ML25210A012

Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection 05000352/2025403 and 05000353/2025403

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

05000353/2025403

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

GLENN DENTEL

Date: 2025.07.29

07:00:24 -04'00'

ML25210A012

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,

Cyber Security (ML21330A088)

NRC Inspectors:

En De Chen, Lead Joseph Cunningham

(610) 337-5136 (610) 337-5390

En.Chen@nrc.gov Joseph.Cunningham@nrc.gov

NRC Contractors:

Timothy Hennessey

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

second RFI (i.e., 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 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.