ML24018A189
| ML24018A189 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/26/2024 |
| From: | Daniel Bacon Division of Reactor Safety II |
| To: | Coleman J Southern Nuclear Operating Co |
| References | |
| IR 2024403 | |
| Download: ML24018A189 (9) | |
See also: IR 05000424/2024403
Text
Jamie M. Coleman
Regulatory Affairs Director
Southern Nuclear Operating Co., Inc.
3535 Colonnade Parkway
Birmingham, AL 35243
SUBJECT: VOGTLE ELECTRIC GENERATING PLANT - INFORMATION REQUEST FOR THE
CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000424/2024403; 05000425/2024403
Dear Jamie Coleman:
On March 25, 2024, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
inspection in accordance with Inspection Procedure (IP) 71130.10 Cyber-Security, Revision 0
at your Vogtle Electric Generating Plant, Units 1 and 2. The inspection will be performed to
evaluate and verify your ability to provide assurance that your digital computer and
communication systems and networks associated with safety, security, or emergency
preparedness (SSEP) functions are adequately protected against cyber-attacks in accordance
with Title 10 of the Code of Federal Regulations (10 CFR) 73.54 and the U.S. Nuclear
Regulatory Commission (NRC) approved cyber security plan (CSP). The onsite portion of the
inspection will take place during the week of March 25th, 2024.
Experience has shown that baseline inspections are extremely resource intensive, both for the
NRC inspectors and the licensee staff. 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 IP. This information should
be made available electronically no later than February 9, 2024. The inspection team will
review this information and, by February 16, 2024, will request the specific items that should be
provided for review. This 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 the licensees CSP selected for the cyber-security
inspection. We request that the information provided from the second RFI be made available to
the regional office prior to the inspection by March 15, 2024.
January 26, 2024
J. Coleman
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, March 25, 2024.
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 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 Philipp Braaten. We understand that our regulatory
contact for this inspection is Jamaal Merriweather of your organization. If there are any
questions about the inspection or the material requested, please contact the lead inspector at
(404) 997-4651 or via e-mail at Philipp.braaten@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.
In accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding,
of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available
electronically for public inspection in the NRCs Public Document Room or from the Publicly
Available Records (PARS) component of the NRC's Agencywide Documents Access and
Management System (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
Daniel Bacon, Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 50-424; 50-425
Enclosure:
Vogtle Electric Generating Plant Cyber-Security
Inspection Document Request
cc w/encl: Distribution via LISTSERV
Signed by Bacon, Daniel
on 01/26/24
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE
RII/DRS
RII/DRS
NAME
P. Braaten
D. Bacon
DATE
01/25/2024
01/26/2024
VOGTLE ELECTRIC GENERATING PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
Enclosure
Inspection Report: 05000424/2024403; 05000425/2024403
Inspection Dates:
March 25 - March 29, 2024
Inspection Procedure:
IP 71130.10, Cyber-Security, Revision 0 (Effective: 01/01/2022)
Reference:
Guidance Document for Development of the Request for
Information (RFI) and Notification Letter for Full-Implementation of
the Cyber-Security Inspection, Rev. 2 (Issued: 11/22/2021)
NRC Inspectors:
404-997-4651
404-997-4440
philipp.braaten@nrc.gov
David.strickland@nrc.gov
301-415-5097
Jeff.rady@nrc.gov
NRC Contractors:
Balla Barro
balla.barro@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 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 9, 2024,
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 February 16, 2024, 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.
VOGTLE ELECTRIC GENERATING PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
2
We request that the additional information provided from the second RFI be made available to
the regional office prior to the inspection by March 15, 2024. All requests for information shall
follow the guidance document U.S. NRC - Guidance Document for Development of the Request
for Information (RFI) and Notification Letter for Full Implementation of the Cyber-Security
Inspection, referenced above.
VOGTLE ELECTRIC GENERATING PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
3
The required Table RFI 1 information shall be provided electronically to the lead inspector by
February 9, 2024. The preferred file format for all lists is a searchable Excel spreadsheet file.
The information 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
Paragraph Number/Title:
IP Ref
1
A list of all Identified Critical Systems and Critical Digital Assets, -
highlight/note any additions, deletions, reclassifications due to
new guidance from white papers, changes to NEI 10-04, 13-10,
etc. since the last cyber security inspection.
Overall
2
A list of EP and Security onsite and offsite digital communication
systems.
Overall
3
Network Topology Diagrams to include information and data flow
for critical systems in levels 2, 3, and 4 (If available).
Overall
4
Ongoing Monitoring and Assessment program documentation.
03.01(a)
5
The most recent effectiveness analysis of the Cyber Security
Program.
03.01(b)
6
Vulnerability screening/assessment and scan program
documentation.
03.01(c)
7
Cyber Security Incident Response program documentation,
including incident detection, response, and recovery
documentation as well as contingency plan development,
implementation, and including any program documentation that
requires testing of security boundary device functionality.
03.02(a)
and
03.04(b)
8
Device Access and Key Control program documentation.
03.02(c)
9
Password/Authenticator program documentation.
03.02(c)
10
User Account/Credential and Authentication program
documentation.
03.02(d)
11
Portable Media and Mobile Device control program
documentation, including kiosk security control
assessment/documentation.
03.02(e)
12
Design change/ modification program documentation and a list of
all design changes completed since the last cyber security
03.03(a)
VOGTLE ELECTRIC GENERATING PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
4
Table RFI #1
Paragraph Number/Title:
IP Ref
inspection, including either a summary of the design change or
the 50.59 documentation for the change.
13
Supply Chain Management program documentation including a
list of security impact analysis for new acquisitions.
03.03(a),
(b) and
(c)
14
Configuration Management program documentation including a
list of security impact analysis performed due to configuration
changes since the last cyber inspection.
03.03(a)
and (b)
15
Cyber Security Plan and any 50.54(p) analysis to support
changes to the plan since the last inspection.
03.04(a)
16
Cyber Security Performance Metrics tracked (if applicable).
03.06(b)
17
Provide a list of all cyber security procedures and policies with
their descriptive name and associated number.
Overall
19
Performance testing report (if applicable).
03.06(a)
20
Any cyber security event reports submitted in accordance with 10
CFR 73.77 since the last cyber security inspection and any
copies of any recordable cyber security events since the last
inspection
03.04(a)
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 February 16, 2024 for
the second RFI (i.e., RFI #2).
II.
Additional Information Requested to be Available Prior to Inspection.
As stated in Section I above, 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 February 16, 2024 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 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 referenced above.
The Table RFI 2 information shall be provided to the lead inspector by March 15, 2024.
The preferred file format for all lists is a searchable Excel spreadsheet. The information
VOGTLE ELECTRIC GENERATING PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
5
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
Paragraph Number/Title:
Items
For the system(s) chosen for inspection provide:
1
Ongoing Monitoring and Assessment activity performed on the
selected system(s).
03.01(a)
2
All Security Control Assessments for the selected design changes
and system(s).*
03.01(a)
3
All vulnerability screenings/assessments associated with or scans
performed on the selected system(s) since the last cyber security
inspection.* All vulnerability screenings and assessments completed
prior to putting new equipment into service as part of the select
design changes.
03.01(c)
4
Documentation (including configuration files and rules sets) for
Network-based Intrusion Detection/Protection Systems (NIDS/NIPS),
Host-based Intrusion Detection Systems (HIDS), and Security
Information and Event Management (SIEM) systems for system(s)
chosen for inspection. *
03.02(b)
5
Documentation (including configuration files and rule sets) for intra-
security level firewalls and boundary devices used to protect the
selected system(s).
03.02(c)
6
Copies of all periodic reviews of the access authorization list for the
selected systems since the last cyber inspection.
03.02(d)
7
Baseline configuration data sheets for the selected CDAs and for
selected design changes. *
03.03(a)
8
Security impact analysis for the selected design changes.
03.03(b)
9
Copies of the purchase order documentation for selected design
changes.
03.03(c)
10
Copies of any reports/assessment for cyber security drills performed
since the last inspection.
03.02(a)
03.04(b)
11
Copy of the individual recovery plan(s) for the selected system(s)
including documentation of the results the last time the backups
were executed.
03.02(a)
03.04(b)
VOGTLE ELECTRIC GENERATING PLANT CYBER-SECURITY INSPECTION DOCUMENT
REQUEST
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Table RFI #2
Paragraph Number/Title:
Items
12
List of Corrective actions taken as a result of cyber security
incidents/issues to include previous NRC violations and Licensee
Identified Violations since the last cyber security inspection.
03.05
- Some selected systems may have a large number of CDAs. For these systems reach out to
the team leader for a specific selection of CDAs when responding to this request.
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 Week Onsite) to the team by March 25, 2024, the first day of
the inspection. All requested information shall follow the guidance document referenced
above.
The preferred file format for all lists is a searchable Excel spreadsheet file. The
information 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 Week Onsite
Paragraph Number/Title:
Items
1
Updated copies of corrective actions taken as a result of cyber
security incidents/issues, to include previous NRC violations and
Licensee Identified Violations since the last cyber security
inspection, as well as vulnerability-related corrective actions.
03.05
2
The most recent Cyber-Security Quality Assurance audit and/or
self-assessment and a list of Corrective Actions generated as a
result
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.