ML23220A018

Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection 05000352/2023401 and 05000353/2023401

ML23220A018
Person / Time
Site:	Limerick
Issue date:	08/08/2023
From:	Glenn Dentel NRC/RGN-I/DORS
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2023401
Download: ML23220A018 (1)

See also: IR 05000352/2023401

Text

August 8, 2023

David P. Rhoades

Senior Vice President

Constellation Energy Generation, LLC

President and Chief Nuclear Officer (CNO)

Constellation Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: LIMERICK GENERATING STATION, UNITS 1 AND 2 - INFORMATION

REQUEST FOR THE CYBERSECURITY BASELINE INSPECTION,

NOTIFICATION TO PERFORM INSPECTION 05000352/2023401 AND

05000353/2023401

Dear David Rhoades:

On December 4, 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 Limerick Generating Station, Units 1 and 2. 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 December 4 - 8, 2023.

Experience has shown that baseline 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 IP 71130.10. This information should be

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

than September 15, 2023. The inspection team will review this information and, by

October 13, 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 cybersecurity program selected for the cybersecurity inspection.

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

November 10, 2023, as identified above.

D. Rhoades 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, December 4, 2023.

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 Brandon Pinson. We understand that our regulatory

contact for this inspection is Rod Wheeler of your organization. If there are any questions about

the inspection or the material requested, please contact the lead inspector at (610) 337-5091 or

via email at Brandon.Pinson@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 website at

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

Sincerely,

Digitally signed by Glenn

Glenn T. T. Dentel

Date: 2023.08.08

Dentel 07:19:12 -04'00'

Glenn T. Dentel, Chief

Engineering Branch 2

Division of Operating Reactor Safety

Docket Nos. 05000352 and 05000353

License Nos. NPF-39 and NPF-85

Enclosure:

Cybersecurity Inspection Document Request

cc: Distribution via ListServ

ML23220A018

Non-Sensitive Publicly Available

SUNSI Review

Sensitive Non-Publicly Available

OFFICE RI/DORS RI/DORS

NAME BPinson GDentel

DATE 8/1/2023 8/7/2023

LIMERICK CYBERSECURITY INSPECTION DOCUMENT REQUEST

Inspection Report: 05000352/2023401 and 05000353/2023401

Inspection Dates: December 4 - 8, 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: Brandon Pinson, Lead Manan Patel

(610) 337-5091 (610) 337-5304

Brandon.Pinson@nrc.gov Manan.Patel@nrc.gov

NRC Contractors: Louis Manning Alan Konkal

(610) 337-5044 Alan.Konkal@nrc.gov

Louis.Manning@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

September 15, 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 October 13, 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

November 10, 2023.

Enclosure

LIMERICK CYBERSECURITY 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 September 15, 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 -

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

1 Overall

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

cyber security inspection.

A list of emergency preparedness and Security onsite and offsite digital

2 Overall

communication systems.

Network Topology Diagrams to include information and data flow for

3 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 Password/Authenticator documentation. 03.02(c)

Design change/modification program documentation and a list of all design

changes completed since the last two cyber security inspections, including

7 03.03(a)

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

change.

03.03(a),

Supply Chain Management documentation including any security impact

8 (b) and

analysis for new acquisitions.

(c)

Configuration Management documentation including any security impact 03.03(a)

9

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

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

10 03.04(a)

plan since the last inspection.

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

Provide documentation describing any cyber security changes to the access

12 Overall

authorization program since the last cyber security inspection.

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

13 Overall

descriptive name and associated number (if available).

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

Corrective actions taken as a result of cyber security incidents/issues to

15 include previous NRC violations and Licensee Identified Violations since two 03.05

last cyber security inspections

List of cybersecurity related IRs initiated since the last cybersecurity

16 inspection to include date written, IR title, and IR status (Excel format 03.05

preferred)

In addition to the above information please provide the following:

2

LIMERICK CYBERSECURITY INSPECTION DOCUMENT REQUEST

(1) Electronic copy of the Updated Final Safety Analysis Report 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 October 13, 2023, 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 October 13, 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

November 10, 2023. The preferred file format for all lists is a searchable Excel

spreadsheet. 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 #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-

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

4 03.02(b)

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

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

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).

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

6 03.02(d)

selected systems since the last inspection.

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

Documentation on any changes, including Security Impact Analyses,

8 03.03(b)

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

3

LIMERICK CYBERSECURITY INSPECTION DOCUMENT REQUEST

Table RFI #2

Section 3,

Paragraph Number/Title: Items

Copies of the purchase order documentation for any new equipment

9 03.03(c)

purchased for the selected systems since the last inspection.

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

10

the last inspection. 03.04(b)

Copy of the individual recovery plan(s) for the selected system(s) including 03.02(a)

11

documentation of the results the last time the backups were executed. 03.04(b)

For the selected systems, provide design change/modification packages

12 03.03(a)

including completed work orders since the last cyber security inspection.

13 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)

14 plan development, implementation and including any program and

documentation that requires testing of security boundary device 03.04(b)

functionality

15 Device Access and Key Control documentation 03.02(c)

16 User Account/Credential documentation 03.02(d)

Portable Media and Mobile Device control documentation, including kiosk

17 03.02(e)

security control assessment/documentation

03.03(a)

Configuration Management documentation including any security impact

18 and

analysis performed due to configuration changes since the last inspection

03.03(b)

Provide documentation describing any cyber security changes to the

19 Overall

access authorization program 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 1ST Week Onsite) to the team by December 4, 2023, the first

day of the inspection.

Table 1ST Week Onsite

Section 3,

Paragraph Number/Title: Items

Any cyber security event reports submitted in accordance with 10 CFR

1 03.04(b)

73.77 since the last cyber security inspection.

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

incidents/issues, to include previous NRC violations and Licensee

2 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:

4

LIMERICK CYBERSECURITY INSPECTION DOCUMENT REQUEST

(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 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/probabilistic 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.

5