IR 07200041/2024401
| ML24228A266 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/16/2024 |
| From: | Christopher Jewett NRC/RGN-IV/DRSS/PSB |
| To: | Bailly F Southern California Edison Co |
| Jewett C | |
| References | |
| IR 2024401 | |
| Download: ML24228A266 (12) | |
Text
August 16, 2024
SUBJECT:
SAN ONOFE NUCLEAR GENERATING STATION - SECURITY BASELINE INSPECTION REPORT 07200041/2024401
Dear Frederic Bailly:
On July 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at San Onofre Nuclear Generating Station and discussed the results of this inspection with you 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, Christopher A. Jewett, Acting Branch Chief Physical Security Branch Division of Radiological Safety & Security Signed by Jewett, Christopher on 08/16/24 Docket Nos. 05000361; 05000362; 07200041 License Nos. NPF-10; NPF-15
Enclosure:
As stated
Inspection Report
Docket Nos. 05000361; 05000362; 07200041
Report Nos 07200041/2024401
Enterprise Identifier: I-2024-401-0019
Licensee: Southern California Edison
Facility: San Onofre Nuclear Generating Station
Location: San Clemente, CA
Inspection Dates: July 29, 2024 to July 31, 2024
Inspectors: T. Weir, Physical Security Inspector
Approved By: Christopher A. Jewett, Acting Branch Chief Physical Security Branch Division of Radiological Safety & Security
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a security baseline inspection at San Onofre Nuclear Generating Station, in accordance with the Inspection Procedure 81311, Physical Security Requirements for Independent Spent Fuel Storage Installations.
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 Inspection Procedure 81311, Physical Security Requirements for Independent Spent Fuel Storage Installations, and review of general license requirements contained in 72.212(b), the approved physical security plan, and applicable independent spent fuel storage installation (ISFSI) security orders. 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.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
81311 - Physical Security Requirements for Independent Spent Fuel Storage Installations
- (1) Inspection Scope
02.01 General License Requirements and Guidance.
a. Verify the licensee protects the spent fuel against the DBT of radiological sabotage in accordance with the provisions and requirements as are set forth in the licensees physical security plan pursuant to 10 CFR 73.55 and the conditions and exemptions under the provisions of 10 CFR 72.212(b)(9) and any site-specific security orders.
b. Verify the licensees ISFSI physical protection measures do not decrease the effectiveness of the physical protection program for the protection of vital equipment associated with the reactor and SFP required by 10 CFR 73.55. (10 CFR 72.212(b)(9)(i))
c. Verify the storage of SNF is within a PA, in accordance with 10 CFR 73.55(e), but need not be within a separate VA. Existing PAs may be expanded, or new PAs added for the purpose of storage of spent fuel in accordance with the general license.
02.02 Search Activities (Personnel, Materials, and Vehicles)
a. Verify the licensee has established measures to observe all vehicle search functions (OCA and PA) in a manner that enables the initiation of a response. (10 CFR 73.55(g)(1)(ii)(C))
b. Verify the licensee subjects all personnel, materials, and vehicles to search prior to granting access to the PA and that the search is conducted in accordance with the regulations, licensee security plans, and implementing procedures. (10 CFR 73.55(h)(3))
c. Verify at a minimum, personnel searches are performed by physical pat-down searches or by firearms and explosives detection equipment prior to admission to the PA. (10 CFR 73.55(h)(3)) and (10 CFR 72.212(b)(9)(iii))
d. Verify the licensees security measures for excepting materials from the search process includes the clear identification, positive control, storage, and verification of materials in accordance with the regulation, licensee security plans, and implementing procedures. (10 CFR 73.55(h)(3)(v) and 10 CFR 73.55(h)(3)(vi))
e. Verify the licensees security measures for excepting bulk materials from the search process include providing an armed escort for the excepted material when entering the PA area and that the bulk materials are not, to the extent practicable, offloaded adjacent to a VA (if applicable). (10 CFR 73.55(h)(3)(vii) and 10 CFR 73.55(h)(3)(viii))
f. Verify the licensee implements access denial actions for attempted or suspected introduction of firearms, explosives, and incendiary devices or other items which could be used to commit radiological sabotage in accordance with their security plans and implementing procedures. (10 CFR 73.55(h)(3)(iii))
g. Verify the licensee has established and implements measures to:
- (1) ensure that all vehicles in the PA are used for plant functions or emergencies;
- (2) are operated by personnel with unescorted access to the PA or are escorted in accordance with 10 CFR 73.55(g)(8);
- (3) have keys removed or are otherwise disabled when not in use.
h. Verify the licensee has established and implements measures to assign armed escorts (armed member of the security organization) to vehicles transporting hazardous materials in the PA. (10 CFR 73.55(g)(3)(iv))
02.03 Access Control Points and Access Controls.
a. Verify the licensee has established and implements measures to control keys, locks, combinations, passwords, and related access control devices used to control access to the PA and security systems. (10 CFR 73.55(g)(6)(i))
b. Verify the licensee controls access at each access control point (designed and in use for authorized access) where personnel, materials and vehicles can be brought into the PA in accordance with regulations, licensee security plans and implementing procedures. (10 CFR 73.55(g)(1))
c. Verify the licensee issues access control devices only to individuals who have unescorted access authorization and require access to perform official duties and responsibilities. (10 CFR 73.55(g)(6)(i)(A))
d. Verify the licensee maintains a record of all personnel to whom access control devices have been issued and implements a process to account for access control devices at least annually. (10 CFR 73.55(g)(6)(i)(B))
e. Verify the licensee has established measures to retrieve, change, rotate, deactivate, or otherwise disable access control devices that may have been compromised or when a person with access to access control devices has been terminated under less than favorable conditions. (10 CFR 73.55(g)(6)(i)(D))
f. Verify the licensee has implemented a numbered photo identification badge system for all personnel who are authorized unescorted access to the PA. (10 CFR 73.55(g)(6)(ii))
g. Verify that personnel granted escorted access to the PA have their identity confirmed through physical presentation of a recognized identification card (local, state, federal government issued) that includes a photo or the physical characteristics of the individual; are badged to indicate that an escort is required; register his or her name, date, time, purpose of visit, employment affiliation, citizenship, and name of the individual to be visited before being escorted into the PA; and that the licensee maintains records of the escorted access retained for 3 years. (10 CFR 73.55(g)(7)(i)and 10 CFR 73.55(q)(2))
h. Verify that neither the access control equipment (i.e., card reading devices, biometric devices, etc.), nor the access control measures at the PA personnel access control points allow an individual to enter or re-enter the PA without being identified, authorized, and searched prior to entry or re-entry. (10 CFR 73.55(g))
i. Verify the licensee provides an escort to all visitors at all times while inside the PA.
j. Verify the licensees visitor to escort ratios for the PA are implemented as described in its security plans. (10 CFR 73.55(g)(8)(v))
k. Verify the licensee has established access control portals (personnel, material, and vehicle) outside of, or concurrent with, the physical barrier system (OCA and PA)through which it controls access. (10 CFR 73.55(g)(1)(i)(A))
l. Verify the licensee has equipped access control portals with locking devices, intrusion detection equipment, and surveillance equipment consistent with the intended function. (10 CFR 73.55(g)(1)(i)(B))
m. Verify the licensee implements and maintains measures, as necessary, to protect the badging process. (10 CFR 73.55(g)(1)(i)(C))
02.04 Controlling Access to Information.
Verify the licensee, certificate holder, or applicant has established, implemented, and maintains an information protection system that includes the applicable measures for SGI as specified in 10 CFR 73.22 and subsequently published NRC Orders. (10 CFR 73.21(a)(1)(i) and 10 CFR 73.21(b)(2))
02.05 Security Equipment
a. Verify the licensee has developed testing and maintenance procedures for all security equipment identified as a component of the licensees physical protection program and protective strategy in accordance with the security plans and implementing procedures. (10 CFR 73.55(c)(7) and 10 CFR 73.55(n))
b. Verify the perimeter intrusion detection system (IDS) and assessment equipment the licensee employs in support of its physical protection program and protective strategy is being maintained in accordance with the licensees maintenance procedures to ensure operability and reliability. (10 CFR 73.55(n)(1))
c. Verify, through observation of testing activities, that the licensees IDS detects attempted or actual penetration of the PA perimeter barrier before completed penetration and is tested in accordance with regulations and the licensees testing procedures. (10 CFR 73.55(e)(7)(i)(B), 10 CFR 73.55(i) and 10 CFR 73.55(n))
d. Verify through observation of testing activities, that alarm devices are tamper-indicating and self-checking, including transmission lines to their respective annunciators and junction boxes and that these tests are conducted in accordance with regulations and licensee testing procedures. (10 CFR 73.55(i)(3)(iv) and 10 CFR73.55(n))
e. Verify that PA assessment capability provides for the assessment of detected activity at the PA perimeter and the initiation of timely response. (10 CFR 72.212(b)(9)(iv) and 10 CFR 73.55(i)(3))
f. Verify through observation of testing activities, that video assessment assets at the PA perimeter provide a visual display from which assessment can be made and provide real-time and play-back recorded video images of detected activities before and after each alarm annunciation and that these devices are tested in accordance with regulations and the licensees testing procedures. (10 CFR 73.55(e)(7)(i)(C), 10 CFR 73.55(i)(3)(ii), and 10 CFR 73.55(n))
g. Verify through observation of testing activities or through testing and maintenance record review that the intrusion detection system provides an automatic indication when the alarm system or a component of the system fails or when the system is operating on back-up power and that testing of this function is conducted in accordance with regulations and the licensee testing procedures. (10 CFR 73.55(i)(3)(v) and 10 CFR 73.55(n))
h. Verify (as applicable) that where building walls or roofs comprise a portion of the PA perimeter barrier where the licensee has not established an isolation zone, that the licensee has implemented detection and assessment methodologies and physical barriers that meet the requirements of 10 CFR 73.55 and that this area is described in the security plans. (10 CFR 73.55(e)(8)(iv))
i. Verify that internal detection and assessment equipment the licensee employs in support of its physical protection program and protective strategy is being maintained in accordance with the licensee maintenance procedures to ensure operability and reliability. (10 CFR 73.55(n)(1))
j. Verify that alarm station console equipment the licensee employs in support of its physical protection program and protective strategy is being maintained in accordance with the licensee maintenance procedures to ensure operability and reliability. (10 CFR 73.55(n)(1))
k. Verify there are no activities performed within the alarm stations which would interfere with the alarm station operators ability to execute the detection and assessment of alarms, the initiation and coordination of an adequate response to alarms, the summoning of off-site assistance, and their ability to provide command and control. (10 CFR 73.55(i)(4)(ii)(C))
l. Verify the following configuration requirements for the CAS:
- (1) is located inside a PA;
- (2) interior must not be visible from the PA perimeter; and
- (3) is constructed to be bullet resisting;
- (4) is designated as a VA (as appropriate) (10 CFR 73.55(e)(5), 10 CFR 73.55(e)(9), and 10 CFR 73.55(i)(4)(ii)(A))
m. Verify through observation of testing activities, that CAS maintains continuous communication capabilities with each on-duty security force member and that the testing of this function is conducted in accordance with regulations and licensee testing procedures. (10 CFR 73.55(j)(3), 10 CFR 73.55(j)(4) and 10 CFR 73.55(n)(4))
n. Verify the licensee has a process in place to maintain the integrity of all of its physical barriers, including OCA and PA barriers. (10 CFR 73.55(i)(5)(ii), (iv), and 10 CFR 73.55(n)(1))
o. Verify the operation of active vehicle barrier systems (AVBS) are periodically checked through testing in accordance with licensee testing procedures. (10 CFR 73.55(e)(10)(i)(B) and 10 CFR 73.55(n)(1))
p. Verify through the observation of testing activities, that isolation zones are designed and of sufficient size to permit observation and assessment of activities on either side of the PA barrier. (10 CFR 73.55(e)(7))
q. Verify the licensees testing and evaluation procedures are consistent with the manufacturers design characteristics, performance specifications, and testing recommendations to ensure the equipment is being tested and evaluated to meet acceptance criteria. (10 CFR 73.55(n)(1)(ii))
r. Verify that illumination within the isolation zones and external areas of the PA is being maintained and/or augmented by low-light technology in accordance with regulatory requirements to support assessment and response activities and that this equipment is tested in accordance with regulations and licensee testing procedures.
(10 CFR 73.55(i)(6) and 10 CFR 73.55(n))
s. Verify that a record of all alarm annunciations is maintained which includes the cause of the alarm and the final disposition of the alarm as determined by the licensees security force. (10 CFR 73.55(i)(4)(ii)(H))
t. Verify the compensatory measures that the licensee is implementing to compensate for degraded or inoperable equipment, systems, and components meet all regulatory requirements. (10 CFR 73.55(o))
02.06 Local Law Enforcement Agency (LLEA)
a. Verify the licensee has a documented agreement with applicable LLEA to include estimated response times and capabilities. (10 CFR 73.55(k)(9))
02.07 Weapons Maintenance
a. Verify (if applicable) that the licensee has established and implements measures for the control and accountability of all assigned firearms and ammunition.
b. Verify (if applicable) that the licensee documents activities associated with its firearms maintenance program.
02.08 Reviews
a. Events and Logs. Review and evaluate licensee event reports and safeguards log entries for the previous 12 months, or since the last inspection. (10 CFR 73.55(b)(10)and 10 CFR 73.71)
b. Security Program Reviews. Verify that the licensee is conducting security program reviews in accordance with 10 CFR 73.55(m).
c. Identification and Resolution of Problems. Verify that the licensee is identifying issues related to the security program at an appropriate threshold and entering them in the corrective action program. Verify that the licensee has appropriately resolved the issues regarding regulatory requirements for a selected sample of problems associated with the security program. (10 CFR 73.55(b)(10))
INSPECTION RESULTS
No findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 31, 2024, the inspectors presented the security baseline inspection results to Frederic Bailly and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
81311 Corrective Action 0122-83481
Documents 0322-88461
23-11998
24-39748
23-84475
22-48480
23-94205
24-23952
21-86662
21-50063
22-31170
Corrective Action 0724-41447
Documents 0724-58367
Resulting from
Inspection
Miscellaneous Licensing Physical Security Plan/Safeguards Contingency Revision 4
Document Plan/Training and Qualification Plan
SEL Security Events Log 10/27/2021 -
06/24/2024
Procedures SEC-11 Access Control Device Program Revision-11
EC 1
SEC-12 ISFSI SECURITY TEST AND INSPECTION PROGRAM Revision 8
SEC-15 Notifications, Reporting and Loggable Events Revision 10
SEC-17 Safety/Security Interface Program Revision 2
SEC-2 Alarm Station Operations and Alarm Management Revision 6
SEC-3 Security Communications Systems Revision 6
SEC-4 SEARCHES (VEHICLES, PERSONNEL, AND MATERIAL) Revision 7
ESCORT AND PROTECTED AREA ACCESS
SEC-5 Security Patrols, Inspections, and Surveillances Revision 1
9