ML23173A086
| ML23173A086 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/26/2023 |
| From: | Fanta Sacko NRC/RGN-IV/DORS/EB2 |
| To: | Dent J Nebraska Public Power District (NPPD) |
| References | |
| IR 2023401 | |
| Download: ML23173A086 (10) | |
See also: IR 05000298/2023401
Text
June 26, 2023
John Dent, Jr.
Executive Vice President and Chief Nuclear Officer
Nebraska Public Power District
Cooper Nuclear Station
72676 648A Avenue
P.O. Box 98
Brownville, NE 68321
SUBJECT: COOPER NUCLEAR STATION - INFORMATION REQUEST FOR THE
CYBERSECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000298/2023401
Dear John Dent, Jr.
On September 18, 2023, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
inspection in accordance with Inspection Procedure (IP) 71130.10, Cybersecurity, at your
Cooper Nuclear Station. 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 cyberattacks in
accordance with Title 10 of the Code of Federal Regulations (10 CFR) 73.54 and your approved
cybersecurity 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 cyber security inspections are extremely resource intensive, both for
the NRC inspectors and 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 cybersecurity 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 July 21, 2023. The inspection team will
review this information and, by August 4, 2023, 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 September 8, 2023, as identified above.
J. Dent, Jr. 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, September 18, 2023.
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 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 Philipp Braaten. We understand that our regulatory
contact for this inspection is Mark Unruh of your organization. If there are any questions about
the inspection or the material requested, please contact the lead inspector at 404-997-4651 or
via e-mail at Philipp.braaten@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 under approval number 3150-0011. The burden to the
public for these information collections is estimated to average 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />(s) per response. Send
comments regarding this information collection to the FOIA, Library and Information Collection
Branch, Office of the Chief Information Officer, Mail Stop: T6-A10M, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001, or by email to Infocollects.Resource@nrc.gov, and
to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0011)
OMB, Washington, DC 20503.
Public Protection Notification
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).
J. Dent, Jr. 3
Sincerely,
Signed by Sacko, Fanta
on 06/26/23
Fanta Sacko, Branch Chief
Engineering Branch 2
Division of Operating Reactor Safety
Docket No. 50-298
License No. DPR-46
Enclosure: Cooper Nuclear Station Cyber-Security Inspection Document Request
cc w/encl: Distribution via LISTSERV
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: STM Yes No Publicly Available Sensitive NRC-002
OFFICE RII: DRS/EB2 RIV:DORS/EB2
NAME PBraaten FSacko
SIGNATURE /RA/ /RA/
DATE 06/22/23 06/26/23
WATERFORD STEAM ELECTRIC STATION CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
Inspection Report: 05000298/2023401
Inspection Dates: Week of September 18, 2023
Inspection Procedure: IP 71130.10, CYBERSECURITY
Reference: ML21330A088, Guidance Document for Development of the
Request for Information (RFI) and Notification Letter for IP
71130.10 Cyber Security Inspection, Revision 2
NRC Inspectors: Philipp Braaten, Lead Nnaerika Okonkwo
404-997-4651 817-200-1114
philipp.braaten@nrc.gov nnaerika.okonkwo@nrc.gov
NRC Contractors: Michael Shock Trace Coleman
301-415-7000 301-415-7000
michael.shock@nrc.gov trace.coleman@nrc.gov
I. Information Requested for In-Office Preparation
This initial request for information (i.e., Table RFI #1) 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 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 cybersecurity IP. The first RFIs requested information is specified below in Table RFI #1.
Please provide the information requested in Table RFI #1 to the regional office by July 21,
2023, 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 August
4, 2023, which will be utilized to evaluate the equipment, defensive architecture, and the areas
of the cyber security program for review during the inspection.
Please provide the information requested by the second RFI to the regional office by
September 8, 2023. 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.
Enclosure
The required Table RFI #1 information shall be provided on digital media (CD/DVD)) or an
online document repository to the lead inspector by July 21, 2023. 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 contact 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 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 program 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 control program 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 a list of 03.03(a),
13
security impact analysis for new acquisitions. (b) and (c)
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WATERFORD STEAM ELECTRIC STATION CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
Table RFI #1
Paragraph Number/Title: IP Ref
Configuration Management program documentation including a list of
03.03(a)
14 security impact analysis performed due to configuration changes since
and (b)
the last 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 cyber security procedures and policies with their
18 Overall
descriptive name and associated number.
19 Performance testing report (if applicable). 03.06(a)
20 Electronic Copy of UFSAR and Technical Specifications Overall
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 August 4, 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 August 4, 2023, 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 cybersecurity 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 September 8, 2023. The preferred file format for
all lists is a searchable Excel spreadsheet file. The submitted information should be indexed and
hyper-linked to facilitate ease of use. If you have any questions regarding this information,
please contact the inspection team leader as soon as possible.
3
Table RFI #2
Paragraph Number/Title: Items
For the system(s) chosen for inspection provide:
Ongoing Monitoring and Assessment activity performed on the
1 03.01(a)
selected 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 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 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 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 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)
List of Corrective actions taken as a result of cyber security
12 incidents/issues to include previous NRC violations and Licensee 03.05
Identified Violations since the last cyber security inspection.
- Some selected systems may have a large number of CDAs. For these systems reach out to
the team leader for a specific selection of CDAs when responding to this request.
4
WATERFORD STEAM ELECTRIC STATION 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 Onsite Week) on digital media (CD/DVD) or an online document repository by
September 18, 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 contact the inspection team leader as soon as possible.
Table Onsite Week
Section 3,
Paragraph Number/Title: Items
Any cyber security event reports submitted in accordance with
1 03.04(a)
10 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, if not previously provided;
b. Current FSAR Volume;
c. SER and Supplements for Cybersecurity Program;
d. FSAR Question and Answers related to Cybersecurity Program;
e. Quality Assurance Plan for Cybersecurity;
f. Technical Specifications, if not previously provided;
(2) Vendor Manuals for the CDAs selected
(3) Assessments and Corrective Actions:
5
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) 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) 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.
6