ML25128A174
| ML25128A174 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/08/2025 |
| From: | Alan D NRC/RGN-III/DORS/EB2 |
| To: | Mlynarek M Holtec Decommissioning International |
| References | |
| Download: ML25128A174 (1) | |
Text
Mike Mlynarek Site Vice President Holtec Decommissioning International, LLC Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
SUBJECT:
PALISADES NUCLEAR PLANT - INFORMATION REQUEST FOR THE CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM INSPECTION
Dear Mike Mlynarek:
On June 9, 2025, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline inspection in accordance with Inspection Procedure (IP) 81000.12 Cyber-Security Restart Inspection - Pre-Fuel Load, Revision 0 at your Palisades Nuclear Plant. The inspection will be performed to evaluate and verify that the Palisades Nuclear Plants cybersecurity program is being properly reestablished to provide reasonable assurance that digital computer and communication systems and networks associated with safety, security, or emergency preparedness (SSEP) functions are adequately protected against cyberattacks in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 73, Section 54, Protection of Digital Computer and Communication Systems and Networks, and the U.S. Nuclear Regulatory Commission (NRC) approved cybersecurity plan (CSP). The onsite portion of the inspection will take place June 9-13, 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 three groups.
The first group specifies information necessary to assist the inspection team in planning for the inspection. It is requested that this information be provided to the lead inspector via mail or electronically no later than May 30, 2025.
The second group lists information are possible areas for discussion that the inspection team will review or need access to during the inspection. Please have this information available for the team review during the onsite inspection, June 09, 2025.
May 8, 2025
M. Mlynarek 2
The third 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.
The lead inspector for this inspection is Alan Dahbur. We understand that our regulatory contact for this inspection is Ms. Amy Filbrandt from your organization. If there are any questions about the inspection or the material requested, please contact the lead inspector at 630-829-9810 or via email at Alan.dahbur@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 NRCs 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 NRCs 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, Alan Dahbur, Senior Reactor Inspector Engineering Branch 2 Division of Operating Reactor Safety Docket No. 05000255 License No. DPR-20
Enclosure:
Palisades Nuclear Power Station Cyber-Security Inspection Document Request cc w/encl: Distribution via LISTSERV Signed by Dahbur, Alan on 05/08/25
M. Mlynarek 3
Letter to Mike Mlynarek from Alan Dahbur dated May 8, 2025.
SUBJECT:
PALISADES NUCLEAR PLANT - INFORMATION REQUEST FOR THE CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM INSPECTION DISTRIBUTION:
Tim Steadham RidsNrrPMPalisades Resource RidsNrrDorlLpl3 RidsNrrDroIrib Resource Jack Giessner Mohammed Shuaibi Diana Betancourt-Roldan Bryan Bergeon David Curtis Jared Heck R3-DORS ADAMS Accession Number: ML25128A174 Publicly Available Non-Publicly Available Sensitive Non-Sensitive OFFICE RIII NAME ADahbur:anm DATE 05/08/2024 OFFICIAL RECORD COPY
PALISADES CYBER-SECURITY INSPECTION DOCUMENT REQUEST Enclosure Inspection Report: 05000255/2025405 Inspection Dates:
June 09-13, 2025 Inspection Procedure:
IP 81000.12, Cyber-Security Restart Inspection - Pre-Fuel Load, Revision 0 NRC Inspectors:
Benny Jose Alan Dahbur, Lead 630-829-9756 630-829-9810 Benny.Jose@nrc.gov Alan.Dahbur@nrc.gov NRC Observer:
Rodney Fanner (NISR)
Musab AbuHamdan 404-997-4541 630-829-9633 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 aid the inspection team preparing for the inspection. The Table RFI #1 information is requested to be provided to the regional office by May 30, 2025, or sooner, to facilitate the selection of the specific items that will be reviewed and discussed during the onsite inspection weeks.
The required Table RFI #1 information shall be provided electronically to the lead inspector by May 30, 2025. If a compact disk (CD) is provided, please provide four copies (one for each inspector/contactor). The preferred file format for all lists is a searchable Excel spreadsheet file. These files 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 Request:
IP Ref 1
Provide the following documentation for the Cyber-Security Assessment Team (CSAT):
- a. procedures establishing the CSAT team
- b. list of CSAT members noting primary areas of responsibility
- c. procedures detailing qualification requirements for CSAT members
- d. supporting documentation that demonstrates each CSAT member meets the requirements to fulfill their respective position on the team For example: member resumes; evaluation of previous education and experience; training required by your implementing procedures and supporting documentation which shows training was completed; or industry certifications.
(02.01)
PALISADES CYBER-SECURITY INSPECTION DOCUMENT REQUEST 2
Table RFI #1 Request:
IP Ref 2
- a. list of plant systems noting which systems have been identified as Critical Systems (CSs)
- b. list of all digital assets noting which have been classified as Critical Digital Assets (CDAs), and which have not
- c. procedure documenting the process by which CSs and CDAs are identified in accordance with your CSP, Section 3.1.3
- d. list of CDAs that have completed assessment and/or baseline documentations (02.02) 3
- a. Procedures establishing your cyber defensive architecture. Explain any variances from your CSP, Section 4.3, and tracking documents for their correction.
- b. Provide an overview of your cyber defensive architecture, preferably with overview level Network Topology Diagrams to include information and data flow for critical systems in levels 2, 3 and 4 (If available).
- c. Provide details of the implementation of the subject deterministic one-way device.
(02.03) 4 Procedures implementing the security control Access Control for Portable and Mobile Devices. Including kiosk security control assessment/documentation.
(02.04) 5
- a. Procedures implementing the ongoing monitoring and assessment activities as described in your CSP, Section 4.4.
- b. Design Change/ Modification and Configuration Management Policy and Procedures (02.05) 6 Supply Chain Management documentation including a list of all new acquisitions (02.06) 7 Corrective actions taken as a result of cyber-security incidents/issues (02.07) 8 Cyber-Security Plan and any 50.54(p) analysis to support changes to the plan (02.08) 10 Provide a list of all procedures and policies provided to the NRC with their descriptive name and associated number (if available)
Overall 11 Device Access and Key Control documentation Overall
PALISADES CYBER-SECURITY INSPECTION DOCUMENT REQUEST 3
In addition to the above information please provide the following:
(1) Name(s) and phone numbers for the regulatory and technical contacts.
(2) Current management and engineering organizational charts.
II.
Additional Information Requested to be Available During the Onsite Week June 9, 2025.
The team inspection will review a subset of the listed controls below, related to program monitoring, assessment, configuration, and change management, for the selected SSEP, CSs, and CDAs samples and review how the licensee addresses those applicable controls:
- Baseline Configuration (NEI (E.10.3) RG (C.11.3))
- Installing Operating Systems, Applications, and Third-Party Software Updates (NEI (D.5.5) RG (B.5.5))
- Security Impact Analysis (NEI (A.4.4.2, E.10.5) RG (C.11.5))
- Flaw Remediation (NEI (E.3.2) RG (C.3.2))
- Access Restrictions for Change (NEI (E.10.6) RG (C.11.6))
- Security Functionality Verification (NEI (E.3.6) RG (C.3.6))
- Configuration Settings (NEI (E.10.7) RG (C.11.7))
- Evaluate and Manage Cyber Risk (NEI (E.12) RG (C.13.1))
- Ongoing Monitoring and Assessment (NEI (A.4.4) RG (C.4.1))
III.
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.