IR 05000244/2024402
| ML24172A002 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 06/20/2024 |
| From: | Glenn Dentel NRC/RGN-I/DORS |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2024402 | |
| Download: ML24172A002 (1) | |
Text
June 20, 2024
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 Cyber security, 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 Cyber security 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 cyber security 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. 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 SUBJECT: R.E. GINNA NUCLEAR POWER PLANT - INFORMATION REQUEST FOR THE CYBERSECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM INSPECTION 05000244/2024402, DATED JUNE 20, 2024
DISTRIBUTION:
LDumont, DORS GDentel, DORS ECarfang, DORS EEve, DORS KSmetana, DORS CSwisher, DORS, SRI ACass, DORS, AA MSimmons, RI OEDO RidsNrrPMREGinna Resource RidsNrrDorlLpl1 Resource
DOCUMENT NAME: https://usnrc.sharepoint.com/teams/EngineeringBranch2/Shared Documents/_Cyber Security/_Baseline Inspections - OUO_SRI/2024/Ginna/RFI/Ginna Cybersecurity RFI 1.docx ADAMS ACCESSION NUMBER: ML24172A002 SUNSI Review n -Sensitive Publvlle Sensitive n -Publiclyvlable
OFFICE / /
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R.E. GINNA NUCLEAR POWER PLANT CYBERSECURITY INSPECTION DOCUMENT REQUEST
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, Cyber security (ML21330A088)
NRC Inspectors: Louis Dumont, Lead Brandon Pinson (610) 337-5 183 (610) 337-5 091 Louis.Dumont@nrc.gov Brandon.Pinson@nrc.gov
Louis Manning (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.
Enclosure R.E. Ginna Nuclear Power Plant CYBERSECURITY INSPECTION DOCUMENT REQUEST
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 A list of all Identified Critical Systems and Critical Digital Assets -
1 highlight/note any additions, deletions, or reclassifications due to new Overall guidance from white papers, changes to NEI 10-04, 13-10, etc. since the last cybersecurity inspection 2 A list of emergency preparedness and Security onsite and offsite digital Overall communication 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)
Cybersecurity incident response documentation, including incident detection, response, and recovery documentation as well as contingency 03.02(a)
7 plan development and implementation, including any program and documentation that requires testing of security boundary device 03.04(b)
functionality 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, 03.02(e)
including kiosk security control assessment / documentation Design change/modification program documentation and a list of all design 12 changes completed ( field complete) since the last cybersecurity inspection, 03.03(a)
including either a summary of the design change or the 50.59 documentation for the change 03.03(a),
13 Supply Chain Management documentation (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 03.04(a)
plan since the last inspection 16 Cybersecurity Metrics tracked (if applicable) 03.06 (b)
17 Provide documentation describing any cybersecurity changes to the access Overall authorization program since the last cybersecurity inspection
R.E. Ginna Nuclear Power Plant CYBERSECURITY INSPECTION DOCUMENT REQUEST
Table RFI #1 Section 3, Paragraph Number / Title: IP Ref Provide a list of all procedures and policies provided to the NRC as part of 18 this RFI with their descriptive name and associated procedure number (if Overall available)
19 Performance testing report (if applicable) 03.06 (a)
List of Condition Reports (or similar) associated with cybersecurity issues 20 written since the last inspection. Please include CR #, date written, and a Overall short description / title
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 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 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
Table RFI #2 Section 3, Paragraph Number/Title: Items All vulnerability screenings/assessments associated with, or scans 3 performed on the selected system(s) since the last cybersecurity 03.01(c)
inspection Documentation (including configuration files and rules sets) for Network-4 based Intrusion Detection/Protection Systems (NIDS/NIPS), Host-based 03.02(b)
Intrusion Detection Systems (HIDS), and Security Information and Event Management (SIEM) systems for system(s) chosen for inspection Documentation (including configuration files and rule sets) for intra-5 security level firewalls and boundary devices used to protect the selected 03.02(c)
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 10 Copies of any reports/assessment for cybersecurity drills performed since 03.02(a)
the last inspection 03.04(b)
11 Copy of the individual recovery plan(s) for the selected system(s) including 03.02(a)
documentation of the results the last time the backups were executed 03.04(b)
Corrective actions taken as a result of cybersecurity incidents/issues to 12 include previous NRC violations and Licensee Identified Violations since 03.05 the last cybersecurity inspection 13 For the selected systems, provide design change/modification packages 03.03(a)
including completed work orders since the last cybersecurity 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 1 ST Week Onsite) to the team by November 4, 202 4, 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 03.04(b)
73.77 since the last cybersecurity inspection Updated copies of corrective actions taken as a result of cybersecurity 2 incidents/issues, to include previous NRC violations and Licensee 03.05 Identified Violations since the last cybersecurity inspection, as well as vulnerability-related corrective actions
In addition to the above information please provide the following:
R.E. Ginna Nuclear Power Plant CYBERSECURITY INSPECTION DOCUMENT REQUEST
(1) Copies of the following documents do not need to b e 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/p robabilistic 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.
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