ML22179A303
| 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;
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,
Greg A. Pick
Senior Reactor Inspector
Engineering Branch 2
Division of Operating Reactor Safety
Signed by Pick, Gregory
on 06/28/22
K. Peters
3
Dockets: 50-445; 50-446
Enclosure:
Comanche Peak Nuclear Power Plant
Cyber-Security Inspection Document Request
cc w/encl: Distribution via LISTSERV
SUNSI Review
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
By: GAP
Yes No
Publicly Available
Sensitive
OFFICE
DORS/EB2:SRI
NAME
GPick
SIGNATURE
Gap
DATE
6/28/2022
Enclosure
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:
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:
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
2
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
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 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 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
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 inspection,
03.03(a)
3
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.
13
Supply Chain Management documentation including any security
impact analysis for new acquisitions
03.03(a),
(b) and
(c)
14
Configuration Management documentation including any security
impact analysis performed due to configuration changes since the
last 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 Metrics tracked (if applicable)
03.06 (b)
17
Provide documentation describing any cyber security changes to the
access authorization program since the last cyber security
inspection.
Overall
18
Provide a list of all procedures and policies provided to the NRC with
their descriptive name and associated number (if available)
Overall
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.
4
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
system(s)
03.01(a)
2
All Security Control Assessments for the selected 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
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 inspection
03.02(d)
7
Baseline configuration data sheets for the selected CDAs
03.03(a)
8
Documentation on any changes, including Security Impact Analyses,
performed on the selected system(s) since the last inspection
03.03(b)
9
Copies of the purchase order documentation for any new equipment
purchased for the selected systems since the last inspection
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)
12
Corrective actions taken because of cyber security incidents/issues
to include previous NRC violations and Licensee Identified Violations
since the last cyber security inspection
03.05
5
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
CFR 73.77 since the last cyber security inspection
03.05
2
Updated Copies of corrective actions taken because 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
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
6
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.