IR 05000461/2021402

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Security Baseline Inspection Report 05000461/2021402
ML21235A138
Person / Time
Site: Clinton Constellation icon.png
Issue date: 08/23/2021
From: Steven Orth
Plant Support Branch II
To: Rhoades D
Exelon Generation Co, Exelon Nuclear
References
IR 2021402
Download: ML21235A138 (7)


Text

SUBJECT:

CLINTON POWER STATION - SECURITY BASELINE INSPECTION REPORT 05000461/2021402

Dear Mr. Rhoades:

On August 6, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Clinton Power Station and discussed the results of this inspection with Ms. N. Plumey, 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, Steven K. Orth, Chief Plant Support Branch Division of Reactor Safety Docket No. 05000461 License No. NPF-62

Enclosure:

As stated

Inspection Report

Docket Number:

05000461

License Number:

NPF-62

Report Number:

05000461/2021402

Enterprise Identifier:

I-2021-402-0064

Licensee:

Exelon Generation Company, LLC

Facility:

Clinton Power Station

Location:

Clinton, IL

Inspection Dates:

August 02, 2021 to August 06, 2021

Inspectors:

J. Kutlesa, Physical Security Inspector

A. Woyansky, Security Specialist

Approved By:

Steven K. Orth, Chief

Plant Support Branch

Division of Reactor Safety

SUMMARY

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

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. Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework.

In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

SAFEGUARDS

71130.05 - Protective Strategy Evaluation

On January 31, 2020, the Secretary of the United States Department of Health and Human Services declared a Public Health Emergency (PHE) on the public health risks of the COVID-19 coronavirus. In response to the PHE, Clinton Power Station pursued an exemption to security officer training and requalification requirements (ML20323A434 for specific exemptions approved). In addition to these exemptions, licensees implemented additional actions or alternatives in response to health concerns. As described in existing regulatory guidance (e.g.,

Regulatory Guide 5.75), licensees implemented measures to ensure annual Force on Force exercises were conducted as safely as possible while maintaining the requirements to simulate as closely as practicable site specific conditions and minimizing the number and effects of artificialities associated with these exercises (Part 73, Appendix B, VI.C.3).

The inspectors evaluated the licensee's protective strategy through completion of the following procedure elements:

Protective Strategy Evaluation (2 Samples)

(1) Tier I: All Requirements

Tier II: All requirements

Tier III: 02.09; 02.10; 02.11

(2) Observed annual Force-on-Force conducted on 08/03/2021.

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 Sample)

(1) Since the last NRC inspection of this program area, Security Plan Revision 19 to 20 was implemented based on your 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 inspectors 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.

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 6, 2021, the inspectors presented the security baseline inspection results to Ms. N. Plumey, Plant Manager and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CC-AA-309-1001

Design Analysis Minor Revision

Calculations

CC-AA-309-1001

Design of Passive VBS

AR 04438519

71130.05 NRC Day One Observations

08/02/2021

Corrective Action

Documents

Resulting from

Inspection

AR 04439093

71130.05 NRC Day Four Observations

08/05/2021

Force on Force Drill Folders

2018 - 2020

Security Aid 16

Security Power System Configuration

Security Aid 17

Subterranean Penetration Pictures

Miscellaneous

SY-AA-101-133-

F-01

Supporting Law Enforcement Agency Response Capability

01/19/2021

SY-AA-150-1006-

F-01

Responder Timeline Worksheet

SY-AA-500-127

Safety/Security Interface

71130.05

Procedures

SY-CL-101-501

Site Specific Defensive Strategy

Clinton Power Station Security Plan

71130.09

Miscellaneous

Clinton Power Station Security Plan

20