IR 05000352/2023402
| ML23038A012 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/07/2023 |
| From: | Daniel Schroeder Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| IR 2023402 | |
| Download: ML23038A012 (1) | |
Text
February 7, 2023
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - SECURITY BASELINE INSPECTION REPORT 05000352/2023402 AND 05000353/2023402
Dear David Rhoades:
On January 25, 2023, 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 Matthew Bonanno, Plant Manager, 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:
05000352/2023402 and 05000353/2023402
Enterprise Identifier: I-2023-402-0024
Licensee:
Constellation Energy Generation, LLC
Facility:
Limerick Generating Station, Units 1 and 2
Location:
Limerick, PA
Inspection Dates:
January 23, 2023 to January 25, 2023
Inspectors:
D. Caron, Senior Physical Security Inspector
T. Eck, Physical Security Inspector
S. McCarver, 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
71130.01 - Access Authorization
The inspectors evaluated the access authorization program. The following elements were
===evaluated:
Access Authorization===
(1)
- Tier I: All Requirements
- Tier II: 6 Requirements (02.05 a and b, 02.06 a - c, 02.07 a)
- Tier III: 4 Requirements (02.09, 02.10 a and b, 02.11 a)
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 - d)
- Tier III: 2 Requirements (02.09, 02.10 a)
71130.08 - Fitness For Duty Program
The inspectors evaluated the fitness for duty program by completing the following inspection
===elements:
Fitness For Duty Program===
(1)
- Tier I: All Requirements
- Tier II: 29 Requirements (02.05 a - l, 02.06 a, b, d, e - g, 02.07 a - e, 02.08 a, b, 02.09 a, b, d, e)
- Tier III: 9 Requirements (02.10, 02.11 a, 02.12 a, 02.13 a - d, 02.14 b, c)
71130.09 - Security Plan Changes
The inspectors evaluated the security plan changes through completion of the following
===procedure 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, 2022 through December 31,
INSPECTION RESULTS
No findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On January 25, 2023, the inspectors presented the security baseline inspection results to Matthew Bonanno, Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
29698
4537749
25842
0444675
4402100
Miscellaneous
Access
Authorization
Files for all
Categories
Audit VA22007
Callaway Energy Center (CEC) NEI Audit Pinnacle
Investigations
Nantel Generic
Fitness-for-Duty
and Behavior
Observation
Content
Document
(training)
June 2021
PSEG Audit
Number:
NOV2021-121
PSEG Nuclear, LLC Audit Report of Confidential Services
Inc.
7/19/2021
Procedures
Access Authorization Program
Revision 17
Utilizing the Personnel Access Data System (PADS)
Revision 17
Review Criteria for Determining Trustworthiness and
Reliability
Revision 9
Corrective Action
Documents
04508554
04440568
04393794
04376806
04351799
04351395
04349764
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
04344535
04330356
04328722
Miscellaneous
NOSA-LIM-20-02
Security Programs Audit Report
2/12/2020
NOSA-LIM-21-01 Security Programs Audit Report
03/10/2021
Procedures
Control and Classification of Safeguards Information and
Sensitive Unclassified Non-Safeguards Information
Revision 22
Security Sealing Operations
Revision 13
Exelon Security Search Processes
Revision 38
SY-AA-101-112-
1004
Protected Area Search Processes
Revision 5
SY-AA-101-112-
1005
Owner Controlled Area Inspection Processes
Revision 4
Processing and Escorting of Personnel and Vehicles
Revision 34
Control of Security Access Control Devices
Revision 9
Security Assessment and Response to Unusual Activities
Revision 36
SY-LG-101-112
Limerick Generating Station Search Processes
Revision 9
SY-LG-101-116
Conducting Security Patrols
Revision 6
SY-LG-101-119
Control of Receiving Warehouse at Limerick Generating
Station
Revision 11
SY-LG-101-120
Governance for Security Keys in the OCA
Revision 2
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 15
Corrective Action
Documents
04403906
04442177
04496297
04371583
Miscellaneous
MEDTOX Annual Statistical Report 01/01/2022 - 12/31/2022
Blind Sample Quarterly Reports 2020 - 2022
AR 2022-02994
MedTox Laboratory Inc. Audit
04/07/2022
N-AN-SY-FFD
LMS Training and Qualification Records
01/24/2023
N-AN-SY-FFD-
SpecimenColl
LMS Training and Qualification Records
01/24/2023
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
NE 2021-17
ELSohly Laboratories, Inc. Audit
11/17/2021
Procedures
Exelon Generation Fitness for Duty Program
Revision 22
Testing for Cause
Revision 21
Treatment Plan and Follow-Up Testing
Revision 09
Random Selection and Notification Process
Revision 14
Fitness for Duty Appeal Review
Revision 10
Reporting Use of Medication
Revision 11
Notification of Fitness for Duty Test Results
Revision 10
Handling and Storage of Fitness for Duty Records
Revision 13
Handling Suitable Inquiries Records
Revision 05
Fitness for Duty Screening Process
Revision 07
Test Results and MRO Response
Revision 11
Designated Collection Facility
Revision 09
Collection of Specimens for Testing in an Exelon Facility
Revision 16
Breath Alcohol Testing
Revision 12
Calibration of Alco Sensor Equipment
Revision 12
Laboratory Blind Performance Test Specimens
Revision 08
Fitness for Duty Training and Qualification Requirements
Revision 05