IR 05000315/2021403
| 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
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, 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:
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
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.
SAFEGUARDS
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 Sample)
- (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 Sample)
- (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
Procedure
Type
Designation
Description or Title
Revision or
Date
NANTeL
Generic Fitness-For-Duty and Behavioral Observation Content
Document
06/01/2021
Miscellaneous
NE-2020-29
Supplier Audit Report for Confidential Services INC.
06/23/2020
SPP-2060-SFI-
20
Access Authorization Program Elements
PMP-2060-ACS-
2
Access Authorization Program
PMP-2060-ACS-
003
In-Processing / Out-Processing
SPP-2060-SFI-
2
Unescorted Access Denial Appeal Process
SPP-2060-SFI-
23
Review Criteria for Unescorted Access Authorization
Procedures
SPP-2060-SFI-
24
Employee Identification - Issuance and Control of Keycards
SPP_2060-SFI-
209
Protected Area Access/Exit Requirements
SPP_2060-SFI-
214
Security Core, Key and Lock Program
Procedures
SPP_2060-SFI-
308
Tests of Security Related Equipment
Calculations
1601075
Minimum Safe Standoff Distance for the Large and Small NRC
Design Basis Explosive Threats
07/10/2021
Corrective Action
Documents
AR-2021-5001
SAC Self-Assessment Condition
06/01/2021
Calc 2998626-C-
005 RO
Engineering Evaluation of Delay Barrier Steel Post Overturning
08/15/2013
Engineering
Evaluations
SL-014566
Evaluation of Revised Vehicle Barrier System Layout
03/17/2021
SE-C-AR048
Controller Training
Miscellaneous
SE-O-RRTT01
Adversary Task Performance Evaluation Card
Procedures
SPP-2060-SFI-
201
Armed Response Actions, Firearms, and Strategy
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SPP-2060-SFI-
205
Central and Secondary Alarm Station (CAS/SAS)
SPP-2060-SFI-
205-1
Alarm Dispatch and Response
SPP-2060-SFI-
206
Security Patrols
SPP-2060-SFI-
2
Compensatory Measures
SPP_2060-1-SFI-
2
Compensatory Measures Risk Assessment
SPP_2060-SFI-
2
Security Safeguards Contingency Actions
SPP_2060-SFI-
213
Integrated Response Procedure
SPP_2060-SFI-
216
Plant Response to a Security Event
SPP_2060-SFI-
219
Responding to a UAV/UAS in the OCA and PA
Self-Assessments
20-0505-1
Protective Strategy Evaluation and Performance Evaluation
Program
Donald C. Cook Tactical Course
NRA Approval of Tactical Qualification Course
03/12/2020
NRA Duty Rifle/Thermal Site Qualification Course Approval
2/26/2020
SE-C-AR023
Patrol Responsibilities Lesson plan
Miscellaneous
SE-C-AR028
Deadly Force Lesson Plan
SE-Q-FOF01-1
Force-on-Force 40 hr. Qualification Card
SPP_2060-SFI-
505
Force-on-Force Training
SPP_2060-SFI-
511
Gas Masks
Procedures
TPD-600-SEC
Security Training Program Description
Donald C. Cook Nuclear Plant Security Plan
Miscellaneous
NEI 11-08 Security Plan Change Evaluation, Security Plan
Revision 20
01/04/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
PRA-STUDY-030
DC Cook Nuclear Plant PRA Study
2/01/2007
SD-061206-001
Flooding Evaluation Report for DC Cook Nuclear Plant
Calculations
08/01/2003
Procedures
SPP_2060-SFI-
507
Target Set Development
Self-Assessments
GT 2021-0892-1
Self-Assessment Review of Reactor Target Sets
07/22/2021
71151
Procedures
PMP-7110-PIP-
001
Reactor Oversight Program Performance Indicator and
Monthly Operating Report Data
2