ML22075A048
| ML22075A048 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/16/2022 |
| From: | William Monk NRC/RGN-II/DRS/EB2 |
| To: | Stoddard D Dominion Energy South Carolina |
| References | |
| IR 2022401 | |
| Download: ML22075A048 (9) | |
See also: IR 05000395/2022401
Text
Daniel Stoddard, SVP
Dominion Energy
Innsbrook Technical Center
5000 Dominion Blvd., Floor: IN-2SW
Glen Allen, VA 29060
SUBJECT: V.C. SUMMER NUCLEAR STATION - INFORMATION REQUEST FOR THE
CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000395/2022401
Dear Mr. Stoddard:
On June 27, 2022, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
inspection, in accordance with Inspection Procedure (IP) 71130.10 Cyber-Security, Revision 0,
at your V.C. Summer Nuclear Station. The inspection will be performed to evaluate and verify
your ability to provide assurance that your digital computer and communication systems and
networks associated with safety, security, or emergency preparedness (SSEP) functions are
adequately protected against cyber-attacks, in accordance with Title 10 of the Code of Federal
Regulations (10 CFR) 73.54 and the U.S. Nuclear Regulatory Commission (NRC) approved
cyber security plan (CSP). The onsite portion of the inspection will take place during the week
of June 27, 2022.
Experience has shown that baseline 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 IP. This information should
be made available electronically no later than April 8, 2022. The inspection team will review
this information and, by April 18, 2022, 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 the licensees CSP selected for the cyber-security inspection.
This information will be requested for review in the regional office prior to the inspection by
May 30, 2022, as identified above.
March 16, 2022
D. Stoddard
2
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 27, 2022.
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 William Monk. We understand that our regulatory
contact for this inspection is Michael Moore, Licensing Manager of your organization. If there
are any questions about the inspection or the material requested, please contact the lead
inspector at (404) 997-4579 or via e-mail at william.monk@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.
In accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding,
of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available
electronically for public inspection in the NRCs Public Document Room or from the Publicly
Available Records (PARS) component of the NRC's Agencywide Documents Access and
Management System (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Gerry McCoy, Branch Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-395
License Nos. NPF-12
Enclosure:
V.C. Summer Nuclear Station Cyber-Security Inspection Document Request
cc w/encl: Distribution via LISTSERV
X
SUNSI Review
X
Non-Sensitive
Sensitive
X
Publicly Available
Non-Publicly Available
OFFICE RII/DRS
RII/DRS
RII/DRS
NAME
W. Monk
G. McCoy
J. Montgomery
DATE
03/16/2022
03/16/2022
03/16/2022
SUMMER NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Enclosure
Inspection Report: 05000395/2022401
Inspection Dates:
June 27-July 01, 2022
Inspection Procedure:
IP 71130.10, Cyber-Security, Revision 0 (Effective: 01/01/2022)
Reference:
Guidance Document for Development of the Request for
Information (RFI) and Notification Letter for Full-Implementation of
the Cyber-Security Inspection, Rev. 2 (Issued: 11/22/2021)
NRC Inspectors:
404-909-4579
404-997-4880
william.monk@nrc.gov
jonathan.montgomery@nrc.gov
NRC Contractors:
Tim Marshall
Balla Barro
301-415-7000
301-415-7000
timothy.marshall@nrc.gov
balla.barro@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 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 electronically to the inspection team by April 8, 2022, 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 April 18, 2022, 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 inspection team by May 30, 2022. All requests for
information shall follow the guidance document U.S. NRC - Guidance Document for
Development of the Request for Information (RFI) and Notification Letter for Full
Implementation of the Cyber-Security Inspection, referenced above.
SUMMER NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST
2
The required Table: RFI 1 information shall be provided electronically to the lead
inspector by April 8, 2022. The preferred file format for all lists is a searchable Excel
spreadsheet file. The information 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
Paragraph Number/Title:
IP Ref
1
A list of all Identified Critical Systems and Critical Digital Assets, -
highlight/note any additions, deletions, reclassifications due to new
guidance from white papers, changes to NEI 10-04, 13-10, etc. since
the last cyber security inspection.
Overall
2
A list of EP and Security onsite and offsite digital communication
systems.
Overall
3
Network Topology Diagrams to include information and data flow for
critical systems in levels 2, 3, and 4 (If available).
Overall
4
Ongoing Monitoring and Assessment program documentation.
03.01(a)
5
The most recent effectiveness analysis of the Cyber Security Program.
03.01(b)
6
Vulnerability screening/assessment and scan program documentation.
03.01(c)
7
Cyber Security Incident Response documentation, including incident
detection, response, and recovery documentation as well as
contingency plan development, implementation, and including any
program documentation that requires testing of security boundary
device functionality.
03.02(a)
and
03.04(b)
8
Device Access and Key Control program documentation.
03.02(c)
9
Password/Authenticator program documentation.
03.02(c)
10
User Account/Credential and Authentication program documentation.
03.02(d)
11 Portable Media and Mobile Device (PMMD) control documentation,
including kiosk security control assessment/documentation.
03.02(e)
12
Design change/ modification program documentation and a list of all
design changes completed since the last cyber security inspection,
including either a summary of the design change or the 50.59
documentation for the change.
03.03(a)
13
Supply Chain Management program documentation, including any
security impact analysis for new acquisitions.
03.03(a),
(b) and (c)
SUMMER NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST
3
Table: RFI #1
Paragraph Number/Title:
IP Ref
14
Configuration Management documentation including any security
impact analysis performed due to configuration changes since the last
cyber inspection.
03.03(a)
and (b)
15
Cyber Security Plan and any 50.54(p) analysis to support changes to
the plan since the last inspection.
03.04(a)
16
Cyber Security Performance Metrics tracked (if applicable).
03.06(b)
17
Provide documentation describing any cyber security changes to the
access authorization program since the last cyber security inspection.
Overall
18
Provide a list of all procedures and policies provided to the NRC with
their descriptive name and associated number (if available).
Overall
19
Performance testing report (if applicable).
03.06(a)
In addition to the above information, please provide the following:
(1) electronic copy of the UFSAR 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 April 18, 2022, for the
II.
Additional Information Requested to be Available Prior to Inspection.
As stated in Section I above, 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 April 18, 2022, 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 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 requested information shall follow the guidance
document referenced above.
The Table: RFI 2 information shall be provided to the lead inspector by May 30, 2022.
The preferred file format for all lists is a searchable Excel spreadsheet. The information
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.
SUMMER NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST
4
Table: RFI #2
Paragraph Number/Title:
Items
For the system(s) chosen for inspection provide:
1
Ongoing Monitoring and Assessment activity performed on the
selected inspection samples system(s).
03.01(a)
2
All Security Control Assessments for the selected system(s).
03.01(a)
3
All vulnerability screenings/assessments associated with or scans
performed on the selected system(s) since the last cyber security
inspection.
03.01(c)
4
Documentation (including configuration files and rules sets) for
Network-based Intrusion Detection/Protection Systems (NIDS/NIPS),
Host-based Intrusion Detection Systems (HIDS), and Security
Information and Event Management (SIEM) systems for system(s)
chosen for inspection).
03.02(b)
5
Documentation (including configuration files and rule sets) for intra-
security level firewalls and boundary devices used to protect the
selected system(s).
03.02(c)
6
Copies of all periodic reviews of the access authorization list for the
selected systems since the last cyber inspection.
03.02(d)
7
Baseline configuration data sheets for the selected CDAs.
03.03(a)
8
Documentation on any changes, including Security Impact Analyses,
performed on the selected system(s) since the last inspection.
03.03(b)
9
Copies of the purchase order documentation for any new equipment
purchased for the selected systems since the last inspection.
03.03(c)
10
Copies of any reports/assessment for cyber security drills performed
since the last inspection.
03.02(a)
03.04(b)
11
Copy of the individual recovery plan(s) for the selected system(s)
including documentation of the results the last time the backups
were executed.
03.02(a)
03.04(b)
12
Corrective actions taken as a result of cyber security incidents/issues
to include previous NRC violations and Licensee Identified Violations
since the last cyber security inspection.
03.05
5
III.
Information Requested to be Available on First Day of Inspection
For the specific systems and equipment identified in Section II above, provide the
following RFI (i.e., Table: Week Onsite) to the team by June 27, 2022, the first day of
the inspection. All requested information shall follow the guidance document referenced
above.
The preferred file format for all lists is a searchable Excel spreadsheet file. The
information 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: Week Onsite
Paragraph Number/Title:
Items
1
Any cyber security event reports submitted in accordance with
10 CFR 73.77, since the last cyber security inspection.
03.04(a)
2
Updated copies of corrective actions taken as a result of cyber
security incidents/issues, to include previous NRC violations and
Licensee Identified Violations since the last cyber security
inspection, as well as vulnerability-related corrective actions.
03.05
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.
updated Final Safety Analysis Report (UFSAR), if not previously provided
b.
original FSAR Volumes
c.
original SER and Supplements
d.
FSAR Question and Answers
e.
Quality Assurance (QA) Plan
f.
Technical Specifications, if not previously provided
g.
latest IPE/PRA Report
(2) Vendor Manuals, Assessment and Corrective Actions:
a.
the most recent Cyber-Security Quality Assurance (QA) audit and/or
self-assessment
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 (QA) audit and/or self-assessment
SUMMER NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST
6
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 during daily de-brief meetings)
If you have any questions regarding the information requested, please contact the inspection
team leader.