IR 05000220/2022401

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Security Baseline Inspection Report 05000220/2022401 and 05000410/2022401
ML22236A056
Person / Time
Site: Nine Mile Point  Constellation icon.png
Issue date: 08/30/2022
From: Daniel Schroeder
Decommissioning, ISFSI, and Reactor Health Physics Branch
To: Rhoades D
Constellation Energy Generation, Constellation Nuclear
References
IR 2022401
Download: ML22236A056 (9)


Text

August 30, 2022

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 - SECURITY BASELINE INSPECTION REPORT 05000220/2022401 AND 05000410/2022401

Dear David Rhoades:

On August 10, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station, Units 1 and 2, and discussed the results of this inspection with Pete Orphanos, Site Vice President, 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, Daniel L. Schroeder, 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:

05000220/2022401 and 05000410/2022401

Enterprise Identifier: I-2022-401-0053

Licensee:

Constellation Energy Generation, LLC

Facility:

Nine Mile Point Nuclear Station, Units 1 and 2

Location:

Lycoming, NY

Inspection Dates:

August 8, 2022 to August 10, 2022

Inspectors:

D. Caron, Senior Physical Security Inspector

T. Eck, Physical Security Inspector

M. Ordoyne, Physical Security Inspector

Approved By:

Daniel L. Schroeder, 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,

Units 1 and 2, 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

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 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.

SAFEGUARDS

71130.01 - Access Authorization

The inspectors evaluated the access authorization program. The following elements were

===evaluated:

Access Authorization===

(1)

  • Tier I: All Requirements
  • Tier II: All Requirements
  • Tier III: 5 Requirements (02.09, 02.10 a-c, 02.11 a)

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: 10 Requirements (02.06 c, 02.07 a, 02.08 a-d,f-i)
  • Tier III: 1 Requirement (02.09)

71130.08 - Fitness for Duty Program

The inspectors evaluated the fitness for duty program by completing the following inspection elements. A portion of the inspection was conducted at Limerick Generating Station to review corporate elements of this inspection procedure including interviews of the Constellation fleet medical review officer and substance abuse expert, and fitness for duty documents related to blind samples, random testing files, laboratory audits and reports, specimen collector training, secure methodology for transference of drug test results, pre-access files, random files, follow-up files, for cause files, post event files, appeals, dilute tests, subverted tests, adulterated tests, and substituted tests for inspections this year at the James A. Fitzpatrick Nuclear Power Plant and R.E. Ginna Nuclear Power Plant as well as Nine Mile Point Nuclear Station:

Fitness For Duty Program (1 Sample)

(1)

  • Tier I: All Requirements
  • Tier II: 26 Requirements list requirements (02.05 a - l, 02.06 a - g, 02.07, 02.08, 02.09 a - e)
  • Tier III: 6 Requirements list requirements (02.10, 02.11, 02.12, 02.14 a - c)

71130.09 - Security Plan Changes

The inspectors evaluated the security plan changes through completion of the following

===procedure elements:

Security Plan Changes===

(1) Since the last NRC inspection of this program area, Security Plan Revision 14 was implemented based on your determination, in accordance with 10 CFR 50.54(p)(2),that the changes resulted in no decrease in safeguards effectiveness of the security plan, and that the revised security plan change continues to meet the requirements of 10 CFR 73.55(b). The inspectors conducted a review of the security plan change to evaluate for a potential decrease in safeguards effectiveness of the security plan.

However, this review does not constitute formal NRC approval of the changes.

Therefore, these changes remain subject to future NRC inspection in their entirety.

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 02.17)

=

(1) July 1, 2021 through June 31,

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

  • On August 10, 2022, the inspectors presented the security baseline inspection results to Pete Orphanos, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71130.01

Miscellaneous

NANTEL Generic Fitness for Duty and Behavior Observation

Training

6/1/2021

Procedures

SY-AA-103-500

Access Authorization Program

Revision 17

SY-AA-103-500-

F-04

Critical Group Inclusion/Removal Form

Revision 02

SY-AA-103-506

Utilizing the Personnel Access Data System (PADS)

Revision 17

SY-AA-103-507

Review Criteria for Determining Trustworthiness and

Reliability

Revision 09

SY-AA-103-511

Access Authorization In-Processing/ Out-Processing of

Personnel

Revision 26

SY-AA-103-514

Site Authorization for Unescorted Access

Revision 21

SY-AA-12

Access Authorization Process Description

Revision 1

Self-Assessments

Fitness for Duty and Access Authorization Audit Report

8/26/2020

Fitness for Duty and Access Authorization Program Audit

Report

9/1/2021

21-044 VA

Interquest Northwest Audits

5/27/2021

A-PIC1-21-05

Pinnacle Investigations Audits

5/6/2021

NOV 2021-121

Confidential Services Inc

6/23/2021

XEL 2021-0040

Information Reporting Services Inc Audit

7/28/2021

71130.02

Corrective Action

Documents

04444683

04454314

04460949

04474973

04482637

04483842

04484094

04484519

04484822

04484860

04485365

04487330

04489154

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

04489241

04502969

04426957

04505276

04511767

04505153

04487330

04511956

04481967

04462041

Procedures

Physical Security

Plan

SY-AA-101-106

Control and Classification of Safeguards Information (SGI)

and Sensitive Unclassified Non-Safeguards Information

(SUNSI)

Revision 022

SY-AA-101-109

Response to Contingency Events

Revision 16

SY-AA-101-112

Exelon Search Processes

Revision 038

SY-AA-101-112-

1004

Protected Area Search Processes

Revision 5

SY-AA-101-117

Processing and Escorting of Personnel and Vehicles

Revision 34

SY-AA-101-118

Control of Badges

Revision 010

SY-AA-101-120

Control of Security Access Control Devices

Revision 009

SY-NM-101-117

Processing and Escorting of Visitors at Nine Mile Point

Revision 1

71130.08

Procedures

SY-AA-102

Exelon Generation Fitness for Duty Program

Revision 22

SY-AA-102-202

Testing for Cause

Revision 21

SY-AA-102-203

Treatment Plan and Follow-up Testing

Revision 8

SY-AA-102-204

Random Selection and Notification Process

Revision 14

SY-AA-102-205

Fitness for Duty Appeal Review

Revision 10

SY-AA-102-230

Designated Collection Facility

Revision 9

SY-AA-102-240

Collection of Specimens for Testing in an Exelon Facility

Revision 16

SY-AA-102-242

Breath Alcohol Testing

Revision 12

SY-AA-102-243

Urine Collection in a Temporary Collection Site

Revision 7

SY-AA-102-245-

1001

Operators Manual RBTV IV

Revision 1

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Self-Assessments NOSA-NMP-20-

(AR 4307528)

Security Programs Audit

2/06/2020

NOSA-NMP-20-

(AR4355859)

Fitness for Duty and Access Authorization Audit Report

08/26/2020

NOSA-NMP-21-

(AR 4393708)

Security Programs Audit

2/10/2021

NOSA-NMP-21-

(AR 4435762)

Fitness for Duty and Access Authorization Program Audit

Report

09/01/2021

71130.09

Miscellaneous

Nine Mile Point Nuclear Station Physical Security,

Safeguards Contingency, Security Training and Qualification

Plan and Security Program for the Nine Mile Point

Independent Spent Fuel Storage Installation

Revision 14

71151

Calculations

PI Calculations July 2021 through June 2022