ML23047A451

Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000261/2023402

ML23047A451
Person / Time
Site:	Robinson
Issue date:	02/21/2023
From:	Carey Read Division of Reactor Safety II
To:	Basta L Duke Energy Progress
References
IR 2023402
Download: ML23047A451 (9)

See also: IR 05000261/2023402

Text

February 16, 2023

Laura A. Basta

Site Vice President

H. B. Robinson Steam Electric Plant

Duke Energy Progress, LLC

3581 West Entrance Road, RNPA01

Hartsville, SC 29550

SUBJECT: H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2 - INFORMATION REQUEST

FOR THE CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO

PERFORM INSPECTION 05000261/2023402

Dear Laura Basta:

On May 01, 2023, 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 H. B. Robinson Steam Electric Plant Unit 2. 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 Title 10 of the Code of Federal Regulations (10 CFR) 73.54 and the U.S. Nuclear

Regulatory Commission (NRC) approved cyber security plan (CSP). The onsite portion of the

inspection will take place during the week of May 01, 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 the cyber-security IP. This information should

be made available electronically no later than March 17, 2023. The inspection team will review

this information and, by March 24, 2023, will request the specific items that should be provided

for review. This 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. We

request that the information provided from the second RFI be made available to the regional

office prior to the inspection by April 21, 2023.

L. Basta 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, May 01, 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 William Monk. We understand that our regulatory

contacts for this inspection are Tom Bardaukas and Mark Hubbard, Licensing Managers of your

organization. If there are any questions about the inspection or the material requested, please

contact the lead inspector at (404) 997-4579 or via e-mail at william.monk@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 Read, Carey

on 02/16/23

Carey Mac Read, Acting Branch Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-261

License Nos. DPR-23

Enclosure:

H. B. Robinson Steam Electric Plant Unit 2 Cyber-Security Inspection Document Request

cc w/encl: Distribution via LISTSERV

ML23047A451

X Non-Sensitive X Publicly Available

X SUNSI Review

Sensitive Non-Publicly Available

OFFICE RII/DRS RII/DRS

NAME W. Monk M. Read

DATE 02/16/2023 02/16/2023

H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Inspection Dates: May 01 - 05, 2023

Inspection Procedure: IP 71130.10, Cyber-Security, Revision 0 (Effective: 01/01/2022)

Reference: Guidance Document for Development of the Request for

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

the Cyber-Security Inspection, Rev. 2 (Issued: 11/22/2021)

NRC Inspectors: William Monk, Lead Denise Terry-Ward

404-909-4579 404-997-4514

william.monk@nrc.gov denise.terry-ward@nrc.gov

NRC Contractors: Al Konkal Trace Coleman

561-989-0210 301-415-7000

alan.konkal@nrc.gov trace.coleman@nrc.gov

I. Information Requested for In-Office Preparation

The initial request for information (i.e., RFI #1) 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. RFI #1 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. RFI #1s requested information is specified below

in Table: RFI #1 and requested to be provided electronically to the inspection team by

March 17, 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 RFI #1 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 March 24, 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 RFI

1. 2 be made available to the inspection team by April 21, 2023. All requests for

information shall follow the guidance document U.S. NRC - Guidance Document for

Development of the Request for Information (RFI) and Notification Letter for Full

Implementation of the Cyber-Security Inspection, referenced above.

Enclosure

H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

The required Table: RFI #1 information shall be provided electronically to the lead

inspector by March 17, 2023. The preferred file format for all lists is a searchable Excel

spreadsheet file. The information 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

Paragraph Number/Title: 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 (OM&A) 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 program documentation. 03.02(c)

9 Password/Authenticator program documentation. 03.02(c)

10 User Account/Credential and Authentication program documentation. 03.02(d)

Portable Media and Mobile Device (PMMD) control documentation,

11 03.02(e)

including 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.

Supply Chain Management program documentation, including any 03.03(a),

13

security impact analysis for new acquisitions. (b) and (c)

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H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table: RFI #1

Paragraph Number/Title: IP Ref

Configuration Management documentation including any security

03.03(a)

14 impact analysis performed due to configuration changes since the last

and (b)

cyber inspection.

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

15 03.04(a)

the plan since the last inspection.

16 Cyber Security Performance Metrics tracked (if applicable). 03.06(b)

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).

19 Performance testing report (if applicable). 03.06(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 March 24, 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 March 24, 2023, for the second RFI (i.e., RFI #2). RFI #2 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 and requested information shall follow the guidance

document referenced above.

The Table: RFI #2 information shall be provided to the lead inspector by April 21, 2023.

The preferred file format for all lists is a searchable Excel spreadsheet. The information

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.

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H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

Table: RFI #2

Paragraph Number/Title: Items

For the Critical Systems / CDAs chosen for inspection provide:

Ongoing Monitoring and Assessment activity performed on the

1 03.01(a)

selected inspection samples system(s).

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 systems 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 systems

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 systems.

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

6 03.02(d)

selected systems since the last cyber 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 systems 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 reports/assessment for cyber security drills performed 03.02(a)

10

since the last inspection. 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

were executed. 03.04(b)

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.

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H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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: Week Onsite) to the team by May 01, 2023, the first day of

the inspection. All requested information shall follow the guidance document referenced

above.

The preferred file format for all lists is a searchable Excel spreadsheet file. The

information 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: Week Onsite

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 03.05

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 (UFSAR), if not previously provided

b. Original FSAR Volumes

c. Original SER and Supplements

d. FSAR Question and Answers

e. Quality Assurance (QA) 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; and

b. Corrective action documents (e.g., condition reports, including status of

corrective actions) generated as a result of the most recent Cyber-Security

Quality Assurance (QA) audit and/or self-assessment.

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H. B. ROBINSON STEAM ELECTRIC PLANT UNIT 2

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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 during daily de-brief meetings).

If you have any questions regarding the information requested, please contact the inspection

team leader.

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