IR 07200015/2024401

NRC Independent Spent Fuel Storage Installation Security Inspection Report No. 07200015/2024401

ML24296A067
Person / Time
Site:	Oyster Creek
Issue date:	10/30/2024
From:	Daniel Schroeder NRC Region 1
To:	Trice K Holtec Decommissioning International
References
IR 2024401
Download: ML24296A067 (1)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD, SUITE 102 KING OF PRUSSIA, PA 19406-1415

October 30, 2024

Docket No. 072000 15 License No. DPR-16

Kelly Trice President - HDI Holtec Decommissioning International, LLC Krishna P. Singh Technology Campus 1 Holtec Blvd.

Camden, NJ 08104

SUBJECT: OYSTER CREEK NUCLEAR GENERATING STATION - NRC INDEPENDENT SPENT FUEL STORAGE INSTALLATION SECURITY INSPECTION REPORT NO. 07200015/2024 401

Dear Kelly Tr i c e:

On October 16, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an Independent Spent Fuel Storage Installation (ISFSI) security inspection at the permanently shut down Oyster Creek Generating Station (Oyster Creek) in Forked River, New Jersey. The inspection covered your physical security plan and the October 16, 2002, Interim Compensatory Measures for Dry Independent Spent Fuel Storage Installations Order and was conducted using NRC Inspection Procedure 81311, Physical Security Requirements for Independent Spent Fuel Storage Installations.

Additionally, inspectors performed a 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 in accordance with NRC Inspection Procedure 92702, Follow -Up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders.

The enclosed inspection report documents the inspection results, which were discussed with Jeff Dostal, Site Vice President, and other members of your staff on October 16, 2024.

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 NRCs Rules of Practice, a copy of this letter and the enclosure will be made available electronically for public inspection in the K. Trice 2

NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRCs 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).

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

Enclosure:

1. Public Inspection Report No. 07200015/2024 401

REGION I==

INSPECTION REPORT

Docket No. 07200015

License No. DPR-16

Report No. 0720 0015/2024 401

Enterprise Identifier: I-2024-401- 0035

Licensee: Holtec Decommissioning International, LLC

Address: Forked River, NJ.

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

Inspection Date: October 15-16, 2024

Inspectors: Kenneth Hussar, 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 REPORT DETAILS

a. Inspection Scope

Inspection activities 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) 2690, Inspection Program for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations. 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. The inspection documented below met the objectives and requirements for completion of the IP.

The inspectors evaluated this area by reviewing the Independent Spent Fuel Storage Installation (ISFSI) security plan, implementing procedures, and records; conducted interviews with responsible security personnel and plant employees; and performed walk-downs of the ISFSI.

The inspectors: (1) reviewed the access authorization program for the ISFSI; (2) verified and assessed the licensees testing and maintenance program to assure the functionality and reliability of security equipment; and (3) verified that a rapid, capable response to safeguards contingency events had been appropriately developed and effectively implemented.

The inspectors conducted the following specific inspection activities and evaluated the program to determine if: (a) the access authorization program provided reasonable assurance that individuals granted unescorted access to the ISFSI Protected Area (PA)

were trustworthy and reliable and did not constitute an unreasonable risk to public health and safety; (b) procedures were in place to ensure that vehicles accessing the ISFSI PA had proper authorization and were properly searched; (c) keys, locks, combinations, and associated hardware used in the ISFSI PA were properly controlled; (d) the intrusion detection system (IDS) had the ability to detect and assess unauthorized penetration of the ISFSI PA and adequate response capability existed; (e) alarms for the ISFSI IDS annunciated at a continually staffed alarm station; (f) the ISFSI PA was illuminated to facilitate adequate assessment of PA penetration or unauthorized activity; (g) a program was in place for testing and maintenance of the physical protection systems associated with the ISFSI; (h) the spent fuel storage was within a PA and was protected by two barriers; (i) the vehicle barrier system satisfied the design vehicle bomb attack requirements; (j) communications had been established between onsite security forces and a designated response force or local L aw Enforcement Agency (LLEA); (k) a security organization with written procedures had been established; (l) members of the security organization were trained, equipped, qualified, and requalified to perform assigned duties; (m) the committed responders provided for an adequate armed response; (n) written response procedures were established and maintained; (o) training included ISFSI activities; (p) safeguards events were being properly reported; (q) audits of the physical protection system were conducted; (r) signs were posted in accordance

with requirements; (s) the licensee established an emergency plan; (t) the response force or LLEA had unimpeded access to the ISFSI PA during contingency events; and (u) staffing, procedures, and resources were adequate to protect against radiological sabotage.

b. Observations and Findings

The inspectors reviewed approximately eight condition reports, self and independent assessments, training records, access authorization records, weekly testing records, daily patrol records, and intrusion alarm system performance testing records.

Other Activities

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 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 Order Condition F. 2

Order Condition F.2: For a period of one year after the completion of the fourth quarterly review, the documented effectiveness reviews shall be made available to the NRC for review during an inspection. (The effectiveness reviews were required by Condition F.1.

NRCs reviews of previous effectiveness reviews are documented in inspection report 07200015/2023 401, dated May 16, 2023, ADAMS ACCESSION NUMBER:

(ML23128A119)

The inspectors assessed completion of Condition F.2 by reviewing the fourth quarterly effectiveness review and confirming the review team makeup complied with the order requirements.

This completes follow-up inspection activities for all items associated with NRC Order EA-21- 041.

c. Conclusions

No violations of more than minor security significance were identified.

Exit Meeting Summary

On October 16, 2024, the inspectors presented the inspection results to Jeff 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.

ATTACHMENT SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT

Licensee Personnel J. Dwyer, Manager Site Security M. Gilbert, Lead Security Shift Supervisor

LIST OF ITEMS OPEN, CLOSED, AND DISCUSSED

Opened None

Opened and Closed None

Closed None

INSPECTION PROCEDURES USED

I P 81311, Physical Security Requirements for Independent Spent Fuel Storage Installations I P 92702, Follow-Up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders

LIST OF DOCUMENTS REVIEWED

Procedures DPP-IO-SEC-001, Security Operations, Revision 1 DPP-IO-SEC-002, Security Training, Revision 0 DPP-OC-101-103, Observation and Inspection of Security Barriers, Revision 0 DPP-OC-101-106, Control and Classification of Safeguards Information (SGI) and Sensitive Unclassified Non-Safeguards Information (SUNSI) Revision 1 DPP-OC-101-112, Security Search Processes, Revision 3 DPP-OC-101-117, Processing and Escorting of Personnel and Vehicles, Revision 3 DPP-OC-101-120, Control of Security Access Control Devices, Revision 2 DPP-OC-101-122, Testing Security Equipment, Revision 3 DPP-OC-101-122-1001, Performance of Security Systems Tests, Revision 3 DPP-OC-101-124, Operation of the Security Control Centers, Revision 5 DPP-OC-1016, Oyster Creek Site-Specific Watch Standing Practices, Revision 1

Condition Reports 03445 03502 03508 03942 03960 03966 03998 04130

Miscellaneous Evaluation Report Organizational Effectiveness of the Oyster Creek Nuclear Security Department, dated January 22, 2024 Oyster Creek Nuclear Generating Station ISFSI Only Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, Revision 2 HDI Letter HDI-OC-21-002, Alternate Measures, 7/20/2021

LIST OF ACRONYMS USED

ADAMS Agencywide Documents and Access Management System CFR Code of Federal Regulations HDI Holtec Decommissioning International IP Inspection Procedure IR Inspection Report ISFSI Independent Spent Fuel Storage Installation LLEA Law Enforcement Agency NRC Nuclear Regulatory Commission PA Protected Area PA R S Publicly Available Records

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