IR 05000352/2022402

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Security Baseline Inspection Report 05000352/2022402 and 05000353/2022402
ML22291A439
Person / Time
Site: Limerick  Constellation icon.png
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, 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

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.

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: 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 Sample)

(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

Procedure

Type

Designation

Description or Title

Revision or

Date

71130.02

Corrective Action

Documents

04489175

04491529

04470311

04488474

04503284

04470284

04515894

Procedures

SY-AA-101-106

Control and Classification of Safeguards Information (SGI)

and Sensitive Unclassified Non-Safeguards Information

(SUNSI)

Revision 22

SY-AA-101-112

Exelon Security Search Processes

Revision 38

SY-AA-101-112-

1002

Unitech Laundry Facility Search Processes

Revision 3

SY-AA-101-112-

1003

Ion Scanning Explosives Detector (ISED) Search Processes

Revision 4

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

Performance Indicators

Revision 11

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

Documents

04485847

04494272

04502144

04516753

Miscellaneous

SY-LG-101-124-

F-01

CAS Worksheets

09/01/2022 -

10/04/2022

SY-LG-101-124-

F-02

SAS Worksheets

09/01/2022 -

10/04/2022

Procedures

Limerick Generating Station Physical Security Plan

Revision 034

SI-320

Perimeter Intrusion Detection System Microwave/Fence

Shaker Operability and CCTV Performance Determination

Revision 034

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

SI-322

Protected And Vital Area Barrier Break Wire and Mag Switch

Test Method

Revision 015

SI-328

Early Warning System (EWS) And Unattended Pathway

Operability Determination

Revision 024

SI-330

Duress Alarm Test (CAS/SAS)

Revision 002

SI-400

Remote Operated Weapons System (ROWS) Semi-Annual

Test

Revision 004

SI-401

Remote Operated Weapons System (ROWS) Annual Test

Revision 004

SI-850

Perimeter Intrusion Detection System Shaker Fence System

Performance Test

Revision 004

SI-962

Firearms Detector Operational (Daily) and Performance

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

Operational Test (Prior to Each Use)

Revision 004

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-

101

Performance of Perimeter Intrusion Detection / Camera

System Tests

Revision 000

SY-AA-101-122-

2

Performance of Early Warning Detection System Tests

Revision 000

SY-AA-101-122-

103

Performance of Access Control Device and Portal Tests

Revision 000

SY-AA-101-122-

104

Performance of Special Purpose Detector, Communication,

Lighting, and Biometrics Threshold Tests

Revision 000

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

Performance Determination Test

Revision 008

71130.07

Corrective Action

Documents

04464261

04493647

Corrective Action

Documents

Resulting from

Inspection

04526537

04526994

04527017

04527062

Inspection

Procedure

Type

Designation

Description or Title

Revision or

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-

F-01

Record of Semi-annual Functionality and Accuracy Tests &

Firearms Maintenance Log