IR 05000220/2021402

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Security Baseline Inspection Report 05000220/2021402 and 05000410/2021402
ML21165A076
Person / Time
Site: Nine Mile Point  Constellation icon.png
Issue date: 06/22/2021
From: Fred Bower
Decommissioning, ISFSI, and Reactor Health Physics Branch
To: Rhoades D
Exelon Generation Co
References
IR 2021402
Download: ML21165A076 (9)


Text

June 22, 2021

SUBJECT:

NINE MILE POINT NUCLEAR STATION - SECURITY BASELINE INSPECTION REPORT 05000220/2021402 AND 05000410/2021402

Dear Mr. Rhoades:

On June 3, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station and discussed the results of this inspection with Mr. Adam Schuerman, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Fred L. Bower, III, Chief Security, Emergency Preparedness and Incident Response Branch Division of Radiological Safety and Security

Docket Nos. 05000220 and 05000410 License Nos. DPR-63 and NPF-69

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000220 and 05000410

License Numbers:

DPR-63 and NPF-69

Report Numbers:

05000220/2021402 and 05000410/2021402

Enterprise Identifier: I-2021-402-0038

Licensee:

Exelon Generation Company, LLC

Facility:

Nine Mile Point Nuclear Station

Location:

Lycoming, NY

Inspection Dates:

May 24, 2021 to June 3, 2021

Inspectors:

D. Caron, Senior Physical Security Inspector

S. McCarver, Physical Security Inspector

J. Rey, Physical Security Inspector

M. Ordoyne, Physical Security Inspector (Training)

Approved By:

Fred L. Bower, III, Chief

Security, Emergency Preparedness and Incident Response Branch

Division of Radiological Safety and Security

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a security baseline inspection at Nine Mile Point Nuclear Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Unless otherwise noted, baseline security inspections were conducted in accordance with the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2201, Security Inspection Program for Commercial Nuclear Power Reactors. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards. Publicly available IPs are located at:

http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

In response to the COVID-19 Public Health Emergency declared on January 31, 2020, by the Secretary of the United States Department of Health and Human Services on the public health risks of the coronavirus, Nine Mile Point Nuclear Station pursued an exemption to security officer training and requalification requirements (ML20218A860). In addition to these exemptions, licensees implemented additional actions or alternatives allowed in response to health concerns within existing regulatory guidance available in RG 5.75 to ensure annual Force on Force exercises were conducted as safely as possible while maintaining the requirements to simulate as closely as practicable site specific conditions and minimizing the number and effects of artificialities associated with these exercises (Part 73, Appendix B, VI.C.3)

SAFEGUARDS

71130.02 - Access Control

The inspectors evaluated the access control program through completion of the following

===inspection elements:

Access Control===

(1)

  • Tier I: All Requirements
  • Tier II: 12 Requirements (02.06 a - d, 02.07 a, 02.08 a, b, d, e, f, g, i)
  • Tier III: 1 Requirement (02.09)

71130.05 - Protective Strategy Evaluation

The inspectors evaluated the licensee's protective strategy through completion of the following procedure elements:

Protective Strategy Evaluation (2 Samples)

(1)

  • Tier I: All Requirements
  • Tier II: 14 Requirements (02.05 a, 02.06 a, b, d - m, 02.07 a)
  • Tier III: 4 Requirements (02.08, 02.09 a, 02.10 a, 02.11 a)

(2)

  • The inspectors evaluated the Security Performance Evaluation Program.

71130.09 - Security Plan Changes

The inspectors evaluated the security plan changes through completion of the following procedure elements:

Review Security Plan Changes (IP Section 02.01) (1 Sample)

(1) The opportunity to apply this procedure was not available in accordance with Inspection Manual Chapter 0306. This sample was not available because the licensee did not conduct the activity covered by this IP. Specifically, the licensee has not initiated a physical security plan (PSP) change in accordance with Title 10 of the Code of Federal Regulations 10 CFR 50.54(p)(2) since the last performance of this IP and PSP Revision 13 remains current.

71130.14 - Review of Power Reactor Target Sets

The inspectors evaluated the Security Target Set Program. The following elements were

===evaluated:

Review of Power Reactor Target Sets===

(1)02.02 (a-d, f), 02.03, 02.04 (a-b),

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

PP01: Protected Area Security Equipment Performance Index Sample (IP Section 03.17)

=

(1) January 1, 2020 through April 30,

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On June 3, 2021, the inspectors presented the security baseline inspection results to Mr. Adam Schuerman, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71130.02

Corrective Action

Documents

AR 04412779

AR04410091 AR

04380683 AR

04379886 AR

04371532

Corrective Action

Documents

Resulting from

Inspection

AR 04425399 IR

04426957

Procedures

SY-AA-101-106

Control and Classification of Safeguards Information (SGI)

and Sensitive Unclassified Non-Safeguards Information

(SUNSI)

Revision 21

SY-AA-101-112-

1004

Protected Area Search Processes

Revision 4

SY-AA-101-120

Control of Security Access Control Devices

Revision 9

SY-NM-101-115-

1001

Nine Mile Point Gate Controls

Revision 4

71130.05

Calculations

Calc No.

CNSNM069-002

Cooling Tower Culverts - Increase in Delay Time

Revision 1

Calc No. NMP-

7717012-S01

Nine Mile Point Security Building West Analysis

Revision 1

Calc No. NMP-

7717012-S02

Nine Mile Point Blast Analysis Update

Revision 1

Calc No. NMP-

KC-S00

Nine Mile Point Nuclear Facility - NMP Blast Analysis

Summary and Diagram

Revision 0

Calc No. NMP-

KC-S01

Nine Mile Point Nuclear Facility - NMP Unit 1 Minimum Safe

Standoff Distance Analysis

Revision 0

Miscellaneous

NOSA-NMP-20-

Security Program Audit Report

February 6,

20

NOSA-NMP-21-

Security Program Audit Report

February 10,

21

Procedures

NS-843A

NMP Adversary and Responder Timelines

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

SY-AA-150-1007

Exelon Nuclear Security Adversary Force

Revision 2

SY-AA-150-102

Security Drills and Exercises

Revision 0

SY-NM-101-501

NMP Security Defensive Strategy

Revision 9

71130.14

Corrective Action

Documents

AR 04165141

AR 04248972

AR 04369501

Procedures

SY-AA-500-127

Safety/Security Interface

Revision 7

SY-NM-101-116-

1001

Nine Mile Point Patrols and Surveillances

Revision 9

SY-NM-101-502

NMP Security Target Set Procedure

Revision 0