ML24233A137
| ML24233A137 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/26/2024 |
| From: | Daniel Bacon Division of Reactor Safety II |
| To: | Dean E Southern Nuclear Operating Co |
| References | |
| IR 2024402 | |
| Download: ML24233A137 (6) | |
See also: IR 05000348/2024402
Text
Edwin D. Dean
Site Vice President
Joseph M. Farley Nuclear Plant
Southern Nuclear Operating Co., Inc.
7388 North State Highway 95
Columbia, AL 36319-0470
SUBJECT: FARLEY NUCLEAR PLANT UNITS 1 & 2 - INFORMATION REQUEST FOR THE
CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000348/2024402 AND 05000364/2024402
Dear Edwin Dean:
On December 2, 2024, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
inspection in accordance with Inspection Procedure (IP) 71130.10 Cyber-Security, Revision 0,
at your Farley Nuclear Plant Units 1 & 2. 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 December 2, 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 cyber-security IP. This information should
be made available electronically no later than October 4, 2024. The inspection team will review
this information and, by October 18, 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 cyber-security
inspection. We request that the information provided from the second RFI be made available to
the regional office prior to the inspection by November 22, 2024.
August 26, 2024
E. Dean
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, December 2, 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 Mr. William Monk. We understand that our regulatory
contacts for this inspection are Mr. Gene Surber and Mr. Josh Champlin of your organization.
If there are any questions about the inspection or the material requested, please contact the
lead inspector at (404) 997-4579 or via e-mail at william.monk@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, Branch Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-348; 50-364
Enclosure:
Farley Nuclear Plant Units 1 & 2 Cyber-Security
Inspection Document Request
cc w/encl: Distribution via LISTSERV
Signed by Bacon, Daniel
on 08/26/24
X
SUNSI Review
X
Non-Sensitive
Sensitive
X
Publicly Available
Non-Publicly Available
OFFICE
RII/DRS
RII/DRS
RII/DRS
NAME
W. Monk
L. Jones
D. Bacon
DATE
08/20/24
08/20/24
08/26/24
FARLEY NUCLEAR PLANT UNITS 1 & 2
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Enclosure
Inspection Report: 05000280/2024-402 and 05000281/2024-402
Inspection Dates:
December 2 - 6, 2024
Inspection Procedure:
IP 71130.10, Cyber-Security, 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:
(404) 909-4579
(404) 997-4837
william.monk@nrc.gov
larry.jones@nrc.gov
NRC Contractors:
Trace Coleman
James Hartman
trace.coleman@nrc.gov
james.hartman@nrc.gov
I.
Information Requested for In-Office Preparation
The initial request for information (i.e., RFI #1) 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. RFI #1 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 cyber-security IP. RFI #1s requested information is specified below
in Table: RFI #1 and requested to be provided electronically to the inspection team by
October 4, 2024, or sooner, to facilitate the selection of the specific items that will be
reviewed during the onsite inspection week.
The inspection team will examine the returned documentation from RFI #1 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 18, 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
cyber-security inspection. We request that the additional information provided from RFI
- 2 be made available to the inspection team by November 22, 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.
FARLEY NUCLEAR PLANT UNITS 1 & 2
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
2
The required Table: RFI #1 information shall be provided electronically to the lead
inspector by October 4, 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.
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 cyber security inspection.
Overall
2
A list of EP 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 (OM&A) program documentation.
03.01(a)
5
The most recent effectiveness analysis and self-assessments of the
Cyber Security Program.
03.01(b)
6
Password/Authenticator program documentation.
03.02(c)
7
Design change / modification program documentation and a list of all
design changes completed since the last cyber security inspection,
including either a summary of the design change or the 50.59
documentation for the change.
03.03(a)
8
Supply Chain Management program documentation, including any
security impact analysis for new acquisitions.
03.03(a),
(b) and (c)
9
Cyber Security Plan and any 50.54(p) analysis to support changes to
the plan since the last cyber inspection.
03.04(a)
10
Cyber Security Performance Metrics tracked (if applicable).
03.06(b)
11 Provide a list of all cybersecurity procedures and policies with their
descriptive name and associated number.
Overall
12
Performance testing report (if applicable).
03.06(a)
13
Corrective actions taken as a result of cyber security incidents/issues to
include previous NRC violations and Licensee Identified Violations
since the last cyber security inspection.
03.05
FARLEY NUCLEAR PLANT UNITS 1 & 2
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
3
In addition to the above information, please provide the following:
(1) electronic copy of the UFSAR and sites technical specifications.
(2) name(s) and phone numbers for the regulatory and technical contacts.
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 18, 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 18, 2024, for the second RFI (i.e., RFI #2). RFI #2
will request additional information required to evaluate the CSs/CDAs, defensive
architecture, and the areas of the licensees CSP selected for the cyber-security
inspection. The additional information requested for the specific systems and equipment
is identified in Table: RFI #2 and requested information shall follow the guidance
document referenced above.
The Table: RFI #2 information shall be provided to the lead inspector by November
22, 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:
Items
For the Critical Systems / CDAs chosen for inspection provide:
1
Ongoing Monitoring and Assessment (OM&A) activity performed on
the selected inspection samples critical systems.
03.01(a)
2
All Security Control Assessments for the selected critical systems.
03.01(a)
3
All vulnerability screenings/assessments associated with, or scans
performed on the selected critical systems since the last cyber
security 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 the critical
systems chosen for inspection (i.e., the devices that are credited
for protection for the selected critical systems).
03.02(b)
FARLEY NUCLEAR PLANT UNITS 1 & 2
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
4
Table: RFI #2
Paragraph Number / Title:
Items
5
Documentation (including configuration files and rule sets) for intra-
security level firewalls and boundary devices used to protect the
selected critical systems.
03.02(c)
6
Copies of all periodic reviews of the access authorization (AA) list for
the selected critical systems since the last cyber inspection.
03.02(d)
7
Baseline configuration data sheets for the selected CDAs and for the
selected design changes.
03.03(a)
8
Documentation on any changes, including Security Impact Analyses,
performed on the selected critical systems 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/assessments for cyber security drills
performed since the last inspection.
03.02(a)
03.04(b)
11
Copy of the individual recovery plan(s) for the selected critical
systems including documentation of the results the last time the
backups were executed.
03.02(a)
03.04(b)
12
Vulnerability Management program screening and assessment
policies and procedures.
03.01(c)
13
Cyber Security 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 program documentation.
03.02(c)
15
User Account/Credential documentation.
03.02(d)
16
Portable Media and Mobile Device (PMMD) control documentation,
including kiosk security control assessment/documentation.
03.02(e)
17
Configuration Management documentation including any security
impact analysis (SIA) performed due to configuration changes since
the last cyber inspection.
03.03(a)
and (b)
FARLEY NUCLEAR PLANT UNITS 1 & 2
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
5
Table: RFI #2
Paragraph Number / Title:
Items
18
Provide documentation describing any cyber security changes to the
access authorization program (AAP) since the last cyber security
inspection.
Overall
19
The most recent Cybersecurity Quality Assurance audit and/or
self-assessment and a list of Corrective Actions generated as a
result.
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: Week Onsite) to the team by December 2, 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:
Items
1
Any cyber security event reports submitted in accordance with 10
CFR 73.77, since the last cyber security inspection.
03.04(a)
2
Updated copies of corrective actions taken as a result of cyber
security incidents/issues, to include previous NRC violations and
Licensee Identified Violations since the last cyber security
inspection, as well as vulnerability-related corrective actions.
03.05
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 access to them.
a.
Updated Final Safety Analysis Report (UFSAR), if not previously provided.
b.
Original SER and Supplements.
c.
FSAR Question and Answers.
d.
Quality Assurance (QA) Plan.
e.
Technical Specifications, if not previously provided.
f.
Latest IPE/PRA Report.
FARLEY NUCLEAR PLANT UNITS 1 & 2
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
6
(2) Vendor Manuals, Assessments and Corrective Actions:
a.
The most recent Cyber-Security Quality Assurance (QA) audit and/or
self-assessment.
b.
Corrective action documents (e.g., condition reports, including status of
corrective actions) generated 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 during daily de-brief meetings).
If you have any questions regarding the information requested, please contact the inspection
team leader.