ML20086M006

Information Request for the Cyber Security Inspection and Notification to Perform Inspection 05000327/2020401 and 05000328/2020401

ML20086M006
Person / Time
Site:	Sequoyah
Issue date:	03/26/2020
From:	Scott Shaeffer NRC/RGN-II/DRS/EB2
To:	Jim Barstow Tennessee Valley Authority
References
IR 2020401
Download: ML20086M006 (11)

See also: IR 05000327/2020401

Text

March 26, 2020

Mr. Jim Barstow

Vice President

Tennessee Valley Authority

1101 Market Street, LP 3D-C

Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT - INFORMATION REQUEST FOR THE CYBER-SECURITY

INSPECTION AND NOTIFICATION TO PERFORM INSPECTION 05000327/2020401 and

05000328/2020401

Dear Mr. Barstow:

On July 20, 2020, the U.S. Nuclear Regulatory Commission (NRC) will begin an inspection in accordance

with Inspection Procedure (IP) 71130.10P Cyber-Security, Revision 0 at Sequoyah Nuclear Plant. The

inspection will be performed to evaluate and verify your ability to meet the Milestone 8 (i.e., 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 July 20, 2020, and August 3,

2020.

Experience has shown that these types of 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. 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

via secure site (i.e., SharePoint, Certrec) no later than April 27, 2020. The inspection team will review

this information and, by May 25, 2020, 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

via secure site (i.e., SharePoint, Certrec) before June 24, 2020.

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, July 20, 2020.

J. Barstow

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 Melana Singletary. We understand that our regulatory contact

for this inspection is Mr. Zachary Kitts of your organization. If there are any questions about the

inspection or the material requested, please contact the lead inspector at 404-997-4752 or via e-mail at

Melana.Singletary@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 not 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/

Scott M. Shaeffer, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-327 and 50-328

License Nos. DPR-77 and DPR-79

Enclosure:

Security Inspection Document Request

cc: See Page 3

3

cc:

Jeff Sowa

Site Licensing Manager

Sequoyah Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000, OPS 4C-SQN

Soddy Daisy, TN 37384-2000

Zachary Kitts

Licensing

Sequoyah Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000, OPS 4C-SQN

Soddy Daisy, TN 37384-2000

4

SUBJECT:

SEQUOYAH NUCLEAR PLANT - INFORMATION REQUEST FOR THE CYBER-SECURITY

INSPECTION AND NOTIFICATION TO PERFORM INSPECTION 05000327/2020401 and

05000328/2020401

DISTRIBUTION:

M. Singletary, RII

L. Jones, RII

C. DeBisschop, NSIR

A. Konkal, NSIR

PUBLIC

PUBLICLY AVAILABLE

NON-PUBLICLY AVAILABLE

SENSITIVE

NON-SENSITIVE

ADAMS:

Yes

ACCESSION NUMBER: _ML20086M006

SUNSI REVIEW COMPLETE

FORM 665 ATTACHED

OFFICE

RII/DRS/EB2

RII:DRS/EB2

SIGNATURE

MJS6

SMS

NAME

MSINGLETAR

SSHAEFFER

DATE

3/26/2020

3/26/2020

E-MAIL COPY?

YES

NO

YES

NO

Enclosure

SEQUOYAH NUCLEAR PLANT CYBER SECURITY INSPECTION DOCUMENT REQUEST

Inspection Reports:

05000327/2020401 and 05000328/2020401

Inspection Dates:

Weeks of July 20, 2020, and August 3, 2020

Inspection Procedure:

IP 71130.10P, Cyber-Security, Revision 0

Reference:

ML17156A215, Guidance Document for Development of the Request

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

the Cyber-Security Inspection, Revision 0

NRC Inspectors:

Melana Singletary, Lead

Larry Jones

404-997-4752

404-997-4837

Melana.Singletary@nrc.gov

Larry.Jones@nrc.gov

NRC Contractors:

Cynthia DeBisschop

Al Konkal

Cynthia.DeBisschop@nrc.gov

Alan.Konkal@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 by, April 27, 2020 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 May 25, 2020, 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 by May 25, 2020.

All requests for information shall follow the guidance document ML17156A215 referenced

above.

The required Table RFI 1 information shall be provided via secure site (i.e., Sharepoint, Certrec)

by April 27, 2020. The preferred file format for all lists is object character recognition (OCR)

readable or a searchable Excel spreadsheet file. These files should be indexed and hyper-linked

OFFICIAL USE ONLY - SECURITY RELATED INFORMATION

2

to facilitate ease of use. If you have any questions regarding this information, please call the

inspection team leader as soon as possible.

2

Table RFI #1

Section 3,

Paragraph Number/Title:

Items

1

List All Identified Critical Systems and Critical Digital Assets

All

2

List CDA Facility and Site Ethernet - Transmission Control Protocol/Internet

Protocol (TCP/IP) based Local Area Networks (LANs) and identify those LANs

that have non-CDAs on them

All

3

List CDA facility and site non-ethernet TCP/IP based LANs including those

industrial networks and identify LANs that have non-CDAs on them

All

4

Network Topology Diagrams (be sure to include all NIDS and SIEMs for EP

networks and Security level 3 and 4 networks)

All

8

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

security boundary devices for levels 3 and 4

All

9

List CDA wireless Industrial networks

All

11 Network intrusion detection system documentation for Critical Systems that

have CDAs associated with them

11.a.1)

11.a.2)

12 Security Information and Event Management (SIEM) documentation for

Critical systems that have CDAs associated with them

12.a.1)

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

28

Copy of Current Cyber Security Plan and copy of any 50.54(p) analysis to

support changes to the plan

All

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 May 25, 2020 for the second RFI (i.e., RFI #2).

3

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 May 25, 2020 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 ML17156A215 referenced above.

The Table RFI 2 information shall be provided on secure site (i.e., Sharepoint or Certrec) by May

25, 2020. The preferred file format for all lists is object character recognition (OCR) readable or a

searchable Excel spreadsheet file. These files 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

5 Plant Computer System Block Diagram (if Plant Computer System is selected

for inspection)

All

6 Plant Security System Block Diagram (if Security Computer System is

selected for inspection)

All

7 Systems that are distributed Block Diagrams (for systems selected for

inspection)

All

10 Host-Based Intrusion Detection System Documentation (for CDAs for

systems selected for inspection)

10.a.1)

10.a.2)

13 List all Maintenance and Test Equipment (M&TE) used on CDAs for systems

selected for inspection

All

15 Configuration Management

All

16 Supply Chain Management

16.a.

16.b

17 Portable Media and Mobile Device Control

All

18 Software Management

All

20 Vendor Access and Monitoring

All

21 Work Control

All

OFFICIAL USE ONLY - SECURITY RELATED INFORMATION

4

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 above, provide the following RFI

(i.e., Table 1ST Week Onsite) by July 20, 2020, the first day of the inspection. All requested

information shall follow the guidance document ML17156A215 referenced above.

The preferred file format for all lists is object character recognition (OCR) readable or a

searchable Excel spreadsheet file. These files 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 Host-Based Intrusion Detection System Documentation (for CDAs for

systems selected for inspection)

10.a.3)

thru

10.a.12)

11 Network Intrusion Detection System Documentation for Critical Systems

that have CDAs associated with them

11.a.3)

thru

11.a.15)

12 Security Information and Event Management (SIEM) Documentation for

Critical Systems that have CDAs associated with them

12.a.3)

thru

12.a.14)

16 Supply Chain Management

16.c

19 Cyber-Security Event Notifications

All

5

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 FSAR Volumes;

c. Original SER and Supplements;

d. FSAR Question and Answers;

e. Quality Assurance Plan;

f.

Technical Specifications, if not previously provided; and

g. Vendor Manuals, for applicable systems selected

(2) Assessment and Corrective Actions:

a.

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

self-assessment; and

b.

The last 73.55(m) assessment performed; and

c.

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

corrective actions) generate as a result of the most recent Cyber-Security

Quality Assurance (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.