IR 05000352/2021401
| ML22046A064 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/15/2022 |
| From: | Daniel Schroeder Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| Schroeder D | |
| References | |
| IR 2021-401 | |
| Download: ML22046A064 (10) | |
Text
February 15, 2022
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - SECURITY BASELINE INSPECTION REPORT 05000352/2021401 AND 05000353/2021401
Dear Mr. Rhoades:
On January 21, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Limerick Generating Station, Units 1 and 2 and discussed the results of this inspection with Mr. Frank Sturniolo, Site Vice President, 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, Daniel L. Schroeder, Chief Security, Emergency Preparedness and Incident Response Branch Division of Radiological Safety and Security
Docket Nos. 05000352 and 05000353 License Nos. NPF-39 and NPF-85
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000352 and 05000353
License Numbers:
Report Numbers:
05000352/2021401 and 05000353/2021401
Enterprise Identifier: I-2021-401-0099
Licensee:
Constellation Energy Generation, LLC
Facility:
Limerick Generating Station, Units 1 and 2
Location:
Limerick, PA
Inspection Dates:
November 29, 2021 to January 21, 2022
Inspectors:
D. Caron, Senior Physical Security Inspector
S. McCarver, Physical Security Inspector
J. Rey, Security Specialist
Approved By:
Daniel L. Schroeder, 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 baseline inspection at Limerick Generating Station,
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 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 activity were met consistent with Inspection Manual Chapter (IMC) 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.
On February 1, 2022, the license for Limerick Generating Station, Units 1 and 2 was transferred to Constellation Energy Generation, LLC (Constellation) as documented in license amendments (ML22021B660). While some or all of the inspection documented in this report was performed while the licensee was referred to as Exelon Generation Company, LLC, this report will refer to the licensee as Constellation throughout.
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, 02.07 a, 02.08 a, b, e)
- 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: 9 Requirements (02.09 a, b, 02.10, 02.11 a - e, 02.13 a)
- Tier III: 4 Requirements (02.14, 02.15 a - c)
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, b, c, d, 02.06 a, b)
- Tier III: 5 Requirements (02.10, 02.11 a, 02.12 a, b, 02.13 a)
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 Revisions 23 and 24 were 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 changes continue 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.
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) July 1, 2020 through September 30,
INSPECTION RESULTS
No findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On December 2, 2021, the inspectors presented a security inspection debrief to Mr. Frank Sturniolo, Site Vice President, and other members of the licensee staff.
- On January 21, 2022, the inspectors presented the security baseline inspection results to Mr. Frank Sturniolo, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
04376806
04382141
04393794
04400200
04401297
04418898
04436358
04453245
Procedures
Exelon Security Search Processes
Revision 37
SY-AA-101-112-
1004
Protected Area Search Processes
Revision 4
SY-AA-101-112-
1005
Owner Controlled Area Inspection Processes
Revision 2
Processing and Escorting of Personnel and Vehicles
Revision 33
Control of Badges
Revision 10
Control of Security Access Control Devices
Revision 9
Operation of The Security Control Centers
Revision 15
Security Assessment and Response to Unusual Activities
Revision 34
SY-LG-101-112
Limerick Generating Station Search Processes
Revision 9
SY-LG-101-115
Operations of Active Vehicle Barriers and Gates
Revision 10
SY-LG-101-119
Control of Receiving Warehouse at Limerick Generating
Station
Revision 11
SY-LG-101-124
Duties and Responsibilities of Security Control Centers and
Security Supervision at Limerick Generating Station
Revision 14
SY-LG-1016
Limerick Watch Standing Practices
Revision 14
SY-LG-1039
Visitor Authorization
Revision 10
Procedures
SI-500
Security Light Surveillance and Calibration
Revision 16
SI-851
Early Warning System (EWS) and Unattended Pathway
Performance Determination Test
Revision 1
SI-955
Observation and Inspection of Security Barriers
Revision 022
Testing Security Equipment
Revision 23
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SY-AA-101-122-
101
Performance of Perimeter Intrusion Detection/Camera
System Tests
Revision 30
SY-AA-101-122-
2
Performance of Early Warning Detection System Tests
Revision 00
Corrective Action
04374991
263398
04400010
04393115
04436358
04376806
04393794
04400200
04401297
04436358
04376806
04418898
04408675
04440700
04422944
04382141
04454693
04416309
04408675
Corrective Action
Documents
Resulting from
Inspection
04464261
04464322
04464325
04464329
04464343
Miscellaneous
Approved Firearms Courses of Fire
Procedures
Avon Protective Respirator
Revision 1
Firearm Training Simulator (FATS)
Revision 1
Exelon Nuclear Security Training
Revision 2
Exelon Nuclear Security Physical Fitness Test, Development
and Conduct
Revision 1
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Tactical Course Development Approval and Conduct
Revision 7
Self-Assessments NOSA-LIM-20-02
Security Programs Audit Report
01/21/20
NOSA-LIM-21-01
Security Programs Audit Report
01/19/21
Miscellaneous
Limerick Generation Station Physical Security Plan, Training
and Qualification Plan, Safeguards Contingency Plan, and
Independent Spent Fuel Storage Installation Security
Program
Revision 23
Limerick Generation Station Physical Security Plan, Training
and Qualification Plan, Safeguards Contingency Plan, and
Independent Spent Fuel Storage Installation Security
Program
Revision 24
71151
Procedures
SI-034
Protected Area Security Performance Indicator Instruction
Revision 13
Security Events and Nuclear Regulatory Commission
Performance Indicators
Revision 11