ML25210A012
| ML25210A012 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/29/2025 |
| From: | Glenn Dentel Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation |
| References | |
| IR 2025403 | |
| Download: ML25210A012 (1) | |
See also: IR 05000352/2025403
Text
July 29, 2025
David P. Rhoades
Senior Vice President
Constellation Energy Generation, LLC
President and Chief Nuclear Officer (CNO)
Constellation Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - INFORMATION
REQUEST FOR THE CYBERSECURITY BASELINE INSPECTION,
NOTIFICATION TO PERFORM INSPECTION 05000352/2025403 AND
Dear David Rhoades:
On December 8, 2025, the U.S. Nuclear Regulatory Commission (NRC) will begin a baseline
inspection in accordance with Inspection Procedure (IP) 71130.10, Cyber Security, dated
December 14, 2021, at your Limerick Generating Station, Units 1 and 2. The inspection will be
performed to evaluate and verify your ability to meet the requirements of the NRCs Cyber
Security Rule, Title 10 of the Code of Federal Regulations (10 CFR) Part 73, Section 54,
Protection of Digital Computer and Communication Systems and Networks. The onsite portion
of the inspection will take place December 8-12, 2025.
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 IP 71130.10. This information should be
made available either on an online repository (preferred) or digital media (CD/DVD) no later
than September 5, 2025. The inspection team will review this information and, by October 3,
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, defensive architecture, and the areas
of the licensees cybersecurity program selected for the cybersecurity inspection. This
information will be requested for review in the regional office prior to the inspection by
October 31, 2025, as identified above.
D. Rhoades
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, December 8, 2025.
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 En De Chen. We understand that our regulatory contact
for this inspection is Jordan Rajan of your organization. If there are any questions about the
inspection or the material requested, please contact the lead inspector at (610) 337-5136 or via
email at En.Chen@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 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 component of the NRC's 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,
Glenn T. Dentel, Chief
Engineering Branch 2
Division of Operating Reactor Safety
Docket Nos. 05000352 and 05000353
License Nos. NPF-39 and NPF-85
Enclosure:
Cybersecurity Inspection Document Request
cc: Distribution via ListServ
GLENN
DENTEL
Digitally signed by
Date: 2025.07.29
07:00:24 -04'00'
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE
RI/DORS
RI/DORS
NAME
EChen
GDentel
DATE
7/28/2025
7/28/2025
LIMERICK CYBERSECURITY INSPECTION DOCUMENT REQUEST
Enclosure
Inspection Report: 05000352/2025403 and 05000353/2025403
Inspection Dates:
December 8 to December 12, 2025
Inspection Procedure:
Inspection Procedure (IP) 71130.10, Cyber Security,
dated December 14, 2021 (ADAMS Accession
Number: ML21271A106)
Reference:
Guidance Document for Development of the Request for
Information (RFI) and Notification Letter for IP 71130.10,
NRC Inspectors:
En De Chen, Lead Joseph Cunningham
(610) 337-5136 (610) 337-5390
En.Chen@nrc.gov Joseph.Cunningham@nrc.gov
NRC Contractors:
Balla Barro
(610) 337-5135
Balla.Barro@nrc.gov
Timothy.Hennessey@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 Program (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 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 September 5, 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 October 3, 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 October 31, 2025.
LIMERICK CYBERSECURITY INSPECTION DOCUMENT REQUEST
2
The required Table RFI 1 information shall be provided on an online repository
(preferred) or digital media (CD/DVD) to the lead inspector by September 5, 2025. The
preferred file format for all lists is a searchable Excel spreadsheet file. The information
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.
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 or 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 and
the most recent cybersecurity Quality Assurance audit/assessment. Please
include any condition reports (or similar) generated as a result of the
audits/assessments.
03.01(b)
6 Vulnerability screening/assessment and scan program documentation.
03.01(c)
7 Device Access and Key Control program documentation.
03.02(c)
8
Password/Authenticator documentation.
03.02(c)
9 User Account/Credential program documentation.
03.02(d)
10 Portable Media and Mobile Device control program documentation,
including kiosk security control assessment/documentation.
03.02(e)
11
Design change/modification program documentation and a list of all design
changes completed since the last two cyber security inspections, including
either a summary of the design change or the 50.59 documentation for the
change. Please notate/highlight which design changes affected Critical
Digital Assets (added, modified, deleted, etc.)
03.03(a)
12
Supply Chain Management documentation including any security impact
analysis for new acquisitions.
03.03(a),
(b) and
(c)
13
Configuration Management documentation including any security impact
analysis performed due to configuration changes since the last inspection.
03.03(a)
and (b)
14
Cyber Security Metrics tracked (if applicable).
03.06 (b)
15
Provide documentation describing any cyber security changes to the access
authorization program since the last cyber security inspection.
Overall
16
Provide a list of all procedures and policies provided to the NRC as part of
this RFI with their descriptive name and associated number (if available).
Overall
17
Performance testing report (if applicable).
03.06 (a)
18
List of Condition Reports (or similar) associated with cybersecurity issues
written since the last inspection. Please include CR #, date written, and a
short description / title.
Overall
LIMERICK CYBERSECURITY INSPECTION DOCUMENT REQUEST
3
In addition to the above information please provide the following:
(1) Name(s) and phone numbers for the regulatory and technical contacts.
(2) 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 October 3, 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 October 3, 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 to the lead inspector by October 31,
2025. The preferred file format for all lists is a searchable Excel spreadsheet. The
information 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.
Table RFI #2
Section 3,
Paragraph Number/Title:
Items
For the systems and CDAs 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)
LIMERICK CYBERSECURITY INSPECTION DOCUMENT REQUEST
4
Table RFI #2
Section 3,
Paragraph Number/Title:
Items
9 Copies of the purchase order documentation for any new equipment
purchased for the selected systems since the last inspection.
03.03(c)
10 For the selected systems, provide design change/modification packages
including completed work orders since the last cyber security inspection.
03.03(a)
III.
Information Requested to be Available on First Day of Inspection
Please provide the following information to the team by December 8, 2025, the first day
of the inspection.
Table 1ST Week Onsite
Section 3,
Paragraph Number/Title:
Items
1
Updated list of corrective actions that were generated since the
corrective actions provided for RFI #2, to include any corrective actions
generated as a result of self assessments performed prior to the
inspection.
03.01b
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.