ML24071A212

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

ML24071A212
Person / Time
Site:	LaSalle
Issue date:	03/12/2024
From:	Alan Dahbur NRC/RGN-III/DORS/EB2
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
Download: ML24071A212 (1)

Text

David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer (CNO)

Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

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

Dear David Rhoades:

On July 22, 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 LaSalle County Station Units 1 and 2. The inspection will be performed to evaluate and verify that the LaSalle County 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 June 10-14, 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 May 10, 2024. The inspection team will review this information and, by May 31, 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 July 5, 2024, as identified above.March 12, 2024 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, July 22, 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 Jereme Greenblott from 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, Alan Dahbur, Senior Reactor Inspector Engineering Branch 2 Division of Operating Reactor Safety Docket Nos. 05000373 and 05000374 License Nos. NPF-11 and NPF-18

Enclosure:

LaSalle County Station Cyber-Security Inspection Document Request cc w/encl: Distribution via LISTSERV Signed by Dahbur, Alan on 03/12/24

D. Rhoades 3

Letter to David P. Rhoades from Alan Dahbur dated March 12, 2024.

SUBJECT:

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

DISTRIBUTION:

Farrah Gaskins RidsNrrDorlLpl3 RidsNrrPMLaSalle Resource RidsNrrDroIrib Resource John Giessner Mohammed Shuaibi Diana Betancourt-Roldan Allan Barker David Curtis Jefferson Clark R3-DORS SOSBInspRptDistro@usnrc.onmicrosoft.com

ADAMS Accession Number: ML24071A212 Publicly Available Non-Publicly Available Sensitive Non-Sensitive OFFICE RIII RIII RIII RIII

NAME ADahbur:gmp

DATE 03/12/2024

OFFICIAL RECORD COPY LASALLE COUNTY STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Inspection Report: 05000373/2024402 AND 05000374/2024402

Inspection Dates: July 22-26, 2024

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

NRC Inspectors:Benny Jose Alan Dahbur, Lead 630-829-9756 630-829-9810 Benny.Jose@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 May 10, 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 May 31, 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 July 5, 2024.

The required Table RFI 1 information shall be provided electronically to the lead inspector by May 10, 2024. If a compact disk (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 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.

Enclosure LASALLE COUNTY STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table RFI #1

Request: IP Ref

A list of all Identified Critical Systems and Critical Digital 1 Assets,- highlight/note any . additions, deletions, reclassifications due Overall to new guidance from white papers, changes to NEI 10-04, 13-10, etc. since the last cyber security 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 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 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)

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)

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

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Table RFI #1

Request: IP Ref 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 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 May 31, 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 May 31, 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 July 5, 2024. If a compact disk (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 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. If you have any questions regarding this information, please call the inspection team leader as soon as possible.

3 LASALLE COUNTY STATION 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

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 1 ST Week Onsite) electronically by July 22, 2024, 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. 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; and

g. Latest IPE/PRA Report.

(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.

5 (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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