Text

Security Baseline Inspection Report 05000255/2021402
	ML21278B086
Person / Time
Site:	Palisades
Issue date:	10/06/2021
From:	Steven Orth; Plant Support Branch II
To:	Corbin D; Entergy Nuclear Operations
	Egan N
References
	IR 2021402
	Download: ML21278B086 (8)
	v • d • e

October 6, 2021

SUBJECT:

PALISADES NUCLEAR PLANT - SECURITY BASELINE INSPECTION REPORT 05000255/2021402

Dear Mr. Corbin:

On August 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palisades Nuclear Plant and discussed the results of this inspection with Mr. Dale Lucy 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, Signed by Orth, Steven on 10/06/21 Steven K. Orth, Chief Plant Support Branch Division of Reactor Safety Docket No. 05000255 License No. DPR-20

Enclosure:

As stated

Inspection Report

Docket Number: 05000255 License Number: DPR-20 Report Number: 05000255/2021402 Enterprise Identifier: I-2021-402-0060 Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant Location: Covert, MI Inspection Dates: June 14, 2021 to August 31, 2021 Inspectors: N. Egan, Senior Physical Security Inspector C. St. Peters, Resident Inspector Approved By: Steven K. Orth, Chief Plant Support Branch Division of Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a security baseline inspection at Palisades Nuclear Plant, 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.

SAFEGUARDS

71130.02 - Access Control

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

inspection elements: Access Control

Main article: IP 71130.02

(1) Tier I: All Requirements Tier II: 02.06 a-d, 02.07 b, 02.08 d-f Tier III: 02.10 a

71130.05 - Protective Strategy Evaluation

On January 31, 2020, the Secretary of the United States Department of Health and Human Services declared a Public Health Emergency (PHE) on the public health risks of the COVID-19 coronavirus. In response to the PHE, Palisades Nuclear Power Plant pursued an exemption to security officer training and requalification requirements (ML20330A000 for specific exemptions approved). In addition to these exemptions, licensees implemented additional actions or alternatives in response to health concerns. As described in existing regulatory guidance (e.g.,

Regulatory Guide 5.75), licensees implemented measures 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).

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: 02.05 a, 02.06 a-I, 02.06 m-n, 02.07 a, 02.07 d-e Tier III: 02.09 a-b, 02.10 a, 02.11 a

(2) Observed annual Force-on-Force exercises conducted on 06/15/2021.

71130.07 - Security Training

The inspectors evaluated the security training program through completion of the following

procedure elements: Security Training

Main article: IP 71130.07

(1) Tier I: All Requirements Tier II: 02.05 a-d, 02.06 a, 02.09 a Tier III: 02.11 a, 02.12 a-b, 02.13 a, c

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 Partial)

(1) (Partial)

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 change in accordance with Title 10 of the Code of Federal Regulations, Part 50.54(p)(2) since the implementation of this IP.

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 31, 2021, the inspectors presented the security baseline inspection results to Mr. Dale Lucy and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71130.02 Procedures EN-NS-204 Protection of Unclassified Safeguards Information 7

EN-NS-224 SOCA Access Controls 3

EN-NS-228 Search and Sealing of Material 2

EN-NS-231 Protected Area Search 3

EN-NS-236 Warehouse Material Search 0

EN-NS-237 Lock and Key 0

Self-Assessments LO-PLPO-2021- Access Control Pre-NRC Focused Self-Assessment 03/11/2021

00016

71130.05 Corrective Action CR-PLP-2021- SOCA 06/16/2021

Documents 01599

CR-PLP-2021- Mask Lens 06/16/2021

01601

CR-PLP-2021- Mask Checklist 06/16/2021

01602

Miscellaneous Palisades Nuclear Plant Physical Security Plan 16

Procedures EN-NS-215 Conduct of Security Force Exercises and Drills 21

EN-NS-215-01 Tactical Response Drills 0

EN-NS-215-02 Annual Force-on-Force Exercises 0

EN-NS-215-03 Triennial Force-on-Force Exercises 0

EN-NS-216 Controller Responsibility Guidelines 12

EN-NS-234 Force-on-Force Mock Adversary Program 2

EN-NS-306 Development and Maintenance of Target Sets 6

Self-Assessments LO-PLPLO-2021- IP 71130.05 Protective Strategy Evaluation and Performance 02/12/2021

00017 Evaluation Program

71130.07 Miscellaneous National Rifle Association Approval Certificate for Semi- 05/19/2021

Automatic Daylight and Lowlight Handgun Qualification

Courses

National Rifle Association Approval Letter for Semi- 12/19/2018

Automatic Rifle with Special Purpose Optic Qualification

Course

National Rifle Association Approval Letter for Semi- 07/22/2020

Automatic Lowlight Rifle Qualification Course