IR 05000461/2009403

NRC Security Baseline Inspection Report 05000461-09-403(DRS)

ML11174A125
Person / Time
Site:	Clinton
Issue date:	10/20/2009
From:	Eric Duncan Region 3 Branch 3
To:	Pardee C Exelon Nuclear
References
FOIA/PA-2011-0187 IR-09-403
Download: ML11174A125 (12)

Text

UNITED STATES NUCLEAR REGULATORYCOMMISSION REGION II1I'

ber 20, 2009

SUBJECT:

CLINTON POWER STATION NRC SECURITY BASELINE INSPECTION REPORT 05000461/2009403(DRS)

Dear Mr. Pardee:

On September 18, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed a security baseline inspection atLyou.w 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 September 18, 2009, 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 Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http:t/www.nrc.qov/readinq-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.

Enclo re cont ensitive Unclassified Non-Sa s Information. When separated fro trlo re, this transmittal document is decontrolled.

OFF 1iii US NL0 SE IY Ei ED FOiO

Eý ýIýOMýNý 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 05000461/2009403(DRS)

w/Attachment: Supplemental Information cc w/encl: S. Coker, NSIR/DSO/DDSO/ST C. Williamson, Clinton Station Security Manager J. Klinger, State Liaison Officer Illinois Emergency Management Agency cc w/o encl: Distribution via ListServ FICI U ONLY- EC ITY-R AT INF TIO

OF C JSýE L- ýCUR! - ýED FOýR AT N

SUMMARY OF FINDINGS

IR 05000461/2009403(DRS); 09/14/2009 - 09/18/2009, 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 four 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-ldentified and Self-Revealed Findings

Cornerstone: Physical Protection

No findings of significance were identified.

Licensee-Identified Violations

None.

OFFI ALSE L E0I1RE E N MA ION

I E L -SE "RITY- LA EDI FO M TI

REPORT DETAILS

SAFEGUARDS

Cornerstone: Physical Protection (PP)

S04 Equipment Performance, Testing, and Maintenance (71130.04)

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 andother applicable Commission 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 Design Basis Threat and other contingencies. The inspectors conducted the following specific inspection activities:

reviewed and evaluated licensee event reports, safeguards log entries, and corrective action documents dated between September 2008 to September 2009 (no licensee event reports were documented);verified the licensee developed appropriate testing and maintenance procedures; verified-for the perimeter intrusion detection system that the licensee ensured:

(a) alarm devices are tamper-indicating and self-checking;

(b) the system functioned as designed;

(c) required alarms annunciated and could be assessed;

(d) alarm station operators could recognize individuals in the detection zones;

(e) compensatory measures were established, when required;

(f) fields of view were effective; and

(g) lighting was being maintained; verified for the internal detection and assessment capabilities that:

(a) equipment was maintained and tested for functionality and reliability; -(b) the equipment was being properly tested; (c). neither the biometric readers or the card readers at the nF protected area access points allowed a user/ into the protected area V _(d) an alarm or notification was generated to /7 it' advise the alarm station operators that were attempted;.:and

(e) security force responded appropriately to an alarmVor notification;

• - Verified for the independent, redundant alarm stations that the licensee:

(a)-ensured failure of one station would not affect the other;

(b) maintained and tested all enunciator, assessment, surveillance, and communication systems;

(c) was not vulnerable to external manipulation;

(d) ensured that no single act could remove the capability from both alarm stations;

(e) provided all alarm

S oL I RMTI

FI6C L ýSE.

- SE UýRI -RE ýT IN RATI, stations withý_ that annunciate in at least the other alarm station; nr

(f) ensured operational activities does not interfere with the execution of alarm assessment and response;

(g) maintained continuous communications with each on-duty security force member and with local law enforcement authorities; and

(h) maintained continuous communication between the alarm stations; verified for security communication systems that the licensee:

(a) maintained each type;

(b) appropriately tested equipment; and

(c) provided independent power for non-portable equipment; verified for the weapons maintenance program that the licensee:

(a) maintained each weapon;

(b) test fired all weapons at the required periodicity;

(c) developed and maintains procedures; and

(d) documented activities associated with the program; verified for other security-related devices and equipment that the licensee:

(a) appropriately maintained and tested those devices and equipment;

(b) performed appropriate tests of access control equipment;

(c) performed testing in accordance with procedures; (d)*ensured that testing of at least one train of search equipment included the most challenging test procedure used by the licensee;

(e) established sensitivity settings on the equipment in accordance with the routine calibration/maintenance settings;

(f) maintained and tested vital area detection aids;

(g) tested all assessment aids, including night-vision, thermal or other devices;

(h) maintained and tested all personnel access control and personnel search equipment;

(i) maintained and tested all package and material search equipment;

(j) maintained and tested all vehicle search equipment;

(k) maintained and tested the security system emergency power supply; and (I) powered all alarm systems by an uninterruptible power source; verified for new security systems/equipment that the licensee:

(a) conducted pre-operational testing and evaluation prior to integration into the security program; and

(b) ensured the testing complied with design criteria and performance specifications (the licensee had not installed any new equipment or systems); and verified for physical barriers that the licensee:

(a) maintained the integrity of all its physical barriers including both the protected area and vital area along with the isolation zones;

(b) periodically monitored their condition; and

(c) located all vital equipment within a vital area.

The inspectors 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 program at an appropriate threshold, that adequate attention was being given to timely corrective action, and that adverse trends were identified and addressed.

The inspectors completed 46 of the required 46 samples.

b. Findin-is No findings of significance were identified.

S09 Owner-Controlled Area Controls (71130.09)

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 owner-controlled area (OCA) and vehicle checkpoint.

The inspectors verified that the licensee:

(1) implemented OCA controls in accordance with the NRC-approved security plan and other applicable regulatory requirements; and

(2) ensured that OCA controls provided reasonable protection against the Design Basis Threat.

The inspectors conducted the following inspection activities:

reviewed and evaluated licensee event reports, safeguards log entries and corrective action documents dated between September 2008 and September 2009 (no licensee event reports were documented);verified for OCA controls that the licensee:

(a) ensured personnel maintained communication with the alarm stations and validated OCA controls effectiveness through drills or exercises; and

(b) actions taken to implement their NRC-approved security plan did not impede the arrival of emergency response personnel or affect implementation of the emergency plan.

verified for the OCA check point that the licensee, in conformance with the measures specified in their NRC-approved security plan:

(a) effectively implemented procedures for controlling plant personnel, vendor, delivery, and visitor access;

(b) effectively implemented procedures and controls for channeling vehicles to access control points; and

(c) effectively implemented procedures for controlling vehicle entry through the vehicle check point.

verified for OCA patrols and surveillance that the licensee:

(a) effectively implemented procedures for surveillance activities;

(b) ensured personnel on patrol did not perform collateral duties that decreased the effectiveness of their surveillance activities; and

(c) effectively implemented applicable procedures for maritime coordination, river intake control, and surveillance; and verified for OCA barriers and equipment that the licensee, in conformance with the measures specified in their NRC-approved security plan:

(a) effectively implemented controls to limit the potential for unauthorized vehicles and equipment; and

(b) ensured the OCA patrols had the necessary weapons and equipment readily accessible.

F Cl USE -S CU AT DI TI "Mm

0*FI1 I EON E ý-S ýU -L LA ED N ýR The inspectors reviewed OCA controls-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 12 of the required 12 samples.

b. Findings

No findings of significance were identified.

40A6 Meetings Exit Meetincl The inspectors presented the inspection results to Mr. F. A. Kearney and other members of licensee management at the conclusion of the inspection on September 18, 2009.

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

C. Williamson, Security Manager

J. Waddell, Security Supervisor

D. Montgomery, Access Authorization

Nuclear Requlatory Commission

B. Kemker, Senior Resident Inspector

D. Lords, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed, and Discussed

None