ML18348A532
| ML18348A532 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/13/2018 |
| From: | Glenn Dentel Engineering Region 1 Branch 2 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Dentel G | |
| References | |
| IR 2019403 | |
| Download: ML18348A532 (8) | |
See also: IR 05000220/2019403
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD., SUITE 100
KING OF PRUSSIA, PA 19406-2713
December 13, 2018
Mr. Bryan C. Hanson
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:
NINE MILE POINT NUCLEAR STATION - INFORMATION REQUEST FOR THE
CYBER-SECURITY INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000220/2019403 AND 05000410/2019403
Dear Mr. Hanson:
On June 3, 2019, the U.S. Nuclear Regulatory Commission (NRC) will begin a team inspection
in accordance with Inspection Procedure 71130.10P, Cyber-Security, issued May 15, 2017, at
your Nine Mile Point Nuclear Station, Units 1 and 2. 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 (10 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 June 3 - 7, 2019, and June 17 - 21, 2019.
Experience has shown that team 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 (CD) or digital versatile disc (DVD) and
delivered to the regional office no later than February 11, 2019. The inspection team will review
this information and, by March 11, 2019, 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 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
May 6, 2019.
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, June 3, 2019.
B. Hanson
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 Jigar Patel. We understand that our regulatory contact
for this inspection is Rose Demko of your organization. If there are any questions about the
inspection or the material requested, please contact the lead inspector at 610-337-5188 or via
e-mail at Jigar.Patel1@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 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/
Glenn T. Dentel, Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-220 and 50-410
License Nos. DPR-63 and NPF-69
Enclosure:
Nine Mile Point Nuclear Station
Cyber-Security Inspection Document Request
cc w/encl: Distribution via ListServ
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE
RI/DRS
RI/DRS
NAME
JPatel/JP via email
GDentel/GTD
DATE
12/12/18
12/13/18
NINE MILE POINT NUCLEAR STATION
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
1
Enclosure
Inspection Report: 05000220/2019403 and 05000410/2019403
Inspection Dates:
June 3 - 7, 2019 and June 17 - 21, 2019
Inspection Procedure:
IP 71130.10P, Cyber-Security, Issue Date May 15, 2017
Reference:
Guidance Document for Development of the Request for
Information (RFI) and Notification Letter for Full-Implementation of
the Cyber Security Inspection, Issue Date October 26, 2017
NRC Inspectors:
610-337-5188
610-337-5380
Jigar.Patel1@nrc.gov
Jeff.Rady@nrc.gov
NRC Contractors:
William.Johns@nrc.gov
Leyton.Pitzer@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 (O&M) security control portions of the
CSP to be chosen as the sample set required to be inspected by the cyber security 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
February 11, 2019, 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 March 11, 2019, 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 by May 6, 2019. All requests for
information responses shall follow the RFI table matrix and the guidance document
referenced above.
The required Table RFI #1 information shall be provided on compact disc (CD) or digital
versatile disc (DVD) to the lead inspector by February 11, 2019. Please provide four
NINE MILE POINT NUCLEAR STATION
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
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copies of each CD or DVD submitted (i.e., one for each inspector/contractor). The
preferred file format for all lists is a searchable Excel spreadsheet file on a disc. These
discs 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 Critical Systems and Critical Digital Assets
All
2
List CDA Facility and Site Ethernet - Transmission Control
Protocol/Internet Protocol (TCP/IP) Based Local Area Networks
(LANs) and Identify Those LANs That Have Non-CDAs On Them
All
3
List CDA Facility and Site Non-Ethernet TCP/IP Based LANs Including
Those Industrial Networks and Identify LANs That Have Non-CDAs On
Them
All
4
Network Topology Diagrams (Be Sure To Include all Network Intrusion
Detection Systems (NIDS) and Security Information and Event
Management (SIEMs) for Emergency Preparedness (EP) networks
and Security Level 3 and 4 Networks)
All
8 List All Network Security Boundary Devices for EP Networks and All
Network Security Boundary Devices for Levels 3 and 4
All
9 List CDA Wireless Industrial Networks
All
11 NIDS Documentation for Critical Systems That Have CDAs Associated
with Them
11.a.1)
11.a.2)
12 SIEM Documentation for Critical systems 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
In addition to the above information please provide the following:
(1) Electronic copy of your current Cyber Security Plan.
(2) Electronic copy of summary of changes (if any), including any 10 CFR 50.54p
analysis to support those changes, made to the originally approved Cyber
Security Plan.
(3) Electronic copy of a matrix that summarizes what controls are in place to satisfy
the controls required by Policies and Procedures.
(4) Electronic copy of the Updated Final Safety Analysis Report and technical
specifications.
(5) Name(s) and phone number(s) for the regulatory and technical contacts.
(6) Current management and engineering organizational charts.
NINE MILE POINT NUCLEAR STATION
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
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(7) In a separate directory, an electronic copy of the documents listed in the matrix
from (3) above.
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
will submit a list of specific systems and equipment to your staff by March 11, 2019, 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 March 11, 2019, 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 your stations CSP 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 Table RFI #2 and the guidance document referenced above.
The Table RFI #2 information shall be provided on CD or DVD to the lead inspector by
May 6, 2019. Please provide four copies of each CD or DVD submitted (i.e., one for
each inspector/contractor). The preferred file format for all lists is a searchable Excel
spreadsheet file on a disc. These discs 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
5 Plant Computer System Block Diagram (If Plant Computer System Is
Selected for Inspection)
All
6 Plant Security System Block Diagram (If Security Computer System Is
Selected for Inspection)
All
7 Systems That Are Distributed Block Diagrams (For Systems Selected
For Inspection)
All
10 Host-Based Intrusion Detection System Documentation (For CDAs for
Systems Selected for Inspection)
10.a.1)
10.a.2)
13 List all Maintenance and Test Equipment Used On CDAs for Systems
Selected for Inspection
All
15 Configuration Management
All
16 Supply Chain Management
16.b.
16.c.1)
16.c.5)
16.c.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
NINE MILE POINT NUCLEAR STATION
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
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Table RFI #2
Section 3,
Paragraph Number/Title:
Items
23 Password/Authenticator Policy
All
24 User Account/Credential Policy
All
26 Corrective Actions Since Last NRC Inspection
All
In addition to the above information please provide the following:
(1) The documented CSP assessment and analysis for each CDA in each of the
selected systems.
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 a CD or DVD by June 3, 2019, the first
day of the inspection. All requested information shall follow the Table 1ST Week Onsite
and the guidance document referenced above.
The preferred file format for all lists is a searchable Excel spreadsheet file on a CD or
DVD. The CD or DVD 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
Section 3,
Paragraph Number/Title:
Items
10 Host-Based Intrusion Detection System Documentation for CDAs
for systems selected for inspection
10.a.3)
thru
10.a.12)
11 NIDS Documentation for Critical Systems That Have CDAs
Associated with Them
11.a.3)
thru
11.a.15)
12 SIEM Documentation for Critical Systems That Have CDAs
Associated with Them
12.a.3)
thru
12.a.14)
16 Supply Chain Management
16.c.2)
16.c.3)
16.c.4)
19 Cyber Security Event Notifications
All
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;
NINE MILE POINT NUCLEAR STATION
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
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b. Original Safety Evaluation Report and Supplements;
c. Final Safety Analysis Report Question and Answers;
d. Quality Assurance (QA) Plan;
e. Latest Individual Plant Examination for External Events / Probabilistic Risk
Assessment Report; and
f.
Vendor Manuals.
(2) 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.