IR 05000315/2020410

Information Request for the Cyber Security Full Implementation Inspection, Notification to Perform Inspection 05000315/2020410; 05000316/2020410

ML19323F427
Person / Time
Site:	Cook
Issue date:	11/19/2019
From:	Alan Dahbur Division of Reactor Safety III
To:	Gebbie J Indiana Michigan Power Co
References
IR 2020410
Download: ML19323F427 (8)

Text

ber 19, 2019

SUBJECT:

DONALD C. COOK NUCLEAR POWER PLANT, UNITS 1 AND 2 INFORMATION REQUEST FOR THE CYBER-SECURITY FULL IMPLEMENTATION INSPECTION, NOTIFICATION TO PERFORM INSPECTION 05000315/2020410; 05000316/2020410

Dear Mr. Gebbie:

On March 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) will begin an inspection in accordance with Inspection Procedure 71130.10P Cyber-Security, issued May 15, 2017, at your Donald C. Cook Nuclear Power Plant, Units 1 and 2. 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, 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 30, 2020, and April 13, 2020.

Experience has shown that these 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 10, 2020. The inspection team will review this information and, by January 31, 2020, 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, 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 28, 2020.

• 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 30, 2020. * 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 Alan Dahbur. We understand that our regulatory contact for this inspection is Mat Hoholek of your organization. If there are any questions about the inspection or the material requested, please contact the lead inspector at 630-829-9810 or via e-mail at Alan.Dahbur@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 made 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 Title 10 of the Code of Federal Regulations, Part 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA John Robbins for/

Alan Dahbur, Senior Reactor Inspector Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74 Enclosure:

Document Request for Cyber-Security Inspection cc: Distribution via LISTSERV

ML19323F427 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available OFFICE RIII/DRS NAME ADahbur/JR DATE 11/19/19

Inspection Report: 05000315/2020410; 05000316/2020410 Inspection Dates: Weeks of March 30, 2020, and April 13, 2020 Inspection Procedure: 71130.10P, Cyber-Security, Issue Date May 15, 2017 Reference: Guidance Document for Development of the Request for Information and Notification Letter for Full-Implementation of the Cyber-Security Inspection, Issue Date October 26, 2017 (ML17156A215)

NRC Inspectors: Alan Dahbur, Lead John Robbins 630-829-9810 630-829-9744 Alan.Dahbur@nrc.gov John. Robbins@nrc.gov NRC Contractors: Joseph Cristiano Timothy B. Marshall 301-415-7000 703-964-6891 Joseph.Cristiano@nrc.gov Timothy.Marshall@nrc.gov Observer: Ann Marie Stone 630-829-9729 AnnMarie.Stone@nrc.gov I Information Requested for In-Office Preparation The initial request for information (i.e., first Request for Information (RFI)) concentrates on providing the inspection team with the general 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 (CSs) and critical digital assets (CDAs) plus operational and management security control portions of the Cyber-Security Program to be chosen as the sample set required to be inspected by the Cyber-Security Inspection Procedure. 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 10, 2020, 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 31, 2020, 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. All requests for this 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 10, 2020. Please provide five 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. 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 CSs and CDAs All 2 List CDA Facility and Site EthernetTransmission Control All Protocol/Internet Protocol Based Local Area Networks (LANs) and Identify Those LANs That Have Non-CDAs On Them 3 List CDA Facility and Site Non-Ethernet Transmission Control All Protocol/Internet Protocol Based LANs Including Those Industrial Networks and Identify LANs That Have Non-CDAs On Them 4 Network Topology Diagrams (Be Sure To Include All Network Intrusion All Detection System and Security Information and Event Managements (SIEM) for Emergency Preparedness (EP) Networks and Security Level 3 and 4 Networks)

8 List All Network Security Boundary Devices for EP Networks and All All Network Security Boundary Devices for Levels 3 and 4 9 List CDA Wireless Industrial Networks All 11 Network Intrusion Detection System Documentation for CSs That Have 11.a.1)

CDAs Associated with Them 11.a.2)

12 SIEM Documentation for CSs 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 All Teams 28 Copy of Current Cyber Security Plan and Copy of 50.54(p) Analysis To All Support Changes To That Plan 29 Copy Of Any Licensee-Identified Violations and Associated Corrective All Action Program Documentation To Resolve Issue(s)

In addition to the above information please provide the following:

(1) Electronic copy of the Updated Finals Safety Analysis Report 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 31, 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 January 31, 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 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 requests for this 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 28, 2020. Please provide five 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. 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 Reference Section 3, Paragraph Number/Title: Items 5 Plant Computer System Block Diagram (If Plant Computer System Is All Selected for Inspection)

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

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

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

Systems Selected for Inspection) 10.a.2)

13 List All Maintenance and Test Equipment Used On CDAs for Systems All Selected for Inspection 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

Table RFI #2 Reference Section 3, Paragraph Number/Title: Items 23 Password/Authenticator Policy All 24 User Account/Credential Policy All 26 Corrective Actions Since Last U.S. Nuclear Regulatory Commission All Inspection 27 Cyber Security Assessments for Selected Systems All III Information Requested to be Available on First Day of Inspection For the specific systems and equipment identified in this enclosures Section II., provide the following RFI (i.e., Table 1st Week Onsite) on CD by March 30, 2020, the first day of the inspection. All requests for this information shall follow the Table 1st Week Onsite and the guidance document referenced above.

Please provide five 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. 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 Reference Section 3, Paragraph Number/Title: Items 10 Host-Based Intrusion Detection System Documentation for CDAs for 10.a.3)

Systems Selected for Inspection thru 10.a.12)

11 Network Intrusion Detection System Documentation for CSs That Have 11.a.3)

CDAs Associated with Them thru 11.a.15)

12 SIEM Documentation for CSs 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 29 Update to Licensee Identified Violations and Corrective Action Program All Actions Taken Since the Initial Request Was Made 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 Plan; e. Latest Individual Plant Examination/Probabilistic Risk Assessment Report; and f. Vendor Manuals.

(2) Assessment and Corrective Actions:

a. The most recent Cyber-Security Quality Assurance 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 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.

5