ML21012A059
| ML21012A059 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/12/2021 |
| From: | Hausman G Engineering Branch 3 |
| To: | Gebbie J Indiana Michigan Power Co |
| References | |
| IR 2021401 | |
| Download: ML21012A059 (8) | |
See also: IR 05000315/2021401
Text
January 12, 2021
Mr. Joel P. Gebbie
Senior VP and Chief Nuclear Officer
Indiana Michigan Power Company
Nuclear Generation Group
One Cook Place
Bridgman, MI 49106
SUBJECT: DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2
INFORMATION REQUEST FOR THE CYBER-SECURITY FULL
IMPLEMENTATION INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000315/2021401; 05000316/2021401
Dear Mr. Gebbie:
On November 19, 2019, the U.S. Nuclear Regulatory Commission (NRC) provided the
Donald C. Cook Nuclear Power Plant, Units 1 and 2, an Information Request for the
Cyber-Security Full Implementation Inspection and Notification to Perform Inspection
05000315/2020410; 05000316/2020410 (ML19323F427). The onsite portion of this inspection
was to take place during the weeks of March 30, 2020, and April 13, 2020. However, because
of the coronavirus pandemic (COVID-19) and potential related health concerns, the inspection
was delayed by the NRC.
Based on discussions with your staff for an acceptable date to perform this inspection, the NRC
has rescheduled this inspection. The onsite portion of the inspection will take place during the
weeks of June 7 and June 21, 2021. The inspection will be performed in accordance with
Inspection Procedure 71130.10P Cyber-Security, issued May 15, 2017, at your
Donald C. Cook Nuclear Power Plant, Units 1 and 2. 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.
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, the November 19, 2019, letter
(ML19323F427) enclosed a request for documents needed for the inspection. These
documents were divided into four groups.
The first group specified 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 and the specific items to be reviewed have been previously
provided to the regional office.
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
J. Gebbie
2
Inspection. This information and the specific items to be reviewed have been previously
provided to the regional office.
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, June 7, 2021.
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 George M. Hausman. We understand that our
regulatory contact for this inspection is Kristen M. Harper of your organization. If there are any
questions about the inspection or the material requested, please contact the lead inspector at
630-829-9743 or via e-mail at George.Hausman@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/
George M. Hausman, Senior Reactor Inspector
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-315; 50-316
Enclosure:
Document Request for Cyber-Security
Inspection
cc: Distribution via LISTSERV
J. Gebbie
3
Letter to Joel P. Gebbie from George M. Hausman dated January 12, 2021.
SUBJECT: DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2
INFORMATION REQUEST FOR THE CYBER-SECURITY FULL
IMPLEMENTATION INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000315/2021401; 05000316/2021401
DISTRIBUTION:
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RidsNrrPMDCCook Resource
RidsNrrDroIrib Resource
Kenneth OBrien
DRPIII
DRSIII
ADAMS Accession Number: ML21012A059
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
NAME
GHausman:mb via
DATE
01/12/2021
OFFICIAL RECORD COPY
DOCUMENT REQUEST FOR CYBER-SECURITY INSPECTION
Enclosure
Inspection Report: 05000315/2021401; 05000316/2021401
Inspection Dates:
Weeks of June 7, 2021, and June 21, 2021
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:
George M. Hausman, Lead
Jasmine A. Gilliam
630-829-9743
630-829-9831
George.Hausman@nrc.gov
Jasmine.Gilliam@nrc.gov
NRC Contractors:
Alan B. Konkal
Alexander R. Prada
561-989-0210
240-449-5791
Alan.Konkal@nrc.gov
Alexander.Prada@nrc.gov
Observer:
NSIR/DPCP/CSB
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 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 security
control portions of the Cyber-Security Program 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 has been previously provided to the regional office to facilitate the selection
of the specific items that will be reviewed during the onsite inspection weeks.
The inspection team has examined the returned documentation from the first RFI and
identified/selected specific systems and equipment (e.g., CSs/CDAs) to provide a more
focused follow-up request to develop the second RFI. The inspection team has
previously provided the specific systems and equipment list to your staff which
identified 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.
DOCUMENT REQUEST FOR CYBER-SECURITY INSPECTION
2
The required Table RFI #1 information has been previously provided.
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
Protocol/Internet Protocol Based Local Area Networks (LANs) and
Identify Those LANs That Have Non-CDAs on Them
All
3
List CDA Facility and Site Non-Ethernet Transmission Control
Protocol/Internet Protocol Based LANs Including Those Industrial
Networks and Identify LANs That Have Non-CDAs on Them
All
4
Network Topology Diagrams (Be Sure to Include All Network Intrusion
Detection System and Security Information and Event Managements
(SIEM) 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 CDA Wireless Industrial Networks
All
11 Network Intrusion Detection System Documentation for CSs That Have
CDAs Associated with Them
11.a.1)
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
Teams
All
28 Copy of Current Cyber Security Plan and Copy of 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 ensure the following information has been
provided to the inspection team:
(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 has previously identified and selected
the specific systems and equipment (e.g., CSs/CDAs) from the information requested
by Table RFI #1 and has previously submitted a list of specific systems and equipment
to your staff for the second RFI (i.e., Table RFI #2).
DOCUMENT REQUEST FOR CYBER-SECURITY INSPECTION
3
II
Additional Information Requested to Be Available Prior to Inspection
As stated above, in Section I of this enclosure, the inspection team examined the
returned documentation requested from Table RFI #1 and has previously submitted the
list of specific systems and equipment to your staff for the second RFI (i.e., RFI #2).
The second RFI requested 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 has previously been submitted on CD to the lead
inspector. 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
Selected for Inspection)
All
6
Plant Security System Block Diagram (If Security Computer System Is
Selected for Inspection)
All
7
Systems That Are Distributed Block Diagrams (For Systems Selected
for Inspection)
All
10 Host-Based Intrusion Detection System Documentation (For CDAs for
Systems Selected for Inspection)
10.a.1)
10.a.2)
13 List All Maintenance and Test Equipment Used on CDAs for Systems
Selected for Inspection
All
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
22 Device Access and Key Control
All
23 Password/Authenticator Policy
All
24 User Account/Credential Policy
All
26 Corrective Actions Since Last U.S. Nuclear Regulatory Commission
Inspection
All
27 Cyber Security Assessments for Selected Systems
All
DOCUMENT REQUEST FOR CYBER-SECURITY INSPECTION
4
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 June 7, 2021, 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
Systems Selected for Inspection
10.a.3)
thru
10.a.12)
11 Network Intrusion Detection System Documentation for CSs That Have
CDAs Associated with Them
11.a.3)
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 Corrective Action Program
Actions Taken Since the Initial Request Was Made
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;
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.
DOCUMENT REQUEST FOR CYBER-SECURITY INSPECTION
5
(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) 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 inspection
team leader.