ML24200A106

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Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection 05000336/2024403 and 05000423/2024403
ML24200A106
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 07/22/2024
From: Glenn Dentel
NRC/RGN-I/DORS
To: Carr E
Dominion Energy
References
IR 2024403
Download: ML24200A106 (1)


See also: IR 05000336/2024403

Text

July 22, 2024

Eric S. Carr

President - Nuclear Operations

and Chief Nuclear Officer

Dominion Energy, Inc.

Innsbrook Technical Center

5000 Dominion Blvd.

Glen Allen, VA 23060-6711

SUBJECT:

MILLSTONE POWER STATION, UNITS 2 AND 3 - INFORMATION REQUEST

FOR THE CYBERSECURITY BASELINE INSPECTION, NOTIFICATION TO

PERFORM INSPECTION 05000336/2024403 AND 05000423/2024403

Dear Eric Carr:

On December 9, 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 Millstone Power Station, Units 2 and 3. 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 December 9-13, 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 September 9, 2024. The inspection team will review this information and, by October 4,

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

November 8, 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, December 9, 2024.

E. Carr

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 Brandon Pinson. We understand that our regulatory

contact for this inspection is Daniel C. Beachy of your organization. If there are any questions

about the inspection or the material requested, please contact the lead inspector at (610) 337-

5091 or via email at Brandon.Pinson@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. 05000336 and 05000423

License Nos. DPR-65 and NPF-49

Enclosure:

Cybersecurity Inspection Document Request

cc: Distribution via ListServ

Glenn T.

Dentel

Digitally signed by Glenn

T. Dentel

Date: 2024.07.22

07:23:27 -04'00'

ML24200A106

SUNSI Review

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available

OFFICE RI/DORS

RI/DORS

NAME

BPinson

GDentel

DATE

7/17/2024

7/18/2024

MILLSTONE POWER STATION, UNITS 2 AND 3

CYBERSECURITY INSPECTION DOCUMENT REQUEST

Enclosure

Inspection Report: 05000336/2024403, 05000423/2024403

Inspection Dates:

December 9, 2024 to December 13, 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:

Brandon Pinson, Lead

Louis Dumont

(610) 337-5091

(610) 337-5183

Brandon.Pinson@nrc.gov

Louis.Dumont@nrc.gov

Louis Manning

(610) 337-5044

Louis.Manning@nrc.gov

NRC Contractors:

Alan Konkal

(301) 287-3603

Alan.Konkal@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

September 9, 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 October 4, 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

November 8, 2024.

MILLSTONE POWER STATION, UNITS 2 AND 3

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 September 9, 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, including any security impact

analysis for new acquisitions

03.03(a),

(b) and

(c)

14

Configuration Management program documentation, including any security

impact analysis performed due to configuration changes since the last

inspection

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

MILLSTONE POWER STATION, UNITS 2 AND 3

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 initiated, 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 October 4, 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 October 4, 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 November 8,

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)

MILLSTONE POWER STATION, UNITS 2 AND 3

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/modifications, 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 December 9, 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

MILLSTONE POWER STATION, UNITS 2 AND 3

CYBERSECURITY INSPECTION DOCUMENT REQUEST

5

In addition to the above information please provide the following:

(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.