ML23297A235

Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection

ML23297A235
Person / Time
Site:	Byron
Issue date:	10/26/2023
From:	Alan Dahbur NRC/RGN-III/DORS/EB2
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
Download: ML23297A235 (1)

Text

October 26, 2023 David Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer (CNO)

Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

BYRON STATION - INFORMATION REQUEST FOR THE CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM INSPECTION

Dear David Rhoades:

On February 26, 2024, 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 Byron Station. The inspection will be performed to evaluate and verify that the Byron Stations 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 February 26-March 1, 2024.

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 15, 2023. The inspection team will review this information and, by January 5, 2024, 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 February 16, 2022, as identified above.

D. Rhoades 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, February 26, 2024.

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

Sincerely, Signed by Dahbur, Alan on 10/26/23 Alan Dahbur, Senior Reactor Inspector Engineering Branch 2 Division of Operating Reactor Safety Docket Nos. 05000454 and 05000455 License Nos. NPF-37 and NPF-66

Enclosure:

Byron Station Cyber-Security Inspection Document Request cc w/encl: Distribution via LISTSERV

ML23297A235 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE RIII NAME ADahbur:sw DATE 10/26/2023 Inspection Report: 05000454/2024002 AND 05000455/2024002 Inspection Dates: February 26-March 1, 2024 Inspection Procedure: IP 71130.10, Cyber-Security, Revision 0 NRC Inspectors: Jasmine Gilliam Alan Dahbur, Lead 630-829-9831 630-829-9810 Jasmine.Gilliam@nrc.gov Alan.Dahbur@nrc.gov NRC Contractors: TBD 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 December 15, 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 5, 2024, 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 16, 2024.

The required Table RFI 1 information shall be provided electronically to the lead inspector by December 15, 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

Table RFI #1 Request: IP Ref A list of all Identified Critical Systems and Critical Digital Assets - highlight/note any: additions, deletions, reclassifications due 1 Overall to new 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 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)

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)

Configuration Management documentation including any security 03.03(a) 14 impact analysis performed due to configuration changes since the last and (b) inspection Cyber Security Plan and any 50.54(p) analysis to support changes to 15 03.04(a) the plan since the last inspection 2

Table RFI #1 Request: IP Ref 03.06 16 Cyber Security Metrics tracked (if applicable)

(b)

Provide documentation describing any cyber security changes to the 17 Overall access authorization program since the last cyber security inspection Provide a list of all procedures and policies provided to the NRC with 18 Overall their descriptive name and associated number (if available) 03.06 19 Performance testing report (if applicable)

(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 (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 5, 2024, 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 5, 2024, 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 16, 2024. 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.

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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 intra-security level firewalls and boundary devices used to protect 03.02(c) the selected system(s)

Copies of all periodic reviews of the access authorization list for the 6 03.02(d) selected systems since the last 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 system(s) 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 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 were executed 03.04(b)

Corrective actions taken as a result of cyber security incidents/issues 12 to include previous NRC violations and Licensee Identified Violations 03.04(d) since the last cyber security inspection 4

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 February 26, 2024, 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 and 2 03.04(d)

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, 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.

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.

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(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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