ML22312A536

Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000461/2023401

ML22312A536
Person / Time
Site:	Clinton
Issue date:	11/08/2022
From:	Jasmine Gilliam NRC/RGN-III/DORS/EB2
To:	Rhoades D Constellation Energy Generation
References
IR 2023401
Download: ML22312A536 (1)

See also: IR 05000461/2023401

Text

November 8, 2022

Mr. David Rhoades

Senior Vice President

Constellation Energy Generation, LLC

President and Chief Nuclear Officer (CNO)

Constellation Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: CLINTON POWER STATION - INFORMATION REQUEST FOR THE

CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM

INSPECTION 05000461/2023401

Dear Mr. Rhoades:

On January 30, 2023, 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 Clinton Station. The inspection will be performed to evaluate and verify your ability to

meet 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 January 30-February 3, 2023.

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 December 10, 2022. The inspection team will

review this information and, by December 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 Cyber-Security Plan (CSP) selected for the cyber-security

inspection. This information will be requested for review in the regional office prior to the

inspection by January 16, 2023, as identified above.

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, January 30, 2032.

D. Rhoades -2-

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 Jasmine Gilliam. We understand that our regulatory

contact for this inspection is Chelsie Millar of your organization. If there are any questions about

the inspection or the material requested, please contact the lead inspector at 630-829-9831 or

via email at Jasmine.Gilliam@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 Website at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

Signed by Gilliam, Jasmine

on 11/08/22

Jasmine Gilliam, Senior Reactor Inspector

Engineering Branch 2

Division of Operating Reactor Safety

Docket No. 50-461

License No. NPF-62

Enclosure:

Cyber-Security Inspection

Document Request

cc w/encl: Distribution via LISTSERV

D. Rhoades -3-

Letter to David Rhoades from Jasmine Gilliam dated November 8, 2022.

SUBJECT: CLINTON POWER STATION - INFORMATION REQUEST FOR THE

CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM

INSPECTION 05000461/2023401

DISTRIBUTION:

Jessie Quichocho

Lou McKown

RidsNrrDorlLpl3

RidsNrrPMClinton Resource

RidsNrrDroIrib Resource

John Giessner

Mohammed Shuaibi

Diana Betancourt-Roldan

Allan Barker

R3-DORS

ADAMS Accession Number: ML22312A536

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

OFFICE RIII

NAME JGilliam:sw

DATE 11/08/2022

OFFICIAL RECORD COPY

CLINTON CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Inspection Report: 05000461/2023401

Inspection Dates: January 30-February 3, 2023

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

NRC Inspectors: Jasmine Gilliam, Lead Gregory Hansen

630-829-9831 630-829-9610

Jasmine.Gilliam@nrc.gov Gregory.Hansen@nrc.gov

NRC Contractors: Steven Leigh Alan Konkal

Steven.Leigh@nrc.gov Alan.Konkal@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 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 December 10, 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 December 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

January 16, 2023.

The required Table RFI 1 information shall be provided electronically to the lead

inspector by December 10, 2022. If a compact disc (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 hyperlinked to

facilitate ease of use. If you have any questions regarding this information, please call

the inspection team leader as soon as possible.

Enclosure

CLINTON CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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 and Security onsite and offsite

2 Overall

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 (b) and

impact analysis for new acquisitions

(c)

2

CLINTON CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Configuration Management documentation including any security

03.03(a)

14 impact analysis performed due to configuration changes since the

and (b)

last inspection

Cyber-Security Plan and any 50.54(p) analysis to support changes to

15 03.04(a)

the plan since 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 Overall

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 Updated Final Safety Analysis Report (UFSAR) and

Technical Specifications;

(2) Name(s) and phone numbers for the regulatory and technical contacts; and

(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 December 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 December 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

January 16, 2023. 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 hyperlinked to facilitate ease of use.

If you have any questions regarding this information, please call the inspection team

leader as soon as possible.

3

CLINTON 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 intrasecurity 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 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 03.04(b)

were executed

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

CLINTON CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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 January 30, 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 (SER) and Supplements;

d. FSAR Question and Answers;

e. Quality Assurance (QA) Plan;

f. Technical Specifications, if not previously provided; and

g. Latest Individual Plant Examination and Probabilistic Risk Assessment

(IPE/PRA) Report.

(2) Vendor Manuals, Assessment and Corrective Actions:

a. The most recent Cyber-Security 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.

5

CLINTON CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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.

6