ML23178A001
| ML23178A001 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 06/27/2023 |
| From: | Daniel Bacon Division of Reactor Safety II |
| To: | Dean S Southern Nuclear Operating Co |
| References | |
| IR 2023403 | |
| Download: ML23178A001 (1) | |
See also: IR 05000321/2023403
Text
June 27, 2023
Sonny Dean
Site Vice President
Southern Nuclear Operating Co., Inc.
Edwin I. Hatch Nuclear Plant
11028 Hatch Parkway North
Baxley, GA 31513
SUBJECT: EDWIN I. HATCH NUCLEAR PLANT UNITS 1 & 2 - INFORMATION REQUEST
FOR THE CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO
PERFORM INSPECTION 05000321/2023403 AND 05000366/2023403
Dear Sonny Dean:
On October 02, 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 Hatch Nuclear Plant Units 1 & 2. The inspection will be performed to evaluate and verify
your ability to provide assurance that your digital computer and communication systems and
networks associated with safety, security, or emergency preparedness (SSEP) functions are
adequately protected against cyber-attacks in accordance with Title 10 of the Code of Federal
Regulations (10 CFR) 73.54 and the U.S. Nuclear Regulatory Commission (NRC) approved
cyber security plan (CSP). The onsite portion of the inspection will take place during the week
of October 02, 2023.
Experience has shown that baseline inspections are extremely resource intensive, both for the
NRC inspectors and the 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 electronically no later than July 28, 2023. The inspection team will review
this information and, by August 4, 2023, will request the specific items that should be provided
for review. This 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. We
request that the information provided from the second RFI be made available to the regional
office prior to the inspection by September 8, 2023.
S. Dean 2
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, October 02, 2023.
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 William Monk. We understand that our regulatory
contacts for this inspection are Scott Junkin and Jimmy Collins, Licensing Managers of your
organization. If there are any questions about the inspection or the material requested, please
contact the lead inspector at (404) 997-4579 or via e-mail at william.monk@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 Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
Signed by Bacon, Daniel
on 06/27/23
Daniel Bacon, Branch Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-321; 50-366
Enclosure:
Edwin I. Hatch Nuclear Plant Units 1 & 2 Cyber-Security Inspection Document Request
cc w/encl: Distribution via LISTSERV
X Non-Sensitive X Publicly Available
X SUNSI Review
Sensitive Non-Publicly Available
OFFICE RII/DRS RII/DRS RII/DRS
NAME W. Monk J. Montgomery D. Bacon
DATE 06/272023 06/272023 06/27/2023
H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Inspection Report: 05000321/2023-403 and 05000366/2023-403
Inspection Dates: October 02 - 06, 2023
Inspection Procedure: IP 71130.10, Cyber-Security, Revision 0 (Effective: 01/01/2022)
Reference: Guidance Document for Development of the Request for
Information (RFI) and Notification Letter for Full-Implementation of
the Cyber-Security Inspection, Rev. 2 (Issued: 11/22/2021)
NRC Inspectors: William Monk, Lead Jonathan Montgomery
404-909-4579 404-997-4880
william.monk@nrc.gov jonathan.montgomery@nrc.gov
NRC Contractors: Al Konkal Michael Shock
561-989-0210 301-415-7000
alan.konkal@nrc.gov michael.shock@nrc.gov
I. Information Requested for In-Office Preparation
The initial request for information (i.e., RFI #1) 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. RFI #1 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. RFI #1s requested information is specified below
in Table: RFI #1 and requested to be provided electronically to the inspection team by
July 28, 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 RFI #1 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 August 4, 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 RFI
- 2 be made available to the inspection team by September 8, 2023. All requests for
information shall follow the guidance document U.S. NRC - Guidance Document for
Development of the Request for Information (RFI) and Notification Letter for Full
Implementation of the Cyber-Security Inspection, referenced above.
Enclosure
H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
The required Table: RFI #1 information shall be provided electronically to the lead
inspector by July 28, 2023. The preferred file format for all lists is a searchable Excel
spreadsheet file. The information 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
Paragraph Number/Title: IP Ref
A list of all identified Critical Systems and Critical Digital Assets -
highlight/note any additions, deletions, reclassifications due to new
1 Overall
guidance from white papers, changes to NEI 10-04, 13-10, etc. since
the last cyber security inspection.
A list of EP and Security onsite and offsite digital communication
2 Overall
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 (OM&A) program documentation. 03.01(a)
The most recent effectiveness analysis and self-assessments of the
5 03.01(b)
Cyber Security Program.
6 Password/Authenticator program documentation. 03.02(c)
Design change/ modification program documentation and a list, with
descriptions, of all design changes that affected CDAs that have
7 actually been installed and completed since the last two cyber security 03.03(a)
inspections, including either a summary of the design change or the
50.59 documentation for the change.
Supply Chain Management program documentation, including any 03.03(a),
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security impact analysis for new acquisitions. (b) and (c)
Cyber Security Plan and any 50.54(p) analysis to support changes to
9 03.04(a)
the plan since the last cyber inspection.
10 Cyber Security Performance Metrics tracked (if applicable). 03.06(b)
Provide a list of all procedures and policies provided to the NRC with
11 Overall
their descriptive name and associated number (if available).
12 Performance testing report (if applicable). 03.06(a)
Corrective actions taken as a result of cyber security incidents/issues to
13 include previous NRC violations and Licensee Identified Violations
since two last cyber security inspections. 03.05
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H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
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.
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 August 4, 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 August 4, 2023, for the second RFI (i.e., RFI #2). RFI #2 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 and requested information shall follow the guidance
document referenced above.
The Table: RFI #2 information shall be provided to the lead inspector by September
8, 2023. The preferred file format for all lists is a searchable Excel spreadsheet. The
information 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
Paragraph Number/Title: Items
For the Critical Systems / CDAs chosen for inspection provide:
Ongoing Monitoring and Assessment activity performed on the
1 03.01(a)
selected inspection samples critical systems.
2 All Security Control Assessments for the selected critical systems. 03.01(a)
All vulnerability screenings/assessments associated with or scans
3 performed on the selected critical systems since the last cyber 03.01(c)
security inspection.
Documentation (including configuration files and rules sets) for
4 Network-based Intrusion Detection/Protection Systems (NIDS/NIPS), 03.02(b)
Host-based Intrusion Detection Systems (HIDS), and Security
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H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Table: RFI #2
Paragraph Number/Title: Items
Information and Event Management (SIEM) systems for the critical
systems chosen for inspection.
Documentation (including configuration files and rule sets) for intra-
5 security level firewalls and boundary devices used to protect the 03.02(c)
selected critical systems.
Copies of all periodic reviews of the access authorization (AA) list for
6 03.02(d)
the selected systems since the last cyber 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 critical systems 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 03.02(a)
10
since the last inspection. 03.04(b)
Copy of the individual recovery plan(s) for the selected critical 03.02(a)
11 systems including documentation of the results the last time the
backups were executed. 03.04(b)
Vulnerability screening/assessment and scan program
12 03.01(c)
documentation.
Cyber Security Incident Response documentation, including
incident detection, response, and recovery documentation as 03.02(a)
13 well as contingency plan development, implementation, and and
including any program documentation that requires testing of 03.04(b)
security boundary device functionality.
14 Device Access and Key Control program documentation. 03.02(c)
15 User Account/Credential documentation. 03.02(d)
Portable Media and Mobile Device (PMMD) control documentation,
16 03.02(e)
including kiosk security control assessment/documentation.
Configuration Management documentation including any security
03.03(a)
17 impact analysis performed due to configuration changes since the
and (b)
last cyber inspection.
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H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Table: RFI #2
Paragraph Number/Title: Items
Provide documentation describing any cyber security changes to the
18 access authorization program (AAP) since the last cyber security Overall
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: Week Onsite) to the team by October 02, 2023, the first day
of the inspection. All requested information shall follow the guidance document
referenced above.
The preferred file format for all lists is a searchable Excel spreadsheet file. The
information 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: Week Onsite
Paragraph Number/Title: Items
Any cyber security event reports submitted in accordance with 10
1 03.04(a)
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 03.05
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 (UFSAR), if not previously provided
b. Original FSAR Volumes
c. Original SER and Supplements
d. FSAR Question and Answers
e. Quality Assurance (QA) Plan
f. Technical Specifications, if not previously provided
g. Latest IPE/PRA Report
(2) Vendor Manuals, Assessment and Corrective Actions:
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H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
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) generated 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 during daily de-brief meetings).
If you have any questions regarding the information requested, please contact the inspection
team leader.
6