IR 05000220/2019403

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Information Request for the Cyber-Security Inspection, Notification to Perform Inspection 05000220/2019403 and 05000410/2019403
ML18348A532
Person / Time
Site: Nine Mile Point Exelon icon.png
Issue date: 12/13/2018
From: Dentel G T
NRC/RGN-I/DRS/EB2
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
Dentel G T
References
Download: ML18348A532 (8)


Text

December 13, 2018

Mr. Bryan Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT: NINE MILE POINT NUCLEAR STATION - INFORMATION REQUEST FOR THE CYBER-SECURITY INSPECTION, NOTIFICATION TO PERFORM

INSPECTION 05000220/2019403 AND 05000410/2019403

Dear Mr. Hanson:

On June 3, 2019, the U.S. Nuclear Regulatory Commission (NRC) will begin a team inspection in accordance with Inspection Procedure 71130.10P, "Cyber-Security," issued May 15, 2017, at your Nine Mile Point Nuclear Station, Units 1 and 2. The inspection will be performed to evaluate and verify your ability to meet full implementation requirements of the NRC's Cyber-Security Rule, Title 10 of the Code of Federal Regulations (10 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 June 3 - 7, 2019, and June 17 - 21, 2019.

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 (CD) or digital versatile disc (DVD) and delivered to the regional office no later than February 11, 2019. The inspection team will review this information and, by March 11, 2019, 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 plant's 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 May 6, 2019.

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, June 3, 2019. 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 Jigar Patel. We understand that our regulatory contact for this inspection is Rose Demko of your organization. If there are any questions about the inspection or the material requested, please contact the lead inspector at 610-337-5188 or via

e-mail at Jigar.Patel1@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 Nos.50-220 and 50-410 License Nos. DPR-63 and NPF-69

Enclosure:

Nine Mile Point Nuclear Station Cyber-Security Inspection Document Request cc w/encl: Distribution via ListServ

ML18348A532 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRS RI/DRS NAME JPatel/JP via email GDentel/GTD DATE 12/12/18 12/13/18

NINE MILE POINT NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST 1 Enclosure Inspection Report: 05000220/2019403 and 05000410/2019403 Inspection Dates: June 3 - 7, 2019 and June 17 - 21, 2019 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 October 26, 2017 NRC Inspectors: Jigar Patel, Lead Jeff Rady 610-337-5188 610-337-5380 Jigar.Patel1@nrc.gov Jeff.Rady@nrc.gov NRC Contractors: William Johns Leyton Pitzer William.Johns@nrc.gov Leyton.Pitzer@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 RFI's requested information is specified below in Table RFI #1. The Table RFI #1 information is requested to be provided to the regional office by February 11, 2019, 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 retu rned 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 March 11, 2019, which will identify the specific systems and equipment that will be utilized to evaluate the CSs/CDAs, defensive architecture, and the areas of the licensee's 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 May 6, 2019. All requests for information responses shall follow the RFI table matrix and the guidance document referenced above. The required Table RFI #1 information shall be provided on compact disc (CD) or digital versatile disc (DVD) to the lead inspector by February 11, 2019. Please provide four NINE MILE POINT NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST 2 copies of each CD or DVD submitted (i.e., one for each inspector/contractor). The preferred file format for all lists is a searchable Excel spreadsheet file on a disc. These discs 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 2 List CDA Facility and Site Ethernet - Transmission Control Protocol/Internet Protocol (TCP/IP) Based Local Area Networks (LANs) and Identify Those LAN's That Have Non-CDAs On Them All 3 List CDA Facility and Site Non-Ethernet TCP/IP Based LANs Including Those Industrial Networks and Identify LANs That Have Non-CDAs On

Them All 4 Network Topology Diagrams (Be Sure To Include all Network Intrusion Detection Systems (NIDS) and Security Information and Event Management (SIEMs) for Emergency Preparedness (EP) networks and Security Level 3 and 4 Networks)

All 8 List All Network Security Boundary Devices for EP Networks and All Network Security Boundary Devices for Levels 3 and 4 All 9 List CDA Wireless Industrial Networks All 11 NIDS Documentation for Critical Systems That Have CDAs Associated with Them 11.a.1) 11.a.2) 12 SIEM Documentation for Critical systems That Have CDAs Associated with Them 12.a.1) 12.a.2) 14 List EP and Security Onsite and Offsite Digital Communication Systems All 25 Cyber Security Assessment and Cyber Security Incident Response Teams All 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. (4) Electronic copy of the Updated Final Safety Analysis Report and technical specifications. (5) Name(s) and phone number(s) for the regulatory and technical contacts.

(6) Current management and engineering organizational charts.

NINE MILE POINT NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST 3 (7) In a separate directory, an electronic copy of the documents listed in the matrix from (3) above. 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 March 11, 2019, 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 submit the list of specific systems and equipment to your staff by March 11, 2019, 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 station's 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 or DVD to the lead inspector by May 6, 2019. Please provide four copies of each CD or DVD submitted (i.e., one for each inspector/contractor). The preferred file format for all lists is a searchable Excel spreadsheet file on a disc. These discs 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 5 Plant Computer System Block Diagram (If Plant Computer System Is Selected for Inspection)

All 6 Plant Security System Block Diagram (If Security Computer System Is Selected for Inspection)

All 7 Systems That Are Distributed Block Diagrams (For Systems Selected For Inspection)

All 10 Host-Based Intrusion Detection System Documentation (For CDAs for Systems Selected for Inspection)

10.a.1) 10.a.2) 13 List all Maintenance and Test Equipment Used On CDAs for Systems Selected for Inspection All 15 Configuration Management All 16 Supply Chain Management 16.b. 16.c.1)

16.c.5)

16.c.6) 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 NINE MILE POINT NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST 4 Table RFI #2 Section 3, Paragraph Number/Title: Items 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 enclosure's Section II., provide the following RFI (i.e., Table 1 ST Week Onsite) on a CD or DVD by June 3, 2019, the first day of the inspection. All requested information shall follow the Table 1 ST Week Onsite and the guidance document referenced above.

The preferred file format for all lists is a searchable Excel spreadsheet file on a CD or DVD. The CD or DVD 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 1 ST Week Onsite Section 3, Paragraph Number/Title: Items 10 Host-Based Intrusion Detection System Documentation for CDAs for systems selected for inspection 10.a.3) thru 10.a.12) 11 NIDS Documentation for Critical Systems That Have CDAs Associated with Them 11.a.3) thru 11.a.15) 12 SIEM Documentation for Critical Systems That Have CDAs Associated with Them 12.a.3) thru 12.a.14) 16 Supply Chain Management 16.c.2) 16.c.3)

16.c.4) 19 Cyber Security Event Notifications All 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;

NINE MILE POINT NUCLEAR STATION CYBER-SECURITY INSPECTION DOCUMENT REQUEST 5 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 team's 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.