ML18348A532

Information Request for the Cyber-Security Inspection, Notification to Perform Inspection 05000220/2019403 and 05000410/2019403

ML18348A532
Person / Time
Site:	Nine Mile Point
Issue date:	12/13/2018
From:	Glenn Dentel Engineering Region 1 Branch 2
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Dentel G
References
IR 2019403
Download: ML18348A532 (8)

See also: IR 05000220/2019403

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD., SUITE 100

KING OF PRUSSIA, PA 19406-2713

December 13, 2018

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: 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 NRCs 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 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

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.

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 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

Non-Sensitive Publicly Available

SUNSI Review

Sensitive 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

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 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

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 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 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 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 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

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NINE MILE POINT NUCLEAR STATION

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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

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.

(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.

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NINE MILE POINT NUCLEAR STATION

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

(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 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 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

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.b.

16.c.1)

16 Supply Chain Management

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

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NINE MILE POINT NUCLEAR STATION

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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 enclosures Section II., provide

the following RFI (i.e., Table 1ST Week Onsite) on a CD or DVD by June 3, 2019, the first

day of the inspection. All requested information shall follow the Table 1ST 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 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.c.2)

16 Supply Chain Management 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;

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NINE MILE POINT NUCLEAR STATION

CYBER-SECURITY INSPECTION DOCUMENT REQUEST

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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