ML19295E162
| ML19295E162 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/22/2019 |
| From: | Nick Taylor Division of Reactor Safety IV |
| To: | Peters K Vistra Operations Company |
| Taylor N | |
| References | |
| IR 2020401 | |
| Download: ML19295E162 (8) | |
See also: IR 05000445/2020401
Text
October 22, 2019
Mr. Ken J. Peters, Senior Vice President
and Chief Nuclear Officer
Attention: Regulatory Affairs
Vistra Operations Company LLC
P.O. Box 1002
Glen Rose, TX 76043
SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 -
NOTIFICATION OF CYBER SECURITY INSPECTION (NRC
INSPECTION REPORT 05000445/2020401 AND
05000446/2020401) AND REQUEST FOR INFORMATION
Dear Mr. Peters:
On February 10, 2020, the U.S. Nuclear Regulatory Commission (NRC) will begin an
inspection in accordance with Inspection Procedure (IP) 71130.10P, Cyber Security,
Revision 0, at Comanche Peak Nuclear Power Plant, 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 February 10 and February 24, 2020.
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 a secure document management
service or passive media (i.e. CD, DVD) and delivered to the regional office no later than
December 2, 2019. The inspection team will review this information and by the end of the
planned information gathering visit on January 16, 2020, 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 our review in the regional
office prior to the inspection, by January 27, 2020.
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, February 10, 2020.
K. Peters 2
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
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 Jim Barnette. 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 collections that are subject to the
Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and
Budget (OMB) approved these information collections (approval number 3150-0011). The NRC
may not conduct nor 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 OMB control number.
This letter, its enclosure, and your response (if any) 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/
Nicholas H. Taylor, Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos. 05000445 and 05000446
License Nos. NPF-87 and NPF-89
Enclosure:
Comanche Peak Nuclear Power Plant -
Cyber Security Inspection Document Request
cc: Mr. Mike McNally
Manager, Nuclear Security
Comanche Peak Nuclear Power Plant
Vistra Operations Company LLC
6322 N FM 56
P.O. Box 1002
Glen Rose, TX 76043
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: STG Yes No Publicly Available Sensitive NRC-002
OFFICE SRI:EB2 C:EB2
NAME SGraves NTaylor
SIGNATURE /RA/ /RA/
DATE 10/22/2019 10/22/2019
Comanche Peak Nuclear Power Plant - Cyber Security Inspection Document Request
Inspection Report: 05000445/2020401 and 05000446/2020401
Inspection Dates: Weeks of February 10 and February 24, 2020
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
NRC Inspectors: Sam Graves, Lead Steven Alferink
817-200-1102 817-200-1548
Samuel.Graves@nrc.gov Steven.Alferink@nrc.gov
David You, Observer
817-200-1233
David.You@nrc.gov
NRC Contractors: Alan Konkal William Johns
561-989-0210 301-287-3752
Alan.Konkal@nrc.gov William.Johns@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 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 lead in the regional office, by December 2, 2019, or sooner,
to facilitate the selection of the specific items that will be reviewed during the onsite
inspection weeks.
The required Table RFI #1 information shall be provided on a secure document
management service or passive media (i.e. CD or DVD) to the lead inspector. Please
provide five copies of each media submitted (i.e., one for each inspector/contractor). The
preferred file format for all lists is a searchable Excel spreadsheet file on a CD or DVD.
These files should be indexed and hyperlinked to facilitate efficient review. If you have
any questions regarding this information, please contact the inspection team lead as
soon as possible.
Enclosure
Table RFI #1
Section 3: Initial Documentation Requests (See Items
Reference 1) Paragraph Number/Title:
1 List all identified critical systems and critical digital assets All
List critical digital asset facility and site ethernet - transmission control
2 protocol/internet protocol (TCP/IP) based local area networks (LANs) All
and identify those LANs that have non-critical digital assets on them
List critical digital asset facility and site non-ethernet TCP/IP based
3 LANs including those industrial networks and identify LANs that have All
non-critical digital assets on them
Network topology diagrams (be sure to include all network intrusion
detection systems and security information and event management
4 All
(SIEMs) for emergency preparedness (EP) networks and security
level 3 and 4 networks)
List all network security boundary devices for EP networks and all
8 All
network security boundary devices for levels 3 and 4
9 List critical digital asset wireless Industrial networks All
Network Intrusion detection system documentation for critical systems 11.a.1)
11 that have critical digital assets associated with them 11.a.2)
SIEM documentation for critical systems that have critical digital assets 12.a.1)
12 associated with them 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
Copy of current cyber security plan and copy of any 50.54(p) analysis
28 All
to support changes to that plan
Copy of any licensee identified violations and associated corrective
29 All
action program documentation to resolve issue(s)
In addition to the above information please provide the following:
(1) Electronic copy of the updated safety analysis report and technical specifications
(2) Name(s) and phone number(s) for the regulatory and technical contacts
(3) Current management and engineering organizational charts related to cyber security
(4) Cyber security program procedures
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
staff by the end of the information gathering visit on January 16, 2020, for the second
information request (i.e., Table RFI #2).
2
II. Additional Information Requested to be Available Prior to Inspection
As stated in Section I, the team will examine the documents 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 January 16, 2020. This second information request
(i.e., Table RFI #2) obtains additional documents required 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. 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 a secure document management
service or passive media to the lead inspector, by January 27, 2020, or sooner. Please
provide five copies of each CD/DVD submitted (i.e., one for each inspector/contractor).
The preferred file format for all lists is a searchable Excel spreadsheet file on a CD/DVD.
These files should be indexed and hyperlinked to facilitate efficient review. If you have
any questions regarding this information, please call the inspection team lead as soon as
possible.
Table RFI #2
Section 3: Initial Documentation Requests (See Items
Reference 1) Paragraph Number/Title:
Plant computer system block diagram (if plant computer system is
5 All
selected for inspection)
Plant security system block diagram (if security computer system is
6 All
selected for inspection)
Block diagrams for distributed systems (for systems selected for
7 All
inspection)
Host-based intrusion detection system documentation for critical 10.a.1)
10
digital assets (for systems selected for inspection) 10.a.2)
List all maintenance and test equipment (M&TE) used on critical digital
13 All
assets (for systems selected for inspection)
15 Configuration management All
16.a
16 Supply chain management 16.b
17 Portable media and mobile device control All
18 Software management All
20 Vendor access and monitoring All
21 Work control All
22 Device access and key control All
23 Password/authenticator policy All
3
Table RFI #2
Section 3: Initial Documentation Requests (See Items
Reference 1) Paragraph Number/Title:
24 User account/credential policy All
26 Corrective actions since last NRC inspection All
27 Cyber security assessments for selected systems All
In addition to the above information please provide the following:
(1) Names and positions of the CSAT and CSIRT members.
(2) Copies of lessons plans and training presented to the CSAT and CSIRT members,
continuing technical training for engineers, as well as any general awareness
training.
(3) List of dates of CSAT meetings that have occurred.
III. Information Requested to be Available on First Day of Inspection
For the specific systems and equipment identified in Section II, provide the following
request for information (i.e., Table 1st Week Onsite) on a secure document management
service or passive media, by February 10, 2020, the first day of the inspection. All
requested information shall follow the guidance in Reference 1.
Please provide four copies of each CD submitted (i.e., one for each inspector/contactor).
The preferred file format for all lists is a searchable Excel spreadsheet file on a CD/DVD.
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 lead as soon as
possible.
Table 1st Week Onsite
Section 3: Initial Documentation Requests (See
Reference 1) Paragraph Number/Title: Items
10.a.3)
10 Host-based intrusion detection system documentation for critical thru
digital assets (for systems selected for inspection) 10.a.12)
11.a.3)
11 Network Intrusion detection system documentation for critical thru
systems that have critical digital assets associated with them 11.a.15)
12.a.3)
12 SIEM documentation for critical systems that have critical digital thru
assets associated with them 12.a.14)
16 Supply chain management 16.c
19 Cyber security event notifications All
4
Table 1st Week Onsite
Section 3: Initial Documentation Requests (See
Reference 1) Paragraph Number/Title: Items
Update to licensee identified violations and corrective action All
29
program actions taken since the initial request was made
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. Quality Assurance Plan;
b. Technical Specifications, if not previously provided;
c. Latest Individual Plant Examination/Probabilistic Risk Assessment
Report; and,
(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 lead.
5