IR 05000317/2020402

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Security Baseline Inspection Report 05000317/2020402 and 05000318/2020402
ML20300A489
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 10/26/2020
From: Fred Bower
Plant Support Branch 1
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
Bower F
References
IR 2020402
Download: ML20300A489 (9)


Text

October 26, 2020

SUBJECT:

CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 - SECURITY BASELINE INSPECTION REPORT 05000317/2020402 AND 05000318/2020402

Dear Mr. Hanson:

On September 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Calvert Cliffs Nuclear Power Plant, Units 1 and 2 and discussed the results of this inspection with Mr. Thomas P. Haaf, 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 20-23, 2020, and on-site inspections were completed on September 28-30, 2020.

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, X /RA/

Signed by: Fred L. Bower

Fred L. Bower, III, Chief Plant Support Branch Division of Reactor Safety

Docket Nos. 05000317 and 05000318 License Nos. DPR-53 and DPR-69

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000317 and 05000318

License Numbers:

DPR-53 and DPR-69

Report Numbers:

05000317/2020402 and 05000318/2020402

Enterprise Identifier: I-2020-402-0003

Licensee:

Exelon Generation Company, LLC

Facility:

Calvert Cliffs Nuclear Power Plant, Units 1 and 2

Location:

Lusby, MD

Inspection Dates:

April 20, 2020, to September 30, 2020

Inspectors:

J. Bream, Senior Physical Security Inspector

D. Caron, Senior Physical Security Inspector

K. Hussar, Physical Security Inspector

S. McCarver, Physical Security Inspector

Approved By:

Fred L. Bower, III, 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 Calvert Cliffs Nuclear Power Plant,

Units 1 and 2, 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 April 20, 2020, unless otherwise noted. Additionally, remote inspections were completed on April 20-April 23, 2020, and on-site inspections were completed on September 28-30, 2020. 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: 8 Requirements (02.06 a - d, 02.08 e-g, i)
  • Tier III: 1 Requirement (02.09)

71130.04 - Equipment Performance, Testing, and Maintenance

The inspectors evaluated the security equipment testing and maintenance program. The following elements were evaluated from this IP:

Equipment Performance, Testing, and Maintenance (1 Sample)

(1)

  • Tier I: All requirements
  • Tier II: 4 requirements (02.09 a, b, 02.11 d, 02.12 a.)
  • Tier III: All requirements

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 a, b)
  • 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 all the procedure elements. Since the last NRC inspection of this program area, Security Plan Revision 16 was implemented based on your determination, in accordance with 10 CFR 50.54(p)(2), that the change did not decrease the security plan safeguards effectiveness, and the revised security plan continues to meet 10 CFR 73.55(b) requirements. Inspectors reviewed the security plan change to assess its impact on the security plan and your implementation of the 10 CFR 50.54(p)(2) change process. However, this review does not constitute formal NRC approval of the change and it remains subject to future NRC inspection.

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)

=

The inspectors verified licensee performance indicator submittals listed below:

(1) Third quarter 2019 through second quarter

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===81311 - Physical Security Requirements for Independent Spent Fuel Storage Installations

The inspectors assessed the adequacy of Exelon's Independent Spent Fuel Storage Installation co-located at Calvert Cliffs Nuclear Power Plant.

Physical Security Requirements for Independent Spent Fuel Storage Installations===

(1)1 Sample

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 30, 2020, the inspectors presented the security baseline inspection results to Mr. Thomas P. Haaf, Site Vice President, and other members of the licensee staff.
  • On April 23, 2020, the inspectors presented a debrief of inspection results from the remote potion of the security baseline inspection to Thomas Haaf, 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

AR 045305853

AR 04314354

AR 04314355

AR 04321145

Procedures

SY-AA-101-106

Control and Classification of Safeguards Information (SGI)

and Sensitive Unclassified Non-Safeguards Information

(SUNSI)

Revision 21

SY-AA-101-112

Exelon Security Search Processes

Revision 37

SY-AA-101-112-

1004

Protected Area Search Processes

Revision 3

SY-AA-101-117

Processing and Escorting of Personnel and Vehicles

Revision 31

SY-AA-101-118

Control of Badges

Revision 9

SY-AA-101-120

Control of Security Access Control Devices

Revision 9

SY-AA-101-124

Operation of the Security Control Centers

Revision 15

SY-CA-1008

Vehicle Admittance to the Protected Area (PA)

Revision 7

SY-CA-101-115

Controlling Gates and Power Operated Active Vehicle

Barriers

Revision 6

71130.04

Corrective Action

Documents

AR 04293253

AR 04305096

AR 04315879

Corrective Action

Documents

Resulting from

Inspection

AR 04336891

AR04372563

AR04331831

Procedures

FTI-115I

Infrared IDS Specification Testing

Revision 0

FTI-115M

Microwave IDS Specification Testing

Revision 0

SY-AA-101-103

Observation and Inspection of Security Barriers

Revision 12

SY-AA-101-116

Conducting Patrols

Revision 16

SY-AA-101-122

Testing Security Equipment

Revision 22

SY-AA-101-122-

1001

Performance Of Security System Tests

Revision 13

SY-AA-150-103

Firearms Maintenance, Testing, and Accountability

Revision 2

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

SY-CA-101-122-

1001

Security System Testing

Revision 18

71130.07

Corrective Action

Documents

AR 04320927

AR 04318292

Miscellaneous

Lesson Plan No.

1108

Use of Force Continuum (Laws Governing Arrest, Search

and Seizure)

Lesson Plan No.

2101

Patrol Officer

Lesson Plan No.

2109

Insider Mitigation - Cyber Related Tampering

Procedures

SY-AA-150

Nuclear Security Training Program

SY-AA-150-1007

Exelon Nuclear Security Adversary Force

SY-AA-150-101

Exelon Nuclear Security Training

SY-AA-150-102

Security Drills and Exercises

SY-AA-150-104

Exelon Nuclear Security OJT Program

SY-AA-150-105

Exelon Nuclear Security Physical Fitness Test Development,

Approval & Conduct

SY-AA-152

Tactical Course Development, Approval & Conduct

71130.09

Miscellaneous

Physical Security Plan, Training and Qualification Plan, and

Safeguards Contingency Plan

Revision 16

81311

Calculations

Calculation No.:

BGE-093-C-1

HSM and DSC Blast Analysis

Procedures

SY-CA-201

ISFSI Security Operations

5