ML24213A312
| ML24213A312 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 08/01/2024 |
| From: | Daniel Bacon NRC/RGN-II/DRS/EB2 |
| To: | Flippin N Duke Energy Carolinas |
| References | |
| IR 2024403 | |
| Download: ML24213A312 (9) | |
See also: IR 05000413/2024403
Text
Nicole Flippin
Site Vice President
Duke Energy Carolinas, LLC
Catawba Nuclear Station
4800 Concord Road
York, SC 29745
SUBJECT: CATAWBA NUCLEAR STATION - INFORMATION REQUEST FOR THE
CYBERSECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000413/2024403; 05000414/2024403
Dear Nicole Flippin:
On October 28, 2024, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
inspection in accordance with Inspection Procedure (IP) 71130.10 Cybersecurity, Revision 0 at
your Catawba Nuclear Station. The inspection will be performed to evaluate and verify your
ability to provide assurance that your digital computer and communication systems and
networks associated with safety, security, or emergency preparedness (SSEP) functions are
adequately protected against cyber-attacks in accordance with Title 10 of the Code of Federal
Regulations (10 CFR) 73.54 and the U.S. Nuclear Regulatory Commission (NRC) approved
cyber security plan (CSP). The onsite portion of the inspection will take place during the week of
October 28th, 2024.
Experience has shown that baseline inspections are extremely resource intensive, both for the
NRC inspectors and the licensee staff. 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 cybersecurity IP. This information should
be made available electronically no later than September 6, 2024. The inspection team will
review this information and, by September 13, 2024, will request the specific items that should
be provided for review. This 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 cybersecurity
inspection. We request that the information provided from the second RFI be made available to
the regional office prior to the inspection by October 18, 2024.
August 1, 2024
N. Flippin
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, October 28, 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 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 Philipp Braaten. We understand that our regulatory
contact for this inspection is Sherry Andrews of your organization. If there are any questions
about the inspection or the material requested, please contact the lead inspector at (404) 997-
4651 or via e-mail at Philipp.braaten@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 Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
Daniel Bacon, Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-413; 50-414
Enclosure
As stated:
cc w/encl: Distribution via LISTSERV
Signed by Bacon, Daniel
on 08/01/24
N. Flippin
3
SUBJECT: CATAWBA NUCLEAR STATION - INFORMATION REQUEST FOR THE
CYBERSECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000413/2024403; 05000414/2024403
DATED AUGUST 1, 2024
DISTRIBUTION:
P. Braaten, RII
M. Carothers, RII
D. Bacon, RII
E. Stamm, RII
P. Carman, RII
D. Jackson, RII
D. Rivard, RII
ADAMS ACCESSION NO ML24213A312
OFFICAL RECORD COPY
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE RII/DRS
RII/DRS
NAME
P.Bratten
D.Bacon
DATE
7/31/2024
8/1/2024
Enclosure
Inspection Report: 05000413/2024403; 05000414/2024403
Inspection Dates:
October 28 - November 01, 2024
Inspection Procedure:
IP 71130.10, Cybersecurity, Revision 0 (Effective: 01/01/2022)
Reference:
Guidance Document for Development of the Request for
Information (RFI) and Notification Letter for Full-Implementation of
the Cyber Security Inspection, Rev. 2 (Issued: 11/22/2021)
NRC Inspectors:
Matthew Carothers
404-997-4651
404-997-4806
philipp.braaten@nrc.gov
matthew.carothers@nrc.gov
NRC Contractors:
Al Konkal
Charles Simpson
alan.konkal@nrc.gov
charles.simpson@nrc.gov
2
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 cybersecurity 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 September 6, 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 September 13, 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 October
18, 2024. All requests for information shall follow the guidance document U.S. NRC -
Guidance Document for Development of the Request for Information (RFI) and
Notification Letter for Full Implementation of the Cyber Security Inspection, referenced
above.
The required Table RFI 1 information shall be provided electronically to the lead
inspector by September 6, 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 call the
inspection team leader as soon as possible.
3
Table RFI #1
Paragraph Number/Title:
IP Ref
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
Network Topology Diagrams to include information and data flow
for critical systems in levels 2, 3, and 4 (If available).
Overall
3
The most recent effectiveness analysis of the Cybersecurity
Program.
03.01(b)
4
Cybersecurity Incident Response program 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)
5
Design change/ modification program documentation and a list of
all design changes completed since the last cybersecurity
inspection, including either a summary of the design change or
the 50.59 documentation for the change.
03.03(a)
6
Configuration Management program documentation including a
list of security impact analysis performed due to configuration
changes since the last cybersecurity inspection.
03.03(a)
and (b)
7
Cyber Security Plan and any 50.54(p) analysis to support
changes to the plan since the last inspection.
03.04(a)
8
Cybersecurity Performance Metrics tracked (if applicable).
03.06(b)
9
Provide a list of all cybersecurity procedures and policies with
their descriptive name and associated number.
Overall
10
Performance testing report (if applicable).
03.06(a)
11
Any cybersecurity event reports submitted in accordance with 10
CFR 73.77 since the last cybersecurity inspection and any copies
of any recordable cybersecurity events since the last inspection
03.04(a)
4
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 13, 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 13, 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 to the lead inspector by October 18,
2024. The preferred file format for all lists is a searchable Excel spreadsheet. The
information 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.
Table RFI #2
Paragraph Number/Title:
IP Ref
For the system(s) chosen for inspection provide:
1
Ongoing Monitoring and Assessment activity performed on the
selected system(s).
03.01(a)
2
All Security Control Assessments for the selected design changes
and system(s).*
03.01(a)
3
Copy of vulnerability management program documentation.
All vulnerability screenings and assessments completed prior to
putting new equipment into service as part of the select design
changes.
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 (i.e. the devices that are credit for protection
for the selected systems). *
03.02(b)
5
Table RFI #2
Paragraph Number/Title:
IP Ref
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
Copy of access authorization program policy and procedures
(cyber).
03.02(d)
7
Baseline configuration data sheets for the selected CDAs and for
selected design changes. *
03.03(a)
8
Copies of the purchase order documentation for selected design
changes.
03.03(c)
9
Copies of the 2 most recent incident response drills.
Copies of the last 4 evaluations of plant events that were screened
for potential cybersecurity concerns (incident response entry criteria)
03.02(a)
03.04(b)
10
List 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.
03.05
11
The most recent Cybersecurity Quality Assurance audit and/or self-
assessment and a list of Corrective Actions generated as a result (if
different from request RFI 1-3)
12
Ongoing Monitoring and Assessment program documentation.
03.01(a)
13
Password/Authenticator program documentation.
03.02(c)
14
Supply Chain Management program policy and procedures
(cyber)
03.03(a)
, (b) and
(c)
6
- Some selected systems may have many CDAs. For these systems reach out to the team
leader for a specific selection of CDAs when responding to this request.
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 Week Onsite) to the team by October 28, 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 call the inspection team leader as soon as
possible.
Table Week Onsite
Paragraph Number/Title:
IP Ref
1
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
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.