ML23118A361
| ML23118A361 | |
| Person / Time | |
|---|---|
| Site: | Fermi  (NPF-043) |
| Issue date: | 05/01/2023 |
| From: | Alan Dahbur NRC/RGN-III/DORS/EB2 |
| To: | Peter Dietrich DTE Electric Company |
| References | |
| IR 2023402 | |
| Download: ML23118A361 (1) | |
See also: IR 05000341/2023402
Text
Senior VP and Chief Nuclear Officer
DTE Electric Company
Fermi 2 - 260 TAC
6400 North Dixie Highway
Newport, MI 48166
SUBJECT:
FERMI POWER PLANT, UNIT 2 - INFORMATION REQUEST FOR THE
CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000341/2023402
Dear Peter Dietrich:
On August 14, 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 Fermi Power Plant, Unit 2. The inspection will be performed to evaluate and verify that
the Fermi Power Plants 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),
Part 73, Section 54, Protection of Digital Computer and Communication Systems and
Networks, and the U.S. Nuclear Regulatory Commission (NRC) approved cybersecurity plan
(CSP). The onsite portion of the inspection will take place August 14-18, 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 June 16, 2023. The inspection team will review
this information and, by June 30, 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 CSP selected for the cyber-security inspection. This information
will be requested for review in the regional office prior to the inspection by July 28, 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, August 14, 2023.
May 1, 2023
P. Dietrich
-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 Alan Dahbur. We understand that our regulatory contact
for this inspection is Shane Gatter of your organization. If there are any questions about the
inspection or the material requested, please contact the lead inspector at 630-829-9810 or via
e-mail at Alan.dahbur@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
https://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
Alan Dahbur, Senior Reactor Inspector
Engineering Branch 2
Division of Operating Reactor Safety
Docket No. 05000341
License No. NPF-43
Enclosure:
Fermi Power Plant
Cyber-Security Inspection
Document Request
cc w/encl: Distribution via LISTSERV
Signed by Dahbur, Alan
on 05/01/23
P. Dietrich
-3-
Letter to Peter Dietrich from Alan Dahbur dated May 1, 2023.
SUBJECT:
FERMI POWER PLANT, UNIT 2 - INFORMATION REQUEST FOR THE
CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000341/2023402
DISTRIBUTION:
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ADAMS Accession Number: ML23118A361
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
NAME
ADahbur:sw
DATE
05/01/2023
OFFICIAL RECORD COPY
FERMI CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Enclosure
Inspection Report: 05000341/2023402
Inspection Dates:
August 14-18, 2023
Inspection Procedure:
IP 71130.10, Cyber-Security, Revision 0
NRC Inspectors:
630-829-9843
630-829-9810
Ijaz.Hafeez@nrc.gov
Alan.Dahbur@nrc.gov
NRC Contractors:
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 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 June 16, 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 June 30, 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
July 28, 2023.
The required Table RFI 1 information shall be provided electronically to the lead
inspector by June 16, 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.
FERMI CYBER-SECURITY INSPECTION DOCUMENT REQUEST
2
Table RFI #1
Request:
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)
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
design changes that affected CDAs that have been installed and
completed since the last cyber security inspection, including either a
summary of the design change or the 50.59 documentation of the
change
03.03(a)
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)
FERMI CYBER-SECURITY INSPECTION DOCUMENT REQUEST
3
Table RFI #1
Request:
IP Ref
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)
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; 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 June 30, 2023, for the
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 June 30, 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
July 28, 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. If you have any questions regarding this information, please
call the inspection team leader as soon as possible.
FERMI CYBER-SECURITY INSPECTION DOCUMENT REQUEST
4
Table RFI #2
Request
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)
5
Documentation (including configuration files and rule sets) for
intrasecurity 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 cyber-security drills performed since the last
inspection, along with any reports or assessments generated
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)
5
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 August 14, 2023, the first
day of the inspection.
Table 1ST Week Onsite
Request:
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)
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, Assessment 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.
FERMI CYBER-SECURITY INSPECTION DOCUMENT REQUEST
6
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.