ML23046A095

Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection 05000443/2023401

ML23046A095
Person / Time
Site:	Seabrook
Issue date:	02/15/2023
From:	Glenn Dentel Division of Operating Reactors
To:	Coffey B Florida Power & Light Co
References
IR 2023401
Download: ML23046A095 (1)

See also: IR 05000443/2023401

Text

February 15, 2023

Bob Coffey

Executive Vice President, Nuclear Division

and Chief Nuclear Officer

Florida Power & Light Company

700 Universe Blvd.

Mail Stop: EX/JB

Juno Beach, FL 33408

SUBJECT: SEABROOK STATION - INFORMATION REQUEST FOR THE CYBER

SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM

INSPECTION 05000443/2023401

Dear Bob Coffey:

On July 24, 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 your Seabrook Station. 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

July 24- 28, 2023.

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 IP 71130.10. This information should be

made available either on an online repository (preferred) or digital media (CD/DVD) no later

than April 14, 2023. The inspection team will review this information and, by May 19, 2023 , 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 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 June 23, 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, July 24, 2023.

B. Coffey 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 Jeff Rady. We understand that our regulatory contact for

this inspection is Joshua Greene of your organization. If there are any questions about the

inspection or the material requested, please contact the lead inspector at (610) 337-53 80 or via

email at Jeff.Rady@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 we bsite at

http://www.nrc.gov/reading- rm/adams.html (the Public Electronic Reading Room).

Sincerely,

Glenn T. Dentel, Chief

Engineering Branch 2

Division of Operating Reactor Safety

Docket Nos. 05000443

License Nos. NPF-86

Enclosure:

Cyber Security Inspection Document Request

cc: Distribution via ListServ

B. Coffey 3

SUBJECT: SEABROOK STATION - INFORMATION REQUEST FOR THE CYBER

SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM

INSPECTION 05000443/2023401 DATED FEBRUARY 15, 2023

DISTRIBUTION:

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DOCUMENT NAME: https://usnrc.sharepoint.com/teams/EngineeringBranch2/Shared Documents/Cyber Security/_Baseline

Inspections - OUO_SRI/2023/Seabrook/RFI Letter/Seabrook Cyber Security RFI 1.docx

ADAMS ACCESSION NUMBER: ML23046A095

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OFFIAL RERD COPY

SEABROOK STATION CYBER SECURITY INSPECTION DOCUMENT REQUEST

Inspection Report: 05000443/2023401

Inspection Dates: July 24- 28, 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: Jeff Rady, Lead Brandon Pinson

(610) 337-53 80 (610) 337-5 091

Jeff.Rady@nrc.gov Brandon.Pinson@nrc.gov

NRC Contractors: Tim Hennessey TBD

Timothy.Hennessey@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 April 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 May 19, 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 June 23, 2023.

Enclosure

SEABROOK STATION 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 April 14, 2023. The

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

should be indexed and hyperlinked 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 -

1 highlight/note any additions, deletions or reclassifications due to new Overall

guidance from white papers, changes to NEI 10-04, 13-10, etc. since the last

cyber security inspection.

2 A list of emergency preparedness and Security onsite and offsite digital Overall

communication systems.

3 Network Topology Diagrams to include information and data flow for 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)

11 Portable Media and Mobile Device control documentation, including kiosk 03.02(e)

security control assessment/documentation.

Design change/ modification program documentation and a List of all

12 design changes completed since the last cyber security inspection, including 03.03(a)

either a summary of the design change or the 50.59 documentation for the

change.

03.03(a),

13 Supply Chain Management documentation including any security impact analysis for new acquisitions. (b) and

(c)

14 Configuration Management documentation including any security impact 03.03(a)

analysis performed due to configuration changes since the last inspection. and (b)

15 Cyber Security Plan and any 50.54(p) analysis to support changes to the 03.04(a)

plan since the last inspection.

16 Cyber Security Metrics tracked (if applicable). 03.06 (b)

17 Provide documentation describing any cyber security changes to the access Overall

authorization program since the last cyber security inspection.

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

descriptive name and associated number (if available).

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SEABROOK STATION CYBER SECURITY INSPECTION DOCUMENT REQUEST

Table RFI #1

Section 3,

Paragraph Number/Title: IP Ref

19 Performance testing report (if applicable). 03.06 (a)

In addition to the above information please provide the following:

(1) Electronic copy of the U pdated F inal S afety Analysis R eport 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 19, 202 3, 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 May 19, 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 June 23, 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-

4 based Intrusion Detection/Protection Systems (NIDS/NIPS), Host- based 03.02(b)

Intrusion Detection Systems (HIDS), and Security Information and Event

Management (SIEM) systems for system(s) chosen for inspection).

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SEABROOK STATION CYBER SECURITY INSPECTION DOCUMENT REQUEST

Table RFI #2

Section 3,

Paragraph Number/Title: Items

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).

6 Copies of all periodic reviews of the access authorization list for the 03.02(d)

selected systems since the last inspection.

7 Baseline configuration data sheets for the selected CDAs. 03.03(a)

8 Documentation on any changes, including Security Impact Analyses, 03.03(b)

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

9 Copies of the purchase order documentation for any new equipment 03.03(c)

purchased for the selected systems since the last inspection.

10 Copies of any reports/assessment for cyber security drills performed since 03.02(a)

the last inspection. 03.04(b)

11 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.

13 For the selected systems, provide design change/modification packages 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 1 ST Week Onsite) to the team by July 24, 2023 , the first day of

the inspection.

Table 1ST Week Onsite

Section 3,

Paragraph Number/Title: Items

1 Any cyber security event reports submitted in accordance with 10 CFR 03.04(b)

73.77 since the last cyber security inspection.

Updated Copies of corrective actions taken as a result of cyber security

2 incidents/issues, to include previous NRC violations and Licensee 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;

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SEABROOK STATION CYBER SECURITY INSPECTION DOCUMENT REQUEST

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/p robabilistic risk assessment report.

(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) generate 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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