ML22255A154
| ML22255A154 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/13/2022 |
| From: | Nnaerika Okonkwo NRC/RGN-IV/DORS/EB2 |
| To: | Gerry Powell South Texas |
| Okonkwo N | |
| References | |
| IR 2022401 | |
| Download: ML22255A154 (11) | |
See also: IR 05000498/2022401
Text
September 13, 2022
Mr. G. T. Powell, President
and CEO
STP Nuclear Operating Company
P.O. Box 289,
Wadsworth, TX 77483
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1, AND
2 - INFORMATION REQUEST FOR THE CYBERSECURITY BASELINE
INSPECTION, NOTIFICATION TO PERFORM INSPECTION 05000498/2022401
AND 05000499/2022401
Dear Mr. Powell:
On November 28, 2022, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
inspection in accordance with Inspection Procedure (IP) 71130.10 Cybersecurity, at your
South Texas Project Electric Generating Station, Units 1, and 2. 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 7, 2022. The inspection team will
review this information and, by October 17, 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 7, 2022, as identified above.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
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, November 28, 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 Nnaerika Okonkwo. We understand that our regulatory
contact for this inspection is Stephanie Rodgers of your organization. If there are any questions
about the inspection or the material requested, please contact the lead inspector at 817-200-
1114 or via e-mail at nnaerika.okonkwo@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 Website at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
Nnaerika Okonkwo, Reactor Inspector
Engineering Branch 2
Division of Operating Reactor Safety
Signed by Okonkwo, Nnaerika
on 09/15/22
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Docket Nos. 05000498, 05000499,
Enclosure:
South Texas Project Electric Generating Station, Units 1 And 2.
Cyber Security Inspection Document Request
cc w/encl: Distribution via LISTSERV
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION, UNITS 1, AND 2 -
INFORMATION REQUEST FOR THE CYBERSECURITY BASELINE INSPECTION,
NOTIFICATION TO PERFORM INSPECTION 05000498/2022401 AND 05000499/2022401
DATED SEPTEMBER 13, 2022
DISTRIBUTION:
SMorris, ORA
JMonninger, ORA
RLantz, DORS
MHay, DORS
DCylkowski, RC
LMcKown, RIV/OEDO
VDricks, ORA
LWilkins, OCA
DGalvin, NRR
AMoreno, RIV/OCA
RAlexander, RSLO
PVossmar, DORS
RDeese, DORS
SLichvar, DORS
GKolcum, DORS
CStott, DORS
LReyna, DORS
R4-DORS-IPAT
R4Enforcement
ADAMS ACCESSION NUMBER: ML22255A154
SUNSI Review:
ADAMS:
Non-Publicly Available and Sensitive
By: NPO
Yes No
Publicly Available and non-sensitive
OFFICE
DORS/EB2
NAME
N.Okonkwo
SIGNATURE
NPO1
DATE
09/13/22
OFFICAL RECORD COPY
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Inspection Report: 05000498/2022401; 05000499/2022401
Inspection Date(s):
Week of November 28
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:
817-200-1114
404-997-4837
Nnaerika.okonkwo@nrc.gov
larry.jones@nrc.gov
NRC Contractors:
Steven Leigh
Tim Marshall
301-332-8281
703-964-6891
Steven.leigh@nrc.gov
timothy.marshall@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 7, 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
17, 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 November
7, 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.
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Enclosure
2
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 7, 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 hyperlinked 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, -
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(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
security control assessment/documentation
03.02(e)
12
Design change/modification program documentation and a list of all cyber-
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.
03.03(a)
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Enclosure
3
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)
15
Cyber Security Plan 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)
Enclosure
4
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 17, 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 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 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 7, 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 hyperlinked 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:
IP Ref.
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)
Enclosure
5
Table RFI #2
Section 3,
Paragraph Number/Title:
IP Ref.
Items
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 reports/assessment for cyber security drills performed since
the last inspection.
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)
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
November 28, 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 hyperlinked to facilitate ease of use. If
you have any questions regarding this information, please call the inspection team leader as
soon as possible.
Table Onsite Week
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)
Enclosure
6
Table Onsite Week
Section 3,
Paragraph Number/Title:
Items
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.
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.
(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.