IR 05000333/2023401: Difference between revisions

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{{Adams
{{Adams
| number = ML23152A004
| number = ML23340A146
| issue date = 06/01/2023
| issue date = 12/08/2023
| title = Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection 05000333/2023401
| title = Cybersecurity Inspection Report 05000333/2023401 (Cover Letter Only)
| author name = Dentel G
| author name = Dentel G
| author affiliation = NRC/RGN-I/DORS
| author affiliation = NRC/RGN-I/DORS
Line 11: Line 11:
| contact person =  
| contact person =  
| document report number = IR 2023401
| document report number = IR 2023401
| document type = Inspection Plan, Letter
| document type = Inspection Report, Letter
| page count = 1
| page count = 1
}}
}}
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=Text=
=Text=
{{#Wiki_filter:June 1, 2023
{{#Wiki_filter:December 8, 2023


==SUBJECT:==
==SUBJECT:==
JAMES A. FITZPATRICK NUCLEAR POWER PLANT- INFORMATION REQUEST FOR THE CYBER SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM INSPECTION 05000333/2023401
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - CYBERSECURITY INSPECTION REPORT 05000333/2023401


==Dear David Rhoades:==
==Dear David Rhoades:==
On October 23, 2023, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline inspection in accordance with Inspection Procedure (IP) 71130.10, Cyber Security, dated December 14, 2021, at FitzPatrick. The inspection will be performed to evaluate and verify your ability to meet the requirements of the NRCs Cyber Security Rule, Title 10 of the Code of Federal Regulations (10 CFR) Part 73, Section 54, Protection of Digital Computer and Communication Systems and Networks. The onsite portion of the inspection will take place October 23 through 27, 2023.
On October 27, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at James A. FitzPatrick Nuclear Power Plant and discussed the results of this inspection with Garrick D. Olson, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.


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 four groups.
One finding of very low security significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.


The first group specifies information necessary to assist the inspection team in choosing the focus areas (i.e., sample set) to be inspected by IP 71130.10. This information should be made available either on an online repository (preferred) or digital media (CD/DVD) no later than July 14, 2023. The inspection team will review this information and, by August 18, 2023, will request the specific items that should be provided for review.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; the Director, Office of Nuclear Security and Incident Response; and the NRC Resident Inspector at James A. FitzPatrick Nuclear Power Plant.


The 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 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 September 15, 2023, 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, October 23, 2023.
This letter 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 (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding. The enclosed report contains Security-Related Information, so the enclosed report will not be made publicly available in accordance with 10 CFR 2.390(d)(1). If you choose to provide a response that contains Security-Related Information, please mark your entire response Security-Related Information-Withhold from public disclosure under 10 CFR 2.390 in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). The NRC is waiving the affidavit requirements for your response in accordance with 10 CFR 2.390(b)(1)(ii).


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.
Sincerely, Digitally signed by Glenn Glenn T. T. Dentel Date: 2023.12.08 Dentel 09:07:07 -05'00'
 
The lead inspector for this inspection is Louis Dumont. We understand that our regulatory contact for this inspection is Steven Juravich of your organization. If there are any questions about the inspection or the material requested, please contact the lead inspector at (610) 337-5183 or via email at louis.dumont@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 website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
 
Sincerely, Digitally signed by Glenn Glenn T. T. Dentel Date: 2023.06.01 Dentel 15:33:04 -04'00'
Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket No. 05000333 License No. DPR-59 Enclosure:
Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket No. 05000333 License No. DPR-59 Enclosure:
Cyber Security Inspection Document Request cc: Distribution via ListServ
As stated cc w/o encl: Distribution via LISTSERV cc w/ encl:
 
M. Bellomo, Manager Site Security F. Bundy, Manager Security Operations A. Peterson, State Liaison Officer Designee, NY State Energy, Research and Development Authority B. Wright, NYS Division of Homeland Security and Emergency Services ML23340A143 (Cover letter w/ enclosure(s))
ML23152A004 Non-Sensitive  Publicly Available SUNSI Review Sensitive  Non-Publicly Available OFFICE RI/DORS RI/DORS NAME LDumont GDentel DATE 5/31/2023 5/31/2023
ADAMS ACCESSION NUMBER: ML23340A146 (Cover letter)
 
Entire ReportNon-Sensitive  Publicly Available x SUNSI Review  x Sensitive  x Non-Publicly Available Cover Letter Only: x Non-Sensitive  x Publicly Available x SUNSI Review  Sensitive Non-Publicly Available OFFICE RI/DORS RI/DORS RI/DORS RI/DORS NAME ECarfang DWerkheiser LDumont GDentel DATE 12/4/2023 12/4/2023 12/5/2023 12/4/2023
JAMES A. FITZPATRICK NUCLEAR POWER PLANT CYBER SECURITY INSPECTION DOCUMENT REQUEST Inspection Report: 05000333/2023401 Inspection Dates: October 23 - 27, 2023 Inspection Procedure: IP 71130.10, Cyber Security, dated December 14, 2021 (ADAMS Accession Number: ML21271A106)
Reference:  Guidance Document for Development of the Request for Information (RFI) and Notification Letter for IP 71130.10, Cyber Security (ML21330A088)
NRC Inspectors:  Louis Dumont, Lead  Tanvir Siddiky (610) 337-5183  Tanvir.siddiky@nrc.gov Louis.Dumont@nrc.gov Timothy Hennessey (610) 337-5135 Timothy.hennessey@nrc.gov NRC Contractors: Balla Barro Balla.barro@nrc.gov 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 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 and critical digital assets (CSs/CDAs) plus operational and management 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 July 14, 2023, or sooner, to facilitate the selection of the specific items that will be reviewed during the onsite inspection weeks.
 
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 August 18, 2023, 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 the second RFI be made available to the regional office prior to the inspection by September 15, 2023.
 
Enclosure
 
JAMES A. FITZPATRICK NUCLEAR POWER PLANT CYBER SECURITY INSPECTION DOCUMENT REQUEST The required Table RFI #1 information shall be provided on an online repository (preferred) or digital media (CD/DVD) to the lead inspector by July 14, 2023. 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 Section 3, Paragraph Number/Title:    IP Ref A list of all Identified Critical Systems and Critical Digital Assets -
highlight/note any additions, deletions or reclassifications due to new 1      Overall guidance from white papers, changes to NEI 10-04, 13-10, etc. since the last cyber security inspection.
 
2 A list of EP and Security onsite and offsite digital communication systems Overall Network Topology Diagrams to include information and data flow for 3      Overall critical systems in levels 2, 3 and 4 (If available)
4 Ongoing Monitoring and Assessment program documentation  03.01(a)
5 The most recent effectiveness analysis of the Cyber Security Program 03.01(b)
6 Vulnerability screening/assessment and scan program documentation 03.01(c)
Cyber Security Incident response documentation, including incident detection, response, and recovery documentation as well as contingency 03.02(a)
7 plan development and implementation, including any program  and documentation that requires testing of security boundary device 03.04(b)
functionality 8 Device Access and Key Control documentation  03.02(c)
9 Password/Authenticator documentation  03.02(c)
10 User Account/Credential documentation  03.02(d)
Portable Media and Mobile Device control documentation, including kiosk 11      03.02(e)
security control assessment/documentation Design change/modification program documentation and a list of all design changes that affected CDAs that have actually been installed and completed 12      03.03(a)
since the last cyber security inspection, including either a summary of the design change or the 50.59 documentation of the change.
 
03.03(a),
Supply Chain Management documentation including any security impact 13      (b) and analysis for new acquisitions (c)
Configuration Management documentation including any security impact 03.03(a)
 
analysis performed due to configuration changes since the last inspection and (b)
Cyber Security Plan and any 50.54(p) analysis to support changes to the 15      03.04(a)
plan since the last inspection 16 Cyber Security Metrics tracked (if applicable)  03.06 (b)
Provide documentation describing any cyber security changes to the access 17      Overall authorization program since the last cyber security inspection.
 
Provide a list of all procedures and policies provided to the NRC with their 18      Overall descriptive name and associated number (if available)
19 Performance testing report (if applicable)  03.06 (a)
 
JAMES A. FITZPATRICK NUCLEAR POWER PLANT CYBER SECURITY INSPECTION DOCUMENT REQUEST In addition to the above information please provide the following:
  (1) Electronic copy of the Updated Final Safety Analysis Report (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., CSs/CDAs) from the information requested by Table RFI #1 and submit a list of specific systems and equipment to your staff by August 18, 2023, 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 August 18, 2023, for the second RFI (i.e., 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.
 
The Table RFI #2 information shall be provided to the lead inspector by September 15, 2023. 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)
All vulnerability screenings/assessments associated with or scans 3 performed on the selected system(s) since the last cyber security 03.01(c)
inspection Documentation (including configuration files and rules sets) for Network-based Intrusion Detection/Protection Systems (NIDS/NIPS), Host-based 4      03.02(b)
Intrusion Detection Systems (HIDS), and Security Information and Event Management (SIEM) systems for system(s) chosen for inspection)
Documentation (including configuration files and rule sets) for intra-5 security level firewalls and boundary devices used to protect the selected 03.02(c)
system(s)
Copies of all periodic reviews of the access authorization list for the 6      03.02(d)
selected systems since the last inspection 7 Baseline configuration data sheets for the selected CDAs  03.03(a)
 
JAMES A. FITZPATRICK NUCLEAR POWER PLANT CYBER SECURITY INSPECTION DOCUMENT REQUEST Documentation on any changes, including Security Impact Analyses, 8      03.03(b)
performed on the selected system(s) since the last inspection Copies of the purchase order documentation for any new equipment 9      03.03(c)
purchased for the selected systems since the last inspection Copies of any reports/assessment for cyber security drills performed since 03.02(a)
 
the last inspection. 03.04(b)
Copy of the individual recovery plan(s) for the selected system(s) including 03.02(a)
 
documentation of the results the last time the backups were executed. 03.04(b)
Corrective actions taken as a result of cyber security incidents/issues to 12 include previous NRC violations and Licensee Identified Violations since 03.05 the last cyber security inspection For the selected systems, provide design change/modification packages 13      03.03(a)
including completed work orders since the last cyber security inspection 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 October 23, 2023, the first day of the inspection.
 
Table 1ST Week Onsite Section 3, Paragraph Number/Title:    Items`
Any cyber security event reports submitted in accordance with 10 CFR 1      03.04(b)
73.77 since the last cyber security inspection Updated Copies of corrective actions taken as a result of cyber security incidents/issues, to include previous NRC violations and Licensee 2      03.05 Identified Violations since the last cyber security inspection, as well as vulnerability-related corrective actions 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. Updated Final Safety Analysis Report, if not previously provided; b. Original Cyber Security Safety Evaluation Report and Supplements; c. Quality Assurance (QA) Plan; d. Technical Specifications, if not previously provided; and e. Latest individual plant examination/probabilistic Risk assessment report.
 
JAMES A. FITZPATRICK NUCLEAR POWER PLANT CYBER SECURITY INSPECTION DOCUMENT REQUEST (2) Vendor Manuals, Assessment and Corrective Actions:
a. The most recent Cyber Security QA 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 QA 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.
 
5
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Latest revision as of 22:52, 11 December 2023

Cybersecurity Inspection Report 05000333/2023401 (Cover Letter Only)
ML23340A146
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 12/08/2023
From: Glenn Dentel
NRC/RGN-I/DORS
To: Rhoades D
Constellation Energy Generation, Constellation Nuclear
References
IR 2023401
Download: ML23340A146 (1)


Text

December 8, 2023

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - CYBERSECURITY INSPECTION REPORT 05000333/2023401

Dear David Rhoades:

On October 27, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at James A. FitzPatrick Nuclear Power Plant and discussed the results of this inspection with Garrick D. Olson, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low security significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; the Director, Office of Nuclear Security and Incident Response; and the NRC Resident Inspector at James A. FitzPatrick Nuclear Power Plant.

This letter 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 (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding. The enclosed report contains Security-Related Information, so the enclosed report will not be made publicly available in accordance with 10 CFR 2.390(d)(1). If you choose to provide a response that contains Security-Related Information, please mark your entire response Security-Related Information-Withhold from public disclosure under 10 CFR 2.390 in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). The NRC is waiving the affidavit requirements for your response in accordance with 10 CFR 2.390(b)(1)(ii).

Sincerely, Digitally signed by Glenn Glenn T. T. Dentel Date: 2023.12.08 Dentel 09:07:07 -05'00'

Glenn T. Dentel, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket No. 05000333 License No. DPR-59 Enclosure:

As stated cc w/o encl: Distribution via LISTSERV cc w/ encl:

M. Bellomo, Manager Site Security F. Bundy, Manager Security Operations A. Peterson, State Liaison Officer Designee, NY State Energy, Research and Development Authority B. Wright, NYS Division of Homeland Security and Emergency Services ML23340A143 (Cover letter w/ enclosure(s))

ADAMS ACCESSION NUMBER: ML23340A146 (Cover letter)

Entire Report: Non-Sensitive Publicly Available x SUNSI Review x Sensitive x Non-Publicly Available Cover Letter Only: x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available OFFICE RI/DORS RI/DORS RI/DORS RI/DORS NAME ECarfang DWerkheiser LDumont GDentel DATE 12/4/2023 12/4/2023 12/5/2023 12/4/2023