ML25113A182
| ML25113A182 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/24/2025 |
| From: | Daniel Bacon NRC/RGN-II/DORS/EB2 |
| To: | Snider S Duke Energy Carolinas |
| References | |
| IR 2025403 | |
| Download: ML25113A182 (1) | |
See also: IR 05000269/2025403
Text
Steven M. Snider
Site Vice President
Duke Energy Carolinas, LLC
Oconee Nuclear Station
7800 Rochester Highway
Seneca, SC 29672-0752
SUBJECT: OCONEE NUCLEAR STATION UNITS 1, 2, & 3 - INFORMATION REQUEST FOR
THE CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO
PERFORM INSPECTION 05000269/2025403, 05000270/2025403 AND
Dear Steven M. Snider:
On July 28, 2025, 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 Oconee Nuclear Station Units 1, 2, & 3. 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 July 28, 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 cyber-security IP. This information should
be made available electronically no later than June 6, 2025. The inspection team will review
this information and, by June 13, 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 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 July 18, 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, July 28, 2025.
April 24, 2025
S. Snider
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 Mr. William Monk. We understand that our regulatory
contacts for this inspection are Mrs. Laura Boyce and Mr. Adam Goodman 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 Operating Reactor Safety (DORS)
Docket Nos. 50-269; 50-270; 50-287
License Nos. DPR-38; DPR-47; DPR-55
Enclosure:
Oconee Nuclear Station Units 1, 2 & 3
Cyber-Security Inspection Document Request
cc w/encl: Distribution via LISTSERV
Signed by Bacon, Daniel
on 04/24/25
X
Review
X
Non-Sensitive
Sensitive
X
Publicly Available
Non-Publicly Available
OFFICE
RII/DORS
RII/DORS
RII/DORS
NAME
W. Monk
J. Alamudun
D. Bacon
DATE
04/23/2025
04/24/2025
04/24/2025
OCONEE NUCLEAR STATION UNITS 1, 2, & 3
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Enclosure
Inspection Report: 05000269/2025403, 05000270/2025403 AND 05000287/2025403
Inspection Dates:
July 28 - August 01, 2025
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:
Jimmy Alamudun
(404) 909-4579
(404) 997-4837
william.monk@nrc.gov
folajimi.alamudun@nrc.gov
NRC Contractors:
Al Konkal
Justin Bowden
alan.konkal@nrc.gov
justin.bowden@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 June 6, 2025, 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 2nd RFI. The inspection team will submit the specific systems and equipment list
to your staff by June 13, 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 cyber-security inspection. We request that the additional information
provided from RFI #2 be made available to the inspection team by July 18, 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.
OCONEE NUCLEAR STATION UNITS 1, 2, & 3
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
2
The required Table: RFI #1 information shall be provided electronically to the lead inspector by
June 6, 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 cyber security 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 and self-assessments of the
Cyber Security Program.
03.01(b)
4
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)
5
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)
6
Configuration Management documentation including any security impact
analysis (SIA) performed due to configuration changes since the last
cyber 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 cyber inspection.
03.04(a)
8
Provide a list of all cybersecurity procedures and policies with their
descriptive name and associated number.
Overall
9
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
10
Cyber Security Performance Metrics tracked (if applicable).
03.06(b)
11 Performance testing report (if applicable).
03.06(a)
OCONEE NUCLEAR STATION UNITS 1, 2, & 3
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
3
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 June 13, 2025, for the 2nd 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 June 13, 2025, for the 2nd RFI. 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 July 18, 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
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 design changes and
Critical System selected CDAs.
03.01(a)
3
Copy of vulnerability management program documentation.
All vulnerability screenings and assessments completed prior to placing
new CDA equipment into service as part of the selected 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 the Critical Systems chosen for
inspection (i.e., the devices that are credited for protection for the
selected Critical Systems selected CDAs).
03.02(b)
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) program
policy and associated procedures. Provide documentation describing
03.02(d)
OCONEE NUCLEAR STATION UNITS 1, 2, & 3
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
4
Table: RFI #2
Paragraph Number / Title:
Items
any cyber security changes to the access authorization program (AAP)
since the last cyber security inspection.
7
Baseline configuration data sheets for the selected CDAs and for the
selected cyber design changes.
03.03(a)
8
Copies of the purchase order documentation for any new equipment
purchased for the selected Critical Systems and design changes.
03.03(c)
9
Copies of any reports/assessments for cyber security drills performed
since the last inspection.
03.02(a)
03.04(b)
10
Vulnerability Management program screening and assessment policies
and procedures.
03.01(c)
11
Portable Media and Mobile Device (PMMD) control documentation,
including kiosk security control assessment/documentation.
03.02(e)
12
Device Access and Key Control program documentation.
03.02(c)
13
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 July 28, 2025, the first day of the inspection. 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
OCONEE NUCLEAR STATION UNITS 1, 2, & 3
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
5
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).