ML20049A099
| ML20049A099 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/14/2020 |
| From: | Greg Pick NRC Region 4 |
| To: | Lacal M Arizona Public Service Co |
| Taylor N | |
| References | |
| IR 2020401 | |
| Download: ML20049A099 (8) | |
See also: IR 05000528/2020401
Text
February 14, 2020
Mrs. Maria L. Lacal
Executive Vice President/
Chief Nuclear Officer
Arizona Public Service Company
P.O. Box 52034, MS 7602
Phoenix, AZ 85072-2034
SUBJECT: PALO VERDE NUCLEAR GENERATING STATION - NOTIFICATION
OF CYBER SECURITY INSPECTION (NRC INSPECTION
REPORT 05000528/2020401; 05000529/2020401; AND
05000530/2020401) AND REQUEST FOR INFORMATION
Dear Mrs. Lacal:
On September 28, 2020, the U.S. Nuclear Regulatory Commission (NRC) will begin an
inspection in accordance with Inspection Procedure (IP) 71130.10P, Cyber Security,
Revision 0, at the Palo Verde Nuclear Generating Station. This inspection evaluates and
verifies your ability to meet the full implementation requirements of the NRCs Cyber Security
Rule, Title 10, Code of Federal Regulations (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 September 28 and October 19, 2020.
Experience has shown that these inspections are extremely resource intensive, both for the
NRC inspectors and 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. The document request has been divided into four
groups.
The first group specifies information necessary to assist the team in choosing the focus areas
(i.e., sample set) to be inspected in accordance with the cyber security inspection procedure.
This information should be made available using either a secure document management
service or passive media (i.e. CD, DVD) and delivered to the regional office no later than
June 29, 2020. The inspection team will review this information and by the end of the planned
information gathering visit on August 5, 2020, will request the specific items that should be
provided for review.
The second group of requested documents will assist the team in their evaluation of the critical
systems and critical digital assets, defensive architecture, and the areas of the cyber security
plan selected for inspection. This information will be requested for our review in the regional
office prior to the inspection by August 24, 2020.
The third group of requested documents consists of those items that the team will review or
need access to, during the inspection. Please have this information available by the first day of
the onsite inspection, September 28, 2020.
M. Lacal 2
The fourth group of information is necessary to aid the 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 Mr. Greg Pick. We understand that our regulatory
contact for this inspection is Mr. Sean Dornseif. If there are any questions about the inspection
or the material requested, please contact the lead inspector at 817-200-1270 or by e-mail
at greg.pick@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 (approval number 3150-0011). Send comments
regarding this information collection to the Information Services Branch, Office of the Chief
Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington,
DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office
of Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and
Budget, Washington, DC 20503.
Public Protection Notification
The NRC may not conduct nor 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 OMB control number.
This letter, its enclosure, and your response (if any) 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for
Withholding.
Sincerely,
/RA/
Gregory A. Pick, Senior Reactor Inspector
Engineering Branch 2
Division of Reactor Safety
Dockets: 50-528; 50-529; 50-530
Licenses: NPF-41; NPF-51; NPF-74
Enclosure:
Palo Verde Nuclear Generating Station -
Cyber Security Inspection Document Request
cc w/encl: Electronic Distribution
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: GAP Yes No Publicly Available Sensitive NRC-002
OFFICE SRI:EB2
NAME G. Pick
SIGNATURE /RA/
DATE 02/14/2020
Palo Verde Nuclear Generating Station
Cyber Security Inspection Document Request
Inspection Report: 05000528/2020401; 05000529/2020401; 05000530/2020401
Inspection Dates: Weeks of September 28 and October 19, 2020
Inspection Procedure: IP 71130.10P, Cyber Security, Revision 0
Reference 1: ML17156A215 - Guidance Document for Development of the
Request for Information (RFI) and Notification Letter for
Full-Implementation of the Cyber Security Inspection,
Revision 1, dated October 26, 2017
NRC Inspectors: Greg Pick, Lead Shiattin Makor
817-200-1270 817-200-1507
greg.pick@nrc.gov shiattin.makor@nrc.gov
NRC Contractors: Joe Cristiano Al Konkal
301-287-0582 561-989-0210
joseph.cristiano@nrc.gov alan.konkal@nrc.gov
Other Personnel: Juris Jauntirans Dan Livermore
301-415-3197 817-200-1517
juris.jauntirans@nrc.gov dan.livermore@nrc.gov
I. Information Requested for In-Office Preparation
The initial request for information (i.e., first RFI) provides the team with the general
information necessary to select appropriate components and cyber security plan
elements to develop a site-specific inspection plan. The team will use the first set of
information requested to identify the list of critical systems and critical digital assets
plus operational and management security control portions of the cyber security plan
to be chosen as the sample set required to be inspected during this inspection. The
first information request is specified in Table RFI #1. Provide the first set of
information to the team lead in the regional office by June 29, 2020, or sooner, to
facilitate the selection of the specific items that will be reviewed during the onsite
inspection weeks.
The requested information shall be provided on either a secure document management
service or passive media (i.e. CD or DVD) to the lead inspector. Please provide five
copies of each media submitted (i.e., one for each inspector/contractor). The preferred
file format for all lists is a searchable Excel spreadsheet file on a CD or DVD. These files
should be indexed and hyperlinked to facilitate efficient review. If you have any
questions regarding this information, please contact the inspection team lead as soon as
possible.
Enclosure
Table RFI #1
Section 3: Initial Documentation Requests (See Items
Reference 1) Paragraph Number/Title:
1 List all identified critical systems and critical digital assets All
List critical digital asset facility and site ethernet - transmission control
2 protocol/internet protocol (TCP/IP) based local area networks (LANs) All
and identify those LANs that have non-critical digital assets on them
List critical digital asset facility and site non-ethernet TCP/IP based
3 LANs including those industrial networks and identify LANs that All
have non-critical digital assets on them
Network topology diagrams (be sure to include all network intrusion
detection systems and security information and event management
4 All
(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 critical digital asset wireless Industrial networks All
Network Intrusion detection system documentation for critical systems 11.a.1)
11 that have critical digital assets associated with them 11.a.2)
SIEM documentation for critical systems that have critical digital assets 12.a.1)
12 associated with them 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
Copy of current cyber security plan and copy of any 50.54(p) analysis
28 All
to support changes to that plan
Copy of any licensee identified violations and associated corrective
29 All
action program documentation to resolve issue(s)
In addition to the above information please provide the following:
(1) Electronic copy of the updated safety analysis report and technical specifications
(2) Name(s) and phone number(s) for the regulatory and technical contacts
(3) Current management and engineering organizational charts related to cyber security
(4) Cyber security program procedures
Based on this information, the team will identify and select specific systems and
equipment (e.g., critical systems and critical digital assets) from the information
requested by Table RFI #1 and submit a list of specific systems and equipment to your
staff by the end of the information gathering visit on August 5, 2020, for the second
information request (i.e., Table RFI #2).
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II. Additional Information Requested to be Available Prior to Inspection
As stated in Section I, the team will examine the documents from the initial information
request and submit the list of specific systems and equipment to your staff by the end of
the information gathering visit. This second information request (i.e., Table RFI #2)
obtains additional documents required to evaluate the critical systems and critical digital
assets, defensive architecture, and the areas of the cyber security program 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 guidance document Reference 1.
Provide the Table RFI #2 information on a secure document management service or
passive media to the lead inspector by August 24, 2020, or sooner. Please provide five
copies of each CD/DVD submitted (i.e., one for each inspector/contractor). The preferred
file format for all lists is a searchable Excel spreadsheet file on a CD/DVD. These files
should be indexed and hyperlinked to facilitate efficient review. If you have any questions
regarding this information, please call the inspection team lead as soon as possible.
Table RFI #2
Section 3: Initial Documentation Requests (See Items
Reference 1) Paragraph Number/Title:
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)
Block diagrams for distributed systems (for systems selected for
7 All
inspection)
Host-based intrusion detection system documentation for critical 10.a.1)
10 digital assets (for systems selected for inspection) 10.a.2)
List all maintenance and test equipment (M&TE) used on critical digital
13 All
assets (for systems selected for inspection)
15 Configuration management All
16.a
16 Supply chain management
16.b
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
23 Password/authenticator policy All
3
Table RFI #2
Section 3: Initial Documentation Requests (See Items
Reference 1) Paragraph Number/Title:
24 User account/credential policy All
26 Corrective actions since last NRC inspection All
27 Cyber security assessments for selected systems All
In addition to the above information please provide the following:
(1) Names and positions of the CSAT and CSIRT members.
(2) Copies of lesson plans and training presented to the CSAT and CSIRT members,
continuing technical training for engineers, as well as any general awareness
training.
(3) List of dates of CSAT meetings that have occurred.
III. Information Requested to be Available on First Day of Inspection
For the specific systems and equipment identified in Section II, provide the following
request for information (i.e., Table 1st Week Onsite) on a secure document management
service or passive media by September 28, 2020, the first day of the inspection. All
requested information shall follow the guidance in Reference 1.
Please provide four copies of each CD submitted (i.e., one for each inspector/contactor).
The preferred file format for all lists is a searchable Excel spreadsheet file on a CD/DVD.
These files should be indexed and hyperlinked to facilitate ease of use. If you have any
questions regarding this information, please call the inspection team lead as soon as
possible.
Table 1st Week Onsite
Section 3: Initial Documentation Requests (See
Reference 1) Paragraph Number/Title: Items
10.a.3)
10 Host-based intrusion detection system documentation for critical thru
digital assets (for systems selected for inspection) 10.a.12)
11.a.3)
11 Network Intrusion detection system documentation for critical thru
systems that have critical digital assets associated with them 11.a.15)
12.a.3)
12 SIEM documentation for critical systems that have critical digital thru
assets associated with them 12.a.14)
16 Supply chain management 16.c
19 Cyber security event notifications All
4
Table 1st Week Onsite
Section 3: Initial Documentation Requests (See
Reference 1) Paragraph Number/Title: Items
Update to licensee identified violations and corrective action All
29 program 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. Quality Assurance Plan;
b. Technical Specifications, if not previously provided;
c. Latest Individual Plant Examination/Probabilistic Risk Assessment
Report; and,
(2) Vendor Manuals, Assessments, 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.
c. Vendor manuals for the selected critical digital assets.
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 team lead.
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