IR 05000461/2010403

NRC Security Baseline Inspection Report 05000461/2010-403(DRS)

ML11129A286
Person / Time
Site:	Clinton
Issue date:	05/26/2010
From:	Eric Duncan Plant Support Branch II
To:	Pardee C Exelon Generation Co, Exelon Nuclear
References
FOIA/PA-2011-0187 IR-10-403
Download: ML11129A286 (19)

Text

N FREGII UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532-4352 May 26, 2010 Mr. Charles Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO), Exelon Nuclear 4300 Winfield Road Warrenville IL 60555 SUBJECT: CLINTON POWER STATION NRC SECURITY BASELINE INSPECTION REPORT 05000461/2010403(DRS)

Dear Mr. Pardee:

On April 29, 2010, the U. S. Nuclear Regulatory Commission (NRC) completed a security baseline inspection at your Clinton Power Station. The inspection covered one or more of the key attributes of the security cornerstone of the NRC's Reactor Oversight Process. The enclosed inspection report documents the inspection results, which were discussed on April 29, 2010, with Mr. F. A. Kearney and other members of your staff.

The inspection examined activities conducted under your license as they relate to security and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspector reviewed selected procedures and records, observed activities, and interviewed personnel.

.No findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly AvailableRecords System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

However, because of the security-related concerns contained in the enclosure, and in accordance with 10 CFR 2.390, a copy of this letter's enclosure will not be available for public inspection.

ncre contL E Tn classified ffI\(Safc Io~1r, thn's:tr itta douen deInrIe

Ay&ŽbN1ý Y - E URI -RE ED/N FORI ON Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely, IRA by D. Funk for!

Eric Duncan, Chief Plant Support Branch Division of Reactor Safety Docket Nos. 50-461 License Nos. NPF-62 Nonpublic

Enclosure:

Inspection Report 05000461/2010403(DRS)

w/Attachment: Supplemental Information

REGION III==

I.)ocket No: 05000461 LLicense No: NPF-62 FReport No: 05000461/2010403(DRS)

LLicensee: Exelon Generation Company, LLC FFacility: Clinton Power Station LLocation: Clinton, Illinois E)ates: April 26 through 29, 2010 nspectors: T. Eck, Physical Security Inspector D. Funk, Senior Projects Specialist

,/\pproved by: E. Duncan, Chief Plant Support Branch Division of Reactor Safety Enclosure EQ0 S U T - L I " 4TýN

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SUMMARY OF FINDINGS

IR 05000461/2010403(DRS); 04/26/2010 - 04/29/2010, Clinton Power Station; Routine Security

Baseline Inspection.

This report covers a 1 week period of announced routine baseline inspection on security.

The inspection was conducted by two Region III physical security inspectors. No findings of significance were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process."

A. Inspector-Identified and Self-Revealed Findings

Cornerstone: Physical Protection

No findings of significance were identified.

Licensee-Identified Violations

None.

REPORT DETAILS

SAFEGUARDS

Cornerstone: Physical Protection (PP)

S05 Protective Strategqy Evaluation (71130.05)

a. Inspection Scope

The inspectors evaluated this area by: reviewing procedures and records; conducting interviews with responsible personnel and plant employees; and performing walkdowns of defensive positions, areas of attack, and the Protected Area (PA).

The inspectors verified that the licensee's Protective Strategy Evaluation program:

(1) complied with the NRC-approved security plan and other applicable regulatory requirements; and

(2) was being effectively implemented and provided high assurance of protecting certain vital equipment and critical personnel assets from the Design Basis Threat (DBT).

The inspectors conducted the following specific inspection activities:

• reviewed and evaluated licensee event reports, safeguards log entries, and corrective action documents between February 2010 and April 2010 (no licensee event reports were documented);verified that the licensee's protective strategy:

(a) included documentation of the number of armed responders the licensee determined were required to satisfy the design requirements of 10 CFR 73.55(b) and the number of armed security officers the licensee designated to strengthen the onsite response capabilities in security plans;

(b) was designed to protect systems and components that were identified as target set equipment against the DBT of radiological sabotage;

(c) established response timelines that ensured the response force's ability to interdict and neutralize the threat in accordance with 10 CFR 73.55 and 10 CFR Part 73 Appendix C II and the licensee's Safeguards Contingency Plan;

(d) was designed to protect against characteristics, including tactics, of the external attacking force in accordance with the DBT of radiological sabotage;

(e) was designed to protect against the weapons described in the DBT of radiological sabotage;

(f) was designed to protect against the equipment, tools and incapacitating agents described in the DBT of radiological sabotage;

(g) was designed to protect against the land vehicles described in the DBT of radiological sabotage;

(h) was designed to protect against the insider threat described in the

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DBT of radiological sabotage;

(i) was designed to protect personnel, equipment, and systems necessary to prevent significant core damage and spent fuel sabotage against the effects of a vehicle bomb assault in accordance with the DBT of radiological sabotage;

(j) was designed to protect against a waterborne vehicle bomb assault in accordance with the DBT of radiological sabotage;

(k) included all security equipment (i.e., access control devices, physical barriers, intrusion detection systems (IDS), surveillance systems, locking devices, weapon systems, etc.) that was identified by the licensee as a component that supported its protective strategy in the maintenance, testing and calibration program and subjected this equipment to periodic checks for integrity and functionality; (I) included notification to law enforcement agencies (local, State, Federal, etc.)

in accordance with site procedures;

(m) ensured that there was at least one member of the security organization, onsite and available at all times, who had the authority to direct the activities of the security organization and who was assigned no other duties that interfered with this individual's ability to perform these duties in accordance with the physical security plan, safeguards -

contingency plan and the licensee's protective strategy;

(n) was designed to ensure that each alarm station is continuously staffed with at least one trained and qualified alarm station operator who is not assigned other duties and responsibilities that would interfere with the ability to execute the functions described in 10 CFR 73.55(i)(4)(i);

(o) ensured both the licensee's plant operations staff 'and security organization participated in assessing and managing changes to plant configurations, facility conditions, or security before implementing changes such as physical modifications, procedural changes, changes to operator actions or security assignments, maintenance activities, system reconfigurations, access modifications or restrictions and changes to the security plan and it's implementation; and

(p) established, maintained, and implemented measures for the response to alarms to determine the existence and level of a threat in accordance with pre-established assessment methodologies and procedures; verified for components of the protective strategy that the licensee:

(a) implemented continuous surveillance, observation and monitoring activities in thejOwner-Controlled Area to detect and deter intruders and ensure the integrity-of physical barriers 6r other components and functions of the onsite physical protection program;

(b) implemented measures to restrict waterborne vehicle access to areas as identified by their site specific analysis;

(c) implemented periodic surveillance and observation measures (in accordance with its site specific analysis) of waterway approaches and adjacent areas;

(d) employed vehicle barrier systems to protect personnel, equipment and systems necessary to prevent significant core damage and spent fuel sabotage against the effects of the DBT of radiological sabotage land vehicle bomb assault;

(e) implemented protective measures,(i.e., train derailer, remnoval of a section of track, or restrict access to railroad sidings)ifor areas where there is rail access to the PA and provided periodic surveillance of these protective measures;

(f) ensured that unattended openings that intersect a security boundary,(such as underground pathways) were protected by a physical barrier and were monitored

by intrusion detection equipment or observed by security personnel at a frequency that prevented exploitation;

(g) employed physical barriers which provided deterrence, delay or supported access control and supported the effective implementation of the protective strategy;

(h) secured and monitored openings in any physical barrier or barrier system to prevent exploitation of the opening;

(i) provided periodic surveillance and observation of vehicle barriers and barrier systems adequate to detect indications of tampering and degradation;

(j) ensured that the PA perimeter barrier was designed and constructed to limit access into the PA to only those personnel, vehicles and materials required to perform official duties and supported the effective implementation of the protective strategy;

(k) had armed security patrols perform periodic checks of all exterior areas within the PA to include physical barriers and Vital Area (VA) portals in accordance with the security plan and implementing procedures; (I) had armed security patrols perform periodic inspections of VAs to include the physical barriers used at all VA portals in accordance with the security plan and implementing procedures;

(m) performed random patrols of all accessible areas containing target set equipment in accordance with the security plan and implementing procedures;

(n) ensured that a single act, in accordance with the design basis threat of radiological sabotage, could not remove the capabilities of both alarm stations to detect and assess alarms, initiate and coordinate an adequate response to alarms, summon offsite assistance, and provide command and control;

(o) maintained the appropriate number of armed responders available at all times inside the PA within the specified predetermined timelines per the licensee's security plan and safeguards contingency plan;

(p) ensured that armed responders were not assigned other duties or responsibilities that could interfere with their assigned response duties;

(q) ensured appropriate timelines for armed responders;

(r) maintained the appropriate number of armed security officers that were designated in the licensee's security plan and safeguards contingency plan to strengthen its onsite response, onsite and available at all times to carry out their assigned response duties as designated in the licensee's security plan, safeguards contingency plan and protective strategy;

(s) provided the firearms, ammunition, and equipment necessary to implement the protective strategy to armed responders and armed security officers designated to strengthen the onsite response capabilities and ensured that this equipment was of sufficient supply, was in working condition and was readily available;

(t) provided and maintained measures that limit the exposure of security personnel to possible attack, including the incorporation of bullet-resisting protected positions that provide protection against the firearms identified in the DBT of radiological sabotage;

(u) provided protection of systems and components that were identified as target set equipment against the DBT of radiological sabotage; and

(v) maintained a documented copy of liaison agreements that the licensee established with local law enforcement agencies; verified through a protective strategy table top evaluation that the licensee's protective strategy provided a basis of information that demonstrated that the protective strategy was designed to effectively interdict and neutralize the threats up to and including the design basis threat of radiological sabotage as defined in 10 CFR 73.1, to prevent significant core damage and radiological sabotage; and

verified that the licensee was conducting security program reviews in accordance with 10 CFR 73.55(m) and that the licensee's protective strategy was included in a review as required by the regulation.

The inspectors reviewed protective strategy evaluation program-related issues during baseline inspection activities to verify that they were being entered into the licensee's corrective. action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and adequately addressed.

The inspectors completed 42 of the required 42 samples.

b. Findinqs No findings of significance were identified.

OTHER ACTIVITIES

40A5 Other Activities Inspection of Recently Amended Security Requirements The inspectors reviewed the following areas to ensure that the licensee complied with the recently amended Fitness-for-Duty (FFD) program and security regulations.

To verify implementation of the revised requirements the NRC determined that certain elements of the licensee's implementation of these requirements should be inspected prior to March 31, 2011. The following documents inspection activities related to these elements.

S1 Access Authorization (71130.01)

a. Inspection Scope

The inspectors evaluated this area by: reviewing program procedures, implementing procedures, and records; and conducting interviews with responsible personnel and plant employees.

The inspectors verified the licensee's access authorization program:

(1) complied with the NRC-approved security plan and other regulatory requirements;

(2) provided high assurance that personnel granted unescorted access were trustworthy, reliable, and did not constitute an unreasonable risk to public health and safety, or the common defense and security;

(3) established a behavioral observation program that provided high assurance of continued reliability and trustworthiness of personnel with unescorted access; and

(4) implemented the provisions of the insider mitig.ation program to effectively mitigate against theactive and active violent insider,.

l - ATE I OR T

The inspector conducted the following specific inspection activities:

verified for granting unescorted access that the licensee:

(e) ensured that a clinical interview by a licensed psychiatrist or psychologist was conducted for individuals who provided indication of disturbances in personality or psychopathology during the psychological assessment that may have implications on trustworthiness and reliability;

(f) verified that individuals who were members of the population that performed one or more job functions critical to the safe and secure operation of the licensee's facility, as defined in 10 CFR 73.56(i)(1)(v)(B), were subject to a clinical interview by a licensed psychiatrist or psychologist as part of the psychological assessment; and verified for the insider threat and mitigation that the licensee:

(c) implemented provisions for conducting psychological reassessments for individuals who performed one or more job functions critical to the safe and secure operation of the licensee's facility as identified in 10 CFR 73.56(i)(1)(v)(B) at intervals not to exceed 5 years.

The inspector reviewed access authorization related issues during baseline inspection activities to verify that they were being entered into the licensee's corrective action system at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and adequately addressed.

The inspector completed 3 of the required 44 sample. The remaining samples will be performed in a future baseline inspection.

b. Findings

No findings of significance were identified.

.2 Equipment Perfromance, Testing and Maintenance

a. Inspection Scope

The inspectors evaluated this area by: reviewing procedures and records, conducting interviews with responsible personnel and plant employees, and performing walkdowns of the equipment being tested.

The inspectors verified that the security testing and maintenance program:

(1) complied with the NRC-approved security plan and regulatory requirements; and

(2) was being effectively implemented to assure the functionality and reliability of all security equipment necessary for intrusion detection and assessment; searches; and a rapid, capable response to a DBT and other contingencies.

The inspector conducted the following specific inspection activities:

verified through observation of the perimeter intrusion detection system that:

(b) the system detected attempted or actual penetration of the PA perimeter

barrier before completed penetration and was tested in accordance with regulations and the licensee's testing procedures;

(e) video assessment assets at the PA perimeter provided a visual display from which assessment could be made and provided real-time and play-back recorded video images of detected activities before and after each alarm annunciation and that these devices were tested in accordance with regulations and the licensee's testing procedures;

(k) the intrusion detection and assessment equipment at the PA perimeter remained operable from an uninterruptible power supply and that this function was tested in accordance with regulations and licensee testing procedures; verified for alarm stations that:

(b) the status of a detection point, locking mechanism or access control device could not be changed without the knowledge and concurrence of an alarm station operator and that this function was tested in accordance with regulations and licensee testing procedures;

(g) both the central and secondary alarm stations were constructed, located, protected and equipped to the standards of the central alarm station so that both stations were equal and redundant such that all functions could be performed in both alarm stations; and verified for security communication systems that:

(e) the licensee identified areas of its site where communication could be interrupted or could not be maintained and established alternative communication measures or otherwise accounted for these areas in implementing procedures.

The inspector reviewed Equipment Performance, Testing and Maintenance-related issues during baseline inspection activities to verify that they were being entered into the licensee's corrective action system at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and adequately addressed.

The inspector completed 6 of the required 53 samples. The remaining samples will be performed in a future baseline inspection.

b. Findingqs No findings of significance were identified.

.3 Security Training

a. Inspection Scope

The inspectors evaluated this area by: reviewing program procedures, implementing procedures, and records; conducting interviews with responsible personnel and plant employees; and reviewing training drills and exercises.

For the nuclear security training program, the inspector verified that:

(1) the licensee's implementation of its nuclear security training program was in accordance with the-

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regulatory requirements, NRC-approved security plans, and any other applicable NRC requirement;

(2) security-personnel knowledge, skills and ability to conformed with the licensee's Training and Qualification (T & Q) plan, regulatory requirements, and any other applicable NRC requirements; and

(3) equipment assigned to security personnel conformed to the licensee's T&Q plan, regulatory requirements, and any other applicable NRC requirements. The inspector conducted the following specific inspection activities.

The inspectors conducted the following specific inspection activities:

verified for on-the-job training that:

(b) the licensee's training and qualification program included, at a minimum, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of on-the-job contingency-based training for individuals assigned duties and responsibilities to implement the Safeguards Contingency Plan before the individual was assigned the duty or responsibility; and verified for the licensee's performance evaluation program that:

(c) each member of each shift who was assigned duties and responsibilities required to implement the site's safeguards contingency plan and protective strategy participated in tactical drills and force-on-force exercises at the frequency prescribed in 10 CFR Part 73 Appendix B.

The inspectors reviewed security training-related issues during baseline inspection activities to verify that they were being entered into the licensee's corrective action system at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and adequately addressed.

The inspector completed 2 of the required 47 samples. The remaining samples will be performed in a future baseline inspection.

b. Findingqs No findings of significance were identified.

.4 Fitness-for-Duty Program

a. Inspection Scope

The inspectors evaluated this area by: reviewing program procedures, implementing procedures, and records; conducting interviews with responsible personnel and plant employees; and performing walkdowns.

The inspectors verified that:

(1) the licensee properly implemented FFD requirements, including 10 CFR Part NRC requirement 26 (subparts that assured A through licensee personnel and 0) and H, N,(including any otherand applicable contractors vendors)performed their tasks in a reliable and trustworthy manner and were not under the influence of any substance or mentally or physically impaired from any cause that affected their abilities to perform their duties safely and competently;

(2) changes to the

licensee's FFEi program made since the last inspection:

(a) met commitments to resolve previously identified issues or NRC requirements; and

(b) did not adversely affect the performance requirements as prescribed by regulatory requirements and any other applicable U. S. Nuclear Regulatory Commission (NRC) requirement; and

(3) the licensee properly implemented FFD requirements, as prescribed by regulatory requirements including 10 CFR Part 26 (Subpart I) and any other applicable NRC requirement, to ensure, in part, that nuclear facility security force personnel were not assigned to duty while in a fatigued condition that reduced their alertness or ability to perform functions necessary to identify and promptly respond to plant security threats.

The inspectors conducted the following specific inspection activities:

reviewed and evaluated licensee event reports, safeguards log entries, and corrective action documents dated between February 2010 and April 2010 (no licensee event reports were documented); and verified for security force work hours that:

(a) security officers' work hour records did not exceed work hour limits;

(b) the waivers issued from work hour limits were authorized and documented in accordance with the rule requirements.

The inspectors reviewed FFD-related issues during baseline inspection activities to verify that they were being entered into the licensee's corrective action system at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and adequately addressed.

The inspector completed 3 of the required 51 samples. The remaining samples will be performed in a future baseline inspection.

b. Findings

No findings of significance were identified.

40A6 Meetings Exit Meetinq The inspectors presented the inspection results to Mr. F. A. Kearney and other members of licensee management at the conclusion of the inspection on April 29, 2010. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

F. Kearney, Site Vice President

M. Kanavos, Plant Manager

M. Hiter, Security Analyst

S. Gackstetter, Regulatory Assurance Manager

J. Cunningham, Security Manager

J. Waddell, Security Supervisor

D. Montgomery, Access Authorization

Nuclear Regulatory Commission

D. Lords, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

ODened. Closed,

Discussed

None

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