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) | |
See also: IR 05000445/2025401
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
Enclosure:
Comanche Peak Nuclear Power Plant -
Cybersecurity Inspection Document Request
cc w/encl: Electronic Distribution
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:
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.