ML20337A424
| ML20337A424 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/02/2020 |
| From: | Alan Dahbur Engineering Branch 3 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2021401 | |
| Download: ML20337A424 (8) | |
See also: IR 05000237/2021401
Text
December 2, 2020
Mr. Bryan C. Hanson
Senior VP, Exelon Generation Co., LLC
President and CNO, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3INFORMATION
REQUEST FOR THE CYBER-SECURITY FULL IMPLEMENTATION INSPECTION,
NOTIFICATION TO PERFORM INSPECTION 05000237/2021401 AND
Dear Mr. Hanson:
On March 8, 2021, 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 Dresden Nuclear Power Station, Units 2 and 3. 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 8 and March 22, 2021.
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 8, 2021. The inspection team will review this
information and, by January 22, 2021, 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 February 19, 2021.
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 8, 2021.
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 Mr. Alan Dahbur. We understand that our regulatory
contact for this inspection is Mr. Dean Walker 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/
Alan Dahbur, Senior Reactor Inspector
Engineering Branch 3
Division of Reactor Safety
Docket Nos. 50-237; 50-249
Enclosure:
Cyber-Security Inspection
Document Request
cc: Distribution via LISTSERV
B. Hanson
-3-
Letter to Bryan C. Hanson from Alan Dahbur dated December 2, 2020.
SUBJECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3INFORMATION
REQUEST FOR THE CYBER-SECURITY FULL IMPLEMENTATION
INSPECTION, NOTIFICATION TO PERFORM INSPECTION 05000237/2021401
AND 05000249/2021401
DISTRIBUTION:
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RidsNrrPMDresden Resource
RidsNrrDroIrib Resource
Kenneth OBrien
DRPIII
DRSIII
ADAMS Accession Number: ML20337A424
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
NAME
ADahbur:mb via
DATE
12/02/2020
OFFICIAL RECORD COPY
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Enclosure
Inspection Report: 05000237/2021401 and 05000249/2021401
Inspection Dates:
Weeks of March 8, 2021, and March 22, 2021
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:
Clinton Hobbs (Region I)
630-829-9810
610-337-5104
Alan.Dahbur@nrc.gov
Clinton.Hobbs@nrc.gov
NRC Contractors:
Cynthia.DeBisschop@nrc.gov
Alan.Konkal@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 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 No. 1. The
Table RFI No. 1 information is requested to be provided to the regional office by January
8, 2021, 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 22, 2021, 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 No. 1 and the guidance document referenced above.
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
2
The required Table RFI No. 1 information shall be provided on compact disc (CD)
and/or via ShareFile to the lead inspector by January 8, 2021. Please provide four
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 No. 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 NIDs and Security
Information and Event Managements (SIEM) 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 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 (CAP) Documentation To Resolve Issue(s)
All
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.
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
3
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 No. 1 and
submit a list of specific systems and equipment to your staff by January 22, 2021, for the
second RFI (i.e., Table RFI No. 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 No. 1 and submit the list of specific
systems and equipment to your staff by January 22, 2021, for the second RFI
(i.e., Table RFI No. 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 No. 2. All requests for this
information shall follow the Table RFI No. 2 and the guidance document referenced
above.
The Table RFI No. 2 information shall be provided on CD and/or via ShareFile to the
lead inspector by February 19, 2021. Please provide four 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 No. 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
20 Vendor Access and Monitoring
All
21 Work Control
All
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
4
Table RFI No. 2
Reference Section 3, 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 this enclosuresSection II., provide
the following RFI (i.e., Table First Week Onsite) on CD and/or ShareFile by March 8,
2021, the first day of the inspection. All requests for this information shall follow the
Table First Week Onsite and the guidance document referenced above.
Please provide four copies of each CD submitted (i.e., one for each inspector/contractor)
and/or access to ShareFile. 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 First 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 CAP Actions Taken Since
the Initial Request Was Made
All
CYBER-SECURITY INSPECTION DOCUMENT REQUEST
5
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 IPE/PRA 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) generate 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.