IR 05000315/2021403

Security Baseline Inspection Report 05000315/2021403 and 05000316/2021403

ML21320A362
Person / Time
Site:	Cook
Issue date:	11/17/2021
From:	Steven Orth Plant Support Branch II
To:	Gebbie J Indiana Michigan Power Co
Ziolkowski M
References
IR 2021403
Download: ML21320A362 (10)

Text

November 17, 2021

SUBJECT:

DONALD C. COOK NUCLEAR PLANT - SECURITY BASELINE INSPECTION REPORT 05000315/2021403 AND 05000316/2021403

Dear Mr. Gebbie:

On October 13, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Donald C. Cook Nuclear Plant and discussed the results of this inspection with you 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 11/17/21 Steven K. Orth, Chief Plant Support Branch Division of Reactor Safety Docket Nos. 05000315 and 05000316 License Nos. DPR-58 and DPR-74

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000315 and 05000316 License Numbers: DPR-58 and DPR-74 Report Numbers: 05000315/2021403 and 05000316/2021403 Enterprise Identifier: I-2021-403-0031 Licensee: Indiana Michigan Power Company Facility: Donald C. Cook Nuclear Plant Location: Bridgman, MI Inspection Dates: July 19, 2021 to October 13, 2021 Inspectors: J. Mancuso, Resident Inspector M. Ziolkowski, Senior Physical Security 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 Donald C. Cook 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.

71130.01 - Access Authorization

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

procedure elements: Access Authorization

(1) Tier I: All Requirements Tier II: 02.05a; 02.06 a-b Tier III: 02.11a

71130.02 - Access Control

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

procedure elements: Access Control

(1) Tier I: All Requirements Tier II: 02.06 a, d 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, Donald C. Cook Nuclear Plant pursued an exemption to security officer training and requalification requirements (ML20324A003 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. The completion of these elements, combined with the completion of elements documented in report 05000315/2021402 and 05000316/2021402, dated June 9, 2021, constitute two complete samples including the observation of an annual

===FOF exercise on March 11, 2021.

Protective Strategy Evaluation (2 Samples)===

(1) Protective Strategy Evaluation Tier I: 02.01 a-c, e-j; 02.02 a-f; 02.03 a Tier II: 02.06 d-e, h, k-m Tier III: None

(2) Performance Evaluation Program Tier I: 02.04 a, d-e Tier II: 02.07 c Tier III: None

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: 02.05 a - d Tier III: 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) Since the last NRC inspection of this program area, Security Plan Revision 20 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 changed continues to meet the requirements of 10 CFR 73.55(b). The inspectors 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.

71130.14 - Review of Power Reactor Target Sets

The inspectors evaluated the security target set program through completion of the following

procedure elements: Review of Power Reactor Target Sets

(1) Requirements: 02.02 a-e; 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 02.17)

=

(1) Unit 1 (January 01, 2020 through June 30, 2021)

Unit 2 (January 01, 2020 through June 30, 2021)

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

On October 13, 2021, the inspectors presented the security baseline inspection results to Joel P. Gebbie and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71130.01 Miscellaneous NANTeL Generic Fitness-For-Duty and Behavioral Observation Content 06/01/2021

Document

NE-2020-29 Supplier Audit Report for Confidential Services INC. 06/23/2020

Procedures SPP-2060-SFI- Access Authorization Program Elements 18

20

PMP-2060-ACS- Access Authorization Program 28

2

PMP-2060-ACS- In-Processing / Out-Processing 18

003

SPP-2060-SFI- Unescorted Access Denial Appeal Process 7

2

SPP-2060-SFI- Review Criteria for Unescorted Access Authorization 13

23

SPP-2060-SFI- Employee Identification - Issuance and Control of Keycards 10

24

71130.02 Procedures SPP_2060-SFI- Protected Area Access/Exit Requirements 27

209

SPP_2060-SFI- Security Core, Key and Lock Program 27

214

SPP_2060-SFI- Tests of Security Related Equipment 59

308

71130.05 Calculations 1601075 Minimum Safe Standoff Distance for the Large and Small NRC 07/10/2021

Design Basis Explosive Threats

Corrective Action AR-2021-5001 SAC Self-Assessment Condition 06/01/2021

Documents

Engineering Calc 2998626-C- Engineering Evaluation of Delay Barrier Steel Post Overturning 08/15/2013

Evaluations 005 RO

SL-014566 Evaluation of Revised Vehicle Barrier System Layout 03/17/2021

Miscellaneous SE-C-AR048 Controller Training 4

SE-O-RRTT01 Adversary Task Performance Evaluation Card 3

Procedures SPP-2060-SFI- Armed Response Actions, Firearms, and Strategy 36

201

Inspection Type Designation Description or Title Revision or

Procedure Date

SPP-2060-SFI- Central and Secondary Alarm Station (CAS/SAS) 22

205

SPP-2060-SFI- Alarm Dispatch and Response 4

205-1

SPP-2060-SFI- Security Patrols 38

206

SPP-2060-SFI- Compensatory Measures 25

2

SPP_2060-1-SFI- Compensatory Measures Risk Assessment 0

2

SPP_2060-SFI- Security Safeguards Contingency Actions 9

2

SPP_2060-SFI- Integrated Response Procedure 4

213

SPP_2060-SFI- Plant Response to a Security Event 33

216

SPP_2060-SFI- Responding to a UAV/UAS in the OCA and PA 0

219

Self-Assessments 2020-0505-1 Protective Strategy Evaluation and Performance Evaluation 0

Program

71130.07 Miscellaneous Donald C. Cook Tactical Course 1

NRA Approval of Tactical Qualification Course 03/12/2020

NRA Duty Rifle/Thermal Site Qualification Course Approval 02/26/2020

SE-C-AR023 Patrol Responsibilities Lesson plan 4

SE-C-AR028 Deadly Force Lesson Plan 3

Procedures SE-Q-FOF01-1 Force-on-Force 40 hr. Qualification Card 0

SPP_2060-SFI- Force-on-Force Training 19

505

SPP_2060-SFI- Gas Masks 9

511

TPD-600-SEC Security Training Program Description 13

71130.09 Miscellaneous Donald C. Cook Nuclear Plant Security Plan 20

NEI 11-08 Security Plan Change Evaluation, Security Plan 01/04/2021

Revision 20

Inspection Type Designation Description or Title Revision or

Procedure Date

71130.14 Calculations PRA-STUDY-030 DC Cook Nuclear Plant PRA Study 02/01/2007

SD-061206-001 Flooding Evaluation Report for DC Cook Nuclear Plant 3

WCAP-16141 RCP Seal Leakage PRA Model 08/01/2003

Procedures SPP_2060-SFI- Target Set Development 4

507

Self-Assessments GT 2021-0892-1 Self-Assessment Review of Reactor Target Sets 07/22/2021

71151 Procedures PMP-7110-PIP- Reactor Oversight Program Performance Indicator and 2

001 Monthly Operating Report Data

8