ML19003A381

Notification of Cyber Security Inspection Report 05000416/2019410, and Request for Information

ML19003A381
Person / Time
Site:	Grand Gulf
Issue date:	12/31/2018
From:	Greg Werner NRC/RGN-IV/DRS/EB-2
To:	Emily Larson Entergy Operations
Werner G
References
IR 2019410
Download: ML19003A381 (8)

See also: IR 05000416/2019410

Text

December 31, 2018

Mr. Eric Larson, Site Vice President

Entergy Operations, Inc.

Grand Gulf Nuclear Station

P.O. Box 756

Port Gibson, MS 39150

SUBJECT: GRAND GULF NUCLEAR STATION, UNIT 1 - NOTIFICATION OF

CYBER SECURITY INSPECTION (05000416/2019410) AND

REQUEST FOR INFORMATION

Dear Mr. Larson:

On April 29, 2019, the U.S. Nuclear Regulatory Commission (NRC) will begin an inspection in

accordance with Inspection Procedure (IP) 71130.10P, Cyber Security, Revision 0, at the

Grand Gulf Nuclear Station. This inspection evaluates and verifies your ability to meet the full

implementation 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. The onsite portion of the inspection will take place during the weeks

of April 29 and May 13, 2019.

Experience has shown that these 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. The document request has been divided into

four groups. The first group specifies information necessary to assist the team in choosing

the focus areas (i.e., sample set) to be inspected in accordance with the cyber security

inspection procedure. This information should be made available using passive media

(i.e. CD, DVD) and delivered to the regional office no later than March 1, 2019. The inspection

team will review this information and by the end of the planned information gathering visit,

March 21, 2019, will identify the specific items that should be provided for review.

The second group of requested documents will assist the team in their evaluation of the

critical systems and critical digital assets, defensive architecture, and the areas of the cyber

security plan selected for inspection. This information will be requested for review in the

regional office prior to the inspection by April 5, 2019.

The third group of requested documents consists of those items that the team will review or

need access to, during the inspection. Please have this information available by the first day of

the onsite inspection, April 29, 2019.

The fourth group of information is necessary to aid the 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

E. Larson 2

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 Nnaerika Okonkwo. We understand that our regulatory

contact for this inspection is Sheryl Sweet. If there are any questions about the inspection or

the material requested, please contact the lead inspector at 817-200-1114 or by e-mail at

Nnaerika.Okonkwo@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 under 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.

This letter and its enclosure will be made available for public inspection and copying at

http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in

accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA James Drake for/

Gregory. E. Werner, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-416

License No. NPF-29

Enclosure:

Request for Information -

Cyber Security Inspection Document

cc: w/ encl: Electronic Distribution

Request for Information - Cyber Security Inspection Document

Grand Gulf Nuclear Station, Unit 1

Inspection Report: 05000416/2019410

Inspection Dates: Weeks of April 29, 2019, and May 13, 2019

Inspection Procedure: IP 71130.10P, Cyber Security, Revision 0

Reference 1: ML17156A215 - Guidance Document for Development of the

Request for Information (RFI) and Notification Letter for

Full-Implementation of the Cyber Security Inspection,

Revision 1, dated October 26, 2017

NRC Inspectors: Nnaerika Okonkwo, Lead Greg Pick,

817-200-1114 817-200-1270

Nnaerika.Okonkwo@nrc.gov Greg.Pick@nrc.gov

NRC Contractors: Alan Konkal Alexander Prada

561-859-5232 240-449-5791

Alan.Konkal@nrc.gov Alexander.Prada@nrc.gov

I. Information Requested for In-Office Preparation

The initial request for information (i.e., first RFI) provides the team with the general

information necessary to select appropriate components and cyber security plan elements

to develop a site-specific inspection plan. The team will use the first set of information

requested to identify the list of critical systems and critical digital assets plus operational

and management security control portions of the Cyber Security Plan to be chosen as the

sample set required to be inspected during this inspection. The first information request

is specified in Table RFI #1.

The required Table RFI #1 information shall be provided on passive media (i.e. CD or DVD)

to the lead inspector by March 1, 2019, or sooner to facilitate the selection of the specific

items that will be reviewed during the onsite inspection weeks. Please provide four copies

of each media submitted (i.e., one for each inspector/contractor). The preferred file format

for all lists is a searchable Excel spreadsheet file on a CD or DVD. The files should be

indexed and hyperlinked to facilitate efficient review. If you have any questions regarding

this information, please contact the inspection team lead as soon as possible.

Table RFI #1

Par Section 3: Initial Documentation Requests (See Reference 1) Items

No. Number/Title:

1 List all identified critical systems and critical digital assets All

List critical digital asset facility and site ethernet - transmission control

2 protocol/internet protocol (TCP/IP) based local area networks (LANs) and All

identify those LANs that have non-critical digital assets on them

Enclosure

Table RFI #1

Par Section 3: Initial Documentation Requests (See Reference 1) Items

No. Number/Title:

List critical digital asset facility and site non-ethernet TCP/IP based LANs

3 including those industrial networks and identify LANs that have non-critical All

digital assets on them

Network topology diagrams (be sure to include all network intrusion

detection systems and security information and event management

4 All

(SIEM) for emergency preparedness (EP) networks and security level

3 and 4 networks)

List all network security boundary devices for EP networks and all network

8 All

security boundary devices for levels 3 and 4

9 List critical digital asset wireless Industrial networks All

Network Intrusion detection system documentation for critical systems that 11.a.1)

11

have critical digital assets associated with them 11.a.2)

SIEM documentation for critical systems that have critical digital assets 12.a.1)

12

associated with them 12.a.2)

14 List EP and security onsite and offsite digital communication systems All

25 Cyber security assessment and cyber security incident response teams All

Copy of current cyber security plan and copy of any 50.54(p) analysis to

28 All

support changes to that plan

Copy of any licensee identified violations and associated corrective

All

29 action program documentation to resolve issue(s).

In addition to the above information please provide the following:

(1) Electronic copy of the updated safety analysis report and technical specifications

(2) Name(s) and phone number(s) for the regulatory and technical contacts

(3) Current management and engineering organizational charts

(4) Cyber Security Program Procedures

Based on this information, the team will identify and select specific systems and

equipment (e.g., critical systems and critical digital assets) from the information requested

by Table RFI #1, and submit a list of specific systems and equipment to your staff by the

end of the information gathering visit, March 21, 2019, for the second information request

(i.e., Table RFI #2).

2

II. Additional Information Requested to be Available Prior to Inspection

As stated in Section I, the team will examine the documents from the initial information

request, and submit the list of specific systems and equipment to your staff by the end of

the information gathering visit, March 21, 2019. This second information request

(i.e., Table RFI #2) obtains additional documents required to evaluate the critical systems

and critical digital assets, defensive architecture, and the areas of the cyber security

program selected for the cyber security 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 Reference 1.

The Table RFI #2 information shall be provided on passive media to the lead inspector by

April 5, 2019. Please provide four copies of each CD/DVD submitted (i.e., one for each

inspector/contractor). The preferred file format for all lists is a searchable Excel

spreadsheet file on a CD/DVD. These passive media should be indexed and hyperlinked

to facilitate efficient review. If you have any questions regarding this information, please

call the inspection team lead as soon as possible.

Table RFI #2

Par Section 3: Initial Documentation Requests (See Reference 1) Items

No. Number/Title:

5 Plant computer system block diagram (if plant computer system is All

selected for inspection)

Plant security system block diagram (if security computer system is

6 All

selected for inspection)

Block diagrams for distributed systems (for systems selected for

7 All

inspection)

Host-based intrusion detection system documentation for critical 10.a.1)

10

digital assets (for systems selected for inspection) 10.a.2)

List all maintenance and test equipment (M&TE) used on critical

13 All

digital assets (for systems selected for inspection)

15 Configuration management All

Network Intrusion detection system documentation for critical systems 11.a.1)

11

that have critical digital assets associated with them 11.a.2)

16.a

16 Supply chain management

16.b

17 Portable media and mobile device control All

18 Software management All

3

Table RFI #2

Par Section 3: Initial Documentation Requests (See Reference 1) Items

No. Number/Title:

20 Vendor access and monitoring All

21 Work control All

22 Device access and key control All

23 Password/authenticator policy All

24 User account/credential policy All

26 Corrective actions since last NRC inspection All

27 Cyber security assessments for selected systems All

III. Information Requested to be Available on First Day of Inspection

For the specific systems and equipment identified in Section II, provide the following

request for information (i.e., Table 1st Week Onsite) on passive media by April 29, 2019,

the first day of the inspection. All requested information shall follow the guidance in

Reference 1.

Please provide four copies of each CD submitted (i.e., one for each inspector/contactor).

The preferred file format for all lists is a searchable Excel spreadsheet file on a CD/DVD.

These passive media files should be indexed and hyperlinked to facilitate ease of use. If

you have any questions regarding this information, please call the inspection team lead as

soon as possible.

Table 1st Week Onsite

Par Section 3: Initial Documentation Requests (See Reference 1) Items

No. Number/Title:

10.a.3)

Host-based intrusion detection system documentation for critical

10 thru

digital assets (for systems selected for inspection)

10.a.12)

11.a.3)

Network Intrusion detection system documentation for critical systems

11 thru

that have critical digital assets associated with them

11.a.15)

SIEM documentation for critical systems that have critical digital 12.a.3)

12 thru

assets associated with them

12.a.14

16 Supply chain management 16.c

4

Table 1st Week Onsite

Par Section 3: Initial Documentation Requests (See Reference 1) Items

No. Number/Title:

19 Cyber security event notifications All

Update to licensee identified violations and corrective action program

29 All

actions taken since the initial request was made

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 as long as the inspectors have easy and unrestrained access

to them.

a. Quality Assurance Plan;

b. Technical Specifications, if not previously provided;

c. Latest Individual Plant Examination/Probabilistic Risk Assessment Report;

and,

(2) Vendor Manuals, Assessments, and Corrective Actions:

a. The most recent cyber security quality assurance audit and/or

self-assessment; and

b. Corrective action documents (e.g., condition reports, including status of

corrective actions) generated as a result of the most recent cyber security

quality assurance audit and/or self-assessment.

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 team lead.

5

ML19003A381

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002

By: NPO Yes No Publicly Available Sensitive

OFFICE RI:EB2 BC:EB2

NAME N. Okonkwo G. Werner

SIGNATURE /RA-e/ /RA JFD for/

DATE 12/27/2018 12/31/2018