ML19130A042

Information Request for the Cyber-Security Inspection, Notification to Perform Inspection 05000247/2019403 and 05000286/2019403

ML19130A042
Person / Time
Site:	Indian Point
Issue date:	05/08/2019
From:	Glenn Dentel Engineering Region 1 Branch 2
To:	Vitale A Entergy Nuclear Operations
Dentel G
References
IR 2019403
Download: ML19130A042 (8)

See also: IR 05000247/2019403

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BOULEVARD, SUITE 100

KING OF PRUSSIA, PA 19406-2713

May 8, 2019

Mr. Anthony J. Vitale

Site Vice President

Entergy Nuclear Operations, Inc.

Indian Point Energy Center

450 Broadway, General Services Building

P.O. Box 249

Buchanan, NY 10511-0249

SUBJECT: INDIAN POINT NUCLEAR GENERATING - INFORMATION REQUEST FOR

THE CYBER-SECURITY INSPECTION, NOTIFICATION TO PERFORM

INSPECTION 05000247/2019403 AND 05000286/2019403

Dear Mr. Vitale:

On September 16, 2019, the U.S. Nuclear Regulatory Commission (NRC) will begin a team

inspection in accordance with Inspection Procedure 71130.10P, Cyber-Security, issued

May 15, 2017, at Indian Point Nuclear Generating (Indian Point), Units 2 and 3. 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 (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 September 16, 2019, and

September 30, 2019. Experience has shown that team inspections are extremely resource

intensive, both for the NRC inspectors and the licensee staff. 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 with dates agreed by the site. 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 June 20, 2019. The inspection team will review this information and, by July 19,

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 (CSs/CDAs), 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

August 21, 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, September 16, 2019.

A. Vitale 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 David Werkheiser. We understand that our regulatory

contact for this inspection is George Dahl of your organization. If there are any questions about

the inspection or the material requested, please contact the lead inspector at 610-337-5316 or

via e-mail at David.Werkheiser@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 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/

Glenn T. Dentel, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-247 and 50-286

License Nos. DPR-26 and DPR-64

Enclosure:

Indian Point Nuclear Generating

Cyber-Security Inspection Document Request

cc w/encl: Distribution via ListServ

ML19130A042

Non-Sensitive Publicly Available

SUNSI Review

Sensitive Non-Publicly Available

OFFICE RI/DRS RI/DRS

NAME DWerkheiser GDentel

DATE 5/8/19 5/8/19

INDIAN POINT NUCLEAR GENERATING

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Inspection Report: 05000247/2019403 and 05000286/2019403

Inspection Dates: September 16 - 20 and September 30 - October 4, 2019

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

Reference: Guidance Document for Development of the Request for

Information (RFI) and Notification Letter for Full-Implementation of

the Cyber Security Inspection, Issue Date October 26, 2017

NRC Inspectors: David Werkheiser, Lead Louis Dumont

610-337-5316 610-337-5183

David.Werkheiser@nrc.gov Louis.Dumont@nrc.gov

NRC Contractors: Alan Konkal William (Bill) Johns

Alan.Konkal@nrc.gov William.Johns@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 (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 to the regional office by

June 20, 2019, 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 July 19, 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. We request that the additional information provided from

the second RFI be made available to the regional office by August 21, 2019. All

requests for information responses shall follow the RFI table matrix and the guidance

document referenced above.

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

lead inspector by June 20, 2019. Please provide four 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 on a CD. 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.

1 Enclosure

INDIAN POINT NUCLEAR GENERATING

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table RFI #1

Reference Section 3,

Paragraph Number/Title: Items

1 List All Identified Critical Systems and Critical Digital Assets All

List CDA Facility and Site Ethernet - Transmission Control

2 Protocol/Internet Protocol (TCP/IP) Based Local Area Networks All

(LANs) and Identify Those LANs That Have Non-CDAs On Them

List CDA Facility and Site Non-Ethernet TCP/IP Based LANs Including

3 Those Industrial Networks and Identify LANs That Have Non-CDAs On All

Them

Network Topology Diagrams (Be Sure To Include all Network Intrusion

Detection Systems (NIDS) and Security Information and Event

4 All

Management (SIEMs) for Emergency Preparedness (EP) networks

and Security Level 3 and 4 Networks)

List All Network Security Boundary Devices for EP Networks and All

8 All

Network Security Boundary Devices for Levels 3 and 4

9 List CDA Wireless Industrial Networks All

NIDS Documentation for Critical Systems That Have CDAs Associated 11.a.1)

11 with Them

11.a.2)

SIEM Documentation for Critical systems That Have CDAs Associated 12.a.1)

12 with Them

12.a.2)

List EP and Security Onsite and Offsite Digital Communication

14 All

Systems

Cyber Security Assessment and Cyber Security Incident Response

25 All

Teams

In addition to the above information please provide the following:

(1) Electronic copy of your current Cyber Security Plan.

(2) Electronic copy of summary of changes (if any), including any 10 CFR 50.54p

analysis to support those changes, made to the originally approved Cyber

Security Plan.

(3) Electronic copy of a matrix that summarizes what controls are in place to satisfy

the controls required by Policies and Procedures.

(4) Electronic copy of the Updated Final Safety Analysis Report and Technical

Specifications.

(5) Name(s) and phone numbers for the regulatory and technical contacts.

(6) Current management and engineering organizational charts.

(7) In a separate directory, an electronic copy of the documents listed in the matrix

from (3) above.

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INDIAN POINT NUCLEAR GENERATING

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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

will submit a list of specific systems and equipment to your staff by July 19, 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 July 19, 2019, 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 your stations 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 Table

RFI #2 and the guidance document referenced above.

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

August 21, 2019. Please provide four 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 on a CD. 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

Section 3,

Paragraph Number/Title: Items

Plant Computer System Block Diagram (If Plant Computer System Is

5 All

Selected for Inspection)

Plant Security System Block Diagram (If Security Computer System Is

6 All

Selected for Inspection)

Systems That Are Distributed Block Diagrams (For Systems Selected

7 All

For Inspection)

10.a.1)

Host-Based Intrusion Detection System Documentation (For CDAs for

10

Systems Selected for Inspection)

10.a.2)

List all Maintenance and Test Equipment Used On CDAs for Systems

13 All

Selected for Inspection

15 Configuration Management All

16.b.

16.c.1)

16 Supply Chain Management

16.c.5)

16.c.6)

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

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INDIAN POINT NUCLEAR GENERATING

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table RFI #2

Section 3,

Paragraph Number/Title: Items

24 User Account/Credential Policy All

26 Corrective Actions Since Last NRC Inspection All

In addition to the above information please provide the following:

(1) The documented CSP assessment and analysis for each CDA in each of the

selected systems.

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 a CD by September 16, 2019, the first

day of the inspection. All requested information shall follow the Table: 1ST Week Onsite

and the guidance document referenced above.

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

CD 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

Section 3,

Paragraph Number/Title: Items

10.a.3)

Host-Based Intrusion Detection System Documentation for CDAs

10 thru

for systems selected for inspection

10.a.12)

11.a.3)

NIDS Documentation for Critical Systems That Have CDAs

11 thru

Associated with Them

11.a.15)

12.a.3)

SIEM Documentation for Critical Systems That Have CDAs

12 thru

Associated with Them

12.a.14)

16.c.2)

16 Supply Chain Management 16.c.3)

16.c.4)

19 Cyber Security Event Notifications All

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;

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INDIAN POINT NUCLEAR GENERATING

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

c. Final Safety Analysis Report Question and Answers;

d. Quality Assurance (QA) Plan;

e. Latest Individual Plant Examination for External Events / Probabilistic Risk

Assessment Report; and

f. Vendor Manuals.

(2) 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.

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