ML22119A135
| ML22119A135 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/09/2022 |
| From: | Gerald Mccoy NRC/RGN-II/DRS/EB2 |
| To: | Krakuszeski J Progress Energy Carolinas |
| References | |
| IR 2022403 | |
| Download: ML22119A135 (8) | |
See also: IR 05000324/2022403
Text
May 9, 2022
Mr. John A. Krakuszeski
Site Vice President
Brunswick Steam Electric Plant
8470 River Rd. SE
Southport, NC 28461
SUBJECT: BRUNSWICK STEAM ELECTRIC PLANT - INFORMATION REQUEST FOR THE
CYBER-SECURITY ASELINE SECURITY INSPECTION, NOTIFICATION TO
PERFORM INSPECTION 05000325/2022403; 05000324/2022403
Dear Mr. Krakuszeski:
On July 11, 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 Brunswick Steam Electric Plant. The inspection will be performed to evaluate and verify
your ability to provide assurance that your 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 the requirements of Title 10,
Code of Federal Regulations (CFR), Part 73, Section 54, and the NRC approved Cyber Security
Plan (CSP). The onsite portion of the inspection will take place during the week of
July 11, 2022.
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 the 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 electronically no later than May 19, 2022. The inspection team will review
this information and, by June 2, 2022, 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 by June 18, 2022, as
identified above.
J. Krakuszeski 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, July 11, 2022.
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 Larry J. Jones Jr. We understand that our regulatory
contact for this inspection is David Feitl of your organization. If there are any questions about
the inspection or the material requested, please contact the lead inspector at 404-997-4837 or
via e-mail at Larry.Jones@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 Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
Signed by McCoy, Gerald
on 05/09/22
Gerald McCoy, Branch Chief
Engineering Branch 2
Division of Reactor Safety
Docket No.: 50-325, 50-324
Enclosure:
Brunswick Steam Electric Plant Cyber-Security Inspection Document Request
X Non-Sensitive X Publicly Available
X SUNSI Review
Sensitive Non-Publicly Available
OFFICE RII/DRS
NAME G. McCoy
DATE 05/09/2022
BRUNSWICK STEAM ELECTRIC PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
Inspection Report: 05000325/2022403 and 05000324/2022403
Inspection Dates: July 11-15, 2022
Inspection Procedure: IP 71130.10, Cyber-Security, Revision 0
NRC Inspectors: Larry J. Jones Jr., Lead David Strickland
404-997-4837 404-997-4440
Larry.Jones @nrc.gov David.Strickland@nrc.gov
NRC Contractors: Alexander Prada Al Konkal
Alexander.Prada@nrc.gov Alan.Konkal @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 May 19, 2022, 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 2, 2022, 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 18, 2022.
Enclosure
BRUNSWICK STEAM ELECTRIC PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
The required Table RFI 1 information shall be provided electronically to the lead
inspector by May 19, 2022. If a compact disk (CD) is provided, please provide four
copies (one for each inspector/contactor). The preferred file format for all lists is a
searchable Excel spreadsheet file. These files 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
Request: IP Ref
A list of all Identified Critical Systems and Critical Digital Assets,-
highlight/note any additions, deletions, 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 EP and Security onsite and offsite digital communication
2 Overall
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 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 03.02(a)
7 contingency plan development, implementation and including any and
program documentation that requires testing of security boundary 03.04(b)
device 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)
Portable Media and Mobile Device control documentation, including
11 03.02(e)
kiosk security control assessment/documentation
Design change/ modification program documentation and a List of all
design changes completed since the last cyber security inspection,
12 03.03(a)
including 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
13 , (b) and
impact analysis for new acquisitions
(c)
Configuration Management documentation including any security
03.03(a)
14 impact analysis performed due to configuration changes since the last
and (b)
inspection
Cyber Security Plan and any 50.54(p) analysis to support changes to
15 03.04(a)
the plan since the last inspection
03.06
16 Cyber Security Metrics tracked (if applicable)
(b)
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BRUNSWICK STEAM ELECTRIC PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
Table RFI #1
Request: IP Ref
Provide documentation describing any cyber security changes to the
17 Overall
access authorization program since the last cyber security inspection.
Provide a list of all procedures and policies provided to the NRC with
18 Overall
their descriptive name and associated number (if available)
03.06
19 Performance testing report (if applicable)
(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 January 4, 2021, for the
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 2, 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 electronically to the lead inspector by
June 18, 2022. If a compact disk (CD) is provided, please provide four copies (one for
each inspector/contactor). The preferred file format for all lists is a searchable Excel
spreadsheet file. These files 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. If you have any questions regarding this information,
please call the inspection team leader as soon as possible.
Table RFI #2
Request Items
For the system(s) chosen for inspection provide:
Ongoing Monitoring and Assessment activity performed on the
1 03.01(a)
system(s)
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BRUNSWICK STEAM ELECTRIC PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
Table RFI #2
Request Items
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),
4 Host-based Intrusion Detection Systems (HIDS), and Security 03.02(b)
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 03.02(c)
selected 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
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 cyber security drills performed since the last 03.02(a)
10
inspection, along with any reports or assessments generated. 03.04(b)
Copy of the individual recovery plan(s) for the selected system(s)
03.02(a)
11 including documentation of the results the last time the backups
03.04(b)
were executed.
Corrective actions taken as a result of cyber security incidents/issues
12 to include previous NRC violations and Licensee Identified Violations 03.05
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) electronically by July 11, 2022, the first day of
the inspection.
Table 1ST Week Onsite
Request: 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 03.05
Licensee Identified Violations since the last cyber security
inspection, as well as vulnerability-related corrective actions
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BRUNSWICK STEAM ELECTRIC PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
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
(2) Vendor Manuals, Assessment and Corrective Actions:
a. The most recent Cyber-Security Quality Assurance (QA) audit and/or
self-assessment
b. Corrective action documents (e.g., condition reports, including status of
corrective actions) generate 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) 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