ML22097A083
| ML22097A083 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 04/07/2022 |
| From: | Alan Dahbur Engineering Branch 3 |
| To: | Rhoades D Constellation Energy Generation |
| References | |
| IR 2022403 | |
| Download: ML22097A083 (8) | |
See also: IR 05000373/2022403
Text
Mr. David P. Rhoades
Senior Vice President
Constellation Energy Generation, LLC
President and Chief Nuclear Officer (CNO)
Constellation Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: LASALLE COUNTY STATION - INFORMATION REQUEST FOR THE
CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000373/2022403 AND 05000374/2022403
Dear Mr. Rhoades:
On August 1, 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 LaSalle County Station Units 1 and 2. The inspection will be performed to evaluate and
verify that the LaSalle County Stations digital computer and communication systems and
networks associated with safety, security, or emergency preparedness (SSEP) functions are
adequately protected against cyberattacks in accordance with Title 10 of the Code of Federal
Regulations (10 CFR), Part 73, Section 54, Protection of Digital Computer and Communication
Systems and Networks, and the U.S. Nuclear Regulatory Commission (NRC) approved
cyber-security plan (CSP). The onsite portion of the inspection will take place August 1 - 5,
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 May 20, 2022. The inspection team will review
this information and, by June 17, 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 July 15, 2022, as
identified above.
April 7, 2022
D. Rhoades
- 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, August 1, 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 Alan Dahbur. We understand that our regulatory
contact for this inspection is Jereme Greenblott 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.
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,
Alan Dahbur, Senior Reactor Inspector
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 05000373 and 05000374
License Nos. NPF-11 and NPF-18
Enclosure:
LaSalle County Station Cyber-Security
Inspection Document Request
cc w/encl: Distribution via LISTSERV
Signed by Dahbur, Alan
on 04/07/22
D. Rhoades
- 3 -
Letter to David P. Rhoades from Alan Dahbur dated April 7, 2022.
SUBJECT: LASALLE COUNTY STATION - INFORMATION REQUEST FOR THE
CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000373/2022403 AND 05000374/2022403
DISTRIBUTION:
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ADAMS Accession Number: ML22097A083
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
NAME
ADahbur:mb
DATE
04/07/2022
OFFICIAL RECORD COPY
LASALLE CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Enclosure
Inspection Report: 05000373/2022403 and 05000374/2022403
Inspection Dates:
August 1-5, 2022
Inspection Procedure:
IP 71130.10, Cyber-Security, Revision 0
NRC Inspectors:
630-829-9831
630-829-9810
Jasmine.Gilliam@nrc.gov
Alan.Dahbur@nrc.gov
NRC Contractors:
Balla Barro
Balla.Barro@nrc.gov
Frederick.Priester@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
cyber-security plan (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 Inspection
Procedure (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
May 20, 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 June 17, 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 July 15,
2022.
LASALLE CYBER-SECURITY INSPECTION DOCUMENT REQUEST
2
The required Table RFI #1 information shall be provided electronically to the lead
inspector by May 20, 2022. If a compact disk (CD) is provided, please provide four
copies (one for each inspector/contactor). The preferred file format for all lists is a
searchable Excel spreadsheet file. These files 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
Request:
IP Ref
1
A list of all Identified CSs/CDAs-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 Emergency Preparedness (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 documentation.
03.02(c)
9
Password/Authenticator documentation.
03.02(c)
10
User Account/Credential documentation.
03.02(d)
11
Portable Media and Mobile Device control documentation, including
kiosk security control assessment/documentation.
03.02(e)
12
Design change/modification program documentation and a list of all
design changes that affected CDAs that have been installed and
completed since the last cyber-security inspection, including either a
summary of the design change or the 50.59 documentation of the
change.
03.03(a)
13
Supply Chain Management documentation including any security
impact analysis for new acquisitions.
03.03(a),
(b) and
(c)
14
Configuration Management documentation including any security
impact analysis performed due to configuration changes since the
last inspection.
03.03(a)
and (b)
LASALLE CYBER-SECURITY INSPECTION DOCUMENT REQUEST
3
Table RFI #1
Request:
IP Ref
15
CSP and any 50.54(p) analysis to support changes to the plan since
the last inspection.
03.04(a)
16
Cyber Security 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 Updated Final Safety Analysis Report (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 June17, 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 June 17, 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.
The Table RFI #2 information shall be provided electronically to the lead inspector by
July 15, 2022. If a CD is provided, please provide four copies (one for each
inspector/contactor). The preferred file format for all lists is a searchable Excel
spreadsheet file. These files 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. If you have any questions regarding this information,
please call the inspection team leader as soon as possible.
LASALLE CYBER-SECURITY INSPECTION DOCUMENT REQUEST
4
Table RFI #2
Request
Items
For the system(s) chosen for inspection provide:
1
Ongoing Monitoring and Assessment activity performed on the
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 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 cyber-security drills performed since the last
inspection, along with any reports or assessments generated.
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.
03.04(d)
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 1ST Week Onsite) electronically by August 1, 2022, the first
day of the inspection.
Table 1ST Week Onsite
Request:
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.
03.04(d)
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.
UFSAR, if not previously provided;
b.
Original Final Safety Analysis Report (FSAR) Volumes;
c.
Original Safety Evaluation Report and Supplements;
d.
FSAR Question and Answers;
e.
Quality Assurance Plan;
f.
Technical Specifications, if not previously provided; and
g.
Latest Individual Plant Examination and Probabilistic Risk Assessment
Report.
(2)
Vendor Manuals, Assessment and Corrective Actions:
a.
The most recent Cyber-Security Quality Assurance (QA) 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 QA
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.