ML25072A130
| ML25072A130 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/13/2025 |
| From: | Sam Graves NRC/RGN-IV/DORS/EB2 |
| To: | Peters K Vistra Operations Company |
| References | |
| IR 2025401 | |
| Download: ML25072A130 (1) | |
Text
March 13, 2025 Ken Peters, Executive 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 CYBERSECURITY INSPECTION (NRC INSPECTION REPORT 05000445/2025401 AND 05000446/2025401)
AND REQUEST FOR INFORMATION
Dear Ken Peters:
On October 27, 2025, the U.S. Nuclear Regulatory Commission (NRC) will begin an inspection in accordance with Inspection Procedure (IP) 71130.10, Cybersecurity, at Comanche Peak Nuclear Power Plant, Units 1 and 2. The inspection will be performed to evaluate and verify your ability to meet the requirements of the NRCs cybersecurity rule, Title 10 of the Code of Federal Regulations (10 CFR) Part 73, Section 54, Protection of Digital Computer and Communication Systems and Networks.
Experience has shown that these inspections are extremely resource intensive, both for the NRC inspectors and licensee staff. In order to minimize the inspection impact to 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 inspection team in choosing the focus areas (i.e., sample set) to be inspected by IP 71130.10. This information should be made available either in an online repository (preferred) or digital media (CD/DVD) and delivered/available to the regional office no later than August 1, 2025. The inspection team will review this information and, by August 29, 2025, will request the specific items that should be provided for review.
The second group of 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 your cybersecurity program selected for review. This information will be requested for review in the regional office prior to the inspection by September 26, 2025, as identified above.
K. Peters 2
The third group of requested documents consists of additional 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 27, 2025.
The fourth group of information aids 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 all requested 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 Sam Graves. We understand that our regulatory contact for this inspection is Ms. Kassie Mandrell of your organization. If there are any questions about the inspection or the material requested, please contact the lead inspector at 817-200-1102 or via e-mail at samuel.graves@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 under approval number 3150-0011. The burden to the public for these information collections is estimated to average 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />(s) per response. Send comments regarding this information collection to the FOIA, Library and Information Collection Branch, Office of the Chief Information Officer, Mail Stop: T6-A10M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by email to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202, (3150-0011)
OMB, Washington, DC 20503.
Public Protection Notification 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, Sam Graves, Senior Reactor Inspector Engineering Branch 2 Division of Operating Reactor Safety Signed by Graves, Samuel on 03/13/25
K. Peters 3
Docket Nos. 50-445; 50-446 License Nos. NPF-87; NPF-89
Enclosure:
Comanche Peak Nuclear Power Plant -
Cybersecurity Inspection Document Request cc w/encl: Electronic Distribution
ML25072A130 SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: STG Yes No Publicly Available Sensitive NRC-002 OFFICE SRI:DORS:EB2 NAME S Graves SIGNATURE
/RA/
DATE 03/13/25
Enclosure Comanche Peak Nuclear Power Plant - Cybersecurity Inspection Document Request Inspection Report: 05000445/2025401 and 05000446/2025401 Inspection Dates:
Week of October 27, 2025 Inspection Procedure:
IP 71130.10, Cybersecurity Reference 1:
ML21330A088, Guidance Document for Development of the Request for Information (RFI) and Notification Letter for IP 71130.10 Cyber Security Inspection, Revision 2 NRC Inspectors:
Sam Graves, Lead Nnaerika Okonkwo 817-200-1102 817-200-1114 Samuel.Graves@nrc.gov Nnaerika.Okonkwo@nrc.gov NRC Contractors:
Trace Coleman James Hendricks 301-415-7000 301-415-7000 Trace.Coleman@nrc.gov James.Hendricks@nrc.gov NRC Supporting Staff:
D. Daszkiewicz Daniel.Daszkiewicz@nrc.gov I.
Information Requested for In-Office Preparation This initial request for information (i.e., Table RFI #1) concentrates on providing the inspection team with information necessary to select appropriate components and cybersecurity program elements to develop a site-specific inspection plan. The first RFI is used to identify the critical digital assets or systems to be chosen as the sample set required to be inspected by the cybersecurity IP. The first RFIs requested information is specified below in Table RFI #1. Please provide the information requested in Table RFI #1 to the regional office by August 1, 2025, or sooner, to facilitate the selection of the specific items for review.
The inspection team will examine the documentation from the first RFI and select specific systems and equipment 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 August 29, 2025, which will be utilized to evaluate the equipment, defensive architecture, and the areas of the licensees cybersecurity program for review.
2 Please provide the information requested by the second RFI to the regional office by September 26, 2025. All requests for information shall follow the guidance document (Reference 1) identified above. For information requests that have more than ten (10) documents, please provide a compressed (i.e., Zip) file of the documents.
The required Table RFI #1 information shall be provided in an online document repository (preferred) or on digital media (CD/DVD) to the lead inspector by August 1, 2025. 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 contact 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 (CSs) and critical digital assets (CDAs), - highlight/note any additions, deletions, reclassifications due to new guidance (white papers, changes to NEI 10-04, 13-10, etc.)
since the last cybersecurity inspection Overall 2
Network topology diagrams to include information and data flow for critical systems in levels 2, 3, and 4 (If available). Please provide digital copies with this response. Provide printed copies during the onsite activities. (See Table 1ST Week Onsite)
Overall 3
The most recent effectiveness analysis and self-assessments of the cybersecurity program 03.01(b) 4 Design change/modification program documentation and a list, with descriptions, of all design changes that affected CDAs and that have been installed and completed (i.e. available for use) since the last cybersecurity inspection, including either a summary of the design change or the 50.59/50.54(p) documentation for the change as appropriate 03.03(a) 5 Provide copies of all cybersecurity program related procedures and policies with their descriptive name and associated number (if available)
Overall 6
The most recent cybersecurity quality assurance (QA) audit, and/or self-assessment Overall 7
Cybersecurity Plan and any 50.54(p) analysis to support changes to the plan since the last inspection 03.04(a) 8 Corrective actions taken as a result of cybersecurity incidents/issues to include previous NRC violations and Licensee Identified Violations since last two cybersecurity inspections 03.05 9
Cybersecurity Metrics tracked (if applicable) 03.06(b) 10 Performance testing report (if applicable) 03.06(a)
In addition to the above information please provide the following:
electronic copies of the UFSAR, technical specifications, and operating license(s) name(s) and phone number(s) for the regulatory and technical contacts
3 current management and engineering organizational charts related to cybersecurity 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 this selection to your staff by August 29, 2025, for the second RFI (i.e., Table 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 August 29, 2025, for the second RFI (i.e., Table RFI #2). The second RFI will request additional information required to evaluate the CSs/CDAs, defensive architecture, and the areas of the CSP selected for the cybersecurity inspection. The additional information requested for the specific systems and equipment is identified in Table RFI #2.
All requested information should follow the guidance document (Reference 1) identified above.
The Table RFI #2 information shall be provided to the lead inspector by September 26, 2025. The preferred file format for all lists is a searchable Excel spreadsheet. The information should be indexed and hyper-linked to facilitate ease of use. If you have any questions regarding this information, please contact the inspection team leader as soon as possible.
Table RFI #2 Section 3, Paragraph Number/Title:
Items For the system(s)/assets chosen for inspection provide:
1 Documentation of ongoing monitoring and assessment activity performed on the system(s)/assets 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 cybersecurity inspection 03.01(c) 4 Documentation (including configuration files and rules sets) for:
Security Information and Event Management (SIEM) system Network-based Intrusion Detection/Protection Systems (NIDS/NIPS), Host-based Intrusion Detection Systems (HIDS) for system(s) chosen for inspection Intra-security level firewalls and boundary devices used to protect the selected system(s) 03.02(b) 03.02(c) 5 Copies of all periodic reviews of the access authorization list for the selected systems since the last inspection 03.02(d) 6 Baseline configuration information for the selected CDAs 03.03(a) 7 Configuration management and change documentation including any security impact analysis performed on the selected system(s) due to configuration changes since the last inspection 03.03(a) and (b)
4 Table RFI #2 Section 3, Paragraph Number/Title:
Items 8
Supply chain management documentation including any security impact analysis for new acquisitions. Include copies of the purchase order documentation for any equipment purchased for the selected systems since the last inspection 03.03(a)
(b) and (c) 9 Vulnerability screening/assessments and scan program documentation 03.01(c) 10 Cybersecurity incident response documentation, including incident detection, response, and recovery documentation as well as contingency plan development and implementation; include any program documentation that requires testing of security boundary device functionality 03.02(a) and 03.04(b) 11 Copies of any reports/assessments for cybersecurity drills performed since the last inspection 03.02(a) 03.04(b) 12 Copies of the individual recovery plan(s) for the selected system(s) including documentation of the results the last time the backups were executed and tested 03.02(a) 03.04(b) 13 Device access and key control documentation 03.02(c) 14 User account/credential documentation 03.02(d) 15 Portable media and mobile services (PMMD) control documentation, including kiosk security control assessment/documentation 03.02(e) 16 Provide documentation describing any cybersecurity changes to the access authorization program since the last cybersecurity inspection Overall 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 information (i.e., Table 1ST Week Onsite) to the team by October 27, 2025, the first day of the onsite inspection. All requested information should follow the guidance document (Reference 1) identified 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 contact the inspection team leader as soon as possible.
5 Table 1ST Week Onsite Section 3, Paragraph Number/Title:
Items 1
Any cybersecurity event reports submitted in accordance with 10 CFR 73.77 since the last cybersecurity inspection 03.04(a) 2 Printed copies of network topology diagrams. Please provide in ANSI size C or larger, if possible Overall 3
Updated copies of corrective actions taken as a result of cybersecurity incidents/issues, to include previous NRC-identified violations and licensee-identified violations since the last cybersecurity inspection, as well as related corrective actions 03.04(d)
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 access to them:
original SER and supplements related to cybersecurity FSAR question and answers (Q&A) related to cybersecurity Quality Assurance Plan (2) Vendor Manuals, and Corrective Actions:
vendor manuals for the equipment selected as samples; and corrective action documents (e.g., SAPNs), including status of corrective actions generated as a result of the most recent cybersecurity quality assurance (QA) 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. If using a document repository to transfer information to the team, please create a separate area or item for corrective action documents generated in response to the teams questions.
(2) copies of the list of questions submitted by the inspection team members and the status/resolution of the information requested (typically provided daily during the inspection to each inspection team member).
If you have any questions regarding the information requested, please contact the team lead.