IR 05000324/2024403
| ML24044A122 | |
| Person / Time | |
|---|---|
| Site: |  |
| Issue date: | 02/14/2024 |
| From: | Daniel Bacon NRC/RGN-II/DRS/EB2 |
| To: | Krakuszeski J Duke Energy Progress |
| References | |
| IR 2024403 | |
| Download: ML24044A122 (7) | |
Text
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT - INFORMATION REQUEST FOR THE CYBERSECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM INSPECTION 05000325/2024403; 05000324/2024403
Dear John Krakuszeski:
On May 6, 2024, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline inspection in accordance with Inspection Procedure (IP) 71130.10 Cybersecurity, Revision 0 at your Brunswick Steam Electric Plant. 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 May 6, 2024.
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 cybersecurity IP. This information should be made available electronically no later than March 22, 2024. The inspection team will review this information and, by March 29, 2024, 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 cybersecurity inspection. We request that the information provided from the second RFI be made available to the regional office prior to the inspection by April 26, 2024.
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, May 6, 2024.February 14, 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 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 Philipp Braaten. We understand that our regulatory contact for this inspection is Thomas Sherrill of your organization. If there are any questions about the inspection or the material requested, please contact the lead inspector at (404) 997-4651 or via e-mail at Philipp.braaten@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, Daniel Bacon, Branch Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 05000324; 05000325 License Nos. DPR-71; DPR-62 Enclosure:
Brunswick Steam Electric Plant Cybersecurity Inspection Document Request cc w/encl: Distribution via LISTSERV Signed by Bacon, Daniel on 02/14/24
ML24044A122 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available
OFFICE RII/DRP RII/DCO RIII/DRP RII/DRS RII/DRP NAME P. Braaten D. Bacon DATE 2/13/2024 2/14/2024
CYBERSECURITY INSPECTION DOCUMENT REQUEST
Inspection Report: 05000324/2024403; 05000325/2024403
Inspection Dates: May 6 - 10, 2024
Inspection Procedure: IP 71130.10, Cybersecurity, 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: Philipp Braaten, Lead 404-997-4651 philipp.braaten@nrc.gov
Jonathan Montgomery 404-997-4880 jonathan.montgomery@nrc.gov
NRC Contractors: Michael Shock michael.shock@nrc.gov
Justin Bowden justin.bowden@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 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 cybersecurity 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 March 22, 2024, 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 March 29, 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 cybersecurity inspection. We request that the additional information provided from the second RFI be made available to the regional office prior to the inspection by April 26, 2024. 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 The required Table RFI 1 information shall be provided electronically to the lead inspector by March 22, 2024. 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, -
1 highlight/note any additions, deletions, reclassifications due to Overall new guidance from white papers, changes to NEI 10-04, 13-10, etc. since the last cybersecurity inspection.
2 A list of EP and Security onsite and offsite digital communication Overall systems.
3 Network Topology Diagrams to include information and data flow Overall for 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 Cybersecurity 03.01(b)
Program.
Cybersecurity Incident Response program documentation, including incident detection, response, and recovery 03.02(a)
6 documentation as well as contingency plan development, and implementation, and including any program documentation that 03.04(b)
requires testing of security boundary device functionality.
7 Password/Authenticator program documentation. 03.02(c)
Design change/ modification program documentation and a list of 8 all design changes completed since the last cybersecurity 03.03(a)
inspection, including either a summary of the design change or the 50.59 documentation for the change.
Supply Chain Management program documentation including a 03.03(a),
9 list of security impact analysis for new acquisitions. (b) and (c)
Configuration Management program documentation including a 03.03(a)
10 list of security impact analysis performed due to configuration and (b)
changes since the last cybersecurity inspection.
11 Cyber Security Plan and any 50.54(p) analysis to support 03.04(a)
changes to the plan since the last inspection.
12 Cybersecurity Performance Metrics tracked (if applicable). 03.06(b)
13 Provide a list of all cybersecurity procedures and policies with Overall their descriptive name and associated number.
14 Performance testing report (if applicable). 03.06(a)
Any cybersecurity event reports submitted in accordance with 10 15 CFR 73.77 since the last cybersecurity inspection and any copies 03.04(a)
of any recordable cybersecurity events since the last inspection
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 March 29, 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 March 29, 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 cybersecurity inspection. The additional information requested for the specific systems and equipment is identified in Table RFI #2. All requested information shall follow the guidance document referenced above.
The Table RFI 2 information shall be provided to the lead inspector by April 26, 2024.
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 system(s) chosen for inspection provide:
1 Ongoing Monitoring and Assessment activity performed on the 03.01(a)
selected system(s).
2 All Security Control Assessments for the selected design changes 03.01(a)
and system(s).*
All vulnerability screenings/assessments associated with or scans performed on the selected system(s) since the last cybersecurity 3 inspection.* 03.01(c)
All vulnerability screenings and assessments completed prior to putting new equipment into service as part of the select design changes.
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 (i.e. the devices that are credit for protection for the selected systems). *
Documentation (including configuration files and rule sets) for intra-5 security level firewalls and boundary devices used to protect the 03.02(c)
selected system(s).
6 Copies of all periodic reviews of the access authorization list for the 03.02(d)
selected systems since the last cybersecurity inspection.
7 Baseline configuration data sheets for the selected CDAs and for 03.03(a)
selected design changes. *
8 Security impact analysis for the selected design changes. 03.03(b)
9 Copies of the purchase order documentation for selected design 03.03(c)
changes.
Table RFI #2 Paragraph Number/Title: Items 10 Copies of any reports/assessment for cybersecurity drills performed 03.02(a)
since the last inspection. 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.
List of Corrective actions taken as a result of cybersecurity 12 incidents/issues to include previous NRC violations and Licensee 03.05 Identified Violations since the last cybersecurity inspection.
13 Vulnerability Management program screening and assessment 03.01(c)
policies and procedures 14 The most recent Cybersecurity Quality Assurance audit and/or self-assessment and a list of Corrective Actions generated as a result
- Some selected systems may have a large number of CDAs. For these systems reach out to the team leader for a specific selection of CDAs when responding to this 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 Week Onsite) to the team by May 6, 2024, 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 Updated copies of corrective actions taken as a result of 1 cybersecurity incidents/issues, to include previous NRC violations 03.05 and Licensee Identified Violations since the last cybersecurity inspection, as well as vulnerability-related corrective actions.
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).
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