ML22179A303

Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000445/2022401; 05000446/2022401

ML22179A303
Person / Time
Site:	Comanche Peak
Issue date:	06/28/2022
From:	Greg Pick NRC/RGN-IV/DORS/EB2
To:	Peters K Vistra Operating Co. (VistraOpCo)
Pick G
References
IR 2022401
Download: ML22179A303 (10)

See also: IR 05000445/2022401

Text

June 28, 2022

Mr. Ken 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 -

INFORMATION REQUEST FOR THE CYBER-SECURITY BASELINE

INSPECTION, NOTIFICATION TO PERFORM INSPECTION 05000445/2022401;

05000446/2022401

Dear Mr. Peters,

On October 24, 2022, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline

inspection in accordance with Inspection Procedure (IP) 71130.10, Cyber-Security, at your

Comanche Peak Nuclear Power Plant. The inspection evaluates and verifies your ability to meet

the 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.

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 inspection procedure. This

information should be made available via electronic means (e.g., compact disc or other

electronic means) and delivered to the regional office no later than August 1, 2022. The

inspection team will review this information and, by August 22, 2022, 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 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 September 19, 2022.

K. Peters 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, October 24, 2022.

The fourth group of information is necessary to aid the inspection team in tracking issues

identified during 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 these

documents are up to date and complete 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 Greg Pick. We understand that our regulatory contact

for this inspection is Jim Barnette at 817-408-0934 (m) or via email

james.barnette@luminant.com of your organization. If there are any questions about the

inspection or the material requested, please contact the lead inspector Greg Pick

at 817-504-2105 (m) or via e-mail at greg.pick@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter contains mandatory 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). Send comments

regarding this information collection to the Information Services Branch, Office of the Chief

Information Officer, Mail Stop: T6 A10M, U.S. Nuclear Regulatory Commission, Washington, DC

20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of

Information and Regulatory Affairs, NEOB-10202, (3150-0011) Office of Management and

Budget, Washington, DC 20503.

PUBLIC PROTECTION NOTIFICATION

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 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 (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding. Your cooperation and support during this

inspection will be appreciated.

Sincerely,

Signed by Pick, Gregory

on 06/28/22

Greg A. Pick

Senior Reactor Inspector

Engineering Branch 2

Division of Operating Reactor Safety

K. Peters 3

Dockets: 50-445; 50-446

Licenses: NPF-87; NPF-89

Enclosure:

Comanche Peak Nuclear Power Plant

Cyber-Security Inspection Document Request

cc w/encl: Distribution via LISTSERV

ML22179A303

SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: GAP Yes No Publicly Available Sensitive NRC-002

OFFICE DORS/EB2:SRI

NAME GPick

SIGNATURE Gap

DATE 6/28/2022

Inspection Report: 05000445/2022401; 05000446/2022401

Inspection Dates: October 24 - 28, 2022

Inspection Procedure: IP 71130.10, Cyber-Security, dated January 1, 2022

Reference: ML21330A088, Guidance Document for Development of the

Request for Information (RFI) and Notification Letter for

Full-Implementation of the Cyber-Security Inspection, Revision 1

NRC Inspectors: Greg Pick, (Lead) Stella Opara-Ogunmola

817-504-2105 301-287-9286

greg.pick@nrc.gov stella.opara@nrc.gov

Marcus Chisolm

817-200-1426

marcus.chisolm@nrc.gov

NRC Contractors: Casey Priester Alan Konkal

frederick.priester@nrc.gov alan.konkal@nrc.gov

I. Information Requested for In-Office Preparation

The initial request for information (Table RFI#1) provides the team with the general

information necessary to select appropriate components and cyber security program

elements to develop a site-specific inspection plan. The initial request for information is

used to identify the list of critical systems and critical digital assets plus operational and

management security control portions of the cyber security program to be chosen as the

sample set to be inspected. Please provide the information listed in Table RFI#1 to the

regional office by August 1, 2022, or sooner, to facilitate the selection of the specific

items that will be reviewed.

The team will examine the returned documentation from the initial request for information

and select specific critical systems and critical digital assets to provide for a more

deliberate, focused second request for information. The team will submit the second

request by August 22, 2022, which will identify the critical systems and critical digital

assets that will be utilized to evaluate the defensive architecture and the areas of your

cyber security program selected for the inspection. We request that the information for

the second request be made available for review by September 19, 2022.

All requests for information shall follow the referenced guidance document ADAMS

Accession No. ML21330A088. If a secure document management service is utilized, it is

recommended that a separate folder be used corresponding to each item listed below. It

is recommended that multiple documents within each folder be individually entered and

also combined into a ZIP file that is uploaded into the same folder. Documents should be

identified by both document number and noun name. Electronic media on compact disc

Enclosure

or paper records (hard copy) are also acceptable. 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

Section 3,

Paragraph Number/Title: IP Ref

A list of all Identified Critical Systems and Critical Digital Assets,-

1 highlight/note any . additions, deletions, reclassifications due to new Overall

guidance from white papers, changes to NEI 10-04, 13-10, etc. since

the last cyber security inspection.

2 A list of EP and Security onsite and offsite digital communication Overall

systems

3 Network Topology Diagrams to include information and data flow for Overall

critical systems in levels 2, 3 and 4 (If available)

4 Ongoing Monitoring and Assessment program documentation 03.01(a)

5 The most recent effectiveness analysis of the Cyber Security 03.01(b)

Program

6 Vulnerability screening/assessment and scan program 03.01(c)

documentation

Cyber Security Incident response documentation, including incident

detection, response, and recovery documentation as well as 03.02(a)

7 contingency plan development, implementation and including any and

program documentation that requires testing of security boundary 03.04(b)

device functionality

8 Device Access and Key Control documentation 03.02(c)

9 Password/Authenticator documentation 03.02(c)

10 User Account/Credential documentation 03.02(d)

11 Portable Media and Mobile Device control documentation, including 03.02(e)

kiosk security control assessment/documentation

12 Design change/ modification program documentation and a List of all 03.03(a)

design changes completed since the last cyber security inspection,

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Table RFI#1

Section 3,

Paragraph Number/Title: IP Ref

including either a summary of the design change or the 50.59

documentation for the change.

03.03(a),

13 Supply Chain Management documentation including any security (b) and

impact analysis for new acquisitions (c)

Configuration Management documentation including any security 03.03(a)

14 impact analysis performed due to configuration changes since the

and (b)

last inspection

15 Cyber Security Plan and any 50.54(p) analysis to support changes to 03.04(a)

the plan since the last inspection

16 Cyber Security Metrics tracked (if applicable) 03.06 (b)

Provide documentation describing any cyber security changes to the

17 access authorization program since the last cyber security Overall

inspection.

18 Provide a list of all procedures and policies provided to the NRC with Overall

their descriptive name and associated number (if available)

19 Performance testing report (if applicable) 03.06 (a)

In addition to the above information please provide the following:

(1) Electronic copy of the UFSAR and technical specifications

(2) Name(s) and phone numbers for the regulatory and technical contacts

(3) Current management and engineering organizational charts

II. Additional Information Requested to be Available Prior to Inspection

As stated in Section I above, the team will examine the documentation requested from

Table RFI#1 and submit the list of critical systems and critical digital assets to your staff

by August 22, 2022 (i.e., RFI#2). The additional information requested for the specific

systems and equipment is identified in Table RFI#2. Please provide the Table RFI#2

information to the lead inspector by September 19, 2022. If you have any questions

regarding this information, please call the inspection team leader as soon as possible.

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Table RFI#2

Section 3,

Paragraph Number/Title: IP Ref

For the system(s) chosen for inspection provide:

1 Ongoing Monitoring and Assessment activity performed on the 03.01(a)

system(s)

2 All Security Control Assessments for the selected system(s) 03.01(a)

All vulnerability screenings/assessments associated with or scans

3 performed on the selected system(s) since the last cyber security 03.01(c)

inspection

Documentation (including configuration files and rules sets) for

Network-based Intrusion Detection/Protection Systems (NIDS/NIPS),

4 Host-based Intrusion Detection Systems (HIDS), and Security 03.02(b)

Information and Event Management (SIEM) systems for system(s)

chosen for inspection )

Documentation (including configuration files and rule sets) for intra-

5 security level firewalls and boundary devices used to protect the 03.02(c)

selected system(s)

6 Copies of all periodic reviews of the access authorization list for the 03.02(d)

selected systems since the last inspection

7 Baseline configuration data sheets for the selected CDAs 03.03(a)

8 Documentation on any changes, including Security Impact Analyses, 03.03(b)

performed on the selected system(s) since the last inspection

9 Copies of the purchase order documentation for any new equipment 03.03(c)

purchased for the selected systems since the last inspection

03.02(a)

10 Copies of any reports/assessment for cyber security drills performed

since the last inspection. 03.04(b)

Copy of the individual recovery plan(s) for the selected system(s) 03.02(a)

11 including documentation of the results the last time the backups

03.04(b)

were executed.

Corrective actions taken because of cyber security incidents/issues

12 to include previous NRC violations and Licensee Identified Violations 03.05

since the last cyber security inspection

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III. Information Requested to be Available on First Day of Inspection

For the critical systems and critical digital assets identified in Section II, provide the

following request for information (i.e., Table 1ST Week Onsite) to the team by

October 24, 2022, the first day of the inspection.

Table 1ST Week Onsite

Section 3,

Paragraph Number/Title: IP Ref

1 Any cyber security event reports submitted in accordance with 10 03.05

CFR 73.77 since the last cyber security inspection

Updated Copies of corrective actions taken because of cyber

2 security incidents/issues, to include previous NRC violations and 03.05

Licensee Identified Violations since the last cyber security

inspection, as well as vulnerability-related corrective actions

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. Updated Final Safety Analysis Report (if not previously provided)

b. Original FSAR Volumes

c. Original SER and Supplements

d. FSAR Question and Answers

e. Quality Assurance Plan

f. Technical Specifications (if not previously provided)

g. Latest IPE/PRA Report

(2) Vendor Manuals, Assessment and Corrective Actions:

a. The most recent Cyber-Security Quality Assurance (QA) audit and/or

self-assessment

b. Corrective action documents (e.g., condition reports, including status of

corrective actions) generate because of the most recent Cyber-Security

Quality Assurance (QA) audit and/or self-assessment

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IV. Information Requested To Be Provided Throughout the Inspection

(1) Copies of any corrective action documents generated because 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.

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