ML22123A270
| ML22123A270 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/03/2022 |
| From: | Greg Pick NRC/RGN-IV/DORS/EB2 |
| To: | Reasoner C Wolf Creek |
| References | |
| IR 2022401 | |
| Download: ML22123A270 (8) | |
See also: IR 05000482/2022401
Text
May 3, 2022
Mr. Cleve Reasoner, Chief Executive Officer
and Chief Nuclear Officer
Wolf Creek Nuclear Operating Corp.
P.O. Box 411
Burlington, KS 66839
SUBJECT: WOLF CREEK GENERATING STATION - INFORMATION REQUEST FOR THE
CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000482/2022401
Dear Mr. Reasoner:
On August 8, 2022, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
inspection in accordance with Inspection Procedure 71130.10 Cyber-Security, Revision 0 at
your Wolf Creek Generating Station. The inspection will be performed to evaluate and verify
your ability to meet the requirements of the NRCs Cyber-Security Rule, Title 10, Code of
Federal Regulations (CFR), Part 73, Section 54, Protection of Digital Computer and
Communication Systems and Networks.
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 inspection procedure.
This information should be made available via electronic means (e.g., compact disc or other
electronic means) and delivered to the regional office no later than May 16, 2022. The
inspection team will review this information and, by June 13, 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 your cyber security program selected for the cyber-security inspection. This
information will be requested for review in the regional office prior to the inspection by July 11,
2022.
C. Reasoner 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 8, 2022.
The fourth group of information is necessary to aid the inspection team in tracking issues
identified during 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 Greg Pick. We understand that our regulatory contact
for this inspection is Jason Knust of your organization. If there are any questions about the
inspection or the material requested, please contact the lead inspector at 817-504-2105 or via
email at greg.pick@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 NRCs Agency 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 Pick, Gregory
on 05/03/22
Greg Pick, Senior Reactor Inspector
Engineering Branch 2
Division of Operating Reactor Safety
Docket No. 50-482
License No. NPF-42
Enclosure:
Cyber-Security Inspection Document Request
Distribution via Listserv
Inspection Report: 05000482/2022401
Inspection Dates: August 8 - 12, 2022
Inspection Procedure: IP 71130.10, Cyber-Security, Revision 0
Reference: ADAMS Accession No. ML21330A088, Guidance Document for
Development of the Request for Information (RFI) and Notification
Letter for Full-Implementation of the Cyber-Security Inspection,
Revision 1
NRC Inspectors: Greg Pick, Lead Shiattin Makor
817-504-2105 817-200-1507
greg.pick@nrc.gov shiattin.makor@nrc.gov
Johnathan Lee
817-200-1550
johnathan.lee@nrc.gov
NRC Contractors: Tim Marshall Alan Konkal
timothy.marshall@nrc.gov alan.konkal@nrc.gov
I. Information Requested for In-Office Preparation
The initial request for information (Table RFI #1) provides the team with the general
information necessary to select appropriate components and cyber security program
elements to develop a site-specific inspection plan. The initial request for information is
used to identify the list of critical systems and critical digital assets (CSs/CDAs) plus
operational and management security control portions of the cyber security program to
be chosen as the sample set to be inspected. Please provide the information listed in
Table RFI #1 to the regional office by May 16, 2022, or sooner, to facilitate the selection
of the specific items that will be reviewed during the onsite inspection week.
The team will examine the returned documentation from the initial request for information
and select specific critical systems and critical digital assets to provide for a more
deliberate, focused second request for information. The team will submit the second
request by June 13, 2022, which will identify the critical systems and critical digital
assets that will be utilized to evaluate the defensive architecture and the areas of your
cyber security program selected for the inspection. We request that the information for
the second request be made available for review by July 11, 2022. All requests for
information shall follow the referenced guidance document ADAMS Accession
No. [ML21330A088].
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
Section 3,
Paragraph Number/Title: IP Ref
A list of all identified critical systems and critical digital assets.
1 Highlight/note any additions, deletions, reclassifications due to new Overall
guidance from white papers, changes to NEI 10-04, 13-10, and
more since the last cyber security inspection
2 A list of EP and Security onsite and offsite digital communication Overall
systems
3 Network Topology Diagrams to include information and data flow Overall
for 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 03.01(b)
Program
6 Vulnerability screening/assessment and scan program 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, and implementation, 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)
11 Portable Media and Mobile Device control documentation, 03.02(e)
including kiosk security control assessment/documentation
Design change/modification program documentation and a list of all
12 design changes completed since the last cyber security inspection, 03.03(a)
including either a summary of the design change or the 50.59
documentation for the change
Supply Chain Management documentation including any security 03.03(a),
13
impact analysis for new acquisitions (b) and (c)
Configuration Management documentation including any security 03.03(a)
14 impact analysis performed due to configuration changes since the and (b)
last inspection
15 Cyber Security Plan and any 50.54(p) analysis to support changes 03.04(a)
to the plan since the last inspection
4
Table RFI #1
Section 3,
Paragraph Number/Title: IP Ref
16 Cyber Security Metrics tracked, if applicable 03.06 (b)
Provide documentation describing any cyber security changes to
17 the access authorization program since the last cyber security Overall
inspection.
18 Provide a list of all procedures and policies provided to the NRC Overall
with their descriptive name and associated number, if available
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
II. Additional Information Requested to be Available Prior to Inspection.
As stated in Section I, the team will examine the documentation requested from
Table RFI #1 and submit the list of critical systems and critical digital assets to your staff
by June 13, 2022 (i.e., RFI #2). The additional information requested is identified in
Table RFI #2. All requested information shall follow the referenced guidance document
ADAMS Accession No. [ML21330A088].
Please provide the Table RFI 2 information to the lead inspector by July 11, 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.
Table RFI #2
Section 3,
Paragraph Number/Title: 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 and/or
3 scans performed on the selected system(s) since the last cyber 03.01(c)
security inspection
5
Table RFI #2
Section 3,
Paragraph Number/Title: Items
Documentation, including configuration files and rules sets) for
Network-based Intrusion Detection/Protection Systems
4 (NIDS/NIPS), Host-based Intrusion Detection Systems (HIDS), and 03.02(b)
Security 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 inspection
7 Baseline configuration data sheets for the selected CDAs 03.03(a)
Documentation on any changes, including Security Impact
8 Analyses, performed on the selected system(s) since the last 03.03(b)
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 03.02(a)
10
performed 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)
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
III. Information Requested to be Available on First Day of Inspection
For the critical systems and critical digital assets identified in Section II, provide the
following request for information (i.e., Table 1ST Week Onsite) to the team by August 8,
2022, the first day of the inspection. All requested information shall follow the referenced
guidance document in ADAMS Accession No. [ML21330A088].
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.
6
Table 1ST Week Onsite
Section 3,
Paragraph Number/Title: Items
1 Any cyber security event reports submitted in accordance with
03.04(a)
10 CFR 73.77 since the last cyber security inspection
Updated Copies of corrective actions taken because of cyber
2 security incidents/issues, to include previous NRC violations and
03.04(d)
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 if the inspectors have easy and unrestrained access to them.
a. Updated Final Safety Analysis Report (if not previously provided)
b. Original FSAR Volumes
c. Original SER and Supplements
d. FSAR Question and Answers
e. Quality Assurance Plan
f. Technical Specifications, if not previously provided
g. Latest IPE/PRA Report
(2) Vendor Manuals, Assessments 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) generate as a result of the most recent Cyber-Security
Quality Assurance (QA) audit and/or self-assessment
IV. Information Requested to be Provided Throughout the Inspection
(1) Copies of any corrective action documents generated because 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.
7
X SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword
By: GAP X Yes No X Non-Sensitive X Publicly Available NRC-002
OFFICE DORS:EB2
NAME GPick
SIGNATURE /RA/
DATE 5/3/2022