IR 05000445/2022402

Security Baseline Inspection Report 05000445/2022402 and 05000446/2022402

ML22109A049
Person / Time
Site:	Comanche Peak
Issue date:	04/25/2022
From:	Ray Kellar NRC/RGN-IV/DRSS
To:	Peters K Vistra Operations Company
References
IR 2022402
Download: ML22109A049 (9)

Text

April 25, 2022

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - SECURITY BASELINE INSPECTION REPORT 05000445/2022402 AND 05000446/2022402

Dear Mr. Peters:

On March 24, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant, Units 1 and 2 and, the NRC inspector discussed the results of this inspection with Mr. John Dreyfuss, Director, Organizational Effectiveness, 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, Ray L. Kellar, P.E., Chief Plant Support Branch Division of Radiological Safety & Security 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:

05000445/2022402 and 05000446/2022402

Enterprise Identifier:

I-2022-402-0000

Licensee:

VISTRA Operating Company, LLC

Facility:

Comanche Peak Nuclear Power Plant, Units 1 and 2

Location:

Glen Rose, TX

Inspection Dates:

March 21, 2022 to March 24, 2022

Inspector:

J. Buchanan, Physical Security Inspector

Accompanied By:

T. Weir

Approved By:

Ray L. Kellar, P.E., Chief

Plant Support Branch

Division of Radiological Safety & Security

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, 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 inspector 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 inspector evaluated the access control program through completion of the following

inspection elements: Access Control

(1) Tier I: All Requirements

Tier II: All Requirements

Tier III: All Requirements

71130.09 - Security Plan Changes

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

procedure elements: Security Plan Changes

(1) Since the last NRC inspection of this program area, Comanche Peak Nuclear Power Plant Unit 1 and 2 Security Plan Revision 14 was implemented based on the licensee's 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 changed continues to meet the requirements of 10 CFR 73.55(b). The inspector 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 inspector verified licensee performance indicators submittals listed below:

PP01: Protected Area Security Equipment Performance Index Sample (IP Section 02.17) (1 Sample)

(1) January 1, 2021 through December 31,

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

On March 24, 2022, the inspector presented the security baseline inspection results to Mr. John Dreyfuss, Director, Organizational Effectiveness, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Corrective Action

Documents

CR-2021-003925,

CR-2021-003994,

CR-2021-005404,

CR-2021-005889,

CR-2021-007969,

CR-2021-008040,

CR-2022-000206,

CR-2022-001393,

CR-2022-001404,

and

CR-2022-001626

IR-2022-001623

and

IR-2022-001883

TR-2021-002424,

TR-2021-007195,

TR-2021-007509,

TR-2021-007771,

TR-2021-008562,

TR-2022-000869,

and

TR-2022-001254

Corrective Action

Documents

Resulting from

Inspection

CR-2022-001933,

IR-2022-001883,

IR-2022-002023,

IR-2022-002-25,

AND TR-2022-

001943.

71130.02

Miscellaneous

209 Nuclear

Policy Statement

Prohibited and Controlled Items and Site Photography

2/30/2018

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Job Aid

PADS Check for Visitor Processing

2/16/2021

Security Field

Reports

0077-22,

0085-22,

0088-22,

0098-22,

0153-21,

263-21,

267-21,

0353-21,

0479-21,

0505-21,

28-21, and

0557-21

3.11 Security

Instruction

Key Control

3.11 Security

Instruction

Key Control

3.16 Security

Instruction

Portable Explosive Detector Searches

3.2 Security

Instruction

Access Control

4.0 Security

Instruction

Compensatory Measures

SEC-201

Security Procedures During Refueling and Major

Maintenance Operations

SEC-302

Personnel Identification, Key Card Badge Issuance and

Access Control

SEC-304

Vehicle and Material Control

SEC-306

Lock, Key, Password, Combinations and Key Card Badge

Control System

SEC-506

Security Equipment Maintenance, Testing, and Calibration

STA-308

Protection of Safeguard Information and Oher Controlled

Information Types

Procedures

STA-902

Access to CPNPP Site Areas

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

STA-904

Vehicle and Material/Package Control

Self-Assessments

IR-2022-001154

Security Access Control Self-Assessment

Work Orders

27722

50.54 (P)

Site-Specific Analysis

03/29/2016

50.54 (P)

Site-Specific Analysis

03/16/2022

Regulatory

Analysis

SAP Staffing Requirements

04/19/2015

Security Plan

Comanche Peak Nuclear Power Plant Unit 1 and 2 Security

Plan

71130.09

Miscellaneous

Security Plan

Comanche Peak Nuclear Power Plant Unit 1 and 2 Security

Plan

14