ML18061A150
| ML18061A150 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 03/02/2018 |
| From: | Hausman G Engineering Branch 3 |
| To: | Dean Curtland NextEra Energy Duane Arnold |
| References | |
| IR 2018414 | |
| Download: ML18061A150 (8) | |
See also: IR 05000331/2018414
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE RD. SUITE 210
LISLE, ILLINOIS 60532-4352
March 2, 2018
Mr. Dean Curtland
Director of Site Operations
NextEra Energy Duane Arnold, LLC
3277 DAEC Road
Palo, IA 52324-9785
SUBJECT: DUANE ARNOLD ENERGY CENTERINFORMATION REQUEST FOR THE
CYBER-SECURITY FULL IMPLEMENTATION INSPECTION, NOTIFICATION
TO PERFORM INSPECTION 05000331/2018414
Dear Mr. Curtland:
On July 9, 2018, 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 Duane Arnold Energy Center. 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 (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 9, 2018, and July 23, 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. 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 April 16, 2018. The inspection team will review this
information and, by May 14, 2018, 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 June 11, 2018.
D. Curtland
-2-
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, July 9, 2018.
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 Mr. George M. Hausman. We understand that our
regulatory contact for this inspection is Ms. Laura B. Swenzinski of your organization. If there
are any questions about the inspection or the material requested, please contact the lead
inspector at 630-829-9743 or via e-mail at George.Hausman@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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
George M. Hausman, Senior Reactor Inspector
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-331;72-032
License No. DPR-49
Enclosure:
Document Request for Cyber-Security
Inspection
cc: Distribution via LISTSERV
D. Curtland
-3-
Letter to Dean Curtland from George M. Hausman dated March 2, 2018
SUBJECT: DUANE ARNOLD ENERGY CENTERINFORMATION REQUEST FOR THE
CYBER-SECURITY FULL IMPLEMENTATION INSPECTION, NOTIFICATION
TO PERFORM INSPECTION 05000331/2018414
DISTRIBUTION:
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ADAMS Accession Number ML: 18061A150
OFFICE
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RIII
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NAME
GHausman:cl
DATE
03/02/18
OFFICIAL RECORD COPY
DOCUMENT REQUEST FOR CYBER-SECURITY INSPECTION
Enclosure
Inspection Report: 05000331/2018414
Inspection Dates:
Weeks of July 9, 2018, and July 23, 2018
Inspection Procedure:
IP 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
NRC Inspectors:
George M. Hausman, Lead
Jasmine A. Gilliam
630-829-9743
630-829-9831
George.Hausman@nrc.gov
Jasmine.Gilliam@nrc.gov
Kim M. Lawson-Jenkins
301-287-3656
Kim.Lawson-Jenkins@nrc.gov
NRC Contractors:
Alan B. Konkal
Jeffrey Man
561-989-0210
301-310-4275
Alan.Konkal@nrc.gov
Jeffrey.Man@nrc.gov
Observers:
Rodney J. Fanner
John A. Walley
404-997-4638
703-999-9098
Rodney.Fanner@nrc.gov
John.Walley@nrc.gov
Robert C. Daley
630-829-9749
Robert.Daley@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 (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 security control
portions of the CSP 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 April 16, 2018, or sooner, to facilitate the selection of the specific items
that will be reviewed during the onsite inspection weeks.
DOCUMENT REQUEST FOR CYBER-SECURITY INSPECTION
2
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 May 14, 2018, 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 April 16, 2018. 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
Protocol/Internet Protocol Based Local Area Networks (LANs) and
Identify Those LANs That Have Non-CDAs On Them
All
3
List CDA Facility and Site Non-Ethernet Transmission Control
Protocol/Internet Protocol 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 and Security Information and Event
Managements (SIEM) for Emergency Preparedness 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 CSs That
Have CDAs Associated with Them
11.a.1)
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 Teams
All
28
Copy of Current Cyber Security Plan and Copy of 50.54(p)
Analysis To Support Changes To That Plan
All
29
Copy Of Any Licensee-Identified Violations and Associated
Corrective Action Program Documentation To Resolve Issue(s)
All
DOCUMENT REQUEST FOR CYBER-SECURITY INSPECTION
3
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 May 14, 2018, 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 May 14, 2018, for the second RFI
(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 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
June 11, 2018. 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 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
DOCUMENT REQUEST FOR CYBER-SECURITY INSPECTION
4
Table RFI #2
Reference Section 3, Paragraph Number/Title:
Items
20
Vendor Access and Monitoring
All
21
Work Control
All
22
Device Access and Key Control
All
23
Password/Authenticator Policy
All
24
User Account/Credential Policy
All
26
Corrective Actions Since Last U.S. Nuclear Regulatory
Commission 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 this enclosuresSection II., provide
the following RFI (i.e., Table 1st Week Onsite) on CD by July 9, 2018, 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 Systems Selected for Inspection
10.a.3) thru
10.a.12)
11
Network Intrusion Detection System Documentation for CSs That
Have CDAs Associated with Them
11.a.3) 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 Actions Taken Since the Initial Request Was Made
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;
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.
DOCUMENT REQUEST FOR CYBER-SECURITY INSPECTION
5
(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.