ML24204A243
| ML24204A243 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 07/23/2024 |
| From: | Sam Graves NRC/RGN-IV/DORS/EB2 |
| To: | Kapellas B Entergy Operations |
| Graves S | |
| References | |
| IR 2024403 | |
| Download: ML24204A243 (9) | |
See also: IR 05000416/2024403
Text
July 23, 2024
Brad Kapellas, Site Vice President
Entergy Operations, Inc.
Grand Gulf Nuclear Station
P.O. Box 756
Port Gibson, MS 39150
SUBJECT: GRAND GULF NUCLEAR STATION - NOTIFICATION OF CYBERSECURITY
BASELINE INSPECTION AND REQUEST FOR INFORMATION
Dear Brad Kapellas:
On November 18, 2024, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
inspection in accordance with Inspection Procedure (IP) 71130.10 Cybersecurity, at your
Grand Gulf Nuclear Station. The inspection will be performed to evaluate and verify your ability
to meet the requirements of the NRCs Cybersecurity Rule, Title 10, Code of Federal
Regulations (CFR), Part 73, Section 54, Protection of Digital Computer and Communication
Systems and Networks.
Experience has shown that baseline inspections are extremely resource intensive, both for the
NRC inspectors and 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 IP 71130.10. This information should be
made available either in an online repository (preferred) or digital media (CD/DVD) and
delivered/available to the regional office no later than August 30, 2024. The inspection team will
review this information and, by September 27, 2024, will request the specific items that should
be provided for review.
The second group of 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 your cybersecurity program selected for review. This information will be requested for review
in the regional office prior to the inspection by November 1, 2024, as identified above.
The third group of requested documents consists of additional 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 18, 2024.
B. Kappellas
2
The fourth group of information aids the inspection team in tracking issues identified during 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 requested documents are
up to date and complete 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 Sam Graves. We understand that our regulatory contact
for this inspection is Daniel Ryan of your organization. If there are any questions about the
inspection or the material requested, please contact the lead inspector at 817-200-1102 or via
e-mail at samuel.graves@nrc.gov.
Paperwork Reduction Act Statement
This letter contains mandatory information collections that are subject to the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)
approved these information collections under approval number 3150-0011. The burden to the
public for these information collections is estimated to average 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />(s) per response. Send
comments regarding this information collection to the FOIA, Library and Information Collection
Branch, Office of the Chief Information Officer, Mail Stop: T6-A10M, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001, or by email to Infocollects.Resource@nrc.gov, and
to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0011)
OMB, Washington, DC 20503.
Public Protection Notification
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,
Samuel T. Graves, Senior Reactor Inspector
Engineering Branch 2
Division of Operating Reactor Safety
Docket No. 05000416
License No. NPF-29
Signed by Graves, Samuel
on 07/23/24
B. Kappellas
3
Enclosure:
Grand Gulf Nuclear Station Cybersecurity Inspection Document Request
Distribution via LISTSERV
SUNSI Review:
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: STG
Yes No
Publicly Available
Sensitive
OFFICE
SRI:EB2/DORS
NAME
SGraves
SIGNATURE
STG2
DATE
07/23/24
Enclosure
GRAND GULF NUCLEAR STATION CYBERSECURITY INSPECTION DOCUMENT
REQUEST
Inspection Report: 05000416/2024403
Inspection Dates:
Week of November 18, 2024
Inspection Procedure:
IP 71130.10, CYBERSECURITY
Reference:
ML21330A088, Guidance Document for Development of the
Request for Information (RFI) and Notification Letter for IP
71130.10 Cyber Security Inspection, Revision 2
NRC Inspectors:
817-200-1102
817-200-1114
samuel.graves@nrc.gov
Nnaerika.okonkwo@nrc.gov
CSB Liaison:
Tim Marshall
timothy.marshall@nrc.gov
NRC Contractors:
Balla Barro
Michael Shock
Balla.barro@nrc.gov
Michael.shock@nrc.gov
I.
Information Requested for In-Office Preparation
This initial request for information (i.e., Table RFI #1) concentrates on providing the inspection
team with information necessary to select appropriate components and cybersecurity program
elements to develop a site-specific inspection plan. The first RFI is used to identify the critical
digital assets or systems 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.
Please provide the information requested in Table RFI #1 to the regional office by
August 30, 2024, or sooner, to facilitate the selection of the specific items for review.
The inspection team will examine the documentation from the first RFI and select specific
systems and equipment 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
September 27, 2024, which will be utilized to evaluate the equipment, defensive architecture,
and the areas of the licensees cybersecurity program for review.
2
Please provide the information requested by the second RFI to the regional office by
November 1, 2024. All requests for information shall follow the guidance document referenced
above. For information requests that have more than ten (10) documents, please provide a
compressed (i.e., Zip) file of the documents.
The required Table RFI #1 information shall be provided in an online document repository
(preferred) or on digital media (CD/DVD) to the lead inspector by August 30, 2024. The
preferred file format for all lists is a searchable Excel spreadsheet file. The media (CDs/DVDs)
should be indexed and hyper-linked to facilitate ease of use. If you have any questions
regarding this information, please contact the inspection team leader as soon as possible.
Table RFI #1
Section 3
Paragraph Number/Title:
IP Ref. Items
1
A list of all Identified Critical Systems and Critical Digital Assets, -
highlight/note any additions, deletions, 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 EP and Security onsite and offsite digital communication systems
(Provide EP asset list only if you have NOT reclassified items)
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, cybersecurity Quality Assurance
(QA) audit and self-assessments of the cybersecurity program
03.01(b)
6
Portable Media and Mobile Device control documentation, including kiosk
security control assessment/documentation
03.02(e)
7
Design change/modification program documentation and a list of all cyber-
related design changes completed since the last two cybersecurity
inspections, including either a summary describing the design change or the
50.59 documentation for the change.
03.03(a)
8
Supply Chain Management documentation including any security impact
analysis for new acquisitions
03.03(a), (b)
and (c)
9
Cybersecurity Plan and any 50.54(p) analysis to support changes to the plan
since the last inspection
03.04(a)
10
Cybersecurity Metrics tracked (if applicable)
03.06 (b)
3
11
Provide copies of all cybersecurity program related procedures and policies
with their descriptive name and associated number (if available)
Overall
12
Performance testing report (if applicable)
03.06 (a)
13
Corrective actions taken as a result of cybersecurity incidents/issues to
include previous NRC violations and licensee identified violations since
previous two cybersecurity inspections
03.05
In addition to the above information please provide the following:
(1)
Electronic copy of the UFSAR, technical specifications, and Operating Licenses.
(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 September 27, 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 September 27, 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 in an online document repository (preferred) or
on digital media (CD/DVD) to the lead inspector by November 1, 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
contact the inspection team leader as soon as possible.
Table RFI #2
Section 3
Paragraph Number/Title:
IP Ref.
Items
For the system(s) 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 system(s).
03.01(a)
4
Table RFI #2
Section 3
Paragraph Number/Title:
IP Ref.
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 or isolate 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 information 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)
and
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)
and
03.04(b)
12
Vulnerability screening/assessment and scan program documentation.
03.01(c)
13
Cybersecurity Incident response documentation, including incident
detection, response, and recovery documentation as well as contingency
plan development, implementation and including any program
documentation that requires testing of security boundary device
functionality.
03.02(a)
and
03.04(b)
14
Device Access and Key Control documentation.
03.02(c)
15
User Account/Credential documentation.
03.02(d)
16 Password/Authenticator documentation.
03.02(c)
17
Portable Media and Mobile Device control documentation, including kiosk
security control assessment/documentation.
03.02(e)
5
Table RFI #2
Section 3
Paragraph Number/Title:
IP Ref.
Items
18
Configuration Management documentation including any security impact
analysis performed due to configuration changes since the last inspection.
03.03(a)
and (b)
19
Provide documentation describing any cybersecurity changes to the access
authorization program since the last cybersecurity inspection.
Overall
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 - Onsite Week) to the team by November 18, 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 contact the inspection team leader as soon as possible.
Table - Onsite Week
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(a)
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.
03.04(d)
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 SER and Supplements related to cybersecurity;
c.
FSAR Question and Answers related to cybersecurity;
d.
Quality Assurance Plan;
e.
Technical Specifications, if not previously provided;
f.
Operating License(s), if not previously provided.
6
(2) Vendor Manuals, Assessments and Corrective Actions:
a.
Vendor/manufacturer manuals for the selected CDAs; 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.
(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.