ML17341B062

LLC - Information Request for the Cyber Security Inspection, Notification to Perform Inspection 05000244/2018403

ML17341B062
Person / Time
Site:	Ginna
Issue date:	12/05/2017
From:	Glenn Dentel Engineering Region 1 Branch 2
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Dentel G
References
IR 2018403
Download: ML17341B062 (8)

See also: IR 05000244/2018403

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD., SUITE 100

KING OF PRUSSIA, PA 19406-2713

December 5, 2017

Mr. Bryan C. Hanson

Senior Vice President, Exelon Generation Company, LLC

President and Chief Nuclear Officer, Exelon Nuclear

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: R.E. GINNA NUCLEAR POWER PLANT, LLC - INFORMATION REQUEST FOR

THE CYBER-SECURITY INSPECTION, NOTIFICATION TO PERFORM

INSPECTION 05000244/2018403

Dear Mr. Hanson:

On March 26, 2018, the U.S. Nuclear Regulatory Commission (NRC) will begin a team

inspection in accordance with Inspection Procedure (IP) 71130.10P, Cyber-Security, issued

May 15, 2017, at your R.E. Ginna Nuclear Power Plant, LLC (Ginna). The inspection will be

performed to evaluate and verify your ability to meet full implementation requirements of the

NRCs Cyber-Security Rule, Title 10 of the 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 weeks of March 26-30, 2018, and

April 9-13, 2018. Experience has shown that team 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 inspection procedure. This

information should be made available via compact disc and delivered to the regional office no

later than January 5, 2018. The inspection team will review this information and, by January 29,

2018, 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 your plants Cyber Security Program selected for the cyber security inspection.

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

February 26, 2018.

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, March 26, 2018.

B. Hanson 2

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 Mr. David Werkheiser. We understand that our

regulatory contact for this inspection is Mr. E. John Fischer of your organization, at Ginna. If

there are any questions about the inspection or the material requested, please contact the lead

inspector at 610-337-5316 or via e-mail at David.Werkheiser@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.

This letter and its enclosure will be available for public inspection and copying at

http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in

accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Glenn T. Dentel, Chief

Engineering Branch 2

Division of Reactor Safety

Docket No. 50-244

License No. DPR-18

Enclosure:

Ginna Nuclear Power Plant Cyber-Security

Inspection Document Request

cc w/encl: Distribution via ListServ

ML17341B062

Non-Sensitive Publicly Available

SUNSI Review

Sensitive Non-Publicly Available

OFFICE RI/DRS RI/DRS

NAME DWerkheiser GDentel

DATE 12/5/17 12/5/17

GINNA NUCLEAR POWER PLANT

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Inspection Report: 05000244/2018403

Inspection Dates: March 26 - 30, 2018, and April 9 - 13, 2018

Inspection Procedure: IP 71130.10P, Cyber-Security, Issue Date May 15, 2017

Reference: Guidance Document for Development of the Request for

Information (RFI) and Notification Letter for Full-Implementation of

the Cyber Security Inspection, Issue Date May 25, 2017

NRC Inspectors: David Werkheiser, Lead Louis Dumont

610-337-5316 610-337-5183

David.Werkheiser@nrc.gov Louis.Dumont@nrc.gov

NRC Contractors: John Walley Timothy Marshall

301-287-3717 Phone TBD

John.Walley@nrc.gov Timothy.Marshall@nrc.gov

NRC Observers: Charity Pantalo Michael Brown

301-287-9381 301-287-3679

Charity.Pantalo@nrc.gov Michael.Brown@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 (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 January 5,

2018, 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 January 29, 2018, 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 by February 26, 2018. All requests

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GINNA NUCLEAR POWER PLANT

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

for information shall follow the Table RFI #1 and the guidance document referenced

above.

The required Table RFI #1 information shall be provided on compact disc (CD) to the

lead inspector by January 5, 2018. Please provide four copies of each CD submitted

(i.e., one for each inspector/contractor). The preferred file format for all lists is a

searchable Excel spreadsheet file on a CD. These CDs 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

Reference Section 3,

Paragraph Number/Title: Items

1 List All Identified Critical Systems and Critical Digital Assets All

List CDA Facility and Site Ethernet - Transmission Control

2 Protocol/Internet Protocol (TCP/IP) Based Local Area Networks All

(LANs) and Identify Those LANs That Have Non-CDAs On Them

List CDA Facility and Site Non-Ethernet TCP/IP Based LANs Including

3 Those Industrial Networks and Identify LANs That Have Non-CDAs On All

Them

Network Topology Diagrams (Be Sure To Include all Network Intrusion

Detection Systems (NIDS) and Security Information and Event

4 All

Management (SIEMs) for Emergency Preparedness (EP) networks

and Security Level 3 and 4 Networks)

List All Network Security Boundary Devices for EP Networks and All

8 All

Network Security Boundary Devices for Levels 3 and 4

9 List CDA Wireless Industrial Networks All

NIDS Documentation for Critical Systems That Have CDAs Associated 11.a.1)

11

with Them 11.a.2)

SIEM Documentation for Critical systems That Have CDAs Associated 12.a.1)

12

with Them 12.a.2)

List EP and Security Onsite and Offsite Digital Communication

14 All

Systems

Cyber Security Assessment and Cyber Security Incident Response

25 All

Teams

In addition to the above information please provide the following:

(1) Electronic copy of your current Cyber Security Plan.

(2) Electronic copy of summary of changes (if any), including any 10 CFR 50.54p

analysis to support those changes, made to the originally approved Cyber

Security Plan.

(3) Electronic copy of a matrix that summarizes what controls are in place to satisfy

the controls required by Policies and Procedures.

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GINNA NUCLEAR POWER PLANT

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

(4) Electronic copy of the Updated Final Safety Analysis Report and technical

specifications.

(5) Name(s) and phone numbers for the regulatory and technical contacts.

(6) 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

will submit a list of specific systems and equipment to your staff by January 29, 2018, for

the second RFI (i.e., Table RFI #2).

II. Additional Information Requested to be Available Prior to Inspection.

As stated above, in Section I. of this enclosure, the inspection team will examine the

returned documentation requested from Table RFI #1 and will submit the list of specific

systems and equipment to your staff by January 29, 2018, 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 your stations 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 Table RFI #2 and the guidance document referenced above.

The Table RFI #2 information shall be provided on CD to the lead inspector by

February 26, 2018. Please provide four copies of each CD submitted (i.e., one for each

inspector/contractor). The preferred file format for all lists is a searchable Excel

spreadsheet file on a CD. These CDs 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

Plant Computer System Block Diagram (If Plant Computer System Is

5 All

Selected for Inspection)

Plant Security System Block Diagram (If Security Computer System Is

6 All

Selected for Inspection)

Systems That Are Distributed Block Diagrams (For Systems Selected

7 All

For Inspection)

Host-Based Intrusion Detection System Documentation (For CDAs for 10.a.1)

10

Systems Selected for Inspection) 10.a.2)

List all Maintenance and Test Equipment Used On CDAs for Systems

13 All

Selected for Inspection

15 Configuration Management All

16.a.

16.b.1)

16 Supply Chain Management

16.b.5)

16.b.6)

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GINNA NUCLEAR POWER PLANT

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table RFI #2

Section 3,

Paragraph Number/Title: Items

17 Portable Media and Mobile Device Control All

18 Software Management All

20 Vendor Access and Monitoring All

21 Work Control All

22 Device Access and Key Control All

23 Password/Authenticator Policy All

24 User Account/Credential Policy All

26 Corrective Actions Since Last NRC Inspection All

In addition to the above information please provide the following:

(1) The documented CSP assessment and analysis for each CDA in each of the

selected systems.

III. Information Requested to be Available on First Day of Inspection

For the specific systems and equipment identified in this enclosuresSection II., provide

the following RFI (i.e., Table 1ST Week Onsite) on a CD by March 26, 2018, the first day

of the inspection. All requested information shall follow the Table 1ST Week Onsite and

the guidance document referenced above.

Please provide four copies of each CD submitted (i.e., one for each

inspector/contractor). The preferred file format for all lists is a searchable Excel

spreadsheet file on a CD. These CDs 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

10.a.3)

Host-Based Intrusion Detection System Documentation for CDAs

10 thru

for systems selected for inspection

10.a.12)

11.a.3)

NIDS Documentation for Critical Systems That Have CDAs

11 thru

Associated with Them

11.a.15)

12.a.3)

SIEM Documentation for Critical Systems That Have CDAs

12 thru

Associated with Them

12.a.14)

16.b.2)

16 Supply Chain Management 16.b.3)

16.b.4)

19 Cyber Security Event Notifications All

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GINNA NUCLEAR POWER 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. Original Final Safety Analysis Report Volumes;

b. Original Safety Evaluation Report and Supplements;

c. Final Safety Analysis Report Question and Answers;

d. Quality Assurance (QA) Plan;

e. Latest Individual Plant Examination for External Events / Probabilistic Risk

Assessment Report; and

f. Vendor Manuals.

(2) 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) generated 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.

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