ML17284A130

FOIA/PA-2017-0674 - Resp 1 - Final. Agency Records Subject to the Request Are Enclosed

ML17284A130
Person / Time
Site:	Rhode Island Atomic Energy Commission
Issue date:	10/06/2017
From:	Argent N NRC/OCIO
To:	Turco D Cape Downwinders
Shared Package
ML17284A118	List: ML17284A125 ML17284A130
References
FOIA/PA-2017-0674
Download: ML17284A130 (14)

Text

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\'i NRC FORM 464 Part I U.S. NUCLEAR REGULATORY COMMISSION FOIA RESPONSE NUMBER (03-2017) ~~~RllEQ(f(-f *;

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RESPONSE TO FREEDOM OF I 2017-0674 11 1

I INFORMATION ACT (FOIA) REQUEST

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RESPONSE

TYPE D INTERIM [{} FINAL REQUESTER: DATE:

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!Diane Turco 11 10/06/2017 I " 'II

'i DESCRIPTION OF REQUESTED RECORDS:

Pilgrim Nuclear Power Station, "The Problem Identification and Resolution Sample Inspection Report 05000293/2017405"

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PART I. -- INFORMATION RELEASED

, You have the right to seek assistance from the NRC's FOIA Public Liaison. Contact information '

for the NRC's FOIA Public Liaison '

is available at httgs://www.nrc.gov/reading-rm/foia/contact-foia.html

• o Agency records subject to the request are already available on the Public NRC Website, in Public ADAMS or on microfiche in the NRC Public Document Room.

[{] Agency records subject to the request are enclosed. ..

Records subject to the request that contain information originated by or of interest to another Federal agency have been D referred to that agency (see comments section) for a disclosure determination and direct response to you.

D We are continuing to process your request.

[{] See Comments.

I PART I.A -- FEES NO FEES D

AMOUNT" You will be billed by NRC for the amount listed.

[{] Minimum fee threshold not met.

II II D You will receive a refund for the amount listed.

D Due to our delayed response, you will "See Comments for details D Fees waived. not be charged fees.

PART 1.8--INFORMATION NOT LOCATED OR WITHHELD FROM DISCLOSURE We did not locate any agency records responsive to your request. Note: Agencies may treat three discrete categories of law

• D enforcement and national security records as not subject to the FOIA ("exclusions"). 5 U.S.C:552(c). This is a standard notification given to all requesters; it should not be taken to mean that any excluded records do, or do not, exist. I.:*

[{] We have withheld certain information pursu~nt to the FOIA exemptions described, and for the reasons stated, in Part II~

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Because this is an interim response to your request, you may not appeal at this time'. We will notify you of your right to D appeal any of the responses we have issued in response to your request when we issue our final determination.

You may appeal this final determination within 90 calendar days of the date of this response by sending a letter or e-mail to the FOIA Officer, at U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001, or FOIA.Resource@nrc.gov. Please be

[{] sure to include on your letter or email that it is a "FOIA Appeal." You have the right to seek dispute resolution* services from the NRC's Public Liaison, or the Office of Government Information Services (OGIS). Contact information for OGIS is available at httgs://ogis.archives.gov/about-ogis/contact-information.htm PART l.C COMMENTS ( Use attached Comments continuation page if required)  :

The NRC's letter transmitting the enclosed [redacted] report may be found ill public ADAMS as ML17244A109. :Records I with an ML Accession Number are publicly available in ti1e NRC's Public Electronic Reading Room at http:www:nrc.gov/

reading-rm.html. If you need assistance in obtaining these records, please contact the NRC's Public Document Room (PDR) at 301-415-4737, or 1-800-397-4209, or by email to PDR.Resource@nrc.gov.

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Signature - Freedom of Information Act Officer or Designee .; ,f I DigltallysignedbyNlnaArgent l

I INina Argent DN: c==US, o:U.S. Government, ou=U.S. Nuclear Regulatory Commission, ou=NRC-SW, cn"'-Nina Argent, 0.9.2342.19200300.100.1, 1=200013425 i: Date: 2017.10.0614:30:57-04'00'  ;

I' NRG Form 464 Part I (03-2017) j, Ad,d Coritiriuation Pag~ I -.**---~**- ~7**-*-* -*-** --*

Page 2 of 2 I

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NRC FORM 464 Part II U.S. NUCLEAR REGULATORY COMMISSION FOIA (03-2017)

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i RESPONSE TO FREEDOM.OF I 2017-0674 I ,,

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• INFORMATION ACT (FOIA) REQUEST DATE

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I I I 10/06/2017 I 'i*f PART II.A -- APPLICABLE EXEMPTIONS Records subject to the request are being withheld in their entirety or in part under the FOIA exemption(s) as indicated below (5 U.S.C. 552(b)).

D Exemption 1: The withheld information is properly classified pursuant to an Executive Order.protecting national security information.

D Exemption 2: The withheld information relates solely to the internal personnel rules and practices of NRC.

D Exemption 3: The withheld information is specifically exempted from public disclosure by the statute indicated.

D Sections 141-145 of the Atomic Energy Act, which prohibits the disclosure of Restricted Data or Formerly Restricted Data (42 U.S.C. 2161-216q).

D Section 147 of the Atomic Energy Act, which prohibits the disclosure of Unclassified Safeguards Information (42 U.S.C. 2167).

41 U.S.C. 4702(b), which prohibits the disclosure of contractor proposals, except when incorporated into the contract between the agency and the D submitter of the proposal.

Exemption 4: The withheld information is a trade secret or confidential commercial or financial information that is being withheld for the reason(s)  ;

D indicated. '

The information is considered to be proprietary because it concerns a licensee's or applicant's physical protection or material control and D accounting program for special nuclear material pursuant to 10 CFR 2.390(d)(1 ).

D The infonmation is considered to be another type or confidential business (proprietary) information.

D The information was submitted by a foreign source and received in confidence pursuant to 10 CFR 2.390(d)(2).

D Exemption 5: The withheld. information consists of interagency or intraagency records that are normally privileged in civil litigation.

D Deliberative process privilege.

i ;;

D Attorney work product privilege.

D Attorney-client privilege. - /

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Exemption 6: The withheld information from a personnel, medical, or similar file, is exempted from public disclosure because its disclosure would result D in a clearly unwarranted invasion of personal privacy.

0 Exemption 7: The withheld information consists of records compiled for law enforcement purposes and is being withheld for the reason(s) indicated~ :I

I D (A) Disclosure could reasonably be expected to interfere with an open enforcement proceeding. 'I D (C) Disclosure could reasonably be expected to constitute an unwarranted invasion of personal privacy.

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(D) The information consists of names and other information the disclosure of which could reasonably be expected to reveal identities of 'confid!imtial D sources.

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(E) Disclosure would reveal techniques and procedures for law enforcement investigations or prosecutions, or guidelines that could reasonably be D expected to risk circumvention of the law.

0 (F) Disclosure could reasonably be expected to endanger the life or physi.cal safety of an individual.

i.

D Other I I PART 11.B -- DENYING OFFICIALS In accordance with 10 CFR 9.25(g) and 9.25(h) of the U.S. Nuclear Regulatory Commission regulations,. the.

official(s) listed below have made the determination to withhold certain information responsive to your request APPELLATE Off!CIAL DENYING OFFICIAL TITLE/OFFICE RECORDS DENIED EDD SECY INina E. Argent I IActing FOIA Officer I Isecurity-related information I 0 D

,I 11 I D D I 11 I D, D .*,[

Appeals must be made in writing within 90 calendar days of the date of this response by sending a letter or email to the FOIA Officer, at U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001, or*

FOIA.Resource@nrc.gov. Please be sure to include on your letter or email that it is a "FOIA Appeal."

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NRC Form 464 Part II (03-2017) Page 1 of 1

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U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket No. 50-293 License No. DPR-35 Report No. 05000293/2017405 Licensee: Entergy Nuclear Operations, Inc. (Entergy)

Facility: Pilgrim Nuclear Power Station (Pilgrim)

Location: 600 Rocky Hill Road Plymouth, MA 02360 Dates: June 5 - 8, 2017 July 5 - 7, 2017 August 7 - 11, 2017 Inspectors: L. Dumont, Reactor Inspector Approved by: Glenn T. Dentel, Chief Engineering Branch 2 Division of Reactor Safety Enclosure QFFIGIAI:: WGli Q~U:Y GliGWRJJY Rl51::A=Fli9 ltlF9RMMIQ~J

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SUMMARY

IR 05000293/2017405; 06/05/2017 - 06/08/2017, 07/05/2017 - 07/07/2017, 08/07/2017 -

08111/2017; Pilgrim; Problem Identification and Resolution.

The report covered a cyber security problem identification and resolution sample inspection by a region-based inspector. Two NRG-identified findings were identified. These findings were discussed and reviewed during the Security Issues Forum meeting conducted on July 27, 2017.

The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process," dated April 29, 2015. Cross-cutting aspects are determined using I.MC 0310, li'; I 1\

"Aspects Within the Cross-Cutting Areas," dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRC's Enforcement Policy, dated November 1, 2016. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6, dated July 2016.

A. NRC-ldentified Findings Cornerstone: Physical Security

• Green. The inspector identified a finding of very low cyber security significance (Green) involving a non-cited violation (NCV) of Title 10 of the Code of Federal Regulations 10 CFR) 73.55(b)(10), for the failure to perform adequate corrective action (b)(7)(F)

- - - Entergy entered these issues into their corrective action program (CAP) as condition reports (CRs) (PNP-2017~05997, 06020, 06035, 06047, 06050, and 06191).

This finding was more than minor because it was associated with th (b)(7)(F) e inspector evaluated the finding in accordance with NRC IMC 0609, "S1gni 1cance etermination Process," Appendix E:J-'.!:P~au.rtJ.:IV~"~.1.11;:1--1 Security Significance Determination Process," and determined tha (b)(7)(F)

As a result, this finding was determined to be

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of very low safety significance (Green). This finding had a cross-cutting aspect in the area of Problem Identification and Resolution, specifically Resolution, because Entergy did not take effective correctjye action to resolve and correct a oreyjous NRG-identified violation for the failure tol (bJ(7J(Fl

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• Green. The inspector identified a violation of very low safety significance (Green) involving an NCV of 10 CFR 73.55(b)(4), for the failure to perform a;::.:d::.::e~=~.::::..J."""""""'f.,

I, site specific conditions, includin tar et sets. S ecificall , Enter (b)(7)(F)

This finding was more than minor because it was associated with the Response to Contingency Events (Implementation of the Protective Strategy) attribute of the Security cornerstone, and it adversely affected the cornerstone objective to provide assurance that the licensee's security system could protect against !!thl.§eLld;;!!e~smiJWOal>>S..lll1"E!.al;.Q.l.--1 radiolo ical sabota e from external threats. Specifically, (b)(7)(F)

The inspector

~ev:-:-a=i:-:u=atr::e:-:J""ltr=e,.1~n-:r.::1n:-::g:""!1~n-::a:-::c~c=or=a:-::n~c-=-e-:".w-:!1t;i::-;rrn"l"'7':~~.""'ll"!'..-,g:'.".n'.:"!11'!"1c::--:a::-:n:-::c:-::e:--po;'e~termination Process," Appendix E, Part I, "Baseline Security Significance Determination Process for Power Reactors." The inspector determined that the negative impact the performance deficiency had on the probability of physical protection effectiveness was very low, because the modification did not require the licensee to make any changes to their I'

protective strategy. As a result, this finding was determined to be of very low safety i significance (Green). This finding had a cross-cutting aspect in the area of Problem I Identification and Resolution, Evaluation, because Ente did not ade uatel

• evaluate I thei (b)(7)(F)

B. Other Findings None.

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REPORT DETAILS

Background

During 2013 through 2015, the NRG performed a programmatic review of each licensee's implementation of the their cyber security program to assess and verify that interim Milestones 1 through 7 of the licensee's cyber security program implementation schedule had been adequately completed in accordance with the regulatory requirements of 10 CFR 73.54, "Protection of Digital Computer and Communication Systems and Networks," the licensee's CSP, and NRG approved implementation schedules.

4. OTHER ACTIVITIES [OA]

40A2 Identification and Resolution of Problems (71152 - 1 sample)

a. Inspection Scope The inspector performed an in-depth review of Entergy's evaluations and corrective actions for findings previously identified during the conduct of Temporary Instruction (Tl) 2201/004 at Pilgrim. Four NRC-identified findings were documented for Milestone 2, 3, 4, and 6. The inspector specifically reviewed issues associated with these four Milestones within the scope of this inspection.

The inspector assessed Entergy's problem identification threshold, problem analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of corrective actions to determine whether Entergy was appropriately identifying, characterizing, and correcting problems associated .with the NRG-identified findings identified during the Tl 2201/004 inspection, and whether the planned or completed corrective actions were appropriate. The inspector compared the actions taken to the requirements of Entergy's CAP and the facility CSP.

The inspector reviewed cyber security records and implementing program procedures, and interviewed cyber security, physical security, engineering, and operations personnel to assess the effectiveness of the implemented corrective actions, the reasonableness of .

the planned corrective actions. and to evaluate the extent of any ongoing problems.

Milestone 2: Identification & Documentation of Critical Systems & Critical Digital Assets Milestone 2 required licensees to identify and document critical systems and CDAs as described in CSP Section 3.1.3, "Identification of Critical Digital Assets." These systems and digital assets included digital computer and communication systems and networks associated with safety-related and important to safety functions, security functions, emergency preparedness functions (including off-site communications), and support systems and equipment which, if compromised, would adversely impact SSEP functions.

These systems and assets also included additional structures, systems, and components that have a nexus to radiological health and safety and therefore can directly or indirectly affect reactivity of a nuclear power plant and could result in an unplanned reactor shutdown or transient.

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Milestone 3: Installation of a Protective Device between Lower & Higher Security Levels Milestone 3 required licensees to install deterministic one-way devides (e.g., data diodes) between computer networks at a lower security level (i.e., levels 0, 1, and 2) and a higher security level {i.e., levels 3 and 4), as described in CSP Section 4.3, "Defense-In-Depth Protective Strategies." Any lower security level device that bypassed the deterministic device and connected to level 3 or 4 were required to be modified to eliminate the bypass, or modified to meet cyber security requirements commensurate with the higher security level network to which they connect. Milestone 3 also required that any design modification not completed by the required interim implementation date be documented in the site configuration management and ~hange control program to assure completion of the design modification as soon as possible, but no later than the final implementation date.

Milestone 4: Implementation of Access Control for Portable and Mobile Devices Milestone 4 required licensees to implement technical security controls for portable and mobile devices as described in Appendix D, Section 1.19, "Access Control for Portable and Mobile Devices," of Nuclear Energy Institute {NEI} 08-09, "Cyber Security Plan for Nuclear Power Reactors," Revision 6. Those controls, in part, requires the licensee to establish and document usage restrictions and implementation guidance for controlled portable and mobile devices; authorize, monitor, and control device access to CDAs;

• enforce and document mobile device security and integrity at a level consistent with the CDA they support; and enforce and document that mobile devices are used in one security level and are not moved between security levels.

Milestone 6: Implementation of Cyber Security Controls for Critical Digital Assets that could Adversely Impact the Design Function of Target Set Equipment Milestone 6 required licensees to identify, document, and implement technical cyber security controls for CDAs that could adversely impact the design function of physical security target set equipment in accordance with CSP Section 3.1.6, "Mitigation of Vulnerabilities and Application of Cyber Security Controls." CSP Section 3.1.6 required licensees to establish defense-in-depth strategies for CDAs by implementing the recommendations described in Appendix D, "Technical Cyber Security Controls," and Appendix E, "Operational and Management Cyber Security Controls," of NEI 08-09, Revision 6. The technical cyber security controls were intended to provide a high degree of protection against cyber-related attacks. A security control was considered to be applied when there was high assurance that the CDA's safety or security function would not be adversely impacted by the implemented security control. When a cyber .

security control was determined to have an adverse effect, alternate controls were

• • ./

required to protect the CDA. Milestone 6 also required that any design modification not completed by the required interim implementation date, be documented in the site configuration management and change control program to assure completion of the design modification as soon as possible, but no later than the final implementation .date.

Specific documents reviewed by the inspector are listed in the Attachment to this report.

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b. Findings Failure to Complete Milestone 2 Corrective Actions to Identify Critical Digital Assets Introduction. The inspector identified a finding of very low cyber security significance (Green) involving an NCV of 10 CFR 73.55(b)(10), for the failure to perform adequate corrective actions in the identification of CDAs. Specifically, Entergy had a corrective action to identify and document CDAs in accordance with Pilgrim's CSP Section 3.1.3, "Identification of Critical of Digital Assets," but failed to identify and document 23 digital assets, which performed safety-related, important to safety and emergency preparedness functions, as CDAs.

Description. The inspector reviewed corrective actions from several CRs associated with Milestone 2 issues and the Milestone 2 NRG-identified finding documented in NRC Inspection Report 05000293/2015403. On June 6, the ins ector reviewed Pilgrim's Non-CDA Di ital Devices list and identified (b)(T)(F)

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Analysis. Entergy's failure to adequately perform planned corrective actions to resolve a previous NRC-identified violation was a performance deficiency. This performance

~eficiency was a failure to adequately identify and document CDAs in accordance with Pilgrim's CSP Section 3.1.3, "Identification of Critical of Digital Assets."

. I This finding was more than minor because it was associated with the Response to Contingency Events attribute of the Security cornerstone and adversely affected the cornerstone's objective to provide assurance that a licensee's protective strategy can protect against design basis threats of radiolo ical sabota e from external and internal threats. S ecificall ,

(b)(7)(F)

The Inspector evaluated the finding in accordance with NRC IMC 0609, "Significance Determination Process," Appendix E, Part IV, "Cyber Se~c:.!:!.u!!rit!Y...SS21iYJ.U.llJl.i.i1l,ll..6.I;::.,__----,

0 0 Determination Process." The inspector determined that (b)(7)(F)

As a result, this m ing was

...,._.,___,....-.,..,......,....---,...--.,.....--~,....-..-...,..,,....---:=--1 determined to be of very low safety significance (Green) (';No" to Figure 1, Step 2).

I This finding had a cross-cutting aspect in the area of Problem Identification and I Resolution, specifically Resolution, because Entergy did not take effective corrective I actions to resolve and correct a previous NRG-identified violation for the failure to I

identify digital assets associated with critical systems as CDAs. [P.3]

Enforcement. 10 CFR 73.55, "Physical Protection against Radiological Sabotage," subpart (b)(10}, in part, required Entergy to use the site CAP to correct deficiencies in the physical protection program. The cyber security program is a component of the physical protection program as described in 10 )'.L..l.)..lw.!...;..i.=.................- - - ,

Contrar to the above, from Januar 28, 2015, to resent, Enterg (b)(7)(F) as documented in NRC Inspection Report 05000293/2015403. The NRG is

-re_a_m_.g this violation as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy, because this finding was of very low safety significance (Green) and was entered into Entergy's CAP (CR-PNP-2017-05997,06020, 06035, 06047, 06050, and 06191). (NCV 0500029312017405-01, Failure to Complete Milestone 2 Corrective Actions to Identity Critical Digital Assets)

Failure to Adequately Analyze Target Sets and Mitigate Vulnerabilities that could Impact the Design Function of target set equipment Introduction. The inspector identified a violation of very low safety significance (Green) involving an NCV of 10 CFR 73.55(b)(4), for the failure to erform ade uate anal sis of site specific conditions, including target sets. Specifically (b)(7)(F) 9FFl81AI: W&li Q~Jl:Y &158WRl'f¥ REl:A'fE9 IHFQRMA'fl8N

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(b)(?)(F)

Description. During Pilgrim's last Tl 2201/004 inspection, the NRC identified!

(b)(?)(F)

Analysis. The inspector determined that the failure to perform an adequate analysis of site specific conditions, including target sets, in accordance with 10 CFR 73.55(b)(4) was a performance deficiency because Entergy failed to meet a regulatory requirement that was reasonably within its ability to foresee and correct and should have been prevented. Traditional enforcement does not apply because the issue did not have any actual security consequences or potential for impacting the NRC's regulatory function and was not the result of any willful violation of NRC requirements or Entergy procedures.

The performance deficiency was more than minor because it was associated with the Response to Contingency Events (Implementation of the Protective Strategy) attribute of I

the Security cornerstone, and it adversely affected the cornerstone objective to provide I assurance that the licensee's security system could protect against the design basis II I

threat of radiological sabotage from external threats. Soecificallv,r (b)(7)(F)

The inspector evaluated the finding in accordance with IMC 0609, "Significance Determination Process," Appendix E, Part I, "Baseline Security Significance Determination Process for Power Reactors." Figure 1, Baseline Security Significance Determination Processs Flowchart, directed the inspector to Figure 4, Significance ern~1Ai. 1r1&* g~11a¥ imC' IRITY Rliil.ATEO 1McppnnA11aN

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Screen Process, since all findings related to target sets meet the significance screen criteria for physical protection. The inspector determined that the negative impact the performance deficiency had on the probability of physical protection effectiveness was very low, because the modification did not require the licensee to make any changes to their protective strategy. As a result, this finding was determined to be of very low safety significance (Green) (probability matrix was very low on Figure 4, Step 4). This finding had a cross-cutting aspect in the area of Problem Identification and Resolutio Evaluation, because En~rgy did not adequately evaluate their (b)(7)(F)

Enforcement. 10 CFR 73.55(b)(4) requires the licensee, in part, to analyze site specific condition, including target sets, that may affect the specific measures needed to implement the requirements of physical protection. Contrarv to the above on (b)(7)(F)

The NRC is treating this violation as an NCV, consistent with Section 2.3.2.a of the NRC Enforcement Policy, because this finding was of very low safety significance (Green) and was entered into Entergy's CAP. (NCV 05000293/2017405-02, Failure to Adequately Analyze Target Sets and Mitigate Vulnerabilities that could Impact the Design Function of Target Set Equipment) 40A6 Meetings, Including Exit Exit Meeting Summar¥ The inspector presentedthe preliminary inspection results to Mr. Franco Pasquale, Information Technology Manager, and other members of Entergy's staff an August 23, 2017. The inspector verified that no proprietary information was included in this report.

ATTACHMENT: SUPPLEMENTARY INFORMATION i 9FFIGliO.k wsi;;: 9tl1::¥ &i=&WRITY Ri=l:A:ri=e ltlF9AM1oWl9tl i

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SUPPLEMENTARY INFORMATION KEY POINTS OF CONTACT

,.I Licensee Personnel 1

R Byrne, Regulatory Assurance M. Boucher, IT Specialist G. Cassell, Lead Facility and Equipment Specialist N. Eisenman, Engineering/System Supervisor M. Gatslick, Senior Security Supervisor G. McDonald, l&C Technician J. Odonnell, System engineer F. Pasquale, IT Manager ':**

J. Webers, Operations Work Liaison C. Wilson, Senior IT Consultant NRC Personnel E. Carfang, Senior Resident Inspector, Pilgrim . ':'

B. Pinson, Resident Inspector, Pilgrim J. Bream, Physical Security Inspector S. Mccarver, Physical Security Inspector LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None.*

Opened and Closed 05000293/2017405-01 NCV Failure to Complete Milestone 2 Corrective Actions to Identify Critical Digital Assets {Section 40A2) 05000293/2017 405-02 NCV Failure to Adequately Analyze Target Sets and Mitigate Vulnerabilities that could Impact the Design Function of Target Set Equipment (Section 40A2)

Closed None.

Attachment Ol'l'ICIAL tlS! ONLY SECdl\11 f*RELAIED INFORMAllON

A-2 LIST OF DOCUMENTS REVIEWED Licensing and Design Basis Documents Pilgrim Nuclear Power Station Cyber Security Plan, Revision 001 to PNPS letter 2.11.016, Response to Request for Additional Information Procedures EN-EP-202, Equipment Important to Emergency Preparedness, Revision 1 EN-FAP-IT-009, Nuclear Cyber Security Terms and Definitions, Revision 4 EN-IT-103, Nuclear Cyber Security Program, Revision 12 EN-IT-103-01, Control of Portable Media Connected to Critical Digital Assets, Revision 11 EN-IT-103-03, Cyber Security Assessment Process, Revision 1 EN-IT-103-04, Critical Digital Asset Technical Control Requirements, Revision 0 EN-Ll-102, Corrective Action Program, Revision 29 EN-MA-105, Control of Measuring and Test Equipment (M&TE), revision 13 EN-NS-306, Development and Maintenance of Critical Target sets, Revision 4 EP-AD-270, Equipment Important to Emergency Response (EITER), Revision 3 Drawings. and Piping and Instrumentation Diagrams M226A5, Elementary Diagram Emergency& Plant Information Computer System (EPIC) Switch Connections C940-72, Revision 6 M226A6, Elementary Diagram Emergency& Plant Information Computer System (EPIC) Bridge

{BTEB)/DAS Connections C940-73, Revision 5 M226A6 Sheet 2, Elementary Diagram Emergency& Plant Information Computer System (EPIC)

DAS/Switch Connections, Revision 0 M226A7, Elementary Diagram Emergency& Plant Information Computer Center, Revision 9 M226A8, Elementary Diagram Emergency& Plant Information Computer System, Revision 6 PNP network, PNP Switch Interconnect, Revision 16 Condition Reports ("denotes NRC identified during this inspection)

CR-PNP-2017-05959* CR-PNP-2015-00601 CR-PNP-2015-01157 CR-PNP-2017-05997* CR-PN P-2015-00650 CR-PN P-2015-00655 CR-PNP-2017-06020* CR-PNP-2015-00585 CR-PNP-2015-00605 CR-PNP-2017-06034

• CR-PNP~2015-00620 CR-PNP-2015-00653 CR-PNP-2017-06035.. CR-PNP-2015-00644 CR-PNP-2015-00657.

CR-PNP-2017-06047" CR-PNP-2015-00698 CR-PNP-2015-00699 CR-PNP-2017-06050* CR-PNP-2015-00128 CR-PNP-2015-00272 CR-PNP-2015-00508 CR-PNP-2015-00590 CR-PNP-2015-00617 CR-PNP-2015-0061 B CR-PNP-2015-0061 B CR-PNP-2015-00643 CR-PN P-2015-00651 CR-PN P-2017-04 776 Training Documents EN-TQ-131, Nuclear Cyber Security Training & Qualification, Revision 0 Industry Standards NRC Regulatory Guide 5.71, Cyber Security Programs, 1/2016 NEI 08-09, Cyber Security Plan for Nuclear Power Reactors, Revision 6 NE I 10-04, Identifying Systems and Assets Subject to the Cyber Security Rule, Revision 2 "l

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Miscellaneous Documents 2.16.045; Pilgrim Nuclear Power Station's Response to Cyber Security Inspection Report I

!' Identified Enforcement Discretion Violations, Dated 8/15/16 Kiosk Number 2 Maintenance Log from 4/12/17 to 5/31 /17 Kiosk Number 3 Maintenance Log from 4/12/17 to 5/31/17

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Kiosk Number 4 Maintenance Log from 4/12/17 to 5/31 /17 MS Excel file of Critical Digital Asset Approved List, dated 5/10/17 MS Excel file Non-CDA Digital Devices List, dated 5/10/17 List of Critical Plant Systems, dated 5/10/17 List of Non-Critical Plant System, dated 5/10/17

• LIST OF ACRONYMS CAP corrective action program CDA critical digital asset I CFR Code of Federal Regulations i CR condition report I' CSP Cyber Security Plan IMC Inspection Manual Chapter NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission NCV non-cited violation SSEP safety, security, and emergency preparedness Tl temporary instruction

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