IR 05000445/2020410

Security Baseline Inspection Report 05000445/2020410 and 05000446/2020410

ML20254A349
Person / Time
Site:	Comanche Peak
Issue date:	09/10/2020
From:	Ray Kellar Plant Support Branch-1
To:	Peters K Vistra Operations Company
References
IR 2020410
Download: ML20254A349 (8)

Text

September 10, 2020

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT - SECURITY BASELINE INSPECTION REPORT 05000445/2020410 AND 05000446/2020410

Dear Mr. Peters:

On August 27, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant. The NRC inspectors discussed the results of this inspection with Mr. T. McCool, 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,

/RA James R. Larsen Acting for/

Ray L. Kellar, P.E., Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos. 05000445 and 05000446 License Nos. NPF-87 and NPF-89

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000445 and 05000446 License Numbers: NPF-87 and NPF-89 Report Numbers: 05000445/2020410 and 05000446/2020410 Enterprise Identifier: I-2020-410-0004 Licensee: Vistra Operations Company LLC Facility: Comanche Peak Nuclear Power Plant Location: Glen Rose, TX Inspection Dates: August 24, 2020 to August 27, 2020 Inspectors: D. Holman, Sr Physical Security Inspector Approved By: Ray L. Kellar, P.E., Chief Plant Support Branch 1 Division of Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a security baseline inspection at Comanche Peak Nuclear Power Plant, 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

Unless otherwise noted, baseline security inspections were conducted in accordance with the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection. 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. Publicly available IPs are located at:

http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

71130.02 - Access Control

Access Control (1 Sample)

(1)

• Tier I: All Requirements

• Tier II: 6 Requirements (02.08 a-e and g)

• Tier III: 1 Requirement (02.09)

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) The opportunity to apply this procedure was not available in accordance with Inspection Manual Chapter 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 implementation 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)

=

The inspector verified performance indicator data listed below:

(1) October 2019 through June

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On August 27, 2020, the inspectors presented the security baseline inspection results to Mr. T. McCool, 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 2019-007675 Keys in emergency vehicles 10/2/19

Documents 2019-008490 Discovered contraband in x-Ray 11/4/19

Corrective Action 2020-006290 NRC observation about FAC entry sign 8/27/20

Documents 2020-006322 NRC observation, exit side PCMs have gaps that can be 8/27/20

Resulting from circumvented

Inspection 2020-006324 Minor violation of 10 CFR 73.22 protection of safeguards. 8/27/20

20-006325 Minor violation for rusted security padlocks not included in 8/27/20

the maintenance program.

20-006327 NRC observation, SFRs lack necessary details 8/27/20

20-006337 Form SEC-506-12 verbiage does not match verbiage used in 8/27/20

body of procedure.

20-006360 Minor violation of 10 CFR 73.55(c)(7)(i) security procedures 8/28/20

with "should" instead of "shall"

Miscellaneous Email to Security From:

J. Jurado, Subject: SFR and IRs 8/20/20

Supervisors

Email to Security From:

R. Brock, Subject: Post 13 Presentation 3/29/18

Supervisors

SAS Key Cabinet 10/22/18 to 10/25/18 See

Issue/Turn-in Log and Description

SGI Key 11/17/18 to 11/29/18

SFR 0011-20 Unsatisfactory Job performance 1/8/20

SFR 0020-20 On Duty without all Equipment 1/13/20

SFR 0145-20 Unsatisfactory Job Performance 4/26/20

SFR 0146-20 Unsatisfactory Job Performance 4/26/20

SFR 0147-20 Assumed post without duty equipment 4/26/20

SFR 0171-20 For Cause Hold 5/7/20

SFR 0465-18 SGI Safe 10/25/18

Procedures CPNPP SI 1.0 Common Instructions Revision 41

CPNPP SI 3.11 Key Control Revision 24

CPNPP SI 3.13 Key Card Control Revision 52

CPNPP SOP Unescorted Access Authorization Revision 11

SEC-120

Inspection Type Designation Description or Title Revision or

Procedure Date

CPNPP SOP Personnel Identification, Key Card Badge Issuance, and Revision 19

SEC-302 Access Control

CPNPP SOP Lock, Key, Password, Combinations and Key Card Badge Revision 27

SEC306 Control System

CPNPP STA-902 Access To CPNPP Site Areas Revision 26

Work Orders 5847504 Monthly Inspection, CPX-SCEQPD-03 2/4/20

5908056 Monthly Inspection, CPX-SCEQPD-03 6/22/20

5918090 Monthly Inspection, CPX-SCEQPD-03 7/20/20

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