ML25014A193
| ML25014A193 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 01/16/2025 |
| From: | Glenn Dentel Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2025403 | |
| Download: ML25014A193 (1) | |
See also: IR 05000220/2025403
Text
January 16, 2025
David P. Rhoades
Senior Vice President
Constellation Energy Generation, LLC
President and Chief Nuclear Officer (CNO)
Constellation Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:
NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 - INFORMATION
REQUEST FOR THE CYBER SECURITY BASELINE INSPECTION,
NOTIFICATION TO PERFORM INSPECTION 05000220/2025403 AND
Dear David Rhoades:
On May 19, 2025, 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 Nine Mile Point Nuclear Station, Units 1 and 2. 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 May 19-23, 2025.
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 February 28, 2025. The inspection team will review this information and, by
March 21, 2025, 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 April 21, 2025, as identified above.
D. Rhoades
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, May 19, 2025.
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 Matt Rossi 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. 05000220 and 05000410
License Nos. DPR-63 and NPF-69
Enclosure:
Cybersecurity Inspection Document Request
cc: Distribution via ListServ
Glenn T.
Dentel
Digitally signed by Glenn
T. Dentel
Date: 2025.01.16
07:36:03 -05'00'
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE RI/DORS
RI/DORS
NAME
BPinson
GDentel
DATE
1/14/2025
1/14/2025
NINE MILE POINT NUCLEAR STATION CYBERSECURITY INSPECTION DOCUMENT
REQUEST
Inspection Report: 05000220/2025403 and 05000410/2025403
Inspection Dates:
May 19, 2025 to May 23, 2025
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:
En De Chen
(610) 337-5091
(610) 337-5136
Brandon.Pinson@nrc.gov
En.Chen@nrc.gov
NRC Contractors:
Two contractors TBD
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
February 28, 2025, 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 March 21, 2025, 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
April 21, 2025.
Enclosure
NINE MILE POINT NUCLEAR STATION
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 February 28, 2025. 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 and
the most recent cybersecurity Quality Assurance audit/assessment. Please
include any condition reports (or similar) generated as a result of the
audits/assessments
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. Please notate/highlight which design
changes affected Critical Digital Assets (added, modified, deleted, etc.)
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)
NINE MILE POINT NUCLEAR STATION
CYBERSECURITY INSPECTION DOCUMENT REQUEST
3
Table RFI #1
Section 3,
Paragraph Number / Title:
IP Ref
17
Provide documentation describing any cybersecurity changes to the access
authorization program since the last cybersecurity inspection
Overall
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 March 21, 2025, for the
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 March 21, 2025, 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 April 21, 2025.
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)
NINE MILE POINT NUCLEAR STATION
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
Please provide the following information to the team by May 19, 2025, the first day of the
inspection.
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
NINE MILE POINT NUCLEAR STATION
CYBERSECURITY INSPECTION DOCUMENT REQUEST
5
In addition to the above information please make the following information available to
the team. 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.
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.