ML19130A042
| ML19130A042 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/08/2019 |
| From: | Glenn Dentel Engineering Region 1 Branch 2 |
| To: | Vitale A Entergy Nuclear Operations |
| Dentel G | |
| References | |
| IR 2019403 | |
| Download: ML19130A042 (8) | |
See also: IR 05000247/2019403
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BOULEVARD, SUITE 100
KING OF PRUSSIA, PA 19406-2713
May 8, 2019
Mr. Anthony J. Vitale
Site Vice President
Entergy Nuclear Operations, Inc.
Indian Point Energy Center
450 Broadway, General Services Building
P.O. Box 249
Buchanan, NY 10511-0249
SUBJECT: INDIAN POINT NUCLEAR GENERATING - INFORMATION REQUEST FOR
THE CYBER-SECURITY INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000247/2019403 AND 05000286/2019403
Dear Mr. Vitale:
On September 16, 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 Indian Point Nuclear Generating (Indian Point), Units 2 and 3. 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 (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 September 16, 2019, and
September 30, 2019. Experience has shown that team inspections are extremely resource
intensive, both for the NRC inspectors and the licensee staff. 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 with dates agreed by the site. 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 June 20, 2019. The inspection team will review this information and, by July 19,
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
August 21, 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, September 16, 2019.
A. Vitale 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 David Werkheiser. We understand that our regulatory
contact for this inspection is George Dahl of your organization. If there are any questions about
the inspection or the material requested, please contact the lead inspector at 610-337-5316 or
via e-mail at David.Werkheiser@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. 50-247 and 50-286
License Nos. DPR-26 and DPR-64
Enclosure:
Indian Point Nuclear Generating
Cyber-Security Inspection Document Request
cc w/encl: Distribution via ListServ
Non-Sensitive Publicly Available
SUNSI Review
Sensitive Non-Publicly Available
OFFICE RI/DRS RI/DRS
NAME DWerkheiser GDentel
DATE 5/8/19 5/8/19
INDIAN POINT NUCLEAR GENERATING
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Inspection Report: 05000247/2019403 and 05000286/2019403
Inspection Dates: September 16 - 20 and September 30 - October 4, 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: David Werkheiser, Lead Louis Dumont
610-337-5316 610-337-5183
David.Werkheiser@nrc.gov Louis.Dumont@nrc.gov
NRC Contractors: Alan Konkal William (Bill) Johns
Alan.Konkal@nrc.gov William.Johns@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
June 20, 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 July 19, 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 August 21, 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) to the
lead inspector by June 20, 2019. 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. 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.
1 Enclosure
INDIAN POINT NUCLEAR GENERATING
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Table RFI #1
Reference Section 3,
Paragraph Number/Title: Items
1 List All Identified Critical Systems and Critical Digital Assets All
List CDA Facility and Site Ethernet - Transmission Control
2 Protocol/Internet Protocol (TCP/IP) Based Local Area Networks All
(LANs) and Identify Those LANs That Have Non-CDAs On Them
List CDA Facility and Site Non-Ethernet TCP/IP Based LANs Including
3 Those Industrial Networks and Identify LANs That Have Non-CDAs On All
Them
Network Topology Diagrams (Be Sure To Include all Network Intrusion
Detection Systems (NIDS) and Security Information and Event
4 All
Management (SIEMs) for Emergency Preparedness (EP) networks
and Security Level 3 and 4 Networks)
List All Network Security Boundary Devices for EP Networks and All
8 All
Network Security Boundary Devices for Levels 3 and 4
9 List CDA Wireless Industrial Networks All
NIDS Documentation for Critical Systems That Have CDAs Associated 11.a.1)
11 with Them
11.a.2)
SIEM Documentation for Critical systems That Have CDAs Associated 12.a.1)
12 with Them
12.a.2)
List EP and Security Onsite and Offsite Digital Communication
14 All
Systems
Cyber Security Assessment and Cyber Security Incident Response
25 All
Teams
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 numbers for the regulatory and technical contacts.
(6) Current management and engineering organizational charts.
(7) In a separate directory, an electronic copy of the documents listed in the matrix
from (3) above.
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INDIAN POINT NUCLEAR GENERATING
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
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 July 19, 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 July 19, 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 to the lead inspector by
August 21, 2019. 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. 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
Section 3,
Paragraph Number/Title: Items
Plant Computer System Block Diagram (If Plant Computer System Is
5 All
Selected for Inspection)
Plant Security System Block Diagram (If Security Computer System Is
6 All
Selected for Inspection)
Systems That Are Distributed Block Diagrams (For Systems Selected
7 All
For Inspection)
10.a.1)
Host-Based Intrusion Detection System Documentation (For CDAs for
10
Systems Selected for Inspection)
10.a.2)
List all Maintenance and Test Equipment Used On CDAs for Systems
13 All
Selected for Inspection
15 Configuration Management All
16.b.
16.c.1)
16 Supply Chain Management
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
23 Password/Authenticator Policy All
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INDIAN POINT NUCLEAR GENERATING
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Table RFI #2
Section 3,
Paragraph Number/Title: Items
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 by September 16, 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. The
CD 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.a.3)
Host-Based Intrusion Detection System Documentation for CDAs
10 thru
for systems selected for inspection
10.a.12)
11.a.3)
NIDS Documentation for Critical Systems That Have CDAs
11 thru
Associated with Them
11.a.15)
12.a.3)
SIEM Documentation for Critical Systems That Have CDAs
12 thru
Associated with Them
12.a.14)
16.c.2)
16 Supply Chain Management 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;
b. Original Safety Evaluation Report and Supplements;
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INDIAN POINT NUCLEAR GENERATING
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
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.
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