ML22075A048

V.C. Summer Nuclear Station - Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000395/2022401

ML22075A048
Person / Time
Site:	Summer
Issue date:	03/16/2022
From:	William Monk NRC/RGN-II/DRS/EB2
To:	Stoddard D Dominion Energy South Carolina
References
IR 2022401
Download: ML22075A048 (9)

See also: IR 05000395/2022401

Text

Daniel Stoddard, SVP

Dominion Energy

Innsbrook Technical Center

5000 Dominion Blvd., Floor: IN-2SW

Glen Allen, VA 29060

SUBJECT: V.C. SUMMER NUCLEAR STATION - INFORMATION REQUEST FOR THE

CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM

INSPECTION 05000395/2022401

Dear Mr. Stoddard:

On June 27, 2022, 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 V.C. Summer Nuclear Station. 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 June 27, 2022.

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.

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 April 8, 2022. The inspection team will review

this information and, by April 18, 2022, 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 (CSs/CDAs), defensive

architecture, and the areas of the licensees CSP selected for the cyber-security inspection.

This information will be requested for review in the regional office prior to the inspection by

May 30, 2022, as identified above.

March 16, 2022

D. Stoddard

2

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, June 27, 2022.

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 William Monk. We understand that our regulatory

contact for this inspection is Michael Moore, Licensing Manager 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,

/RA/

Gerry McCoy, Branch Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-395

License Nos. NPF-12

Enclosure:

V.C. Summer Nuclear Station Cyber-Security Inspection Document Request

cc w/encl: Distribution via LISTSERV

ML22075A048

X

SUNSI Review

X

Non-Sensitive

Sensitive

X

Publicly Available

Non-Publicly Available

OFFICE RII/DRS

RII/DRS

RII/DRS

NAME

W. Monk

G. McCoy

J. Montgomery

DATE

03/16/2022

03/16/2022

03/16/2022

SUMMER NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Enclosure

Inspection Report: 05000395/2022401

Inspection Dates:

June 27-July 01, 2022

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:

William Monk, Lead

Jonathan Montgomery

404-909-4579

404-997-4880

william.monk@nrc.gov

jonathan.montgomery@nrc.gov

NRC Contractors:

Tim Marshall

Balla Barro

301-415-7000

301-415-7000

timothy.marshall@nrc.gov

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 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 (O&M) security control portions of the CSP to be chosen as the sample

set required to be inspected by the cyber-security IP. The first RFIs requested

information is specified below in Table: RFI #1. The Table RFI #1 information is

requested to be provided electronically to the inspection team by April 8, 2022, 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 April 18, 2022, 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 inspection team by May 30, 2022. 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.

SUMMER NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST

2

The required Table: RFI 1 information shall be provided electronically to the lead

inspector by April 8, 2022. 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

A list of EP and Security onsite and offsite digital communication

systems.

Overall

3

Network Topology Diagrams to include information and data flow for

critical systems in levels 2, 3, and 4 (If available).

Overall

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)

7

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)

8

Device Access and Key Control program documentation.

03.02(c)

9

Password/Authenticator program documentation.

03.02(c)

10

User Account/Credential and Authentication program documentation.

03.02(d)

11 Portable Media and Mobile Device (PMMD) control documentation,

including kiosk security control assessment/documentation.

03.02(e)

12

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)

13

Supply Chain Management program documentation, including any

security impact analysis for new acquisitions.

03.03(a),

(b) and (c)

SUMMER NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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Table: RFI #1

Paragraph Number/Title:

IP Ref

14

Configuration Management documentation including any security

impact analysis performed due to configuration changes since the last

cyber inspection.

03.03(a)

and (b)

15

Cyber Security Plan and any 50.54(p) analysis to support changes to

the plan since the last inspection.

03.04(a)

16

Cyber Security Performance Metrics tracked (if applicable).

03.06(b)

17

Provide documentation describing any cyber security changes to the

access authorization program since the last cyber security inspection.

Overall

18

Provide a list of all procedures and policies provided to the NRC with

their descriptive name and associated number (if available).

Overall

19

Performance testing report (if applicable).

03.06(a)

In addition to the above information, please provide the following:

(1) electronic copy of the 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 April 18, 2022, 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 April 18, 2022, 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. All requested information shall follow the guidance

document referenced above.

The Table: RFI 2 information shall be provided to the lead inspector by May 30, 2022.

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.

SUMMER NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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Table: RFI #2

Paragraph Number/Title:

Items

For the system(s) chosen for inspection provide:

1

Ongoing Monitoring and Assessment activity performed on the

selected inspection samples system(s).

03.01(a)

2

All Security Control Assessments for the selected system(s).

03.01(a)

3

All vulnerability screenings/assessments associated with or scans

performed on the selected system(s) since the last cyber security

inspection.

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 system(s)

chosen for inspection).

03.02(b)

5

Documentation (including configuration files and rule sets) for intra-

security level firewalls and boundary devices used to protect the

selected system(s).

03.02(c)

6

Copies of all periodic reviews of the access authorization list for the

selected systems since the last cyber inspection.

03.02(d)

7

Baseline configuration data sheets for the selected CDAs.

03.03(a)

8

Documentation on any changes, including Security Impact Analyses,

performed on the selected system(s) since the last inspection.

03.03(b)

9

Copies of the purchase order documentation for any new equipment

purchased for the selected systems since the last inspection.

03.03(c)

10

Copies of any reports/assessment for cyber security drills performed

since the last inspection.

03.02(a)

03.04(b)

11

Copy of the individual recovery plan(s) for the selected system(s)

including documentation of the results the last time the backups

were executed.

03.02(a)

03.04(b)

12

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

5

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 June 27, 2022, the first day of

the inspection. All requested information shall follow the guidance document referenced

above.

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

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 (UFSAR), if not previously provided

b.

original FSAR Volumes

c.

original SER and Supplements

d.

FSAR Question and Answers

e.

Quality Assurance (QA) Plan

f.

Technical Specifications, if not previously provided

g.

latest IPE/PRA Report

(2) Vendor Manuals, Assessment and Corrective Actions:

a.

the most recent Cyber-Security Quality Assurance (QA) audit and/or

self-assessment

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 (QA) audit and/or self-assessment

SUMMER NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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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)

If you have any questions regarding the information requested, please contact the inspection

team leader.