IR 05000277/2021401

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Security Baseline Inspection Report 05000277/2021401 and 05000278/2021401
ML21117A343
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 04/27/2021
From: Fred Bower
Decommissioning, ISFSI, and Reactor Health Physics Branch
To: Rhoades D
Exelon Generation Co, Exelon Nuclear
Bower F
References
IR 2021401
Download: ML21117A343 (9)


Text

April 27, 2021

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - SECURITY BASELINE INSPECTION REPORT 05000277/2021401 AND 05000278/2021401

Dear Mr. Rhoades:

On April 8, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Peach Bottom Atomic Power Station, Units 2 and 3 and discussed the results of this inspection with Mr. Matthew Herr, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report. Remote inspections were completed on April 2, 2021, and on-site inspections were completed on April 8, 2021.

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, EP and Incident Response Branch Division of Radiological Safety and Security

Docket Nos. 05000277 and 05000278 License Nos. DPR-44 and DPR-56

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000277 and 05000278

License Numbers:

DPR-44 and DPR-56

Report Numbers:

05000277/2021401 and 05000278/2021401

Enterprise Identifier: I-2021-401-0066

Licensee:

Exelon Generation Company, LLC

Facility:

Peach Bottom Atomic Power Station, Units 2 and 3

Location:

Delta, PA

Inspection Dates:

March 29, 2021 to April 8, 2021

Inspectors:

D. Caron, Senior Physical Security Inspector

K. Hussar, Senior Physical Security Inspector

S. McCarver, Physical Security Inspector

Approved By:

Fred L. Bower, III, Chief

Security, EP 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 Peach Bottom Atomic Power Station, Units 2 and 3, 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 on March 29, 2021, unless otherwise noted.

Additionally, remote inspections were completed on April 2, 2021, and on-site inspections were completed between April 2 and April 8, 2021. 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 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. 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===

(1)

  • Tier I: All Requirements
  • Tier II: 9 Requirements (02.06 a - c, 02.07 a, 02.08 a - d, i)
  • Tier III: 1 Requirement (02.09)

71130.04 - Equipment Performance, Testing, and Maintenance

The inspectors evaluated the security equipment performance, testing, and maintenance program through completion of the following inspection elements:

Equipment Performance, Testing, and Maintenance (1 Sample)

(1)

  • Tier I: All Requirements
  • Tier II: 4 Requirements (02.09 a, b, 02.11 a, e)
  • Tier III: 3 Requirements (02.14, 02.15 a, b)

71130.07 - Security Training

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

===procedure elements:

Security Training===

(1)

  • Tier I: All Requirements
  • Tier II: 6 Requirements (02.05 a - d, 02.06 b, 02.09 a)
  • Tier III: 5 Requirements (02.11 a, 02.012 a - b, 02.13 a - b)

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 change in accordance with 10 CFR 50.54(p)(2)since the last performance of this IP and PSP Revision 20 remains current.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicator submittals listed below:

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

=

(1) January 1, 2020 through December 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 April 8, 2021, the inspectors presented the security baseline inspection results to Mr. Matthew Herr, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71130.02

Corrective Action

Documents

04335350

04344488

04349815

04350001

04354109

04383709

Corrective Action

Documents Resulting

from Inspection

04414204

04414370

04414826

04414965

Procedures

SY-AA-101-112

Exelon Security Search Processes

Revision 37

SY-AA-101-112-

1004

Protected Area Search Processes

Revision 4

SY-AA-101-112-F-

PA Entry - Vehicle Search

Revision 9

SY-AA-101-120

Control of Security Access Control Devices

Revision 9

SY-PB-101-119

Control of Receiving Warehouse

Revision 43

71130.04

Corrective Action

Documents

04338190

04342056

04338445

04354559

04354586

Corrective Action

Documents Resulting

from Inspection

04414653

04414554

04414546

Procedures

SY-AA-101-122

Testing Security Equipment

Revision 22

SY-AA-122-1001

Performance of Security System Tests

Revision 13

SY-AA-150-103

Firearms Maintenance, Testing, and Accountability

Revision 2

SY-AA-500-127

Safety/Security Interface

Revision 7

SY-PB-101-122-

1001

Performance of Security Systems Tests

Revision 98

71130.07

Corrective Action

04333563

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Documents

04336399

04349252

04365316

04365951

04367414

04371717

04379810

Miscellaneous

Peach Bottom Physical Security Plan, Appendix B

Revision 21

CNVD-T

Thermal Rifle Qualification Course

Revision 1

IQT 27D

Daylight Qualification Course for the AR-15 Rifle

Revision 4

IQT 27N

Night Fire Rifle Qualification Course

Revision 2

Lesson Plan 2105

Drill and Exercise Controller Training

Revision 12

Lesson Plan 2108

Exelon Adversary Force Training

Revision 2

Lesson Plan 2109

Insider Mitigation - Cyber Related Tampering

Revision 2

ML20325A017

PEACH BOTTOM ATOMIC STATION, UNITS 2 AND 3

- EXEMPTION FROM

ANNUAL FORCE-ON-FORCE EXERCISE

REQUIREMENT OF 10 CFR PART 73,

APPENDIX B, GENERAL CRITERIA FOR SECURITY

PERSONNEL,

SUBSECTION VI.C.3.(l)(1) (EPID L-2020-LLE-0192

[COVID-19])

Dated

December 10,

20

RS-20-141

Request for an Exemption from 10 CFR 73, Appendix

B,Section VI, Subsection

C.3.(I)(1) Regarding 2020 Annual Force-on-Force

(FOF) Exercises Due to

COVID-19 Public Health Emergency, Attachment 9

Dated

November 13,

20

Procedures

SY-AA-150

Nuclear Security Training Program5

Revision 5

SY-AA-150-1007

Exelon Nuclear Security Adversary Force

Revision 2

SY-AA-150-101

Exelon Nuclear Security Training

Revision 2

SY-AA-150-102

Security Drills and Exercises

Revision 0

SY-AA-150-104

Exelon Nuclear Security OJT Program

Revision 1

SY-AA-150-105

Exelon Nuclear Security Physical Fitness Test

Development, Approval and Conduct

Revision 1

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

SY-AA-150-105

Exelon Nuclear Security Physical Fitness Test

Development, Approval and Conduct

Revision 1

SY-AA-150-105-F-

Peach Bottom Physical Fitness Test (PFT)

Revision 3

SY-AA-152

Tactical Course Development, Approval and Conduct

Revision 7

71151

Procedures

SY-AA-101-155

Security Events and Nuclear Regulatory Commission

Performance Indicators

Revision 10