ML20337A424

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Information Request for the Cyber-Security Full Implementation Inspection, Notification to Perform Inspection 05000237/2021401 and 05000249/2021401
ML20337A424
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 12/02/2020
From: Alan Dahbur
Engineering Branch 3
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
IR 2021401
Download: ML20337A424 (8)
v • d • e


See also: IR 05000237/2021401

Text

December 2, 2020

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Co., LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3INFORMATION

REQUEST FOR THE CYBER-SECURITY FULL IMPLEMENTATION INSPECTION,

NOTIFICATION TO PERFORM INSPECTION 05000237/2021401 AND

05000249/2021401

Dear Mr. Hanson:

On March 8, 2021, 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 Dresden Nuclear Power Station, 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, 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 March 8 and March 22, 2021.

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 January 8, 2021. The inspection team will review this

information and, by January 22, 2021, 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 February 19, 2021.

  • 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, March 8, 2021.

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. Alan Dahbur. We understand that our regulatory

contact for this inspection is Mr. Dean Walker of your organization. If there are any questions

about the inspection or the material requested, please contact the lead inspector at

630-829-9810 or via e-mail at Alan.Dahbur@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/

Alan Dahbur, Senior Reactor Inspector

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-237; 50-249

License Nos. DPR-19; DPR-25

Enclosure:

Cyber-Security Inspection

Document Request

cc: Distribution via LISTSERV

B. Hanson -3-

Letter to Bryan C. Hanson from Alan Dahbur dated December 2, 2020.

SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3INFORMATION

REQUEST FOR THE CYBER-SECURITY FULL IMPLEMENTATION

INSPECTION, NOTIFICATION TO PERFORM INSPECTION 05000237/2021401

AND 05000249/2021401

DISTRIBUTION:

Jessie Quichocho

Richard Skokowski

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RidsNrrPMDresden Resource

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John Giessner

Kenneth OBrien

Jamnes Cameron

Allan Barker

DRPIII

DRSIII

ADAMS Accession Number: ML20337A424

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

OFFICE RIII

NAME ADahbur:mb via

e-mail

DATE 12/02/2020

OFFICIAL RECORD COPY

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Inspection Report: 05000237/2021401 and 05000249/2021401

Inspection Dates: Weeks of March 8, 2021, and March 22, 2021

Inspection Procedure: IP 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,

(ML17156A215)

NRC Inspectors: Alan Dahbur, Lead Clinton Hobbs (Region I)

630-829-9810 610-337-5104

Alan.Dahbur@nrc.gov Clinton.Hobbs@nrc.gov

NRC Contractors: Cynthia DeBisschop Alan Konkal

Cynthia.DeBisschop@nrc.gov Alan.Konkal@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 CSs/CDAs plus

operational and management 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 No. 1. The

Table RFI No. 1 information is requested to be provided to the regional office by January

8, 2021, 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 January 22, 2021, 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 No. 1 and the guidance document referenced above.

Enclosure

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

The required Table RFI No. 1 information shall be provided on compact disc (CD)

and/or via ShareFile to the lead inspector by January 8, 2021. 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. 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 No. 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 NIDs and Security All

Information and Event Managements (SIEM) for 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 SIEM Documentation for CSs 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 All

Teams

28 Copy of Current Cyber Security Plan and Copy of 50.54(p) Analysis To All

Support Changes To That Plan

29 Copy Of Any Licensee-Identified Violations and Associated Corrective All

Action Program (CAP) Documentation To Resolve Issue(s)

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.

2

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 No. 1 and

submit a list of specific systems and equipment to your staff by January 22, 2021, for the

second RFI (i.e., Table RFI No. 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 No. 1 and submit the list of specific

systems and equipment to your staff by January 22, 2021, for the second RFI

(i.e., Table RFI No. 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 No. 2. All requests for this

information shall follow the Table RFI No. 2 and the guidance document referenced

above.

The Table RFI No. 2 information shall be provided on CD and/or via ShareFile to the

lead inspector by February 19, 2021. 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. 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 No. 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)

17 Portable Media and Mobile Device Control All

18 Software Management All

20 Vendor Access and Monitoring All

21 Work Control All

3

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table RFI No. 2

Reference Section 3, Paragraph Number/Title: Items

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 First Week Onsite) on CD and/or ShareFile by March 8,

2021, the first day of the inspection. All requests for this information shall follow the

Table First Week Onsite and the guidance document referenced above.

Please provide four copies of each CD submitted (i.e., one for each inspector/contractor)

and/or access to ShareFile. 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 First 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 IPE/PRA 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

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