ML19095B608

Ltr. 04/05/19 Clinton Power Station - Information Request for the Cyber-Security Full Implementation Inspection, Notification to Perform Inspection 05000461/2019412 (DRS-D.Szwarc)

ML19095B608
Person / Time
Site:	Clinton
Issue date:	04/05/2019
From:	Dariusz Szwarc NRC/RGN-III
To:	Bryan Hanson Exelon Generation Co
References
IR 2019412
Download: ML19095B608 (8)

See also: IR 05000461/2019412

Text

April 5, 2019

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Company, LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: CLINTON POWER STATIONINFORMATION REQUEST FOR THE

CYBER-SECURITY FULL IMPLEMENTATION INSPECTION, NOTIFICATION

TO PERFORM INSPECTION 05000461/2019412

Dear Mr. Hanson:

On August 5, 2019, the U.S. Nuclear Regulatory Commission (NRC) will begin an inspection in

accordance with Inspection Procedure 71130.10P, Cyber-Security, issued May 15, 2017, at

your Clinton Power Station. The inspection will be performed to evaluate and verify your ability

to meet full implementation requirements of the NRCs Cyber-Security Rule, Title 10 of the Code

of Federal Regulations, 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

August 5, 2019, and August 19, 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. 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 via compact disc and delivered to

the regional office no later than May 13, 2019. The inspection team will review this

information and, by June 10, 2019, will request the specific items that should be

provided for review.

• The second group of additional 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 plants Cyber-Security Program selected for the Cyber-Security

Inspection. This information will be requested for review in the regional office prior to the

inspection by July 8, 2019.

• 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, August 5, 2019.

B. Hanson -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 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 Mr. Dariusz Szwarc. We understand that our regulatory

contact for this inspection is Mr. Nicholas Santos of your organization. If there are any

questions about the inspection or the material requested, please contact the lead inspector

at 630-829-9803 or via e-mail at Dariusz.Szwarc@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.

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 Title 10 of the Code of Federal Regulations, Part 2.390, Public Inspections,

Exemptions, Requests for Withholding.

Sincerely,

/RA/

Dariusz Szwarc, Senior Reactor Inspector

Engineering Branch 3

Division of Reactor Safety

Docket Nos. 50-461

License No. NPF-62

Enclosure:

Document Request for Cyber-Security

Inspection

cc: Distribution via LISTSERV

B. Hanson -3-

Letter to Bryan C. Hanson from Dariusz Szwarc dated April 5, 2019.

SUBJECT: CLINTON POWER STATIONINFORMATION REQUEST FOR THE

CYBER-SECURITY FULL IMPLEMENTATION INSPECTION, NOTIFICATION

TO PERFORM INSPECTION 05000461/2019412

DISTRIBUTION:

Michael McCoppin

RidsNrrDorlLpl3

RidsNrrPMClinton Resource

RidsNrrDirsIrib Resource

Darrell Roberts

John Giessner

Jamnes Cameron

Allan Barker

DRSIII

DRPIII

ADAMS Accession Number: ML19095B608

OFFICE RIII

NAME DSzwarc:cl

DATE 04/05/19

OFFICIAL RECORD COPY

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Inspection Report: 05000461/2019412

Inspection Dates: Weeks of August 5, 2019, and August 19, 2019

Inspection Procedure: 71130.10P, Cyber-Security, Issue Date: May 15, 2017

Reference: Guidance Document for Development of the Request for

Information and Notification Letter for Full-Implementation of

the Cyber-Security Inspection, Issue Date October 26, 2017

(ML17156A215)

NRC Inspectors: Dariusz Szwarc, Lead John S. Robbins

630-829-9803 630-829-9744

Dariusz.Szwarc@nrc.gov John.Robbins@nrc.gov

NRC Contractors: Leyton Pitzer Chris P. Fiotes

301-725-9538 301-415-7000

Leyton.Pitzer@nrc.gov Chris.Fiotes@nrc.gov

Observers: Robert C. Daley

630-829-9749

Robert.Daley@nrc.gov

I. Information Requested for In-Office Preparation

The initial request for information (i.e., first Request for Information (RFI)) concentrates

on providing the inspection team with the general information necessary to select

appropriate components and Cyber-Security Program (CSP) elements to develop a

site-specific inspection plan. The first RFI is used to identify the list of critical systems

(CSs) and critical digital assets (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 Inspection Procedure. 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 May 13, 2018, or sooner, to facilitate

the selection of the specific items that will be reviewed during the onsite inspection

weeks.

Enclosure

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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 June 10, 2019, 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. All requests for this information shall follow the Table RFI #1

and the guidance document referenced above.

The required Table RFI #1 information shall be provided on compact disc (CD) to the

lead inspector by May 13, 2019. Please provide five copies of each CD submitted

(i.e., one for each inspector/contractor). The preferred file format for all lists is a

searchable Excel spreadsheet file. These CDs 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

Reference Section 3, Paragraph Number/Title: Items

1 List All Identified CSs and CDAs All

2 List CDA Facility and Site EthernetTransmission Control All

Protocol/Internet Protocol Based Local Area Networks (LANs) and

Identify Those LANs That Have Non-CDAs On Them

3 List CDA Facility and Site Non-Ethernet Transmission Control All

Protocol/Internet Protocol Based LANs Including Those Industrial

Networks and Identify LANs That Have Non-CDAs On Them

4 Network Topology Diagrams (Be Sure To Include All Network Intrusion All

Detections and Security Information and Event Managements for

Emergency Preparedness (EP) Networks and Security Level 3 and 4

Networks)

8 List All Network Security Boundary Devices for EP Networks and All All

Network Security Boundary Devices for Levels 3 and 4

9 List CDA Wireless Industrial Networks All

11 Network Intrusion Detection System Documentation for CSs That Have 11.a.1)

CDAs Associated with Them 11.a.2)

12 Security Information and Event Managements Documentation for CSs 12.a.1)

That Have CDAs 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 All

Teams

28 Copy of Current CSP and Copy of 50.54(p) Analysis To Support All

Changes To That Plan

29 Copy Of Any Licensee-Identified Violations and Associated Corrective All

Action Program Documentation To Resolve Issue(s)

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CYBER-SECURITY INSPECTION DOCUMENT REQUEST

In addition to the above information please provide the following:

(1.) Electronic copy of the Updated Finals Safety Analysis Report 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., CSs/CDAs) from the information requested by Table RFI #1 and

submit a list of specific systems and equipment to your staff by June 10, 2019, for the

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

II. Additional Information Requested to be Available Prior to Inspection

As stated above, in Section I. of this enclosure, 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 10, 2019, for the second RFI

(i.e., Table 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 Cyber-Security Inspection. The additional information requested for

the specific systems and equipment is identified in Table RFI #2. All requests for this

information shall follow the Table RFI #2 and the guidance document referenced above.

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

September 24, 2018. Please provide five copies of each CD submitted (i.e., one for

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

spreadsheet file. These CDs 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

Reference Section 3, Paragraph Number/Title: Items

5 Plant Computer System Block Diagram (If Plant Computer System Is All

Selected for Inspection)

6 Plant Security System Block Diagram (If Security Computer System Is All

Selected for Inspection)

7 Systems That Are Distributed Block Diagrams (For Systems Selected All

for Inspection)

10 Host-Based Intrusion Detection System Documentation (For CDAs for 10.a.1)

Systems Selected for Inspection) 10.a.2)

13 List All Maintenance and Test Equipment Used On CDAs for Systems All

Selected for Inspection

15 Configuration Management All

16 Supply Chain Management 16.b.

16.c.1)

16.c.5)

16.c.6)

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CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table RFI #2

Reference Section 3, Paragraph Number/Title: Items

17 Portable Media and Mobile Device Control All

18 Software Management All

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 this enclosuresSection II., provide

the following RFI (i.e., Table 1ST Week Onsite) on CD by August 5, 2019, the first day of

the inspection. All requests for this information shall follow the Table 1ST Week Onsite

and the guidance document referenced above.

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

The preferred file format for all lists is a searchable Excel spreadsheet file. These CDs

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

Reference Section 3, Paragraph Number/Title: Items

10 Host-Based Intrusion Detection System Documentation for CDAs for 10.a.3)

Systems Selected for Inspection thru

10.a.12)

11 Network Intrusion Detection System Documentation for CSs That Have 11.a.3)

CDAs Associated with Them thru

11.a.15)

12 SIEM Documentation for CSs That Have CDAs Associated with Them 12.a.3)

thru

12.a.14)

16 Supply Chain Management 16.c.2)

16.c.3)

16.c.4)

19 Cyber-Security Event Notifications All

29 Update to Licensee Identified Violations and CAP Actions Taken Since All

the Initial Request Was Made

4

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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. Original Final Safety Analysis Report Volumes;

b. Original Safety Evaluation Report and Supplements;

c. Final Safety Analysis Report Question and Answers;

d. Quality Assurance Plan;

e. Latest Individual Plant Examination/Probabilistic Risk Assessment

Report; and

f. Vendor Manuals.

(2.) Assessment 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) generate 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 inspection

team leader.

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