ML22097A083

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County Station Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000373/2022403 and 05000374/2022403
ML22097A083
Person / Time
Site: LaSalle  Constellation icon.png
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

April 7, 2022

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.

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,

Signed by Dahbur, Alan

on 04/07/22

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

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:

Jessie Quichocho

Linda Howell

RidsNrrDorlLpl3

RidsNrrPMLaSalle Resource

RidsNrrDroIrib Resource

John Giessner

Mohammed Shuaibi

Shelbie Lewman

Allan Barker

DRPIII

DRSIII

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

Inspection Report: 05000373/2022403 and 05000374/2022403

Inspection Dates: August 1-5, 2022

Inspection Procedure: IP 71130.10, Cyber-Security, Revision 0

NRC Inspectors: Jasmine Gilliam Alan Dahbur, Lead

630-829-9831 630-829-9810

Jasmine.Gilliam@nrc.gov Alan.Dahbur@nrc.gov

NRC Contractors: Balla Barro Casey Priester

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.

Enclosure

LASALLE CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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

A list of all Identified CSs/CDAs-highlight/note any additions,

deletions, reclassifications due to new guidance from white papers,

1 Overall

changes to NEI 10-04, 13-10, etc. since the last cyber-security

inspection.

A list of Emergency Preparedness (EP) and Security onsite and

2 Overall

offsite digital communication 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)

The most recent effectiveness analysis of the Cyber Security

5 03.01(b)

Program.

Vulnerability screening/assessment and scan program

6 03.01(c)

documentation.

Cyber Security Incident response 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 documentation. 03.02(c)

9 Password/Authenticator documentation. 03.02(c)

10 User Account/Credential documentation. 03.02(d)

Portable Media and Mobile Device control documentation, including

11 03.02(e)

kiosk security control assessment/documentation.

Design change/modification program documentation and a list of all

design changes that affected CDAs that have been installed and

12 completed since the last cyber-security inspection, including either a 03.03(a)

summary of the design change or the 50.59 documentation of the

change.

03.03(a),

Supply Chain Management documentation including any security

13 impact analysis for new acquisitions. (b) and

(c)

Configuration Management documentation including any security

14 impact analysis performed due to configuration changes since the 03.03(a)

and (b)

last inspection.

2

LASALLE CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table RFI #1

Request: IP Ref

15 CSP and any 50.54(p) analysis to support changes to the plan since 03.04(a)

the last inspection.

16 Cyber Security Metrics tracked (if applicable). 03.06 (b)

Provide documentation describing any cyber-security changes to the

17 access authorization program since the last cyber-security Overall

inspection.

Provide a list of all procedures and policies provided to the NRC with

18 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

second RFI (i.e., RFI #2).

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.

3

LASALLE CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table RFI #2

Request Items

For the system(s) chosen for inspection provide:

Ongoing Monitoring and Assessment activity performed on the

1 03.01(a)

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

5 intra-security level firewalls and boundary devices used to protect 03.02(c)

the selected system(s).

Copies of all periodic reviews of the access authorization list for the

6 selected systems since the last inspection. 03.02(d)

7 Baseline configuration data sheets for the selected CDAs. 03.03(a)

Documentation on any changes, including Security Impact Analyses,

8 performed on the selected system(s) since the last inspection. 03.03(b)

Copies of the purchase order documentation for any new equipment

9 purchased for the selected systems since the last inspection. 03.03(c)

Copies of any cyber-security drills performed since the last 03.02(a)

10 inspection, along with any reports or assessments generated.

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)

Corrective actions taken as a result of cyber-security

12 incidents/issues to include previous NRC violations and Licensee 03.04(d)

Identified Violations since the last cyber-security inspection.

4

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

Any cyber-security event reports submitted in accordance with

1 03.04(a)

10 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

2 03.04(d)

and Licensee Identified Violations since the last cyber-security

inspection, as well as vulnerability-related corrective actions.

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.

5