ML22084A021
| ML22084A021 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/28/2022 |
| From: | Philipp Braaten, Gerald Mccoy NRC/RGN-II/DRS/EB2 |
| To: | Gayheart C Southern Nuclear Operating Co |
| References | |
| IR 2022401 | |
| Download: ML22084A021 (8) | |
See also: IR 05000424/2022401
Text
March 28, 2022
Mrs. Cheryl A. Gayheart
Regulatory Affairs Director
Southern Nuclear Operating Co., Inc.
3535 Colonnade Parkway
Birmingham, AL 35243
SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - INFORMATION REQUEST FOR THE
CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000424/2022401; 05000425/2022401
Dear Mrs. Gayheart:
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 Vogtle Electric Generating Plant. 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. 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 29, 2022. The inspection team will review
this information and, by May 13, 2022, will request the specific items that should be provided for
review. This 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. We
request that the information provided from the second RFI be made available to the regional
office prior to the inspection by June 17, 2022.
C. Gayheart 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 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 Philipp Braaten. We understand that our regulatory
contact for this inspection is Kevin Walden of your organization. If there are any questions
about the inspection or the material requested, please contact the lead inspector at
(404) 997-4651 or via e-mail at Philipp.braaten@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,
Signed by McCoy, Gerald
on 03/28/22
Gerald McCoy, Branch Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 05000424; 05000425
Enclosure:
Vogtle Electric Generating Plant
Cyber-Security Inspection Document Request
cc w/encl: Distribution via LISTSERV
X Non-Sensitive X Publicly Available
X SUNSI Review
Sensitive Non-Publicly Available
OFFICE RII/DRS RII/DRS
NAME P. Braaten G. McCoy
DATE 03/28/2022 03/28/2022
VOGTLE ELECTRIC GENERATING PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
Inspection Report: 05000424/2022401; 05000425/2022401
Inspection Dates: June 27-July 1, 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: Philipp Braaten, Lead Melana Singletary
404-997-4651 404-997-4752
philipp.braaten@nrc.gov melana.singletary@nrc.gov
NRC Contractors: Al Konkal Alex Prada
561-989-0210 301-415-7000
alan.konkal@nrc.gov alexander.prada@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 to the regional office by April 29, 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 May 13, 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 regional office prior to the inspection by
June 17, 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.
VOGTLE ELECTRIC GENERATING PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
The required Table RFI 1 information shall be provided electronically to the lead
inspector by April 29, 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
A list of all Identified Critical Systems and Critical Digital Assets, -
highlight/note any additions, deletions, reclassifications due to new
1 Overall
guidance from white papers, changes to NEI 10-04, 13-10, etc. since
the last cyber security inspection.
A list of EP and Security onsite and offsite digital communication
2 Overall
systems.
Network Topology Diagrams to include information and data flow for
3 Overall
critical systems in levels 2, 3, and 4 (If available).
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)
Cyber Security Incident Response program documentation, including
incident detection, response, and recovery documentation as well as 03.02(a)
7 contingency plan development, implementation, and including any and
program documentation that requires testing of security boundary 03.04(b)
device functionality.
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)
Portable Media and Mobile Device control program documentation,
11 03.02(e)
including kiosk security control assessment/documentation.
Design change/ modification program documentation and a list of all
design changes completed since the last cyber security inspection,
12 03.03(a)
including either a summary of the design change or the 50.59
documentation for the change.
Supply Chain Management program documentation including a list of 03.03(a),
13
security impact analysis for new acquisitions. (b) and (c)
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VOGTLE ELECTRIC GENERATING PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
Table RFI #1
Paragraph Number/Title: IP Ref
Configuration Management program documentation including a list of
03.03(a)
14 security impact analysis performed due to configuration changes since
and (b)
the last cyber inspection.
Cyber Security Plan and any 50.54(p) analysis to support changes to
15 03.04(a)
the plan since the last inspection.
16 Cyber Security Performance Metrics tracked (if applicable). 03.06(b)
Provide documentation describing any cyber security changes to the
17 Overall
access authorization program since the last cyber security inspection.
Provide a list of all cyber security procedures and policies with their
18 Overall
descriptive name and associated number.
19 Performance testing report (if applicable). 03.06(a)
20 Electronic Copy of UFSAR and Technical Specifications Overall
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 May 13, 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 May 13, 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 June 17, 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.
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VOGTLE ELECTRIC GENERATING PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
Table RFI #2
Paragraph Number/Title: Items
For the system(s) chosen for inspection provide:
Ongoing Monitoring and Assessment activity performed on the
1 03.01(a)
selected system(s).
2 All Security Control Assessments for the selected system(s).* 03.01(a)
All vulnerability screenings/assessments associated with or scans
3 performed on the selected system(s) since the last cyber security 03.01(c)
inspection.*
Documentation (including configuration files and rules sets) for
Network-based Intrusion Detection/Protection Systems (NIDS/NIPS),
4 Host-based Intrusion Detection Systems (HIDS), and Security 03.02(b)
Information and Event Management (SIEM) systems for system(s)
chosen for inspection).
Documentation (including configuration files and rule sets) for intra-
5 security level firewalls and boundary devices used to protect the 03.02(c)
selected system(s).
Copies of all periodic reviews of the access authorization list for the
6 03.02(d)
selected systems since the last cyber inspection.
7 Baseline configuration data sheets for the selected CDAs. * 03.03(a)
Documentation on any changes, including Security Impact Analyses,
8 03.03(b)
performed on the selected system(s) since the last inspection.
Copies of the purchase order documentation for any new equipment
9 03.03(c)
purchased for the selected systems since the last inspection.
Copies of any reports/assessment for cyber security drills performed 03.02(a)
10
since the last inspection. 03.04(b)
Copy of the individual recovery plan(s) for the selected system(s) 03.02(a)
11 including documentation of the results the last time the backups
were executed. 03.04(b)
List of Corrective actions taken as a result of cyber security
12 incidents/issues to include previous NRC violations and Licensee 03.05
Identified Violations since the last cyber security inspection.
- Some selected systems may have a large number of CDAs. For these systems reach out to
the team leader for a specific selection of CDAs when responding to this request.
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VOGTLE ELECTRIC GENERATING PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
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
Any cyber security event reports submitted in accordance with 10
1 03.04(a)
CFR 73.77 since the last cyber security inspection.
Updated copies of corrective actions taken as a result of cyber
security incidents/issues, to include previous NRC violations and
2 03.05
Licensee Identified Violations since the last cyber security
inspection, as well as vulnerability-related corrective actions.
The most recent Cyber-Security Quality Assurance audit and/or
3 self-assessment and a list of Corrective Actions generated as a
result
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