ML18306A558

Notification of Cyber Security Inspection(Nrc Inspection Report 05000298/2019410) and Request for Information

ML18306A558
Person / Time
Site:	Cooper
Issue date:	10/30/2018
From:	Greg Werner NRC/RGN-IV/DRS/EB-2
To:	Dent J Nebraska Public Power District (NPPD)
References
IR 2019410
Download: ML18306A558 (12)

See also: IR 05000298/2019410

Text

October 30, 2018

Mr. John Dent, Jr.

Vice President-Nuclear and CNO

Nebraska Public Power District

Cooper Nuclear Station

72676 648A Avenue

P.O. Box 98

Brownville, NE 68321

SUBJECT: COOPER NUCLEAR STATION - NOTIFICATION OF CYBER SECURITY

INSPECTION (NRC INSPECTION REPORT 05000298/2019410) AND

REQUEST FOR INFORMATION

Dear Mr. Dent:

On February 11, 2019, the U.S. Nuclear Regulatory Commission (NRC) will begin an inspection

in accordance with Inspection Procedure (IP) 71130.10P, Cyber Security, Revision 0, at the

Cooper Nuclear Station (CNS). This inspection evaluates and verifies your ability to meet the

full implementation requirements of the NRCs Cyber Security Rule, Title 10, Code of Federal

Regulations (CFR), 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

February 11 and February 25, 2019.

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. The document request has been divided into four

groups.

The first group specifies information necessary to assist the team in choosing the focus areas

(i.e., sample set) to be inspected in accordance with the cyber security inspection procedure.

This information should be made available using either a secure document management service

or passive media (i.e. CD, DVD) and delivered to the regional office no later than

December 3, 2018. The inspection team will review this information and by the end of the

planned information gathering visit on January 10, 2019, will request the specific items that

should be provided for review. The second group of requested documents will assist the team

in their evaluation of the critical systems and critical digital assets, defensive architecture, and

the areas of the cyber security plan selected for inspection. This information will be requested

for our review in the regional office prior to the inspection by January 28, 2019.

The third group of requested documents consists of those items that the team will review or

need access to, during the inspection. Please have this information available by the first day of

the onsite inspection, February 11, 2019.

J. Dent 2

The fourth group of information is necessary to aid the 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 Greg Pick. We understand that our regulatory contact

for this inspection is LuAnn Bray. If there are any questions about the inspection or the

material requested, please contact the lead inspector at 817-200-1270 or by e-mail

at greg.pick@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 under 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 Gregory Pick for/

Gregory E. Werner, Chief

Engineering Branch 2

Division of Reactor Safety

Docket: 50-298

License: DPR-46

Enclosure:

Cooper Nuclear Station -

Cyber Security Inspection Document Request

cc w/ encl: Electronic Distribution

Cooper Nuclear Station - Cyber Security Inspection Document Request

Inspection Report: 05000298/2019410

Inspection Dates: Weeks of February 11, 2019, and February 25, 2019

Inspection Procedure: IP 71130.10P, Cyber Security, Revision 0

Reference 1: ML17156A215 - Guidance Document for Development of the

Request for Information (RFI) and Notification Letter for

Full-Implementation of the Cyber Security Inspection, Revision 1,

dated October 26, 2017

NRC Inspectors: Greg Pick, Lead Shiattin Makor

817-200-1270 817-200-1507

greg.pick@nrc.gov shiattin.makor@nrc.gov

NRC Contractors: A Konkal Joe Cristiano

561-859-5232 301-287-0582

alan.konkal@nrc.gov joseph.cristiano@nrc.gov

I. Information Requested for In-Office Preparation

The initial request for information (i.e., first RFI) provides the team with the general

information necessary to select appropriate components and cyber security plan

elements to develop a site-specific inspection plan. The team will use the first set of

information requested to identify the list of critical systems and critical digital assets plus

operational and management security control portions of the cyber security plan to be

chosen as the sample set required to be inspected during this inspection. The first

information request is specified in Table RFI #1. Provide the first set of information to

the team leader in the regional office by December 3, 2018, or sooner, to facilitate the

selection of the specific items that will be reviewed during the onsite inspection weeks.

The required Table RFI #1 information shall be provided on a secure document

management service or passive media (i.e. CD or DVD) to the lead inspector by

December 3, 2018. Please provide four copies of each media submitted (i.e., one for

each inspector/contractor). The preferred file format for all lists is a searchable Excel

spreadsheet file on a CD or DVD. These files should be indexed and hyperlinked to

facilitate efficient review. If you have any questions regarding this information, please

contact the inspection team leader as soon as possible.

Enclosure

Table RFI #1

Section 3: Initial Documentation Requests (See Reference 1)

Paragraph Number/Title: Items

1 List all identified critical systems and critical digital assets All

List critical digital asset facility and site ethernet - transmission control All

2 protocol/internet protocol (TCP/IP) based local area networks (LANs)

and identify those LANs that have non-critical digital assets on them

List critical digital asset facility and site non-ethernet TCP/IP based All

3 LANs including those industrial networks and identify LANs that have

non-critical digital assets on them

Network topology diagrams (be sure to include all network intrusion All

detection systems and security information and event management

4 (SIEMs) for emergency preparedness (EP) networks and security

level 3 and 4 networks)

List all network security boundary devices for EP networks and all All

8 network security boundary devices for levels 3 and 4

9 List critical digital asset wireless Industrial networks All

Network Intrusion detection system documentation for critical systems 11.a.1)

11 that have critical digital assets associated with them 11.a.2)

SIEM documentation for critical systems that have critical digital assets 12.a.1)

12 associated with them 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

Copy of current cyber security plan and copy of any 50.54(p) analysis All

28 to support changes to that plan

Copy of any licensee identified violations and associated corrective All

29

action program documentation to resolve issue(s)

In addition to the above information please provide the following:

(1) Electronic copy of the updated safety analysis report and technical specifications

(2) Name(s) and phone number(s) for the regulatory and technical contacts

(3) Current management and engineering organizational charts

(4) Cyber security program procedures

Based on this information, the team will identify and select specific systems and

equipment (e.g., critical systems and critical digital assets) from the information

requested by Table RFI #1 and submit a list of specific systems and equipment to your

staff by the end of the information gathering visit on January 10, 2019, for the second

information request (i.e., Table RFI #2).

2

II. Additional Information Requested to be Available Prior to Inspection

As stated in Section I, the team will examine the documents from the initial information

request, and submit the list of specific systems and equipment to your staff by the end of

the information gathering visit on January 10, 2019. This second information request

(i.e., Table RFI #2) obtains additional documents required to evaluate the critical

systems and critical digital assets, defensive architecture, and the areas of the cyber

security program selected for the cyber security inspection. The additional information

requested for the specific systems and equipment is identified in Table RFI #2. All

requested information shall follow the guidance document Reference 1.

The Table RFI #2 information shall be provided on a secure document management

service or passive media to the lead inspector by January 28, 2019, or sooner. Please

provide four copies of each CD/DVD submitted (i.e., one for each inspector/contractor).

The preferred file format for all lists is a searchable Excel spreadsheet file on a CD/DVD.

These files should be indexed and hyperlinked to facilitate efficient review. If you have

any questions regarding this information, please call the inspection team leader as soon

as possible.

Table RFI #2

Section 3: Initial Documentation Requests (See Reference 1)

Paragraph Number/Title: Items

Plant computer system block diagram (if plant computer system is All

5 selected for inspection)

Plant security system block diagram (if security computer system is All

6 selected for inspection)

Block diagrams for distributed systems (for systems selected for All

7 inspection)

Host-based intrusion detection system documentation for critical 10.a.1)

10 digital assets (for systems selected for inspection) 10.a.2)

List all maintenance and test equipment (M&TE) used on critical digital All

13 assets (for systems selected for inspection)

15 Configuration management All

16.a

16 Supply chain management

16.b

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

3

Table RFI #2

Section 3: Initial Documentation Requests (See Reference 1)

Paragraph Number/Title: Items

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 Section II, provide the following

request for information (i.e., Table 1st Week Onsite) on a secure document management

service or passive media by February 11, 2019, the first day of the inspection. All

requested information shall follow the guidance in Reference 1.

Please provide four copies of each CD submitted (i.e., one for each inspector/contactor).

The preferred file format for all lists is a searchable Excel spreadsheet file on a CD/DVD.

These files should be indexed and hyperlinked 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

Section 3: Initial Documentation Requests (See Reference 1)

Paragraph Number/Title: Items

10.a.3)

Host-based intrusion detection system documentation for critical

10 thru

digital assets (for systems selected for inspection)

10.a.12)

11.a.3)

Network Intrusion detection system documentation for critical

11 thru

systems that have critical digital assets associated with them

11.a.15)

12.a.3)

SIEM documentation for critical systems that have critical digital

12 thru

assets associated with them

12.a.14)

16 Supply chain management 16.c

19 Cyber security event notifications All

Update to licensee identified violations and corrective action All

29

program actions taken since the initial request was made

4

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. Quality Assurance Plan;

b. Technical Specifications, if not previously provided;

c. Latest Individual Plant Examination/Probabilistic Risk Assessment Report;

and,

(2) Vendor Manuals, Assessments, 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) generated 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 team leader.

5

ML18306A558

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002

By: GAP Yes No Publicly Available Sensitive

OFFICE SRI:EB2 BC:EB2

NAME G. Pick G. Werner

SIGNATURE /RA/ /RA/

DATE 10/30/2018 10/29/2018