ML21333A157
| ML21333A157 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/30/2021 |
| From: | Sam Graves NRC/RGN-IV/DRS/EB-2 |
| To: | Diya F Ameren Missouri |
| References | |
| IR 2022401 | |
| Download: ML21333A157 (11) | |
See also: IR 05000483/2022402
Text
November 30, 2021
Mr. Fadi Diya, Senior Vice President
and Chief Nuclear Officer
Ameren Missouri Callaway Plant
8315 County Road 459
Steedman, MO 65077
SUBJECT: CALLAWAY PLANT - INFORMATION REQUEST FOR THE CYBER- SECURITY
BASELINE INSPECTION, NOTIFICATION TO PERFORM INSPECTION
Dear Mr. Diya:
On March 28, 2022, 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 Callaway Plant. The inspection objectives are to provide assurance that the digital
computer and communication systems and networks associated with safety, security, or
emergency preparedness (SSEP) functions are adequately protected against cyber-attacks in
accordance with Title 10 of the Code of Federal Regulations (10 CFR) 73.54 and your approved
cyber security plan (CSP), and to verify that any CSP changes and reports have been made in
accordance with 10 CFR 50.54(p).
Experience has shown that baseline inspections are extremely resource intensive, both for the
NRC inspectors and 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 digital media (CD/DVD) or an online document repository and
delivered/available to the regional office no later than January 7, 2022. The inspection team will
review this information and, by January 31, 2022, will request the specific items that should be
provided for review.
The second group of 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 your cyber security program selected for review. This information will be requested for review
in the regional office prior to the inspection by February 28, 2022, as identified above.
F. Diya 2
The third group of requested documents consists of additional 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, March 28, 2022.
The fourth group of information aids the inspection team in tracking issues identified during 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 requested 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 Sam Graves. We understand that our regulatory
contact for this inspection is Anthony Lowry of your organization. If there are any questions
about the inspection or the material requested, please contact the lead inspector
at 817-200-1102 or via e-mail at samuel.graves@nrc.gov
PAPERWORK REDUCTION ACT STATEMENT
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 (approval number 3150-0011). Send comments
regarding this information collection to the Information Services Branch, Office of the Chief
Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington, DC
20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of
Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and
Budget, Washington, DC 20503.
PUBLIC PROTECTION NOTIFICATION
The NRC may not conduct nor 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 OMB control number.
F. Diya 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,
Signed by Graves, Samuel
on 11/30/21
Sam Graves, Senior Reactor Inspector
Engineering Branch 2
Division of Reactor Safety
Docket No.: 50-483
License No.: NPF-30
Enclosure: Cyber-Security Inspection Document Request
cc w/encl: Distribution via LISTSERV
X SUNSI ADAMS: Sensitive Non-Publicly Keyword
Review By: Yes No Non-Sensitive Available NRC-002
STG Publicly Available
OFFICE EB2:SRI
NAME S. Graves
SIGNATURE /RA/
DATE 11/30/2021
F. Diya 5
Inspection Report: 05000483/2022401
Inspection Dates: Onsite the week of March 28, 2022
Inspection Procedure: IP 71130.10, Cyber-Security, Revision 0
Reference: Guidance Document for Development of the Request for
Information (RFI) and Notification Letter for Full-Implementation of
the Cyber-Security Inspection. (ML TBD)
NRC Inspectors: Sam Graves, Lead Stella Opara
817-200-1102 301-287-9286
samuel.graves@nrc.gov stella.opara@nrc.gov
NRC Contractors: Alan Konkal Casey Priester
561-989-0210 301-415-7000
alan.konkal@nrc.gov frederick.priester@nrc.gov
I. Information Requested for In-Office Preparation
This initial request for information (i.e., first RFI) concentrates on providing the inspection
team with information necessary to select appropriate components and cyber security
program elements to develop a site-specific inspection plan. The first RFI is used to
identify the critical digital assets or systems 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. Please provide the Table RFI #1 to the regional office by
January 7, 2022, or sooner, to facilitate the selection of the specific items for review.
The inspection team will examine the documentation from the first RFI and select
specific systems and equipment 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 January 31, 2022, which will be utilized to evaluate the equipment,
defensive architecture, and the areas of the licensees cyber security program for review.
Please provide the information requested by the second RFI to the regional office by
February 28, 2022. All requests for information shall follow the guidance document
referenced above. For information requests that have more than ten (10) documents,
please provide a compressed (i.e., Zip) file of the documents.
The required Table RFI 1 information shall be provided on digital media (CD/DVD)) or an
online document repository to the lead inspector by January 7, 2022. Please provide
four copies of each media submitted (i.e., one for each inspector/contactor). The
preferred file format for all lists is a searchable Excel spreadsheet file. The media
(CDs/DVDs) 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
A list of all Identified Critical Systems and Critical Digital Assets, and
non-CDA digital assets used in the cyber defensive architecture,
(e.g., firewalls, SIEM, NIDS/NIPS, kiosks, access authorization, 10
1 CFR 73.55 equipment not part of the security system) - Overall
highlight/note any changes (e.g., additions, deletions,
reclassifications) since the last cyber security inspection, including
changes to boundary devices
2 A list of CDA and DA wireless Industrial networks Overall
A list of EP and Security onsite and offsite digital communication
3 Overall
systems
4 Network Topology Diagrams Overall
5 Ongoing Monitoring and Assessment program documentation 03.01(a)
The most recent effectiveness analysis of the Cyber Security
6 03.01(b)
Program
Vulnerability screening/assessment and scan program
7 03.01(c)
documentation
Cyber Security Incident response documentation, including incident
detection, response, and recovery documentation as well as 03.02(a)
8 contingency plan development, implementation and including any and
program documentation that requires testing of security boundary 03.04(b)
device functionality
List of all network security boundary devices for EP networks and all
9 03.02(b)
network security boundary devices for levels 3 and 4
10 Device Access and Key Control documentation 03.02(c)
11 Password/Authenticator documentation 03.02(c)
12 User Account/Credential documentation 03.02(d)
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Table RFI #1
Section 3,
Paragraph Number/Title: IP Ref
Portable Media and Mobile Device control documentation, including
13 03.02(e)
kiosk security control assessment/documentation
List of all design changes completed since the last inspection,
14 including 50.59 documentation and the design 03.03(a)
changes/modifications program documentation
03.03(a),
Supply Chain Management documentation including any security
15 (b) and
impact analysis for new acquisitions
(c)
Configuration Management documentation including any security
03.03(a)
16 impact analysis performed due to configuration changes since the
and (b)
last inspection
Cyber Security Plan and any 50.54(p) analysis to support changes
17 03.04(a)
to the plan since the last inspection
Cyber Security Assessment team documentation to include any
18 training documentation (both general cyber security training and any 03.04(c)
specialized training
19 Cyber Security Metrics tracked (if applicable) 03.05(b)
Provide a list of all procedures and policies provided to the NRC
21 Overall
with their descriptive name and associated number
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.
(4) Implementing and program procedures in a single folder.
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 January 31, 2022, for the
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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 January 31, 2022 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.
The Table RFI 2 information shall be provided on digital media (CD/DVD) or an online
document repository to the lead inspector by February 28, 2022. Please provide four
copies of each media (CD/DVD) submitted (i.e., one for each inspector/contactor). The
preferred file format for all lists is a searchable Excel spreadsheet file. The digital media
(CDs/DVDs) 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:
Ongoing Monitoring and Assessment activity performed on the
1 03.01(a)
system(s)
2 All Security Control Assessments for the selected system(s) 03.01(a)
Any effectiveness analysis for the security controls that have been
3 03.01(b)
performed on the system(s)
All vulnerability screenings/assessments associated with or scans
4 03.01(c)
performed on the selected system(s) since the last inspection
Documentation (including configuration files and rules sets) for
Network-based Intrusion Detection/Protection Systems
5 (NIDS/NIPS), Host-based Intrusion Detection Systems (HIDS), and 03.02(b)
Security Information and Event Management (SIEM) systems for
system(s) chosen for inspection)
Documentation (including configuration files and rule sets) for intra-
6 security level firewalls and boundary devices used to protect the 03.02(c)
selected system(s)
Copies of all periodic reviews of the access authorization list for the
7 03.02(d)
selected systems since the last inspection
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Table RFI #2
Section 3,
Paragraph Number/Title: Items
8 Baseline configuration data sheets for the selected system(s) 03.03(a)
Documentation on any changes, including Security Impact
9 Analyses, performed on the selected system(s) since the last 03.03(b)
inspection
Copies of the purchase order documentation for any new
10 equipment purchased for the selected systems since the last 03.03(c)
inspection
Copies of any cyber security drills performed since the last 03.02(a)
11
inspection 03.04(b)
Copy of the individual recovery plan(s) for the selected system(s)
03.02(a)
12 including documentation of the results the last time the backups
03.04(b)
were executed.
Corrective actions taken because of cyber security incidents/issues
13 to include previous NRC violations and Licensee Identified 03.04(d)
Violations since the last cyber security inspection
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Enclosure
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) on digital media (CD/DVD) or an online
document repository by March 28, 2022, the first day of the inspection. All requested
information shall follow the guidance document referenced above.
Please provide four copies of each digital media (CD/DVD) submitted (i.e., one for each
inspector/contactor). The preferred file format for all lists is a searchable Excel
spreadsheet file. The digital media (CDs/DVDs) 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
Any cyber security event reports submitted in accordance with 10
1 03.04(a)
CFR 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
2 03.04(d)
Licensee 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;
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
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Enclosure
b. Corrective action documents (e.g., condition reports, including status of
corrective actions) generate because 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 because 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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