ML22252A035
| ML22252A035 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/12/2022 |
| From: | Sam Graves NRC/RGN-IV/DORS/EB2 |
| To: | Marjorie Mclaughlin Arizona Public Service Co |
| Graves S | |
| References | |
| IR 2022401 | |
| Download: ML22252A035 (11) | |
See also: IR 05000528/2022401
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 EAST LAMAR BOULEVARD
ARLINGTON, TEXAS 76011-4511
September 12, 2022
Mr. Mike McLaughlin
Site Vice President
Arizona Public Service Company
P.O. Box 52034, MS 7602
Phoenix, AZ 85072-2034
SUBJECT: PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -
INFORMATION REQUEST FOR THE CYBERSECURITY BASELINE
INSPECTION, NOTIFICATION TO PERFORM INSPECTION 05000528/2022401;
05000529/2022401; 05000530/2022401
Dear Mr. McLaughlin:
On December 5, 2022, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
inspection in accordance with Inspection Procedure (IP) 71130.10 Cybersecurity, at your Palo
Verde Nuclear Generating Station, Units 1, 2, and 3. The inspection objectives are to provide
assurance that the 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) 73.54
and your approved cybersecurity plan (CSP), and to verify that any CSP changes and reports
have been made in accordance with 10 CFR 50.54(p).
Experience has shown that baseline inspections are extremely resource intensive, both for the
NRC inspectors and 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 via digital media (CD/DVD) or an online document repository and
delivered/available to the regional office no later than October 10, 2022. The inspection team
will review this information and, by October 31, 2022, will request the specific items that should
be provided for review.
The second group of 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 review. This information will be requested for review
in the regional office prior to the inspection by November 14, 2022, as identified above.
M. McLaughlin 2
The third group of requested documents consists of additional 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, December 5, 2022.
The fourth group of information aids 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 requested 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 Sam Graves. We understand that our regulatory contact
for this inspection is Sarah Kane of your organization. If there are any questions about the
inspection or the material requested, please contact the lead inspector at 817-200-1102 or via
e-mail at samuel.graves@nrc.gov
Paperwork Reduction Act Statement
This letter contains mandatory information collections that are subject to the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)
approved these information collections under approval number 3150-0011. The burden to the
public for these information collections is estimated to average 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />(s) per response. Send
comments regarding this information collection to the FOIA, Library and Information Collection
Branch, Office of the Chief Information Officer, Mail Stop: T6-A10M, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001, or by email to Infocollects.Resource@nrc.gov, and
to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0011)
OMB, Washington, DC 20503.
Public Protection Notification
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 Graves, Samuel
on 09/12/22
Sam Graves, Senior Reactor Inspector
Engineering Branch 2
Division of Operating Reactor Safety
Docket Nos. 05000528, 05000529, 05000530
License Nos. NPF-41, NPF-51, NPF-74
Enclosure: Palo Verde Nuclear Generating Station, Units 1, 2, And 3
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: Yes No Publicly Available Sensitive NRC-002
OFFICE RIV:SRI/DORS/EB2
NAME S. Graves
SIGNATURE /RA/
DATE 9/12/2022
PALO VERDE NUCLEAR GENERATING STATION CYBERSECURITY INSPECTION
DOCUMENT REQUEST
Inspection Report: 05000528/2022401; 05000529/2022401; 05000530/2022401
Inspection Dates: Week of December 5, 2022
Inspection Procedure: IP 71130.10, CYBERSECURITY
Reference: ML21330A088, Guidance Document for Development of the
Request for Information (RFI) and Notification Letter for IP
71130.10 Cyber Security Inspection, Revision 2
NRC Inspectors: Sam Graves, Lead Shiattin Makor
817-200-1102 817-200-1507
samuel.graves@nrc.gov shiattin.Makor@nrc.gov
NRC Contractors: Al Konkal Trace Coleman
561-989-0210 301-415-7000
alan.konkal@nrc.gov trace.coleman@nrc.gov
I. Information Requested for In-Office Preparation
This initial request for information (i.e., Table RFI #1) concentrates on providing the inspection
team with information necessary to select appropriate components and cyber security program
elements to develop a site-specific inspection plan. The first RFI is used to identify the critical
digital assets or systems 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.
Please provide the information requested in Table RFI #1 to the regional office by
October 10, 2022, or sooner, to facilitate the selection of the specific items for review.
The inspection team will examine the documentation from the first RFI and select specific
systems and equipment 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
October 31, 2022, which will be utilized to evaluate the equipment, defensive architecture, and
the areas of the licensees cyber security program for review.
Please provide the information requested by the second RFI to the regional office by
Enclosure
PALO VERDE NUCLEAR GENERATING STATION CYBERSECURITY INSPECTION
DOCUMENT REQUEST
November 14, 2022. All requests for information shall follow the guidance document referenced
above. For information requests that have more than ten (10) documents, please provide a
compressed (i.e., Zip) file of the documents.
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PALO VERDE NUCLEAR GENERATING STATION CYBERSECURITY INSPECTION
DOCUMENT REQUEST
The required Table RFI #1 information shall be provided on digital media (CD/DVD)) or an online
document repository to the lead inspector by October 10, 2022. Please provide four copies of
each media submitted (i.e., one for each inspector/contactor). The preferred file format for all lists
is a searchable Excel spreadsheet file. The media (CDs/DVDs) 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. Items
1 A list of all Identified Critical Systems and Critical Digital Assets, - Overall
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.
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 Overall
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)
7 Cyber Security Incident response documentation, including incident 03.02(a) and
detection, response, and recovery documentation as well as contingency 03.04(b)
plan development, implementation and including any program documentation
that requires testing of security boundary device functionality
8 Device Access and Key Control documentation 03.02(d)
9 Password/Authenticator documentation 03.02(d)
10 User Account/Credential documentation 03.02(d)
11 Portable Media and Mobile Device control documentation, including kiosk 03.02(e)
security control assessment/documentation
12 Design change/modification program documentation and a list of all cyber- 03.03(a)
related design changes completed since the last cyber security inspection,
including either a summary describing the design change or the 50.59
documentation for the change.
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PALO VERDE NUCLEAR GENERATING STATION CYBERSECURITY INSPECTION
DOCUMENT REQUEST
13 Supply Chain Management documentation including any security impact 03.03(a), (b)
analysis for new acquisitions and (c)
14 Configuration Management documentation including any security impact 03.03(a) and
analysis performed due to configuration changes since the last inspection (b)
15 Cyber Security Plan and any 50.54(p) analysis to support changes to the 03.04(a)
plan since the last inspection
16 Cyber Security Metrics tracked (if applicable) 03.06 (b)
17 Provide documentation describing any cyber security changes to the access Overall
authorization program since the last cyber security inspection.
18 Provide a list of all procedures and policies provided to the NRC with their Overall
descriptive name and associated number (if available)
19 Performance testing report (if applicable) 03.06 (a)
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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.
(4) Implementing and program procedures in a single folder.
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 October 31, 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 October 31, 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 cybersecurity 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 on digital media (CD/DVD) or an online
document repository to the lead inspector by November 14, 2022. Please provide four copies of
each media (CD/DVD) submitted (i.e., one for each inspector/contactor). The preferred file
format for all lists is a searchable Excel spreadsheet file. The digital media (CDs/DVDs) 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, IP Ref.
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)
All vulnerability screenings/assessments associated with, or scans
3 03.01(c)
performed on the selected system(s) since the last cyber security inspection
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PALO VERDE NUCLEAR GENERATING STATION CYBERSECURITY INSPECTION
DOCUMENT REQUEST
Table RFI #2
Section 3, IP Ref.
Paragraph Number/Title: Items
Documentation (including configuration files and rules sets) for Network-
based Intrusion Detection/Protection Systems (NIDS/NIPS), Host-based
4 03.02(b)
Intrusion Detection Systems (HIDS), and Security Information and Event
Management (SIEM) systems for system(s) chosen for inspection
Documentation (including configuration files and rule sets) for intra-security
5 03.02(c)
level firewalls and boundary devices used to protect the selected system(s)
Copies of all periodic reviews of the access authorization list for the selected
6 03.02(d)
systems since the last 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 since 03.02(a)
10
the last inspection. 03.04(b)
Copy of the individual recovery plan(s) for the selected system(s) including 03.02(a)
11
documentation of the results the last time the backups were executed. 03.04(b)
Corrective actions taken as a result of cyber security incidents/issues to
12 include previous NRC violations and Licensee Identified Violations since the 03.04(d)
last cyber security inspection
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 Onsite Week) on digital media (CD/DVD) or an online document repository by
December 5, 2022, the first day of the inspection. All requested information shall follow the
guidance document referenced above.
Please provide four copies of each passive digital media (CD/DVD) submitted (i.e., one for each
inspector/contactor). The preferred file format for all lists is a searchable Excel spreadsheet file.
The digital media (CDs/DVDs) 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 Onsite Week
Section 3,
Paragraph Number/Title: 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 and
2 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 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; and
(2) Vendor Manuals, Assessments 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 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 as a result of the inspection
teams questions or queries during the inspection.
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PALO VERDE NUCLEAR GENERATING STATION CYBERSECURITY INSPECTION
DOCUMENT REQUEST
(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.
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