IR 05000255/2023401
| ML23292A258 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/23/2023 |
| From: | Steven Orth NRC/RGN-III/DRSS/SEPIR |
| To: | Mlynarek M Holtec Decommissioning International |
| References | |
| IR 2023401 | |
| Download: ML23292A258 (1) | |
Text
SUBJECT:
PALISADES NUCLEAR PLANT - DECOMMISSIONING AND ISFSI SECURITY INSPECTION REPORTS 05000255/2023401; AND 07200007/2023401
Dear Mike Mlynarek:
On September 28, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palisades Nuclear Plant and discussed the results of this inspection with Scott Summers, Security 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, Steven K. Orth, Chief Security, Emergency Preparedness, and Incident Response Branch Division of Radiological Safety and Security Docket Nos. 05000255, 07200007 License No. DPR-20, General License (ISFSI)
Enclosure:
As stated
Inspection Report
Docket Number:
05000255, 07200007
License Number:
DPR-20, General License (ISFSI)
Report Number:
05000255/2023401, 07200007/2023401
Enterprise Identifier:
I-2023-401-0081, I-2023-401-0087
Licensee:
Holtec Decommissioning International, LLC
Facility:
Palisades Decommissioning Nuclear Plant and ISFSI
Location:
Covert, MI
Inspection Dates:
July 24, 2023 to September 28, 2023
Inspectors:
G. Bonano, Physical Security Inspector
Approved By:
Steven K. Orth, 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 inspection of the physical protection program at the Palisades Decommissioning Nuclear Power Plant and Independent Spent Fuel Storage Installation. The inspections were conducted in accordance with the Decommissioning Reactor Oversight Process and the Spent Fuel Storage Oversight Process.
The Decommissioning Reactor Oversight Process is the NRCs program for overseeing the safe decommissioning of commercial nuclear power reactors. Refer to https://www.nrc.gov/waste/decommissioning.html for more information.
The Spent Fuel Storage Oversight Process is the NRCs program for overseeing the safe storage of spent nuclear fuel. Refer to https://www.nrc.gov/waste/spent-fuel-storage/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 in accordance with 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 activities were met consistent with Inspection Manual Chapter 2202, Security Inspection Program for Decommissioning Nuclear Power Reactors and IMC 2690, Inspection Program for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations and for Title 10 of the Code of Federal Regulations, Part 71 Transportation Packaging. The inspector 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.
DECOMMISSIONING SECURITY REQUIREMENTS
81200.01 - Access Authorization for Decommissioning Nuclear Power Reactors
The inspector evaluated the access authorization program for decommissioning nuclear power reactors through completion of the following procedure elements:
Access Authorization for Decommissioning Nuclear Power Reactors (1 Sample)
(1)02.01 (a - g); 02.02 (a - g); 02.03 (a, c - h); 02.04 (a - g); 02.05 (a, b); 02.06
81200.02 - Access Control for Decommissioning Nuclear Power Reactors
The inspector evaluated the security access control program for decommissioning nuclear power reactors through completion of the following procedure elements:
Access Control for Decommissioning Nuclear Power Reactors (1 Sample)
(1)02.01 (a - e); 02.02 (a - g); 02.03 (a - g); 02.04 (a, b); 02.05
81200.07 - Security Training for Decommissioning Nuclear Power Reactors
The inspector evaluated the security training program for decommissioning nuclear power reactors through completion of the following procedure elements:
Security Training for Decommissioning Nuclear Power Reactors (1 Sample)
(1)02.01; 02.02 (a - c); 02.03 (a, b); 02.04 (a, b); 02.05; 02.06 (a - c); 02.07 (a, b); 02.08 (a); 02.09 (a, b); 02.10 (a); 02.11 (a); 02.12 (a, c); 02.13
81200.09 - Security Plan Changes for Decommissioning Power Reactors
Since the last NRC inspection of this program area, Security Plan Revision 18 to 20 was implemented based on your determination, in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 50.54(p)(2), that the changes resulted in no decrease in safeguards effectiveness of the security plan, and that the revised security plan changed continues to meet the requirements of 10 CFR 73.55(b). The inspector conducted a review of the security plan changes to evaluate for 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.
The inspector evaluated the security plan changes through completion of the following procedure elements:
Security Plan Changes for Decommissioning Power Reactors (1 Sample)
(1)02.01 (a - e) ISFSI SECURITY REQUIREMENTS
===81311 - Physical Security Requirements for Independent Spent Fuel Storage Installations The inspector evaluated the Physical Protection Program for the Independent Spent Fuel Storage Installation. The following elements were evaluated:
Physical Security Requirements for Independent Spent Fuel Storage Installations===
(1)02.01 (a - c); 02.02 (a - h); 02.03 (a - m); 02.04; 02.05 (a - t); 02.06; 02.07 (a, b);
INSPECTION RESULTS
No findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On September 28, 2023, the inspectors presented the decommissioning and ISFSI security inspection results to Scott Summers, Security Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Reviewing Official Designation
08/07/2023
Day Review
09/01/2022 -
09/01/2023
Audit 2023-I-17
Internal Audit Report (Holtec)
AA-FFD
07/10/2023 -
09/11/2023
Miscellaneous
FF-002
Access Folder Checklist
Unescorted Access Authorization Program
EN-NS-101-02
AA/FFD Training and Qualification Program
EN-NS-101-03
Processing Individuals for UAA/UA, SGI Access, and Foreign
National Visitors
EN-NS-101-04
Processing Potentially Disqualifying Information (PDI)
EN-NS-101-05
Maintaining Unescorted Access Authorization/Unescorted
Access and Critical Group Status
Procedures
EN-NS-101-06
Terminating, Denial, and Appeal of Unescorted Access
Authorization/Unescorted Access
200.01
Self-Assessments PAL-01090-01
Pre-NRC 81200.01 Inspection Self-Assessment of AA and
FFD for Decommissioning Power Plants
08/10/2023
Security Lock Core Accountability Log
21 - 2022
Security Lock and Key System Inventory
21 - 2022
Miscellaneous
Security Key Accountability Log
21 - 2022
SIP 38
Badging
SIP 4
Personnel Access
SIP 43
Lock and Key
SIP 5
Search Procedures and Property Removal Requirements
Procedures
SIP 6
Vehicle Control
200.02
Self-Assessments PAL-01139-01
Pre-Nuclear Regulatory Commission (NRC) Focused
Self-Assessment: Access Control for Decommissioning
Nuclear Power Reactors
07/10/2023
Miscellaneous
DSP-SEC-207
Range Safety Briefing Slides
09/28/2023
DSP-SEC-300
Security Training Program
200.07
Procedures
DSP-SEC-301
Security Systematic Approach to Training (SAT) Process
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
DSP-SEC-303
Security Training Oversight Program
DSP-SEC-304
Security On-the-Job Training Performance Evaluation and
Training Exemptions
DSP-SEC-304-01
Security Training - On-the-Job Training (OJT) Process
DSP-SEC-304-02
Security - Task Performance Evaluation (TPE) Process
DSP-SEC-307
Security Supervisor Training and Development Program
FJPM-SEC-20.0
Respond to Contingency Events and Execute Defensive
Strategy
JPM-SEC-16.0
Determine Amount of Force Required to Prevent an
Unauthorized Act
JPM-SEC-17.0
Perform Central and Secondary Alarm Station Functions
Self-Assessments PAL-00755-01
IP 81200.07 Security Training
05/25/2023
Palisades Nuclear Plant Physical Security Plan (PSP)
Revision Date: 02/08/2023
50.54 (p) Evaluation Form (Typical), Attch. 2
Palisades Nuclear Plant
SOCA: Reduced IDS, Assessment
01/31/2023
Palisades Nuclear Plant Physical Security Plan (PSP)
Tactical Response Drills Summary
Protective Strategy Revision Project
07/2022
Tactical Response Drill Summary
Protective Strategy Revision for Proposed Protected Area
(PA) Mod Changes
10/2022
Miscellaneous
Tactical Response Drills Summary
Protective Strategy Rev. 19 Project (SOCA)
08/2022
200.09
Self-Assessments Audit 2022-I-23
Internal Audit Report - Security Program (Palisades)
10/05/2022 -
03/13/2023
Perimeter Intrusion Detection System Alarm Testing Record
July - Sept
23
PAL Nuclear Plant SGI Event Log:
Oct - Dec, 2022; Jan - Sept, 2023
81311
Miscellaneous
Van Buren County Sheriff's Office
01/18/2023
81311
Procedures
SIP-19
Law Enforcement Response Plan
2