ML18044A048
| ML18044A048 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 02/12/2018 |
| From: | Greg Werner Division of Reactor Safety IV |
| To: | Richard Anderson Entergy Operations |
| Werner G | |
| References | |
| IR 2018405 | |
| Download: ML18044A048 (8) | |
See also: IR 05000313/2018405
Text
February 12, 2018
Mr. Richard L. Anderson, Vice President
Entergy Operations, Inc.
1448 S.R. 333
Russellville, AR 72802-0967
SUBJECT:
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 - NOTIFICATION OF CYBER-
SECURITY INSPECTION (NRC INSPECTION REPORT 05000313/2018405
AND 05000368/2018405) AND REQUEST FOR INFORMATION
Dear Mr. Anderson:
On July 23, 2018, the U.S. Nuclear Regulatory Commission (NRC) will begin an inspection in
accordance with Inspection Procedure (IP) 71130.10P, Cyber-Security, Revision 0, at
Arkansas Nuclear One, Units 1 and 2. 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 July 23, 2018, and August 6, 2018.
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. 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 IMS/CERTREC (preferred) or passive
media (i.e. CD, DVD) and delivered to the regional office no later than April 30, 2018. The
inspection team will review this information and by the end of the planned information gathering
visit on June 28, 2018, 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 review in the regional office
prior to the inspection by July 9, 2018, as identified above.
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, July 23, 2018.
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
R. Anderson
2
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 Sam Graves. We understand that our regulatory
contact for this inspection is Natalie Mosher. If there are any questions about the inspection or
the material requested, please contact the lead inspector at 817-200-1102, or by e-mail at
samuel.graves@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 under 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Gregory E. Werner, Chief
Engineering Branch 2
Division of Reactor Safety
Dockets: 50-313; 50-368
Enclosure:
Arkansas Nuclear One -
Cyber-Security Inspection Document Request
cc w/ encl: Electronic Distribution
Enclosure
Arkansas Nuclear One - Cyber-Security Inspection Document Request
Inspection Report: 05000313/2018405
Inspection Dates:
Weeks of July 23, 2018, and August 6, 2018
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, [OFFICIAL USE ONLY- SECURITY
RELATED INFORMATION]
NRC Inspectors:
817-200-1102
817-200-1270
samuel.graves@nrc.gov
greg.pick@nrc.gov
Dan Livermore (Observer)
Catherine Allen (HQ Liaison)
817-200-1517
catherine.allen@nrc.gov
dan.livermore@nrc.gov
NRC Contractors:
william.jones2@nrc.gov
cynthia.debisschop@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 (O&M) 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 leader in the regional office by April 30, 2018, or sooner, to facilitate the
selection of the specific items that will be reviewed during the onsite inspection weeks.
The 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 for information to develop the second RFI. The inspection team will submit the
specific systems and equipment list to your staff by the end of the planned information
gathering visit on June 28, 2018, which will identify the specific systems and equipment
that will be utilized 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. We request that the additional information provided from the second RFI be
made available to the regional office prior to the inspection by July 9, 2018. All requests
for information shall follow the guidance in Reference 1.
2
The required Table RFI #1 information shall be provided on IMS/CERTREC or passive
media (i.e. CD or DVD) to the lead inspector by April 30, 2018. Please provide five
copies of each passive media submitted (i.e., one for each inspector/contractor). The
preferred file format for all lists is a searchable Excel spreadsheet file. The files should
be indexed and hyperlinked to facilitate efficient review. If you have any questions
regarding this information, please contact the inspection team leader as soon as
possible.
Table RFI #1
Section 3: Initial Documentation Requests (See Reference 1)
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 LANs 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 NIDS and SIEMs
for 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 Network intrusion detection system documentation for Critical Systems
that have CDAs associated with them
11.a.1)
11.a.2)
12 Security Information and Event Management (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
28
Copy of Current Cyber-Security Plan and copy of any 50.54(p) analysis
to support changes to that plan
All
29
Copy of any Licensee Identified Violations (LIVs) and associated
Corrective Action Program (CAP) documentation to resolve issue(s)
All
In addition to the above information please provide the following:
(1) Electronic copy of the UFSAR 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 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
3
staff by the end of the information gathering visit on June 28, 2018, for the second
information request (i.e., RFI #2).
II.
Additional Information Requested to be Available Prior to Inspection
As stated in Section I above, the team will examine the returned documentation
requested 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 on June 28, 2018,
for the second request for information (i.e., Table 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 requested information shall follow the guidance document
Reference 1.
The Table RFI #2 information shall be provided on IMS/CERTREC or passive media to
the lead inspector by July 9, 2018. Please provide five copies of each passive media
submitted (i.e., one for each inspector/contractor). The preferred file format for all lists is
a searchable Excel spreadsheet file. These files should be indexed and hyperlinked to
facilitate efficient review. If you have any questions regarding this information, please
call the inspection team leader as soon as possible.
Table RFI #2
Section 3: Initial Documentation Requests (See Reference 1)
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 Block Diagrams for distributed systems (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 (M&TE) used on CDAs (for
systems selected for inspection)
All
15 Configuration Management
All
16 Supply Chain Management
16.a.
16.b.1)
16.b.5)
16.b.6)
17 Portable Media and Mobile Device Control
All
18 Software Management
All
20 Vendor Access and Monitoring
All
21 Work Control
All
4
Table RFI #2
Section 3: Initial Documentation Requests (See Reference 1)
Paragraph Number/Title:
Items
22 Device Access and Key Control
All
23 Password/Authenticator Policy
All
24 User Account/Credential Policy
All
26 Corrective Actions since last NRC Inspection
All
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 Section II above, provide the
following RFI (i.e., Table 1st Week Onsite) on either IMS/CERTREC or passive media by
July 23, 2018, the first day of the inspection. All requested information shall follow the
guidance in Reference 1.
Please provide five copies of each passive media submitted (i.e., one for each
inspector/contactor). The preferred file format for all lists is a searchable Excel
spreadsheet file. 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
leader as soon as possible.
Table 1st Week Onsite
Section 3: Initial Documentation Requests (See Reference 1)
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 Network intrusion Detection System documentation for Critical
Systems that have CDAs associated with them
11.a.3)
thru
11.a.15)
12 Security Information and Event Management (SIEM) documentation
for Critical systems that have CDAs associated with them
12.a.3)
thru
12.a.14)
16 Supply Chain Management
16.b.2)
16.b.3)
16.b.4)
19 Cyber-Security Event Notifications
All
29 Copy of any Licensee Identified Violations (LIVs) and associated
Corrective Action Program (CAP) documentation to resolve issue(s)
All
In addition to the above information please provide the following:
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(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. Original FSAR Volumes;
c. Original SER and Supplements;
d. FSAR Question and Answers;
e. Quality Assurance Plan;
f. Technical Specifications, if not previously provided;
g. Latest IPE/PRA Report;
(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.
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 leader.
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword: NRC-002
By: STG Yes No Publicly Available Sensitive
OFFICE
SRI:EB2
BC:EB2
BC:PBE
BC:EB2
NAME
SGraves
GWerner
NOKeefe
GWerner
SIGNATURE
/RA/
/RA/
/RA/
/RA/
DATE
01/23/2018
01/30/2018
02/08/2018
02/12/2018