IR 07200015/2022401

NRC Independent Spent Fuel Storage Installation Security Inspection Report 07200015/2022401 (Letter & Enclosure 1)

ML22334A069
Person / Time
Site:	Oyster Creek
Issue date:	12/06/2022
From:	Daniel Schroeder Decommissioning, ISFSI, and Reactor Health Physics Branch
To:	Trice K Holtec Decommissioning International
References
IR 2022401
Download: ML22334A069 (1)

Text

December 6, 2022

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION - NRC INDEPENDENT SPENT FUEL STORAGE INSTALLATION SECURITY INSPECTION REPORT 07200015/2022401

Dear Mr. Trice:

On November 8, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an Independent Spent Fuel Storage Installation (ISFSI) security inspection at the Independent Spent Fuel Storage Installation at the permanently shut down Oyster Creek Generating Station (Oyster Creek) in Forked River, New Jersey. The inspection covered your physical security plan, Revision 0, and the October 16, 2002, Interim Compensatory Measures for Dry Independent Spent Fuel Storage Installations Order and was conducted using NRC Inspection Procedure 92702, Follow-Up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders.

The inspectors performed follow-up inspection of the completed items and corrective actions associated with NRC Order EA-21-041, Confirmatory Order Related to the NRC Office of Investigations Report No-2020-007.

Additionally, the inspectors performed follow-up inspections on violations documented in EA-21-093 (Inspection Report (IR) 05000219/2021403, ML21301A188 Non-Public, ML21326A151 Public), EA-21-139 & EA-21-150 (OI Report numbers I-2021-002 & I-2021-014, ML22031A208 Non-Public), and IR 05000219/2021404 (ML21238A174 Non-Public).

The enclosed inspection report documents the inspection results, which were discussed with Mr. Jeffrey Dostal, Site Vice-President, and other members of your staff on November 8, 2022.

Enclosure 2 transmitted herewith contain SUNSI. When separated from enclosure 2, this transmittal document and enclosure 1 are decontrolled. The inspection examined activities conducted under your license as they relate to security and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, root causes, apparent causes, corrective actions, and interviewed personnel.

Based on the results of this inspection, no violations were identified.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's Rules of Practice, a copy of this letter and enclosure 1 will be made available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

However, enclosure 2 contains Security-Related Information, so enclosure 2 of the report will not be made publicly available in accordance with 10 CFR 2.390(d)(1). If you choose to provide a response that contains Security-Related Information, please mark your entire response Security-Related Information-Withhold from public disclosure under 10 CFR 2.390, in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1).

The NRC is waiving the affidavit requirements for your response in accordance with 10 CFR 2.390(b)(1)(ii).

Sincerely, Digitally signed by Daniel Daniel L. L. Schroeder Date: 2022.12.06 Schroeder 09:10:28 -05'00'

Daniel L. Schroeder, Chief Security, Emergency Preparedness and Incident Response Branch Division of Radiological Safety and Security

Enclosures:

1. Public Inspection Report No. 07200015/2022401 2. Non-Public Inspection Report No. 07200015/2022401 (OUO-SRI)

REGION I==

INSPECTION REPORT Docket No. 07200015 License No. DPR-16 Report No. 07200015/2022401 Enterprise Identifier: I-2022-401-0077 Licensee: Holtec Decommissioning International, LLC Address: Forked River, NJ.

Location Inspected: Oyster Creek Nuclear Generating Station Independent Spent Fuel Installation (ISFSI)

Inspection Dates: November 7 - 8, 2022 Inspectors: Dana Caron, Senior Physical Security Inspector Sammy McCarver, Physical Security Inspector Approved by: Daniel L. Schroeder, Chief Security, Emergency Preparedness and Incident Response Branch, Division of Radiological Safety and Security Enclosure 1 2

EXECUTIVE SUMMARY

In accordance with guidance in Inspection Procedure (IP) 92702, Follow-Up on

Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, And Orders, effective 01/01/2021, inspectors conducted on-site inspection activities at the permanently shut down Oyster Creek Nuclear Generating Station November 07 - 08, 2022.

Specifically, the inspectors performed follow-up inspection of the completed items and corrective actions associated with NRC Order EA-21-041, Confirmatory Order Related to the NRC Office of Investigations Report No-2020-007. The inspectors confirmed Holtecs completion of the following Order Conditions:

A.1, A.2, A.3, B.1, B.2, C.1, E1 The remaining items will be inspected as they are completed.

REPORT DETAILS

1. Order Condition A.1, HDI report of the maintenance status of all in-service and

contingency weapons on site at Oyster Creek.

a. Inspection Scope

The inspectors evaluated completion of this condition by reviewing the HDI report, matching the report to accountability records, reviewing weapons maintenance records, reviewing relevant weapons maintenance procedures, and inspecting weapons.

b. Findings

No violations were identified.

2. Order Condition A.2, HDI shall complete a root cause evaluation of the events related to

the violations at Oyster Creek described in the Order.

a. Inspection Scope

The inspectors evaluated completion of this condition by reviewing the root cause evaluation, the tools used to analyze the event and identify causal factors, the extent of condition, the extent of cause, the corrective actions to prevent occurrence, the schedule of corrective actions, and effectiveness reviews. Additionally, training documents and other products of corrective actions were reviewed and interviews with security staff were conducted.

b. Findings

No violations were identified.

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3. Order Condition A.3, HDI shall review its process for performing and recording in-service

and out-of-service weapons maintenance. The review shall include a comparison of Oyster Creeks process versus other nuclear sites and include at least one non-HDI nuclear site.

a. Inspection Scope

The inspectors evaluated completion of this condition by reviewing the HDI evaluation, the evaluations conclusions, and corrective action products generated from those conclusions.

b. Findings

No violations were identified.

4. Order Condition B.1, HDI shall communicate the issue to the security personnel at

Oyster Creek and other HDI decommissioning nuclear reactor sites. The communication will be conducted by the President of HDI and shall address wrongdoing and falsification of records.

a. Inspection Scope

The inspectors evaluated completion of this condition by reviewing the communications to Oyster Creek security personnel and verifying the content of those communications.

b. Findings

No violations were identified.

5. Order Condition B.2, HDI will conduct training to be given to security personnel at each

of HDIs nuclear sites. The training will emphasize:

(a) the importance of complete and accurate information,

(b) individual accountability; and

(c) reporting of the observation of non-compliances.

a. Inspection Scope

The inspectors evaluated completion of this condition by reviewing the content of the training and each sites training records indicating completion.

b. Findings

No violations were identified.

6. Order Condition C.1, HDI shall evaluate its implementation of the armorer function at

Oyster Creek. The evaluation shall include a comparison of HDIs weapons maintenance processes versus other nuclear sites and include at least one non-HDI nuclear site.

1 4

a. Inspection Scope

The inspectors evaluated completion of this condition by reviewing the HDI evaluation, the evaluations conclusions, and corrective action products generated from those conclusions.

b. Findings

No violations were identified.

7. Order Condition E.1, HDI shall install a Fleet Security Director and he shall report to the HDI President.

a. Inspection Scope

The inspectors evaluated completion of this condition by verifying that a Fleet Security Director had been installed, interviewing the Fleet Security Director, and verifying that he reports to the President of HDI.

b. Findings

No violations were identified.

Exit Meeting Summary

On November 8, 2022, the inspectors presented the inspection results to Mr. Jeffrey Dostal, Site Vice-President, and other members of the licensees staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

1 5 ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Gagnon, HDI Fleet Security Director

J. Dwyer, Manager Site Security

R. Newhardt, Lead Security Shift Supervisor

LIST OF ITEMS

OPEN, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

None

Closed

LER

05000219, 07200015/2022-001-00 INSPECTION PROCEDURES USED IP 92702, Follow-Up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders