ML22145A446
| ML22145A446 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/06/2022 |
| From: | Pick A NRC Region 4 |
| To: | Schuetz R Energy Northwest |
| References | |
| IR 2022401 | |
| Download: ML22145A446 (8) | |
See also: IR 05000397/2022401
Text
June 6, 2022
Mr. Robert Schuetz
Chief Executive Officer
Energy Northwest
MD 1023
76 North Power Plant Loop
P.O. Box 968
Richland, WA 99352
SUBJECT: COLUMBIA GENERATING STATION - INFORMATION REQUEST FOR THE
CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000397/2022401
Dear Mr. Robert Schuetz,
On October 3, 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 Columbia 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. The onsite portion of the inspection will take place
during the week of October 3, 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 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 July 11, 2022. The
inspection team will review this information and, by August 8, 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
September 5, 2022.
R. Schuetz
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, October 3, 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 these
documents are up to date and complete 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 Dan Cook 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
e-mail 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 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,
Greg Pick, Senior Reactor Inspector
Engineering Branch 2
Division of Operating Reactor Safety
Docket Nos. 50-397
License Nos. NPF-21
Enclosure:
Columbia Generating Station
Cyber-Security Inspection Document Request
Distribution via Listserv
Signed by Pick, Gregory
on 06/06/22
Enclosure
Inspection Report: 05000397/2022401
Inspection Dates:
October 3 - 8, 2022
Inspection Procedure:
IP 71130.10, Cyber-Security, Revision 0
Reference:
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:
Marcus Chisolm
817-504-2105
817-200-1426
greg.pick@nrc.gov
marcus.chisolm@nrc.gov
817-200-1114
nnaerika.okonkwo@nrc.gov
NRC Contractors:
Balla Barro
balla.barro@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 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 July 11, 2022, or sooner, to facilitate the selection of the specific items
that will be reviewed.
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 August 8, 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 September 5, 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.
2
Table RFI#1
Section 3,
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 documentation
03.02(c)
9
Password/Authenticator documentation
03.02(c)
1
0
User Account/Credential documentation
03.02(d)
1
1
Portable Media and Mobile Device control documentation, including kiosk
security control assessment/documentation
03.02(e)
1
2
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)
1
3
Supply Chain Management documentation including any security impact
analysis for new acquisitions
03.03(a),
(b) and
(c)
1
4
Configuration Management documentation including any security impact
analysis performed due to configuration changes since the last inspection
03.03(a)
and (b)
1
5
Cyber Security Plan and any 50.54(p) analysis to support changes to the
plan since the last inspection
03.04(a)
3
Table RFI#1
Section 3,
Paragraph Number/Title:
IP Ref
1
6
Cyber Security Metrics tracked (if applicable)
03.06 (b)
1
7
Provide documentation describing any cyber security changes to the access
authorization program since the last cyber security inspection.
Overall
1
8
Provide a list of all procedures and policies provided to the NRC with their
descriptive name and associated number (if available)
Overall
1
9
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 above, 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 August 8, 2022 (i.e., RFI#2). The additional information requested for the specific
systems and equipment is identified in Table RFI#2. Please provide the Table RFI#2
information to the lead inspector by September 5, 2022. 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:
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)
4
Table RFI#2
Section 3,
Paragraph Number/Title:
Items
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)
1
0
Copies of any reports/assessment for cyber security drills performed since
the last inspection.
03.02(a)
03.04(b)
1
1
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)
1
2
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)
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
October 3, 2022, the first day of the inspection.
Table 1ST Week Onsite
Section 3,
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
03.04(d)
5
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 (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, 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) generate because 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.
X SUNSI Review
By: GAP
ADAMS:
X Yes No
Sensitive
X Non-Sensitive
Non-Publicly Available
X Publicly Available
Keyword
OFFICE
RIV/DORS/EB2
DORS/EB2
NAME
MChisolm
GPick
SIGNATURE
/RA/
/RA/
DATE
6/6/2022
6/6/2022