ML25044A294
| ML25044A294 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 02/18/2025 |
| From: | Daniel Bacon NRC/RGN-II/DORS |
| To: | Coleman J Southern Nuclear Operating Co |
| References | |
| IR 2025403 | |
| Download: ML25044A294 (1) | |
See also: IR 05000321/2025403
Text
Jamie M. Coleman
Regulatory Affairs Director
Southern Nuclear Operating Co., Inc
3535 Colonnade Parkway, N 274.EC
Birmingham, AL 35243
SUBJECT: EDWIN I. HATCH NUCLEAR PLANTS UNITS 1 & 2 - INFORMATION REQUEST
FOR THE CYBERSECURITY BASELINE INSPECTION, NOTIFICATION TO
PERFORM INSPECTION 05000321/2025403; 05000366/2025403
Dear Jamie M. Coleman:
On May 12, 2025, 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 Edwin I. Hatch Nuclear Plant. 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 May 12, 2025.
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 March 21, 2025. The inspection team will review
this information and, by March 28, 2025, 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 May 2, 2025.
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 12, 2025.
February 18, 2025
J. Coleman
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 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 Mark Hunt 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,
Docket Nos. 50-321; 50-366
Enclosure:
Daniel Bacon, Branch Chief
Engineering Branch 2
Division of Reactor Safety
Edwin I. Hatch Nuclear Plant Cybersecurity Inspection Document Request
cc w/encl: Distribution via LISTSERV
Signed by Bacon, Daniel
on 02/18/25
X
Review
X
Non-Sensitive
Sensitive
X
Publicly Available
Non-Publicly Available
OFFICE
RII/DORS
RII/DORS
NAME
P. Braaten
D. .Bacon
DATE
2/13/25
2/18/25
Inspection Report: 05000321/2025403; 05000366/2025403
Inspection Dates:
May 12 - 16, 2025
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:
404-997-4651
404-997-4579
philipp.braaten@nrc.gov
william.monk@nrc.gov
NRC Contractors:
James Hartman
Justin Bowden
james.hartman@nrc.gov
justin.bowden@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 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 March 21, 2025, or sooner, to facilitate
the selection of the specific items that will be reviewed during the onsite inspection
weeks.
Enclosure
2
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 28, 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 May 5,
2025. 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 Mar 21, 2025. 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 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)
3
Table RFI #1
Paragraph Number/Title:
IP Ref
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)
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 28, 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 28, 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. All requested information shall follow the
guidance document referenced above.
The Table RFI 2 information shall be provided to the lead inspector by May 5, 2025. 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.
4
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
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
5
Table RFI #2
Paragraph Number/Title:
IP Ref
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)
- Some selected systems may have a large number of 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 May 12, 2025, 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).