ML24172A002
| ML24172A002 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 06/20/2024 |
| From: | Glenn Dentel Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2024402 | |
| Download: ML24172A002 (1) | |
See also: IR 05000244/2024402
Text
June 20, 2024
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:
R.E. GINNA NUCLEAR POWER PLANT - INFORMATION REQUEST FOR THE
CYBERSECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000244/2024402
Dear David Rhoades:
On November 4, 2024, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
inspection in accordance with Inspection Procedure (IP) 71130.10 Cybersecurity, dated
December 14, 2021, at R.E. Ginna Nuclear Power Plant. The inspection will be performed to
evaluate and verify your ability to meet the requirements of the NRCs Cybersecurity Rule,
Title 10 of the Code of Federal Regulations (10 CFR), Part 73, Section 54, Protection of Digital
Computer and Communication Systems and Networks. The onsite portions of the inspection
will take place from November 4-8, 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 IP 71130.10. This information should be
made available either on an online repository (preferred) or digital media (CD/DVD) no later
than July 26, 2024. The inspection team will review this information and, by August 30, 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 cybersecurity program selected for the cybersecurity inspection.
This information will be requested for review in the regional office prior to the inspection by
September 27, 2024, 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, November 4, 2024.
D. Rhoades
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. If any of the provided information changes between the time of submittal and the
inspection, please inform the inspection team lead.
The lead inspector for this inspection is Louis Dumont. We understand that our regulatory
contact for this inspection is Edward J. Fisher of your organization. If there are any questions
about the inspection or the material requested, please contact the lead inspector at (610) 337-
5183 or via email at Louis.Dumont@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 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,
Glenn T. Dentel, Chief
Engineering Branch 2
Division of Operating Reactor Safety
Docket Nos. 05000244
License Nos. DPR-18
Enclosure:
Cybersecurity Inspection Document Request
cc: Distribution via ListServ
Glenn T.
Dentel
Digitally signed by Glenn
T. Dentel
Date: 2024.06.20
08:14:13 -04'00'
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE RI/DORS
RI/DORS
NAME
LDumont
GDentel
DATE
6/18/2024
6/18/2024
R.E. GINNA NUCLEAR POWER PLANT
CYBERSECURITY INSPECTION DOCUMENT REQUEST
Enclosure
Inspection Report: 05000244/2024402
Inspection Dates:
November 4, 2024 to November 8, 2024
Inspection Procedure:
IP 71130.10, Cybersecurity, dated December 14, 2021
(ADAMS Accession Number: ML21271A106)
Reference:
Guidance Document for Development of the Request for
Information (RFI) and Notification Letter for IP 71130.10,
Cybersecurity (ML21330A088)
NRC Inspectors:
(610) 337-5183
(610) 337-5091
Louis.Dumont@nrc.gov
Brandon.Pinson@nrc.gov
(610) 337-5044
Louis.Manning@nrc.gov
NRC Contractors:
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
Cyber Security Program (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 security control portions of the CSP to
be chosen as the sample set required to be inspected by the cybersecurity inspection
procedure. 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
July 26, 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 August 30, 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
September 27, 2024.
R.E. Ginna Nuclear Power Plant
CYBERSECURITY INSPECTION DOCUMENT REQUEST
2
The required Table RFI 1 information shall be provided on an online repository
(preferred) or digital media (CD/DVD) to the lead inspector by July 26, 2024. The
preferred file format for all lists is a searchable Excel spreadsheet file. The information
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.
Table RFI #1
Section 3,
Paragraph Number / Title:
IP Ref
1
A list of all Identified Critical Systems and Critical Digital Assets -
highlight/note any additions, deletions, or reclassifications due to new
guidance from white papers, changes to NEI 10-04, 13-10, etc. since the last
cybersecurity inspection
Overall
2
A list of emergency preparedness 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
Cybersecurity incident response documentation, including incident
detection, response, and recovery documentation as well as contingency
plan development and implementation, 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 program documentation
03.02(c)
9
Password/Authenticator program documentation
03.02(c)
10
User Account/Credential program documentation
03.02(d)
11 Portable Media and Mobile Device control program documentation,
including kiosk security control assessment / documentation
03.02(e)
12
Design change/modification program documentation and a list of all design
changes completed (field complete) since the last cybersecurity inspection,
including either a summary of the design change or the 50.59
documentation for the change
03.03(a)
13
Supply Chain Management documentation
03.03(a),
(b) and
(c)
14
Configuration Management program documentation
03.03(a)
and (b)
15
Cyber Security Plan and any 50.54(p) analysis to support changes to the
plan since the last inspection
03.04(a)
16
Cybersecurity Metrics tracked (if applicable)
03.06 (b)
17
Provide documentation describing any cybersecurity changes to the access
authorization program since the last cybersecurity inspection
Overall
R.E. Ginna Nuclear Power Plant
CYBERSECURITY INSPECTION DOCUMENT REQUEST
3
Table RFI #1
Section 3,
Paragraph Number / Title:
IP Ref
18
Provide a list of all procedures and policies provided to the NRC as part of
this RFI with their descriptive name and associated procedure number (if
available)
Overall
19
Performance testing report (if applicable)
03.06 (a)
20
List of Condition Reports (or similar) associated with cybersecurity issues
written since the last inspection. Please include CR #, date written, and a
short description / title
Overall
In addition to the above information please provide the following:
(1) Electronic copy of the updated final safety analysis report 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 30, 2024, 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 30, 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.
The Table RFI 2 information shall be provided to the lead inspector by
September 27, 2024. The preferred file format for all lists is a searchable Excel
spreadsheet. The information 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.
Table RFI #2
Section 3,
Paragraph Number/Title:
Items
For the systems and CDAs 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 CDAs
03.01(a)
R.E. Ginna Nuclear Power Plant
CYBERSECURITY INSPECTION DOCUMENT REQUEST
4
Table RFI #2
Section 3,
Paragraph Number/Title:
Items
3
All vulnerability screenings/assessments associated with, or scans
performed on the selected system(s) since the last cybersecurity
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 intra-
security 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 reports/assessment for cybersecurity drills performed since
the last inspection
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 cybersecurity incidents/issues to
include previous NRC violations and Licensee Identified Violations since
the last cybersecurity inspection
03.05
13 For the selected systems, provide design change/modification packages
including completed work orders since the last cybersecurity inspection
03.03(a)
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) to the team by November 4, 2024, the first
day of the inspection.
Table 1ST Week Onsite
Section 3,
Paragraph Number/Title:
Items
1 Any cybersecurity event reports submitted in accordance with 10 CFR
73.77 since the last cybersecurity inspection
03.04(b)
2
Updated copies of corrective actions taken as a result of cybersecurity
incidents/issues, to include previous NRC violations and Licensee
Identified Violations since the last cybersecurity inspection, as well as
vulnerability-related corrective actions
03.05
In addition to the above information please provide the following:
R.E. Ginna Nuclear Power Plant
CYBERSECURITY INSPECTION DOCUMENT REQUEST
5
(1) Copies of the following documents do not need to be specifically 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 Cybersecurity Safety Evaluation Report and Supplements;
c. Quality Assurance (QA) Plan;
d. Technical Specifications, if not previously provided; and
e. Latest individual plant examination/probabilistic risk assessment report.
(2) Vendor Manuals, Assessment and Corrective Actions:
a. The most recent Cybersecurity 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 Cybersecurity 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).
If you have any questions regarding the information requested, please contact the inspection
team leader.