ML22318A184

Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000237/2023401; 05000249/2023401

ML22318A184
Person / Time
Site:	Dresden
Issue date:	11/15/2022
From:	Jasmine Gilliam NRC/RGN-III/DORS/EB2
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2023401
Download: ML22318A184 (1)

See also: IR 05000237/2023401

Text

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: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - INFORMATION

REQUEST FOR THE CYBER-SECURITY BASELINE INSPECTION,

NOTIFICATION TO PERFORM INSPECTION 05000237/2023401;

05000249/2023401

Dear Mr. Rhoades:

On March 13, 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 Dresden 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 March 13-17, 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 January 10, 2023. The inspection team will review

this information and, by January 18, 2023, 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 February 22, 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, March 13, 2023.November 15, 2022

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 Duane Avery II 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,

Jasmine Gilliam, Senior Reactor Inspector

Engineering Branch 2

Division of Operating Reactor Safety

Docket Nos. 50-237; 50-249

License Nos. DPR-19, DPR-25

Enclosure:

Cyber-Security Inspection

Document Request

cc w/encl: Distribution via LISTSERV

Signed by Gilliam, Jasmine

on 11/15/22

D. Rhoades -3-

Letter to David Rhoades from Jasmine Gilliam dated November 15, 2022.

SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - INFORMATION

REQUEST FOR THE CYBER-SECURITY BASELINE INSPECTION,

NOTIFICATION TO PERFORM INSPECTION 05000237/2023401;

05000249/2023401

DISTRIBUTION:

Jessie Quichocho

Marc Ferdas

RidsNrrDorlLpl3

RidsNrrPMDresden Resource

RidsNrrDroIrib Resource

John Giessner

Julio Lara

Diana Betancourt-Roldan

Allan Barker

R3-DORS

ADAMS Accession Number: ML22318A184

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

OFFICE RIII

NAME JGilliam:sw

DATE 11/15/2022

OFFICIAL RECORD COPY

DRESDEN CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Inspection Report: 05000237/2023401; 05000249/2023401

Inspection Dates: March 13-17, 2023

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

NRC Inspectors:Jasmine Gilliam, Lead Alan Dahbur

630-829-9831 630-829-9810

Jasmine.Gilliam@nrc.gov Alan.Dahbur@nrc.gov

NRC Contractors: Casey Priester Steven Leigh

Frederick.Priester@nrc.gov Steven.Leigh@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 January 10, 2023, 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 January 18, 2023, 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

February 22, 2023.

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

inspector by January 10, 2023. 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

DRESDEN CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table RFI #1

Request: IP Ref

A list of all Identified CSs/CDAs-highlight/note any additions,

1 deletions, reclassifications due to new guidance from white papers, Overall

changes to NEI 10-04, 13-10, etc., since the last cyber-security

inspection

2 A list of Emergency Preparedness and Security onsite and offsite Overall

digital communication systems

3 Network Topology Diagrams to include information and data flow for Overall

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, 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)

11 Portable Media and Mobile Device control documentation, including 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

Supply Chain Management documentation including any security 03.03(a),

13 impact analysis for new acquisitions (b) and

(c)

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DRESDEN CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Configuration Management documentation including any security 03.03(a)

14 impact analysis performed due to configuration changes since the last and (b)

inspection

15 Cyber-Security Plan and any 50.54(p) analysis to support changes to 03.04(a)

the 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 Overall

access authorization program since the last cyber-security inspection

18 Provide a list of all procedures and policies provided to the NRC with 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 January 18, 2023, 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 January 18, 2023, 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

February 22, 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.

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DRESDEN CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table RFI #2

Request Items

For the system(s) chosen for inspection provide:

1 Ongoing Monitoring and Assessment activity performed on the 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 intra-security level firewalls and boundary devices used to protect 03.02(c)

the selected system(s)

6 Copies of all periodic reviews of the access authorization list for the 03.02(d)

selected systems since the last inspection

7 Baseline configuration data sheets for the selected CDAs 03.03(a)

8 Documentation on any changes, including Security Impact Analyses, 03.03(b)

performed on the selected system(s) since the last inspection

9 Copies of the purchase order documentation for any new equipment 03.03(c)

purchased for the selected systems since the last inspection

10 Copies of any cyber-security drills performed since the last 03.02(a)

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

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DRESDEN 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 March 13, 2023, the first day

of the inspection.

Table 1ST Week Onsite

Request: 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 as a result of

2 cyber-security incidents/issues, to include previous NRC violations 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) generated as a result of the most recent Cyber-Security

QA audit and/or self-assessment.

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DRESDEN 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.

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