ML13002A182

Notification to Perform and Inspection of Temporary Instruction 2201/004, Inspection of Implementation of Interim Cyber Security Milestones 1 - 7 and Request for Information

ML13002A182
Person / Time
Site:	Calvert Cliffs
Issue date:	01/02/2013
From:	Rogge J Engineering Region 1 Branch 3
To:	George Gellrich Constellation Energy Nuclear Group
References
Download: ML13002A182 (10)

Text

UNITED STATES N UCLEAR REGU LATORY COMTIIISSION

't"ffi REGION I 21OO RENAISSANCE BOULEVARD, SUITE KING OF PRUSSIA, PENNSYLVANIA 19I0G2713 1OO January 2, 20L3 Mr. George Gellrich, Site Vice President Constellation Energy Nuclear Group, LLC Calvert Cliffs Nuclear Power Plant, LLC 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 4702

SUBJECT:

CALVERT CLIFFS NUCLEAR GENERATING STATION. NOTIFICATION TO PERFORM AN INSPECTION OF TEMPORARY INSTRUCTION 22011004,

.INSPECTION OF IMPLEMENTATION OF INTERIM CYBER SECURITY MILESTONES 1 - 7'AND REQUEST FOR INFORMATION

Dear Mr. Gellrich:

On April 8, 2013, the U.S. Nuclear Regulatory Commission (NRC) will begin an inspection of Temporary Instruction (Tl) 22011004 at your Calvert Cliffs Nuclear Power Plant (CCNP) Units 1 and 2. The Tl inspection will be performed to evaluate and verify your ability to meet the interim milestone requirements of the NRC's Cyber Security Rule, Title 10, Code of Federal Regulations (CFR), Part73, Section 54, "Protection of Digital Computer and Communication Systems and Networks."

In accordance with 10 CFR 73.54, each nuclear power plant licensee was required to submit a proposed cyber security plan (CSP) and implementation schedule for NRC approval. On December 14,2009, by letter (ML093080517) to the Nuclear Energy Institute (NEl), the NRC provided their expectations for the proposed implementation schedule. On January 5,2011, by letter (ML110060093) to the NRC, NEI issued an initial "Template for the Cyber Security Plan lmplementation Schedule" (M1110060097). On February28,2011, by letter(M1110600206) to the NRC, NEI provided a revised "Template for the Cyber Security Plan lmplementation Schedule." The purpose of the letter's attachment was to provide the licensee with a generically written template to develop their proposed CSP implementation schedule. Utilization of the generic template required the licensee to make conforming changes to ensure the submitted schedule accurately accounted for site-specific activities. Based on an NRC technical review (ML110070348), the template was found acceptable to develop the licensee's CSP implementation schedule (i.e., Milestones 1 through 8). On August 19,2011, by letter (ML11152A037), the NRC issued license amendments that approved Constellation Energy Nuclear Group, LLC (CENG) facility CSPs and associated implementation schedules. The amendments were in response to the application by CENG dated July 16, 2010 (ML102040473), as supplemented by letters dated April 4 (ML110950664), and July I , 2011 (ML11189A064), for the subject facilities. In addition, the amendments revised the existing license condition regarding physical protection in each of the facility operating licenses to require the licensee to fully implement and maintain in effect all provisions of the NRC-approved CSP.

G. Gellrich The subject Tl inspection provides a programmatic level review and verification of the licensee's site-specific implementation of Interim Milestones 1 through 7. The schedule for the onsite Tl Inspection for the Interim Milestones 1 through 7 is as follows:

lnformation Gathering Visit: March 26 - 28,2013; and Cyber Security Tl Inspection: April I - 12,2013.

The purpose of the information gathering visit is to: (1) obtain information and documentation needed to support the Tl inspection; (2) become familiar with the CCNP's Cyber Security Program and plant layout; and (3) arrange administrative details, such as office space, availability of knowledgeable office personnel and to ensure unescorted site access privileges.

In order to assure a productive Tl inspection, we have enclosed a request for documents needed to ensure that the inspectors are adequately prepared. These documents have been divided into four groups. The first group lists information necessary to aid the inspectors in planning for the Tl inspection. lt is requested that this information be provided to the lead inspector via mail or electronically no later than March 11, 2013. The second group also lists information and possible areas for discussion necessary to assist the inspectors during the Tl inspection. lt is requested this information be available during the information gathering visit (March 26 - 28,2013). The third group of requested documents consists of those items that the inspectors will review, or need access to, during the Tl inspection. Please have this information available by the first day of the second onsite inspection week (April 8, 2013). The fourth group lists the information necessary to aid the inspectors in tracking questions and answers identified as a result of the Tl inspection. lt is requested that this information be provided to the lead inspector as the information is generated during the Tl inspection. lt 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 Tl inspection.

The lead inspector for this inspection is Mr. Dan Orr. We understand that our regulatory contact for this inspection is Ms. Susan Reichard of your organization. lf there are any questions about the Tl inspection or the material requested, please contact the lead inspector at (610) 337-5048 or via e-mail at dan.orr@nrc.qov.

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 3150-001 1 . 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.

G. Gellrich 3 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document 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, u,%,.@

Jonn F. Rogge, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-317, 50-318 License Nos. DPR-53, DPR-69

Enclosure:

Document Request for Cyber Security Temporary lnstruction (Tl) 22011004 Interim Milestones 1 - 7 lnspection cc w/encl: Distribution via ListServ

M113002A182 g Non-Sensitive V Publicly Available A suNslReview tr Sensitive  ! Non-PubliclyAvailable OFFICE RI/DRS RI/DRS NAME DOrr JRogge/

DATE 12t27112 1t2t12 G. Gellrich 4 Distribution w/encl: (via E-mail)

W. Dean, RA (RIORAMAlL RESOURCE)

D. Lew, DRA (RIoRAMATL RESOURCE)

D. Roberts, DRP (RI DRPMATL RESOURCE)

P. Wilson, DRP (RI DRPMATLr RESOURCE)

C. Miller, DRS (RI DRSMATL RESOURCE)

J. Clifford, DRS (RI DRSMATL RESOURCE)

C. Santos, Rl OEDO G. Dentel, DRP S. Shaffer, DRP R. Barkley, DRP T. Ziev, DRP S. Kennedy, SRI E. Torres, DRP, Rl RidsNrrPMCa lvertCl iffs Resource RidsNrrDorlLpl 1 -1 Resource ROPreports Resource

DOCUMENT REQUEST FOR GYBER SECU RITY TE M PORARY I NSTRUCTION (Tal 2201 1 004 INTERIM MILSTONES 1 .7 INSPECTION

l. Information Requested Prior to the Information Gathering Visit The following information is requested by March 11,2013. lf you have any questions regarding this request, please call the lead inspector as soon as possible. All information should be sent to Mr. Dan Orr (e-mail address dan.orr@nrc.gov). Electronic media is preferred. Where information is provided that includes tables and/or lists of data or other such information, please do not scan such tables and/or lists as images. The preferred file format is a searchable "pdf'file on a compact disk (CD). The CD should be indexed and hyper-linked to facilitate ease of use. Please provide three copies of each CD submitted (one for each inspector and for a cyber security contractor),

A. Cyber Security Tl Documentation

1. Provide a list of all documents considered necessary to support verification of the Tl requirements to verify complete each of the Cyber Security Milestones 1 through 7 identified by CENG application dated July 16, 2010 (M1102040473),

as supplemented by letters dated April 4 (ML110950664), and July 1 , 2011 (ML11189A064). Provide each milestone in a separate folder on the CD (e.g., Milestone 1, Milestone 2, etc.). Each milestone document shall be listed in a table as follows:

MILESTONE X, where X equals 1 through 7 Document Number Title Description Rev Status No. 1 No.2 No. 3 No.4 etc.

Based on the list of documents identified in LA.1 above, for each milestone document where the "Status" is identified as completed, place the completed document in its associated folder and hyperlink the associated document number to the completed document. For each document, the "Status" should be identified as "not started," "in-progress" or "completed."

In addition to the documents identified in 1.A.1 above, ensure the documents identified below (1.A.2 - LA.S) for MILESTONE 1 -7 are included in the 1.A,1 table above.

Enclosure

2. MILESTONE 1 - Provide the following documentation for the Cyber Security Assessment Team (CSAT):

a. Procedures establishing the CSAT team.

b. List of CSAT members noting primary areas of responsibility.

c. Procedures detailing qualification requirements for CSAT members.

d. Supporting documentation that demonstrates each CSAT member meets the requirements to fulfill their respective position on the team. For example, member resumes; evaluation of previous education and experience; training required by your implementing procedures and supporting documentation which shows training was completed; or industry certifications.

3. MILESTONE 2 - Provide the following documentation:

a. List of plant systems noting which system have been identified as critical systems (CS).

b. Procedure documenting the process by which CSs and Critical Digital Assets (CDA) are identified in accordance with (lAW) your CSP, Section 3.1.3.

4. MILESTONE 3 - Provide the following documentation:

a. Procedures establishing your cyber defensive architecture. Explain any variances from your CSP, Section 4.3, and tracking documents for their correction.

b. Provide an overview of your cyber defensive architecture, preferably with overview level diagrams showing the various levels and location of the subject deterministic one-way device.

c. Provide details of the implementation of the subject deterministic one-way device.

5. MILESTONE 4 - Provide the following documentation:

a. Procedures implementing the security control "Access Control for Portable and Mobile Devices." Include any training material or promotional literature distributed to staff associated with the control.

6. MILESTONE 5 - Provide the following documentation:

a. Procedures implementing the requirements described in Milestone 5.

b. Training materials associated with the changes to plant programs associated with Milestone 5.

Enclosure

7. MILESTONE 6 - Provide the following documentation:

Procedures documenting the process by which technical cyber security controls have been identified for those CDAs which require the implementation of technical security controls for Milestone 6.

8. MILESTONE 7 - Provide the following documentation:

Procedures implementing the ongoing monitoring and assessment activities as described in your CSP, Section 4.4.

B, Cyber Security Supporting Documentation

1. Provide a copy of the current version of the updated safety analysis report (USAR), Technical Specifications (TS), and technical requirements manual (TRM) or equivalent.

2. Provide a copy of the current cyber security "Health Report," if available'

3. Provide a copy of the current plant drawings use for operator training that provide additional information on system operation, system operating parameters, setpoints, etc. (e.9., some licensee's refer to these drawings as "Horse Notes") for identified cyber security CSs, if available.

4. Provide operator training lesson plans and/or operator training aids for identified cyber security CSs, if available.

ll, lnformation Requested during the Information Gathering Visit (March 26 - 28,2013)

The following information is requested to be provided to the inspectors during the onsite information gathering visit. lt is requested that the following information be provided on three sets of CDs (searchable, if possible).

A. General Information:

1. A listing of abbreviations and/or designators for plant systems;

2. Organizational chart for corporate and site personnel involved in establishing, overseeing, and maintaining the cyber security program and;

3. A phone list for licensee personnel.

B. Facility Information:

1. Provide a presentation/discussion of your CSP, existing cyber security CSs, and associated CDAs.

2. Provide a list and discussion of currently scheduled or planned cyber security related modifications to be installed in the plant.

Enclosure

c. Specific Information Associated with the Milestones:

1. Provide a presentation/discussion of your CSP, existing cyber security CSs, and associated CDAs.

2. MILESTONE 3 - Be prepared to provide an overview walkdown of the cyber architecture within the plant including safety, security, and emergency preparedness related CDAs.

3. MILESTONE 6 - Be prepared to present information for target set CDAs including a list of target set CDAs, and documentation of the process for identifying them.

4. MILESTONE 6 - For selected CDAs, be prepared to produce documentation for each of the technical controls in Appendix D of NEI 08-09, Revision 6, the results of reviews required under your CSP, Section 3.1.6.

(a) For controls that are implemented, provide the procedures implementing the control. Common controls for all CDAs may be provided in a separate list with the procedures implementing each of them.

(b) For alternate controls that have been implemented, provide the documented basis for employing alternative countermeasures, and the procedures implementing the alternative measures.

(c) Where controls have been deemed unnecessary, provide the threat vector analysis supporting the conclusion that the threat vector does not exist.

5. MILESTONE 7 - For the CDAs selected above, be prepared to produce documentation for each of the technical controls in Appendix D of NEI 08-09, Revision 6, and the results of immediate activities required under your CSP, Section 4.4.

(a) For all controls that are implemented, provide the objective evidence that the control is effective IAW your CSP, Section 4.4.3.1. This may be combined with the documentation provided for Milestone 6.

Documentation for common controls for all CDAs may be provided in a separate list with the procedures implementing each of them.

(b) Provide governing procedures and results of vulnerability scans performed to comply with your CSP, Section 4.4.3.2 4 Enclosure

ilt. lnformation Requested to be Available on First Day of the Inspection Week (April 8, 2013)

The following information is requested to be provided on the first day of the Tl inspection.

It is requested that this information be provided on three sets of CDs (searchable, if possible).

A. Any updates to information previously provided.

lv. Information Requested to be Provided Throughout the Tl Assessment A. Copies of the list of questions/documents requested identified by the inspector and the status/resolution of the information requested (provided daily during the Tl inspection to each inspector).

Enclosure