ML25176A209
| ML25176A209 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/25/2025 |
| From: | Lindsay Merker NRC/RGN-III/DORS/EB2 |
| To: | Tony Brown Vistra Operations Company |
| References | |
| IR 2025402 | |
| Download: ML25176A209 (1) | |
See also: IR 05000440/2025402
Text
Terry Brown
Acting Site Vice President
Vistra Operations Company, LLC
Perry Nuclear Power Plant
10 Center Road
Perry, OH 44081
SUBJECT:
PERRY NUCLEAR POWER PLANT - INFORMATION REQUEST FOR THE
CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000440/2025402
Dear Terry Brown:
On September 22, 2025, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
inspection in accordance with Inspection Procedure (IP) 71130.10 Cyber-Security, Revision 0
at your Perry Nuclear Power Plant. The inspection will be performed to evaluate and verify your
ability to meet 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 September 22-26, 2025.
Experience has shown that baseline 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. 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 IP. This information should
be made available electronically no later than July 28, 2025. The inspection team will review this
information and, by August 1, 2025, 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 (CSs/CDAs), defensive architecture,
and the areas of the licensees Cyber-Security Plan (CSP) selected for the cyber-security
inspection. This information will be requested for review in the regional office prior to the
inspection by September 2, 2025, as identified above.
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, September 22, 2025.
June 25, 2025
T. Brown
2
The fourth group of information is necessary to aid the inspection 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 Lindsay Merker. We understand that our regulatory contact
for this inspection is George Dujanovic of your organization. If there are any questions about the
inspection or the material requested, please contact the lead inspector at 630-829-9621 or via
email at Lindsay.Merker@nrc.gov.
This letter does not contain new or amended information collection requirements subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
collection requirements were approved by the Office of Management and Budget,
Control Number 3150-0011. 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 NRCs 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 NRCs Agencywide Documents
Access and Management System (ADAMS). ADAMS is accessible from the NRC website
at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
Lindsay Merker, Senior Project Engineer
Technical Support Staff
Division of Operating Reactor Safety
Docket No. 50-440
License No. NPF-58
Enclosure:
Cyber-Security Inspection
Document Request
cc w/encl: Distribution via LISTSERV
Signed by Merker, Lindsay
on 06/25/25
T. Brown
3
Letter to Terry Brown from Lindsay Merker dated June 25, 2025.
SUBJECT:
PERRY NUCLEAR POWER PLANT - INFORMATION REQUEST FOR THE
CYBER-SECURITY BASELINE INSPECTION, NOTIFICATION TO PERFORM
INSPECTION 05000440/2025402
Distribution:
Tim Steadham
RidsNrrPMPerry Resource
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R3-DORS
ADAMS Accession Number: ML25176A209
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
NAME
LMerker:anm
DATE
06/25/2025
OFFICIAL RECORD COPY
PERRY CYBER-SECURITY INSPECTION DOCUMENT REQUEST
Enclosure
Inspection Report: 05000440/2025402
Inspection Dates: September 22-26, 2025
Inspection Procedure: IP 71130.10, Cyber-Security, Revision 0
NRC Inspectors: Lindsay Merker, Lead
Kevin Fay
630-829-9621
630-829-9866
Lindsay.Merker@nrc.gov
Kevin.Fay@nrc.gov
NRC Contractors: Alan Konkal
Trace Coleman
Alan.Konkal@nrc.gov
Trace.Coleman@nrc.gov
I.
Information Requested for In-Office Preparation
The initial request for information (i.e., first RFI) concentrates on providing the
inspection team with the general information necessary to select appropriate
components and Cyber-Security Plan (CSP) elements to develop a site-specific
inspection plan. The first RFI is used to identify the list of critical systems and critical
digital assets (CSs/CDAs) plus operational and management (O&M) security control
portions of the CSP to be chosen as the sample set required to be inspected by
the cyber-security IP. The first RFIs requested information is specified below in
Table RFI #1. The Table RFI #1 information is requested to be provided to the
regional office by July 28, 2025, or sooner, to facilitate the selection of the specific
items that will be reviewed during the onsite inspection weeks.
The inspection team will examine the returned documentation from the first RFI
and identify/select specific systems and equipment (e.g., CSs/CDAs) 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 1, 2025,
which will identify the specific systems and equipment that will be utilized to evaluate
the CSs/CDAs, defensive architecture, and the areas of the licensees CSP selected
for the cyber-security inspection. We request that the additional information provided
from the second RFI be made available to the regional office prior to the inspection,
by September 2, 2025.
The required Table RFI #1 information shall be provided electronically to the lead
inspector by July 28, 2025. If a compact disc (CD) is provided, please provide four
copies (one for each inspector/contactor). The preferred file format for all lists is a
searchable Excel spreadsheet file. 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 leader as soon as possible.
PERRY CYBER-SECURITY INSPECTION DOCUMENT REQUEST
2
Table RFI #1
Request:
IP Ref
1
A list of all Identified CSs/CDAs-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 Emergency Preparedness 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 that affected CDAs that have been installed and
completed since the last cyber-security inspection, including either a
summary of the design change or the 50.59 documentation of the
change
03.03(a)
13
Supply Chain Management documentation including security impact
analysis for new acquisitions
03.03(a),
(b) and
(c)
PERRY CYBER-SECURITY INSPECTION DOCUMENT REQUEST
3
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 Updated Final Safety Analysis Report (UFSAR)
and Technical Specifications;
(2)
Name(s) and phone numbers for the regulatory and technical contacts; and
(3)
Current management and engineering organizational charts.
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 a list of specific systems and equipment to your staff by August 1, 2025, for the
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 1, 2025, for the second RFI (i.e., RFI #2).
The second RFI will request additional information required to evaluate the
CSs/CDAs, defensive architecture, and the areas of the licensees CSP selected
for the cyber-security inspection. The additional information requested for the
specific systems and equipment is identified in Table RFI #2.
The Table RFI #2 information shall be provided electronically to the lead inspector
by September 2, 2025. If a CD is provided, please provide four copies (one for each
inspector/contactor). The preferred file format for all lists is a searchable Excel
spreadsheet file. 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 leader as soon as possible.
PERRY CYBER-SECURITY INSPECTION DOCUMENT REQUEST
4
Table RFI #2
Request
Items
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)
All vulnerability screenings/assessments associated with or scans
3
performed on the selected system(s) since the last cyber-security
inspection
03.01(c)
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
Information and Event Management (SIEM) systems for system(s)
chosen for inspection
03.02(b)
Documentation (including configuration files and rule sets) for
5
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 cyber-security drills performed since the last
inspection, along with any reports or assessments generated
03.02(a)
03.04(b)
Copy of the individual recovery plan(s) for the selected system(s)
11
including documentation of the results the last time the backups
were executed
03.02(a)
03.04(b)
Corrective actions taken as a result of cyber-security
12
incidents/issues to include previous NRC violations and Licensee
Identified Violations since the last cyber-security inspection
03.04(d)
PERRY CYBER-SECURITY INSPECTION DOCUMENT REQUEST
5
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 RFI (i.e., Table 1ST Week Onsite) electronically by September 22, 2025,
the first day of the inspection.
Table 1ST Week Onsite
Request:
Items
1
Any cyber-security event reports submitted in accordance with
10 CFR 73.77 since the last cyber-security inspection
03.04(a)
Updated Copies of corrective actions taken as a result of
2
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
03.04(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 and unrestrained access
to them.
a. UFSAR, if not previously provided;
b. Original Final Safety Analysis Report (FSAR) Volumes;
c.
Original Safety Evaluation Report (SER) and Supplements;
d. FSAR Question and Answers;
e. Quality Assurance (QA) Plan;
f.
Technical Specifications, if not previously provided; and
g.
Latest Individual Plant Examination and Probabilistic Risk
Assessment (IPE/PRA) Report.
(2)
Vendor Manuals, Assessment and Corrective Actions:
a. The most recent Cyber-Security QA 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 QA audit and/or self-assessment.
PERRY CYBER-SECURITY INSPECTION DOCUMENT REQUEST
6
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 inspection
team leader.