ML17342B126
| ML17342B126 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/08/2017 |
| From: | Hausman G NRC/RGN-III |
| To: | Hamilton D FirstEnergy Nuclear Operating Co |
| References | |
| IP 71130.10P IR 2018410 | |
| Download: ML17342B126 (8) | |
See also: IR 05000440/2018410
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE RD. SUITE 210
LISLE, ILLINOIS 60532-4352
December 8, 2017
Mr. David B. Hamilton
Site Vice President
FirstEnergy Nuclear Operating Company
Perry Nuclear Power Plant
Reg Affairs-A210
10 Center Road, P.O. Box 97
Perry, OH 44081-0097
SUBJECT: PERRY NUCLEAR POWER PLANTINFORMATION REQUEST FOR THE CYBER-SECURITY FULL
IMPLEMENTATION INSPECTION, NOTIFICATION TO PERFORM INSPECTION
Dear Mr. Hamilton:
On April 2, 2018, the U.S. Nuclear Regulatory Commission (NRC) will begin an inspection in accordance
with Inspection Procedure 71130.10P Cyber-Security, issued May 15, 2017, at your Perry Nuclear
Power Plant, Unit 1. The inspection will be performed to evaluate and verify your ability to meet full
implementation requirements of the NRCs Cyber-Security Rule, Title 10 of the Code of Federal
Regulations, Part 73, Section 54, Protection of Digital Computer and Communication Systems and
Networks. The onsite portion of the inspection will take place during the weeks of April 2-6, 2019, and
April 16-20, 2018.
Experience has shown that these 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 the Cyber-Security Inspection Procedure. This
information should be made available via compact disc and delivered to the regional office no
later than January 8, 2018. The inspection team will review this information and, by February 5,
2018, 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, defensive architecture, and the areas
of your plants 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
March 5, 2018.
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, April 2, 2018.
D. Hamilton -2-
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 Mr. George M. Hausman. We understand that our regulatory
contact for this inspection is Mr. Tony Kledzik of your organization. If there are any questions about the
inspection or the material requested, please contact the lead inspector at 630-829-9743 or via e-mail at
George.Hausman@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.
This letter and its enclosure will be made available for public inspection and copying at
http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with
10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
George M. Hausman, Senior Reactor Inspector
Engineering Branch 3
Division of Reactor Safety
Docket No. 50-440
License No. NPF-58
Enclosure:
Cyber-Security Inspection Document Request
cc: Distribution via LISTSERV
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Letter to David B. Hamilton from George M. Hausman dated December 08, 2017
SUBJECT: PERRY NUCLEAR POWER PLANTINFORMATION REQUEST FOR THE CYBER-SECURITY FULL
IMPLEMENTATION INSPECTION, NOTIFICATION TO PERFORM INSPECTION
DISTRIBUTION:
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Cynthia Pederson
Kenneth OBrien
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CYBER-SECURITY INSPECTION DOCUMENT REQUEST
ADAMS Accession Number: ML17342B126
OFFICE RIII
NAME GHausman:cl
DATE 12/08/17
OFFICIAL RECORD COPY
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Inspection Report: 05000440/2018410
Inspection Dates: Weeks of April 2-6, 2018, and April 16-20, 2018
Inspection Procedure: IP 71130.10P, Cyber-Security, Issue Date: May 15, 2017
Reference: Guidance Document for Development of the Request for Information
and Notification Letter for Full-Implementation of the Cyber-Security
Inspection, Issue Date October 26, 2017 (ML17156A215)
NRC Inspectors: George M. Hausman, Lead Gregory P. Hansen
630-829-9743 630-829-9610
George.Hausman@nrc.gov Gregory.Hansen@nrc.gov
Catherine J. Allen
301-287-3620
Catherine.Allen@nrc.gov
NRC Contractors: Alan B. Konkal Cynthia A. DeBisschop
561-989-0210 301-287-3710
Alan.Konkal@nrc.gov Cynthia.DeBisschop@nrc.gov
Observers: James D. Beardsley Robert C. Daley
301-287-0908 630-829-9749
James.Beardsley@nrc.gov Robert.Daley@nrc.gov
I. Information Requested for In-Office Preparation
The initial request for information (i.e., first Request for Information (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 Cyber-Security Inspection Procedure
(IP). 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 January 8, 2018, or sooner, to
facilitate the selection of the specific items that will be reviewed during the onsite inspection
weeks.
Enclosure
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
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 February 5, 2018, 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. All requests for
this information shall follow the Table RFI #1 and the guidance document referenced above.
The required Table RFI #1 information shall be provided on compact disc (CD) to the lead
inspector by January 8, 2018. Please provide five copies of each CD submitted (i.e., one for each
inspector/contractor). The preferred file format for all lists is a searchable Excel spreadsheet
file. These CDs 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
Reference Section 3, Paragraph Number/Title: Items
1 List All Identified CSs and CDAs All
2 List CDA Facility and Site EthernetTransmission Control Protocol/Internet All
Protocol Based Local Area Networks (LANs) and Identify Those LANs That Have
Non-CDAs On Them
3 List CDA Facility and Site Non-Ethernet Transmission Control Protocol/Internet All
Protocol Based LANs Including Those Industrial Networks and Identify LANs
That Have Non-CDAs On Them
4 Network Topology Diagrams (Be Sure To Include All NIDs and Security All
Information and Event Managements (SIEM) for EP Networks and Security
Level 3 and 4 Networks)
8 List All Network Security Boundary Devices for EP Networks and All Network All
Security Boundary Devices for Levels 3 and 4
9 List CDA Wireless Industrial Networks All
11 Network Intrusion Detection System Documentation for CSs That Have CDAs 11.a.1)
Associated with Them 11.a.2)
12 SIEM Documentation for CSs That Have CDAs Associated with Them 12.a.1)
12.a.2)
14 List EP and Security Onsite and Offsite Digital Communication Systems All
25 Cyber-Security Assessment and Cyber-Security Incident Response Teams All
28 Copy of Current Cyber Security Plan and Copy of 50.54(p) Analysis To Support All
Changes To That Plan
29 Copy Of Any Licensee-Identified Violations and Associated Corrective Action All
Program (CAP) Documentation To Resolve Issue(s)
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CYBER-SECURITY INSPECTION DOCUMENT REQUEST
In addition to the above information please provide the following:
(1.) Electronic copy of the Updated Finals Safety Analysis Report 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 February 5, 2018 for the second RFI
(i.e., Table RFI #2).
II. Additional Information Requested to be Available Prior to Inspection
As stated above, in Section I. of this enclosure, 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 February 5, 2018, for the second RFI (i.e., Table 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. All requests for this information shall follow the Table RFI #2 and the guidance
document referenced above.
The Table RFI #2 information shall be provided on CD to the lead inspector by March 5, 2018.
Please provide five copies of each CD submitted (i.e., one for each inspector/contractor). The
preferred file format for all lists is a searchable Excel spreadsheet file. These CDs 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
Reference Section 3, Paragraph Number/Title: Items
5 Plant Computer System Block Diagram (If Plant Computer System Is Selected All
for Inspection)
6 Plant Security System Block Diagram (If Security Computer System Is Selected All
for Inspection)
7 Systems That Are Distributed Block Diagrams (For Systems Selected All
for Inspection)
10 Host-Based Intrusion Detection System Documentation (For CDAs for Systems 10.a.1)
Selected for Inspection) 10.a.2)
13 List All Maintenance and Test Equipment Used On CDAs for Systems Selected All
for Inspection
15 Configuration Management All
16 Supply Chain Management 16.a.
16.b.1)
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CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Table RFI #2
Reference Section 3, Paragraph Number/Title: Items
16.b.5)
16.b.6)
17 Portable Media and Mobile Device Control All
18 Software Management All
20 Vendor Access and Monitoring All
21 Work Control All
22 Device Access and Key Control All
23 Password/Authenticator Policy All
24 User Account/Credential Policy All
26 Corrective Actions Since Last NRC Inspection All
27 Cyber Security Assessments for Selected Systems All
III. Information Requested to be Available on First Day of Inspection
For the specific systems and equipment identified in this enclosuresSection II., provide the
following RFI (i.e., Table 1ST Week Onsite) on CD by April 2, 2018, the first day of the inspection.
All requests for this information shall follow the Table 1ST Week Onsite and the guidance
document referenced above.
Please provide five copies of each CD submitted (i.e., one for each inspector/contractor). The
preferred file format for all lists is a searchable Excel spreadsheet file. These CDs 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 1st Week Onsite
Reference Section 3, Paragraph Number/Title: Items
10 Host-Based Intrusion Detection System Documentation for CDAs for Systems 10.a.3)
Selected for Inspection thru
10.a.12)
11 Network Intrusion Detection System Documentation for CSs That Have CDAs 11.a.3)
Associated with Them thru
11.a.15)
12 SIEM Documentation for CSs That Have CDAs Associated with Them 12.a.3)
thru
12.a.14)
16 Supply Chain Management 16.b.2)
16.b.3)
16.b.4)
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CYBER-SECURITY INSPECTION DOCUMENT REQUEST
19 Cyber-Security Event Notifications All
29 Update to Licensee Identified Violations and CAP Actions Taken Since the All
Initial Request Was Made
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. Original Final Safety Analysis Report Volumes;
b. Original Safety Evaluation Report and Supplements;
c. Final Safety Analysis Report Question and Answers;
d. Quality Assurance Plan;
e. Latest IPE/PRA Report; and
f. Vendor Manuals.
(2.) Assessment and Corrective Actions:
a. The most recent Cyber-Security Quality Assurance audit and/or
self-assessment; and
b. Corrective action documents (e.g., condition reports, including status of
corrective actions) generate as a result of the most recent Cyber-Security
Quality Assurance 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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