ML24123A201

NRC Cybersecurity Baseline Inspection (NRC Inspection Report 05000259/2024404, 05000260-2024404, 05000296/2024404) and Request for Information

ML24123A201
Person / Time
Site:	Browns Ferry
Issue date:	05/02/2024
From:	Daniel Bacon Division of Reactor Safety II
To:	Jim Barstow Tennessee Valley Authority
References
IR 2024404
Download: ML24123A201 (10)

See also: IR 05000259/2024404

Text

Mr. James Barstow

Vice President, Nuclear Regulatory Affairs and Support Services

Tennessee Valley Authority

1101 Market Street, LP 4A-C

Chattanooga, TN 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT UNITS 1, 2 & 3 - NOTIFICATION OF AN

NRC CYBERSECURITY BASELINE INSPECTION (NRC INSPECTION

REPORT 05000259/2024404, 05000260/2024404, 05000296/2024404) AND

REQUEST FOR INFORMATION (RFI)

Dear James Barstow:

On July 29, 2024, 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 Browns Ferry 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 week of July 29th, 2024.

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 via compact disc and delivered to the regional office no later than June 14,

2024. The inspection team will review this information and, by June 21, 2024, 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 July 19, 2024 as

identified above.

May 2, 2024

J. Barstow

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.

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 Jonathan Montgomery. We understand that our

regulatory contact for this inspection is Baruch Calkin of your organization. If there are any

questions about the inspection or the material requested, please contact the lead inspector at

(404) 997-4880 or via e-mail at jonathan.montgomery@nrc.gov.

This letter contains mandatory information collections that are subject to the Paperwork

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB)

approved these information collections under approval number 3150-0011. The burden to the

public for these information collections is estimated to average 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />(s) per response. Send

comments regarding this information collection to the FOIA, Library and Information Collection

Branch, Office of the Chief Information Officer, Mail Stop: T6-A10M, U.S. Nuclear Regulatory

Commission, Washington, DC 20555-0001, or by email to Infocollects.Resource@nrc.gov, and

to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0011)

OMB, Washington, DC 20503.

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.

J. Barstow

3

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,

Daniel Bacon, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-259, 50-260, 50-296

License No. DPR-33, DPR-52, DPR-68

Enclosures:

Browns Ferry Cyber Security Inspection

Document Request

cc w/ enclosure: Distribution via LISTSERV

Signed by Bacon, Daniel

on 05/02/24

ML24123A201

X

SUNSI Review

X

Non-Sensitive

Sensitive

X

Publicly Available

Non-Publicly Available

OFFICE

RII/DRS

RII/DRS

NAME

J. Montgomery

D. Bacon

DATE

5/2/24

5/2/24

BROWNS FERRY CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Enclosure

Inspection Report: 05000259/2024404; 05000260/2024404; 05000296/2024404

Inspection Dates:

Week of July 29, 2024

Inspection Procedure:

IP 71130.10, Cyber-Security, Revision 0

Reference:

ML21330A088, Guidance Document for Development of the

Request for Information (RFI) and Notification Letter for

Full-Implementation of the Cyber-Security Inspection,

Revision 2D

NRC Inspectors:

Jonathan Montgomery, Lead

Ellery Coffman

404-997-4880

404-997-4633

jonathan.montgomery@nrc.gov

ellery.coffman@nrc.gov

NRC Contractors:

James Hendricks

Michael Shock

james.hendricks@nrc.gov

michael.shock@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 to the regional office by June 14, 2024, 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 June 21, 2024, 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 July 19, 2024. All

requests for information shall follow the guidance document referenced above. Items

that have been struck through do not require a response. Bold items denote items that

are not explicitly referenced in the guidance document above.

J. Barstow

4

The required Table RFI 1 information shall be provided on either digital media (CD/DVD)

or an online repository to the lead inspector by June 14, 2024. 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

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 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 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 documentation including any security

impact analysis for new acquisitions

03.03(a)

, (b) and

(c)

14

Configuration Management documentation including any security

impact analysis performed due to configuration changes since the last

inspection

03.03(a)

and (b)

BROWNS FERRY CYBER-SECURITY INSPECTION DOCUMENT REQUEST

3

Table RFI #1

Section 3,

Paragraph Number/Title:

IP Ref

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 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)

20

Any cybersecurity event reports submitted in accordance with

10 CFR 73.77 since the last cybersecurity inspection and any

copies of any recordable cybersecurity events since the last

inspection

03.04(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 June 21, 2024 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 June 21, 2024 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. Items that have been struck through do not require a

response. Bold items denote items that are not explicitly referenced in the guidance

document above.

J. Barstow

4

The Table RFI #2 information shall be provided to the lead inspector by July 19, 2024.

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)

3

All vulnerability screenings/assessments associated with, or scans

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

inspection *

All vulnerability screenings and assessments completed prior

to putting new equipment into service as part of the select

design changes

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 (i.e. the devices that are credited for protection

for the selected systems) *

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 inspection

03.02(d)

7

Baseline configuration data sheets for the selected CDAs and for

selected design changes *

03.03(a)

8

Security Impact Analyses performed for selected design changes

03.03(b)

9

Copies of the purchase order documentation for selected design

changes

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)

BROWNS FERRY CYBER-SECURITY INSPECTION DOCUMENT REQUEST

5

Table RFI #2

Section 3,

Paragraph Number/Title:

Items

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

03.04(d)

13

The most recent Cybersecurity Quality Assurance audit and/or

self-assessment and a list of Corrective Actions generated as a

result

• Some selected systems may have a large number of CDAs. For these systems reach

out to the team leader for a specific selection of CDAs when responding to this request.

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 July 29, 2024, the first day of

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

above. Items that have been struck through do not require a response. Bold denotes

items that are not explicitly referenced in the guidance document 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 1ST Week Onsite

Section 3,

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

03.04(d)

3

Copies of corrective actions written for issues identified since

receipt of RFI #1.

03.04(d)

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.

J. Barstow

4

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;

g.

Latest IPE/PRA Report; and

(2) Vendor Manuals, Assessment and Corrective Actions:

a.

The most recent Cyber-Security Quality Assurance (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

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 leader.