ML15245A346

Review of Physical Security Plan, Revision 13

ML15245A346
Person / Time
Site:	Oyster Creek
Issue date:	09/15/2015
From:	John Lamb Plant Licensing Branch 1
To:	Bryan Hanson Exelon Nuclear
Lamb J, NRR/DORL/LPLI-2, 415-3100
References
Download: ML15245A346 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 15, 2015 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION -REVIEW OF PHYSICAL SECURITY PLAN, REVISION 13

Dear Mr. Hanson:

By letter dated June 30, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15190A354), Exelon Generation Company, LLC (Exelon or the licensee) submitted the Oyster Creek Nuclear Generating Station (OCNGS) Physical Security Plan (PSP), which also included the Training and Qualification Plan and Safeguards Contingency Plan, Revision 13, to the U.S. Nuclear Regulatory Commission (NRG) under the provisions of Title 10 of the Code of Federal Regulations (1 O CFR) Part 50, "Domestic Licensing of Production and Utilization Facilities," Section 50.54, "Conditions of licenses,"

paragraph (p)(2). The enclosure to the letter dated June 30, 2015, contains Safeguards Information that is protected under 10 CFR 73.21 and is withheld from public access pursuant to the requirements of 10 CFR 9.17.

By letter dated March 30, 2015 (ADAMS Accession No. ML14329A625), the NRG issued Amendment No. 285 to Renewed Facility Operating License No. DPR-16 for OCNGS in response to Exelon's application dated December 19, 2013 (ADAMS Accession No. ML13358A245), as supplemented by letters dated January 31, 2014, and November 3, 2014 (ADAMS Accession Nos. ML14035A264 and ML14309A615, respectively). Amendment No. 285 approved the proposed Security Plan changes to implement an "alternative measure" for satisfying applicable requirements of 10 CFR 73.55 related to controlling vital area access for certain portions of the reactor building at OCNGS. The letter dated June 30, 2015, implements an approved alternative measure as indicated in Amendment No. 285.

The NRG staff compared the changes made in the OCNGS PSP, Revision 13, against the previous Revision 12. Based on this review, the NRG staff identified additional clarification areas to be considered for future PSP changes per 10 CFR 50.54(p). These areas are clarifications and administrative changes in nature with regard to identification of security tasks and roles and responsibilities of operator and radiological protection staff to be included in the appropriate sections of the PSP.

On August 19, 2015, the NRG staff conducted a discussion with the licensee pertaining to inclusion of the above areas in future OCNGS PSP revisions.

B. Hanson A copy of the related NRG staff evaluation of the OGNGS PSP, Revision 13, is also enclosed.

The NRG staff did not identify any technical issues that warrant followup action at this time.

If you have questions, please contact me at 301-415-3100 or John.Lamb@nrc.gov .

. Lamb, Senior Project Manager Pia t icensing Branch 1-2 Div on of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-219

Enclosure:

NRG Staff Evaluation cc w/

Enclosure:

Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 STAFF EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR RENEWED FACILITY OPERATING LICENSE NO. DPR-16 REGARDING PHYSICAL SECURITY PLAN, REVISION 13 EXELON GENERATION COMPANY, LLC OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219

1.0 INTRODUCTION

By letter dated June 30, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15190A354), Exelon Generation Company, LLC (Exelon or the licensee) submitted the Oyster Creek Nuclear Generating Station (OCNGS) Physical Security Plan (PSP), which also included the Training and Qualification Plan (T&QP) and Safeguards Contingency Plan (SCP), Revision 13, to the U.S. Nuclear Regulatory Commission (NRC) under the provisions of Title 1O of the Code of Federal Regulations (10 CFR) Part 50, "Domestic Licensing of Production and Utilization Facilities," Section 50.54, "Conditions of License,"

paragraph (p)(2). The enclosure to the letter dated June 30, 2015, contains Safeguards Information that is protected under 10 CFR 73.21 and is withheld from public access pursuant to the requirements of 10 CFR 9.17.

By letter dated March 30, 2015 (ADAMS Accession No. ML14329A625), the NRC issued Amendment No. 285 to Renewed Facility Operating License No. DPR-16 for OCNGS in response to Exelon's application dated December 19, 2013 (ADAMS Accession No. ML13358A245), as supplemented by letters dated January 31, 2014, and November 3, 2014 (ADAMS Accession Nos. ML14035A264 and ML14309A615, respectively). Amendment No. 285 approved the proposed Security Plan changes to implement an "alternative measure" for satisfying applicable requirements of 10 CFR 73.55 related to controlling vital area access for certain portions of the reactor building at OCNGS. The letter dated June 30, 2015, implements an approved alternative measure as indicated in Amendment No. 285.

The NRC staff review of the licensee's PSP was conducted, consistent with the applicable requirements of 10 CFR Part 73, as well as the guidance contained within the Office of Nuclear Security and Incident Response (NSIR) Procedure UC 800, "Security Review Procedure for 10 CFR 50.54(p)(2)," and the NRC-endorsed Nuclear Energy Institute 03-12, Revision 7, template for security plans, as appropriate.

Enclosure

2.0 REGULATORY EVALUATION

Pursuant to 10 CFR 50.54(p)(2):

The licensee may make changes to the plans referenced in paragraph (p)(1) of this section, without prior Commission approval if the changes do not decrease the safeguards effectiveness of the plan. The.licensee shall maintain records of changes to the plans madewithout prior Commission approval for a period of ..

3 years from the date of the change, and shall submit, as specified in § 50.4 or

§ 52.3 of this chapter, a report containing a description of each change within 2 months after the change is made.

The NRC staff review consisted of determining whether the licensee appropriately implemented an NRG-approved alternative measure that meets the same performance objectives specified in 10 CFR 73.55(b) and that the implementation of these changes under 10 CFR 50.54(p) did not decrease the safeguards effectiveness of the Commission-approved PSP.

3.0 TECHNICAL EVALUATION

The NRC staff evaluated these changes consistent with the regulatory and technical basis for an alternative measure that was discussed in the NRC letter dated March 30, 2015. The NRC staff compared Exelon's proposed changes in the OCNGS PSP, Revision 13 to the proposed changes in Amendment No. 285. In addition, the NRC staff compared the changes made in the OCNGS PSP, Revision 13, against the previous Revision 12, and noted that OCNGS PSP, Revision 13, contained 11 changes for OCNGS as stated in the "Table of Changes for Security Plan Change Submittal" of the PSP.

The licensee implemented changes to the PSP T&QP and the SCP. Specifically, Exelon made changes to (1) the insider mitigation program; (2) security badges; (3) security measures related to the access of the Reactor Building (RB); (4) Owner Control Area (OCA) surveillance; (5) security tours in the RB; and (6) T&QP: protocols and personnel training.

As part of the review, the NRC staff identified additional areas to be considered for future OCNGS PSP revisions per 10 CFR 50.54(p). These areas are clarifications and administrative in nature with regard to identification of security tasks and roles and responsibilities of operators and radiological protection staff to be included in the appropriate section of the OCNGS PSP.

These areas do not impact the overall assessment of the NRC staff's finding of the proposed OCNGS PSP, Revision 13. On August 19, 2015, the NRC staff conducted a discussion with the licensee pertaining to inclusion of the above areas in future OCNGS PSP revisions.

Based on the NRC staff evaluation of the licensee's implementation of Amendment No. 285, the NRC staff finds that these changes are consistent with the NRC staff findings in Amendment No. 285.

4.0 CONCLUSION

The NRC staff determined that Exelon properly concluded that the reported changes to the OCNGS PSP, Revision 13, did not result in a decrease in safeguards effectiveness; the NRC staff recommends no further regulatory actions at this time. The effectiveness of the implementation of OCNGS PSP, Revision 13, is subject to future NRC review and inspection.

Principal Contributor: Meagan Parker, NSIR Date: September 15, 2015

B. Hanson A copy of the related NRC staff evaluation of the OCNGS PSP, Revision 13, is also enclosed.

The NRC staff did not identify any technical issues that warrant followup action at this time.

If you have questions, please contact me at 301-415-3100 or John.Lamb@nrc.gov.

Sincerely, IRA/

John G. Lamb, Senior Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-219

Enclosure:

NRC Staff Evaluation

cc w/

Enclosure:

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