ML24018A189

Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000424/2024403; 05000425/2024403

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

License Nos. NPF-68; NPF-81

Enclosure:

Vogtle Electric Generating Plant Cyber-Security

Inspection Document Request

cc w/encl: Distribution via LISTSERV

Signed by Bacon, Daniel

on 01/26/24

ML24018A189

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:

Philipp Braaten, Lead

David Strickland

404-997-4651

404-997-4440

philipp.braaten@nrc.gov

David.strickland@nrc.gov

Jeff Rady

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

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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.