IR 05000352/2022402

Security Baseline Inspection Report 05000352/2022402 and 05000353/2022402

ML22291A439
Person / Time
Site:	Limerick
Issue date:	10/18/2022
From:	Daniel Schroeder Decommissioning, ISFSI, and Reactor Health Physics Branch
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
Schroeder D
References
IR 2022402
Download: ML22291A439 (9)

Text

October 18, 2022

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - SECURITY BASELINE INSPECTION REPORT 05000352/2022402 AND 05000353/2022402

Dear David Rhoades:

On October 6, 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 Mike Gillin, 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, Digitally signed by Daniel L.

Daniel L. Schroeder Date: 2022.10.18 14:53:03 Schroeder -04'00'

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: NPF-39 and NPF-85 Report Numbers: 05000352/2022402 and 05000353/2022402 Enterprise Identifier: I-2022-402-0032 Licensee: Constellation Energy Generation, LLC Facility: Limerick Generating Station, Units 1 and 2 Location: Sanatoga, PA Inspection Dates: October 3, 2022 to October 6, 2022 Inspectors: K. Hussar, Senior Physical Security Inspector D. Caron, Senior Physical Security Inspector T. Eck, Physical Security Inspector Approved By: Daniel L. Schroeder, Chief Security, Emergency Preparedness and Incident Response Branch Division of Radiological Safety and Security Enclosure

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.

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: 13 Requirements (02.06 a - d, 02.07 a, 02.08 a - h)

• Tier III: 2 Requirements (02.09, 02.10)

71130.04 - Equipment Performance, Testing, and Maintenance

The inspectors evaluated the security equipment testing and maintenance program through

completion of the following inspection elements: Equipment Performance, Testing, and Maintenance

(1)

• Tier I: All Requirements

• Tier II: 7 Requirements (02.09 b, 02.10 a, 02.11 a, c, d, e, 02.13 a)

• Tier III: 3 Requirements (02.15 a - c)

71130.07 - Security Training

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

inspection elements: Security Training

(1)

• Tier I: All Requirements

• Tier II: All Requirements

• Tier III: All Requirements

71130.09 - Security Plan Changes

The inspectors evaluated the security plan changes through completion of the following

inspection elements: Security Plan Changes

(1) The opportunity to apply this procedure was not available in accordance with IMC 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.

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) October 1, 2021 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 October 6, 2022, the inspectors presented the security baseline inspection results to Mike Gillin, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71130.02 Corrective Action 04489175

Documents 04491529

04470311

04488474

04503284

04470284

04515894

Procedures SY-AA-101-106 Control and Classification of Safeguards Information (SGI) Revision 22

and Sensitive Unclassified Non-Safeguards Information

(SUNSI)

SY-AA-101-112 Exelon Security Search Processes Revision 38

SY-AA-101-112- Unitech Laundry Facility Search Processes Revision 3

1002

SY-AA-101-112- Ion Scanning Explosives Detector (ISED) Search Processes Revision 4

1003

SY-AA-101-120 Control of Security Access Control Devices Revision 9

SY-AA-101-132 Security Assessment and Response to Unusual Activities Revision 36

SY-AA-101-155 Security Events and Nuclear Regulatory Commission Revision 11

Performance Indicators

SY-LG-101-112 Limerick Generating Station Search Processes Revision 009

SY-LG-101-120 Governance of Security Keys in the OCA Revision 002

71130.04 Corrective Action 04485847

Documents 04494272

04502144

04516753

Miscellaneous SY-LG-101-124- CAS Worksheets 09/01/2022 -

F-01 10/04/2022

SY-LG-101-124- SAS Worksheets 09/01/2022 -

F-02 10/04/2022

Procedures Limerick Generating Station Physical Security Plan Revision 034

SI-320 Perimeter Intrusion Detection System Microwave/Fence Revision 034

Shaker Operability and CCTV Performance Determination

Inspection Type Designation Description or Title Revision or

Procedure Date

SI-322 Protected And Vital Area Barrier Break Wire and Mag Switch Revision 015

Test Method

SI-328 Early Warning System (EWS) And Unattended Pathway Revision 024

Operability Determination

SI-330 Duress Alarm Test (CAS/SAS) Revision 002

SI-400 Remote Operated Weapons System (ROWS) Semi-Annual Revision 004

Test

SI-401 Remote Operated Weapons System (ROWS) Annual Test Revision 004

SI-850 Perimeter Intrusion Detection System Shaker Fence System Revision 004

Performance Test

SI-962 Firearms Detector Operational (Daily) and Performance Revision 004

(Weekly and RTS) Tests, Hand-Held Metal Detector

Operational Test (Prior to Each Use)

SI-990 Tamper Alarm Testing Revision 009

SY-AA-101-103 Observation and Inspection of Security Barriers Revision 013

SY-AA-101-122 Testing Security Equipment Revision 023

SY-AA-101-122- Performance of Perimeter Intrusion Detection / Camera Revision 000

101 System Tests

SY-AA-101-122- Performance of Early Warning Detection System Tests Revision 000

2

SY-AA-101-122- Performance of Access Control Device and Portal Tests Revision 000

103

SY-AA-101-122- Performance of Special Purpose Detector, Communication, Revision 000

104 Lighting, and Biometrics Threshold Tests

SY-AA-150-103 Firearms Maintenance, Testing, And Accountability Revision 002

SY-LG-101-500 Station Security Plan Support Revision 004

SY-LG-2001 Perimeter Intrusion Detection System Microwave Revision 008

Performance Determination Test

71130.07 Corrective Action 04464261

Documents 04493647

Corrective Action 04526537

Documents 04526994

Resulting from 04527017

Inspection 04527062

Inspection Type Designation Description or Title Revision or

Procedure Date

04527298

04527266

Procedures SY-AA-150-101 Exelon Nuclear Security Training Revision 3

SY-AA-150-103 Firearms Maintenance, Testing, and Accountability Revision 2

SY-AA-150-103- Record of Semi-annual Functionality and Accuracy Tests &

F-01 Firearms Maintenance Log

7