are Mr. Gene Surber and Mr. Josh Champlin of your organization.

If there are any questions about the inspection or the material requested, please contact the lead inspector at (404) 997-4579 or via e-mail at william.monk@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, Daniel Bacon, Branch Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-348; 50-364 License Nos. NPF-2; NPF-8 Enclosure:

Farley Nuclear Plant Units 1 & 2 Cyber-Security Inspection Document Request cc w/encl: Distribution via LISTSERV Signed by Bacon, Daniel on 08/26/24

ML24233A137 X

SUNSI Review X

Non-Sensitive Sensitive X

Publicly Available Non-Publicly Available OFFICE RII/DRS RII/DRS RII/DRS NAME W. Monk L. Jones D. Bacon DATE 08/20/24 08/20/24 08/26/24

FARLEY NUCLEAR PLANT UNITS 1 & 2 CYBER-SECURITY INSPECTION DOCUMENT REQUEST Enclosure Inspection Report: 05000280/2024-402 and 05000281/2024-402 Inspection Dates:

December 2 - 6, 2024 Inspection Procedure:

IP 71130.10, Cyber-Security, Revision 0 (Effective: 01/01/2022)

Reference:

Guidance Document for Development of the Request for Information (RFI) and Notification Letter for Full-Implementation of the Cyber-Security Inspection, Rev. 2 (Issued: 11/22/2021)

NRC Inspectors:

William Monk, Lead Larry Jones (404) 909-4579 (404) 997-4837 william.monk@nrc.gov larry.jones@nrc.gov NRC Contractors:

Trace Coleman James Hartman trace.coleman@nrc.gov james.hartman@nrc.gov I.

Information Requested for In-Office Preparation The initial request for information (i.e., RFI #1) concentrates on providing the inspection team with the general information necessary to select appropriate components and CSP elements to develop a site-specific inspection plan. RFI #1 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 cyber-security IP. RFI #1s requested information is specified below in Table: RFI #1 and requested to be provided electronically to the inspection team by October 4, 2024, or sooner, to facilitate the selection of the specific items that will be reviewed during the onsite inspection week.

The inspection team will examine the returned documentation from RFI #1 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 October 18, 2024, 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 RFI

1. 2 be made available to the inspection team by November 22, 2024. All requests for information shall follow the guidance document U.S. NRC - Guidance Document for Development of the Request for Information (RFI) and Notification Letter for Full Implementation of the Cyber-Security Inspection, referenced above.

FARLEY NUCLEAR PLANT UNITS 1 & 2 CYBER-SECURITY INSPECTION DOCUMENT REQUEST

The required Table: RFI #1 information shall be provided electronically to the lead inspector by October 4, 2024. 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 Paragraph Number / Title:

IP Ref

A list of all identified Critical Systems and Critical Digital Assets -

highlight/note any additions, deletions, 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 (OM&A) program documentation.

03.01(a)

The most recent effectiveness analysis and self-assessments of the Cyber Security Program.

03.01(b)

Password/Authenticator program documentation.

03.02(c)

Design change / modification program documentation and a list of all design changes completed since the last cyber security inspection, including either a summary of the design change or the 50.59 documentation for the change.

03.03(a)

Supply Chain Management program documentation, including any security impact analysis for new acquisitions.

03.03(a),

(b) and (c)

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

03.04(a)

Cyber Security Performance Metrics tracked (if applicable).

03.06(b)

11 Provide a list of all cybersecurity procedures and policies with their descriptive name and associated number.

Overall

Performance testing report (if applicable).

03.06(a)

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

FARLEY NUCLEAR PLANT UNITS 1 & 2 CYBER-SECURITY INSPECTION DOCUMENT REQUEST

In addition to the above information, please provide the following:

(1) electronic copy of the UFSAR and sites technical specifications.

(2) name(s) and phone numbers for the regulatory and technical contacts.

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 October 18, 2024, 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 October 18, 2024, for the second RFI (i.e., RFI #2). RFI #2 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 and requested information shall follow the guidance document referenced above.

The Table: RFI #2 information shall be provided to the lead inspector by November 22, 2024. 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 Paragraph Number / Title:

Items For the Critical Systems / CDAs chosen for inspection provide:

Ongoing Monitoring and Assessment (OM&A) activity performed on the selected inspection samples critical systems.

03.01(a)

All Security Control Assessments for the selected critical systems.

03.01(a)

All vulnerability screenings/assessments associated with, or scans performed on the selected critical systems 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 the critical systems chosen for inspection (i.e., the devices that are credited for protection for the selected critical systems).

03.02(b)

FARLEY NUCLEAR PLANT UNITS 1 & 2 CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table: RFI #2 Paragraph Number / Title:

Items

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

03.02(c)

Copies of all periodic reviews of the access authorization (AA) list for the selected critical systems since the last cyber inspection.

03.02(d)

Baseline configuration data sheets for the selected CDAs and for the selected design changes.

03.03(a)

Documentation on any changes, including Security Impact Analyses, performed on the selected critical systems since the last inspection.

03.03(b)

Copies of the purchase order documentation for any new equipment purchased for the selected systems since the last inspection.

03.03(c)

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

03.02(a)

03.04(b)

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

03.02(a)

03.04(b)

Vulnerability Management program screening and assessment policies and procedures.

03.01(c)

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

03.02(a)

and 03.04(b)

Device Access and Key Control program documentation.

03.02(c)

User Account/Credential documentation.

03.02(d)

Portable Media and Mobile Device (PMMD) control documentation, including kiosk security control assessment/documentation.

03.02(e)

Configuration Management documentation including any security impact analysis (SIA) performed due to configuration changes since the last cyber inspection.

03.03(a)

and (b)

FARLEY NUCLEAR PLANT UNITS 1 & 2 CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table: RFI #2 Paragraph Number / Title:

Items

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

Overall

The most recent Cybersecurity Quality Assurance audit and/or self-assessment and a list of Corrective Actions generated as a result.

Overall 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: Week Onsite) to the team by December 2, 2024, the first day of the inspection. All requested information shall follow the guidance document referenced above.

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: Week Onsite Paragraph Number / Title:

Items

Any cyber security event reports submitted in accordance with 10 CFR 73.77, since the last cyber security inspection.

03.04(a)

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 access to them.

a.

Updated Final Safety Analysis Report (UFSAR), if not previously provided.

b.

Original SER and Supplements.

c.

FSAR Question and Answers.

d.

Quality Assurance (QA) Plan.

e.

Technical Specifications, if not previously provided.

f.

Latest IPE/PRA Report.

FARLEY NUCLEAR PLANT UNITS 1 & 2 CYBER-SECURITY INSPECTION DOCUMENT REQUEST

(2) Vendor Manuals, Assessments and Corrective Actions:

a.

The most recent Cyber-Security Quality Assurance (QA) audit and/or self-assessment.

b.

Corrective action documents (e.g., condition reports, including status of corrective actions) generated as a result of the most recent Cyber-Security Quality Assurance (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 during daily de-brief meetings).

If you have any questions regarding the information requested, please contact the inspection team leader.