ML25056A334
| ML25056A334 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/26/2025 |
| From: | Greg Pick NRC/RGN-IV/DORS/EB2 |
| To: | Sullivan J Entergy Operations |
| References | |
| IR 2025401 | |
| Download: ML25056A334 (8) | |
See also: IR 05000382/2025401
Text
February 26, 2025
Joseph Sullivan, Site Vice President
Entergy Operations, Inc.
17265 River Road
Killona, LA 70057
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - INFORMATION REQUEST
FOR THE CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO
PERFORM INSPECTION 05000382/2025401
Dear Joseph Sullivan:
On July 7, 2025, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
inspection in accordance with Inspection Procedure (IP) 71130.10 Cybersecurity, at your
Waterford 3 facility. The inspection evaluates and verifies your ability to meet the requirements
of the NRCs Cyber-Security 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 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 inspection procedure. 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 March 31, 2025. The
inspection team will review this information and, by April 28, 2025, 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, defensive architecture, and the areas of your
cyber security program selected for review. This information is requested for review in the
regional office prior to the inspection by June 2, 2025, as identified above.
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, July 7, 2025.
J. Sullivan
2
The fourth group of information is necessary to aid the inspection team in tracking issues
identified during the inspection. Please provide this information to the lead inspector as the
information is generated during the inspection. It is important that all 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 Greg Pick. We understand that our regulatory contact
for this inspection is Ramon Peter of your organization. If there are any questions about the
inspection or the material requested, please contact the lead inspector at 817-504-2105 or via
e-mail at greg.pick@nrc.gov.
Paperwork Reduction Act Statement
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,
Greg Pick, Senior Reactor Inspector
Engineering Branch 2
Division of Operations and Reactor Safety
Docket No. 50-382
License No. NPF-38
Enclosure:
Waterford 3 - Cyber-Security Inspection Document Request
cc w/encl: Distribution via LISTSERV
Signed by Pick, Gregory
on 02/26/25
SUNSI Review:
ADAMS:
Non-Publicly Available
Non-Sensitive Keyword:
By: GAP Yes No
Publicly Available
Sensitive
OFFICE
SRI:DORS:EB2
NAME
GPick
SIGNATURE
/RA/
DATE
02/26/25
Enclosure
Inspection Report: 05000382/2025401
Inspection Dates:
Week of July 7, 2025
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:
Andrew Saunders
817-504-2105
817-200-1275
greg.pick@nrc.gov
andrew.saunders@nrc.gov
NRC Contractors:
Trace Coleman
Justin Bowden
trace.coleman@nrc.gov
justin.bowden@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 cyber
security 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 cyber-security inspection procedure. Please provide the
information requested in Table RFI #1 to the regional office by March 31, 2025, 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 April 28, which will be utilized to evaluate the equipment, defensive
architecture, and the areas of your cyber security program for review.
Please provide the information requested by the second RFI to the regional office by
June 2, 2025. All requests for information shall follow the referenced guidance
document. For information requests that have more than ten (10) documents, 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 March 31, 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.
2
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 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 program documentation
03.01(a)
5
The most recent effectiveness analysis and self-assessments of the Cyber
Security 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 cyber security
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
Cyber Security Plan and any 50.54(p) analysis to support changes to the
plan since the last inspection
03.04(a)
10
Cyber Security Metrics tracked (if applicable)
03.06 (b)
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 because of cyber security incidents/issues to
include previous NRC violations and Licensee Identified Violations since two
last cyber security inspections
03.05
3
In addition to the above information please provide the following:
(1)
Electronic copy of the UFSAR 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., critical systems/critical digital assets) from the information requested by
Table RFI #1 and submit a list of specific systems and equipment to your staff by April 28, 2025,
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 April 28, 2025, for the second RFI (i.e., RFI #2). The second
RFI will request additional information required to evaluate the critical systems and
critical digital assets, defensive architecture, and the areas of the cyber security program
selected for inspection. The additional information requested for the specific systems
and equipment is identified in Table RFI #2. All requested information shall follow the
referenced guidance document.
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 June 2, 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.
Table RFI #2
Section 3,
Paragraph Number/Title:
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)
3
All vulnerability screenings/assessments associated with, or scans
performed on the selected system(s) 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 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)
4
Table RFI #2
Section 3,
Paragraph Number/Title:
Items
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 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 system(s)
including documentation of the results the last time the backups were
executed.
03.02(a)
03.04(b)
12
Vulnerability screening/assessment and scan program documentation
03.01(c)
13
Cyber Security Incident response documentation, including incident
detection, response, and recovery documentation as well as contingency
plan development, implementation 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)
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 cyber security changes to the
access authorization program since the last cyber security inspection.
Overall
5
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 1ST Week Onsite) to the team by July 7, 2025, the first day of
the inspection. All requested information shall follow the referenced guidance document.
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 1ST Week Onsite
Section 3,
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 because 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
03.04(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 if 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;
(2) Vendor Manuals, Assessment and Corrective Actions:
a.
The most recent Cyber-Security Quality Assurance (QA) audit and/or
self-assessment; and
b.
Corrective action documents (e.g., condition reports, including status of
corrective actions) generated because of the most recent Cybersecurity
Quality Assurance (QA) audit and/or self-assessment.
6
IV.
Information Requested To Be Provided Throughout the Inspection
(1) Copies of any corrective action documents generated because 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.