ML19095B608
| ML19095B608 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/05/2019 |
| From: | Dariusz Szwarc NRC/RGN-III |
| To: | Bryan Hanson Exelon Generation Co |
| References | |
| IR 2019412 | |
| Download: ML19095B608 (8) | |
See also: IR 05000461/2019412
Text
April 5, 2019
Mr. Bryan C. Hanson
Senior VP, Exelon Generation Company, LLC
President and CNO, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: CLINTON POWER STATIONINFORMATION REQUEST FOR THE
CYBER-SECURITY FULL IMPLEMENTATION INSPECTION, NOTIFICATION
TO PERFORM INSPECTION 05000461/2019412
Dear Mr. Hanson:
On August 5, 2019, 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 Clinton Power Station. 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
August 5, 2019, and August 19, 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. 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 May 13, 2019. The inspection team will review this
information and, by June 10, 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, 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 July 8, 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, August 5, 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 Mr. Dariusz Szwarc. We understand that our regulatory
contact for this inspection is Mr. Nicholas Santos of your organization. If there are any
questions about the inspection or the material requested, please contact the lead inspector
at 630-829-9803 or via e-mail at Dariusz.Szwarc@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 Title 10 of the Code of Federal Regulations, Part 2.390, Public Inspections,
Exemptions, Requests for Withholding.
Sincerely,
/RA/
Dariusz Szwarc, Senior Reactor Inspector
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-461
License No. NPF-62
Enclosure:
Document Request for Cyber-Security
Inspection
cc: Distribution via LISTSERV
B. Hanson -3-
Letter to Bryan C. Hanson from Dariusz Szwarc dated April 5, 2019.
SUBJECT: CLINTON POWER STATIONINFORMATION REQUEST FOR THE
CYBER-SECURITY FULL IMPLEMENTATION INSPECTION, NOTIFICATION
TO PERFORM INSPECTION 05000461/2019412
DISTRIBUTION:
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ADAMS Accession Number: ML19095B608
OFFICE RIII
NAME DSzwarc:cl
DATE 04/05/19
OFFICIAL RECORD COPY
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Inspection Report: 05000461/2019412
Inspection Dates: Weeks of August 5, 2019, and August 19, 2019
Inspection Procedure: 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
NRC Inspectors: Dariusz Szwarc, Lead John S. Robbins
630-829-9803 630-829-9744
Dariusz.Szwarc@nrc.gov John.Robbins@nrc.gov
NRC Contractors: Leyton Pitzer Chris P. Fiotes
301-725-9538 301-415-7000
Leyton.Pitzer@nrc.gov Chris.Fiotes@nrc.gov
Observers: Robert C. Daley
630-829-9749
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
(CSs) and critical digital assets (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. 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 May 13, 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 June 10, 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. 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 May 13, 2019. 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 All
Protocol/Internet 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 All
Protocol/Internet 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 Network Intrusion All
Detections and Security Information and Event Managements for
Emergency Preparedness (EP) Networks and Security Level 3 and 4
Networks)
8 List All Network Security Boundary Devices for EP Networks and All All
Network 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 11.a.1)
CDAs Associated with Them 11.a.2)
12 Security Information and Event Managements Documentation for CSs 12.a.1)
That Have CDAs 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 All
Teams
28 Copy of Current CSP and Copy of 50.54(p) Analysis To Support All
Changes To That Plan
29 Copy Of Any Licensee-Identified Violations and Associated Corrective All
Action Program 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 June 10, 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 June 10, 2019, 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
September 24, 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 All
Selected for Inspection)
6 Plant Security System Block Diagram (If Security Computer System Is All
Selected 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 10.a.1)
Systems Selected for Inspection) 10.a.2)
13 List All Maintenance and Test Equipment Used On CDAs for Systems All
Selected for Inspection
15 Configuration Management All
16 Supply Chain Management 16.b.
16.c.1)
16.c.5)
16.c.6)
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CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Table RFI #2
Reference Section 3, Paragraph Number/Title: Items
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 August 5, 2019, 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 10.a.3)
Systems Selected for Inspection thru
10.a.12)
11 Network Intrusion Detection System Documentation for CSs That Have 11.a.3)
CDAs 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.c.2)
16.c.3)
16.c.4)
19 Cyber-Security Event Notifications All
29 Update to Licensee Identified Violations and CAP Actions Taken Since All
the Initial Request Was Made
4
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
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 Individual Plant Examination/Probabilistic Risk Assessment
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.
5