ML19066A207

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Notification of Cyber Security Inspection Report 05000482/2019410) and Request for Information
ML19066A207
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 03/05/2019
From: Ramirez F
Region 4 Engineering Branch 1
To: Heflin A
Wolf Creek
Ramirez F
References
IR 2019410
Download: ML19066A207 (8)


See also: IR 05000482/2019410

Text

March 5, 2019

Adam C. Heflin, President and

Chief Executive Officer

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION - NOTIFICATION OF

CYBER SECURITY INSPECTION (NRC INSPECTION

REPORT 05000482/2019410) AND REQUEST FOR INFORMATION

Dear Mr. Heflin:

On July 15, 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

Wolf Creek Generating Station (WC). 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 July 15 and July 29, 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

April 15, 2019. The inspection team will review this information and by the end of the planned

information gathering visit on May 23, 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 June 17, 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, July 15, 2019.

A. Heflin

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 Jason Knust. 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 Heather Gepford Acting For/

Francis C. Ramirez, Chief

Engineering Branch 1

Division of Reactor Safety

Docket: 50-482

License: NPF-42

Enclosure:

Wolf Creek Generating Station -

Cyber Security Inspection Document Request

cc w/ encl: Electronic Distribution

Enclosure

Wolf Creek Generating Station - Cyber Security Inspection Document Request

Inspection Report: 05000482/2019410

Inspection Dates:

Weeks of July 15, 2019, and July 29, 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

Steven Alferink

817-200-1270

817-200-1548

greg.pick@nrc.gov

steven.alferink@nrc.gov

NRC Contractors:

Casey Priester

Cynthia DeBisschop

703-725-9538

240-483-7938

frederick.priester@nrc.gov cynthia.debisschop@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 April 15, 2019, 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 April 15, 2019. 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.

2

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

2

List critical digital asset facility and site ethernet - transmission control

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

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

All

3

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

LANs including those industrial networks and identify LANs that have

non-critical digital assets on them

All

4

Network topology diagrams (be sure to include all network intrusion

detection systems 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 critical digital asset wireless Industrial networks

All

11

Network Intrusion detection system documentation for critical systems

that have critical digital assets associated with them

11.a.1)

11.a.2)

12

SIEM documentation for critical systems that have critical digital assets

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 any 50.54(p) analysis

to support changes to that plan

All

29

Copy of any licensee identified violations and associated corrective

action program documentation to resolve issue(s)

All

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 May 23, 2019, for the second

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

3

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 May 23, 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 June 17, 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

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

Block diagrams for distributed systems (for systems selected for

inspection)

All

10

Host-based intrusion detection system documentation for critical

digital assets (for systems selected for inspection)

10.a.1)

10.a.2)

13

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

assets (for systems selected for inspection)

All

15 Configuration management

All

16 Supply chain management

16.a

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

4

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

In addition to the above information please provide the following:

(1) Names and positions of the CSAT and CSIRT members.

(2) Copies of lessons plans and training presented to the CSAT and CSIRT

members, as well as any general awareness training.

(3) List of dates of CSAT meetings that have occurred.

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 July 15, 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/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 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 Host-based intrusion detection system documentation for critical

digital assets (for systems selected for inspection)

10.a.3)

thru

10.a.12)

11 Network Intrusion detection system documentation for critical

systems that have critical digital assets associated with them

11.a.3)

thru

11.a.15)

12 SIEM documentation for critical systems that have critical digital

assets associated with them

12.a.3)

thru

12.a.14)

16 Supply chain management

16.c

19 Cyber security event notifications

All

29

Update to licensee identified violations and corrective action

program actions taken since the initial request was made

All

5

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.

ML19066A207

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

F. Ramirez

SIGNATURE

/RA/

/RA HJG for/

DATE

3/4/2019

3/5/2019