ML20009E890

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Notification of Cyber Security Inspection (NRC Inspection Report 05000275/2020401 and 05000323/2020401) and Request for Information
ML20009E890
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 01/08/2020
From: Sam Graves
NRC/RGN-IV/DRS/EB-2
To: Welsch J
Pacific Gas & Electric Co
Taylor N
References
IR 2020401
Download: ML20009E890 (8)


See also: IR 05000275/2020401

Text

January 8, 2020

Mr. James M. Welsch

Senior Vice President, Generation

and Chief Nuclear Officer

Pacific Gas and Electric Company

P.O. Box 56

Mail Code 104/6

Avila Beach, CA 93424

SUBJECT: DIABLO CANYON POWER PLANT, UNITS 1 AND 2 - NOTIFICATION

OF CYBER SECURITY INSPECTION (NRC INSPECTION

REPORT 05000275/2020401 AND 05000323/2020401) AND

REQUEST FOR INFORMATION

Dear Mr. Welsch:

On April 27, 2020, the U.S. Nuclear Regulatory Commission (NRC) will begin an inspection in

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

Canyon Power Plant, Units 1 and 2. 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 April 27 and May 11, 2020.

Experience has shown that these inspections are extremely resource intensive, both for the

NRC inspectors and 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

March 9, 2020. The inspection team will review this information and by the end of the planned

information gathering visit on April 10, 2020, 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 April 20, 2020.

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, April 27, 2020.

J. Welsch 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 Sam Graves. We understand that our regulatory

contact for this inspection is Amanda Sorensen and our technical contact is Chance Siri. If

there are any questions about the inspection or the material requested, please contact the lead

inspector at 817-200-1102 or by e-mail at Samuel.Graves@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter contains mandatory information collections that are subject to the Paperwork

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)

approved these information collections (approval number 3150-0011). Send comments

regarding this information collection to the Information Services Branch, Office of the Chief

Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington,

DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office

of Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and

Budget, Washington, DC 20503.

Public Protection Notification

The NRC may not conduct nor 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 OMB control number.

This letter, its enclosure, and your response (if any) 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/

Samuel T. Graves, Senior Reactor Inspector

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 05000275 and 05000323

License Nos. DPR-80 and DPR-82

Enclosure:

Diablo Canyon Power Plant -

Cyber Security Inspection Document Request

cc w/encl: Electronic Distribution

ML20009E890

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

By: STG Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:EB2

NAME SGraves

SIGNATURE /RA/

DATE 1/8/2020

Diablo Canyon Power Plant - Cyber Security Inspection Document Request

Inspection Report: 05000275/2020401 and 05000323/2020401

Inspection Dates: Weeks of April 27 and May 11, 2020

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: Sam Graves, Lead Shiattin Makor

817-200-1102 817-200-1507

Samuel.Graves@nrc.gov Shiattin.Makor@nrc.gov

NRC Contractors: Casey Priester Leyton Pitzer

301-415-7000 301-287-0582

Frederick.Priester@nrc.gov Leyton.Pitzer@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 lead in the regional office, by March 9, 2020, or sooner, to

facilitate the selection of the specific items that will be reviewed during the onsite

inspection weeks.

The requested information shall be provided on either a secure document management

service or passive media (i.e. CD or DVD) to the lead inspector. If passive media is

chosen, 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 lead as soon as possible.

Enclosure

Table RFI #1

Section 3: Initial Documentation Requests (See Items

Reference 1) Paragraph Number/Title:

1 List all identified critical systems and critical digital assets All

List critical digital asset facility and site ethernet - transmission control

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

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

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

3 LANs including those industrial networks and identify LANs that All

have non-critical digital assets on them

Network topology diagrams (be sure to include all network intrusion

detection systems and security information and event management

4 All

(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 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

28 All

to support changes to that plan

Copy of any licensee identified violations and associated corrective

29 All

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 related to cyber security

(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 April 10, 2020, 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. 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 April 20, 2020, 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 lead as soon as

possible.

Table RFI #2

Section 3: Initial Documentation Requests (See Items

Reference 1) Paragraph Number/Title:

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)

Block diagrams for distributed systems (for systems selected for

7 All

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

13 All

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 Items

Reference 1) Paragraph Number/Title:

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 lesson plans and training presented to the CSAT and CSIRT members,

continuing technical training for engineers, 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 April 27, 2020, 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 lead as soon as

possible.

Table 1st Week Onsite

Section 3: Initial Documentation Requests (See

Reference 1) Paragraph Number/Title: Items

10.a.3)

10 Host-based intrusion detection system documentation for critical thru

digital assets (for systems selected for inspection) 10.a.12)

11.a.3)

11 Network Intrusion detection system documentation for critical thru

systems that have critical digital assets associated with them 11.a.15)

12.a.3)

12 SIEM documentation for critical systems that have critical digital thru

assets associated with them 12.a.14)

16 Supply chain management 16.c

19 Cyber security event notifications All

4

Table 1st Week Onsite

Section 3: Initial Documentation Requests (See

Reference 1) Paragraph Number/Title: Items

Update to licensee identified violations and corrective action All

29 program actions taken since the initial request was made

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 lead.

5