IR 07200074/2021401

(CPNPP) Independent Spent Fuel Storage Installation (ISFSI) IR 07200074/2021401 3-3

ML21064A220
Person / Time
Site:	Comanche Peak
Issue date:	03/17/2021
From:	Ray Kellar Division of Reactor Safety IV
To:	Peters K Vistra Operations Company
References
IR 2021401
Download: ML21064A220 (7)

Text

March 17, 2021

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT - INDEPENDENT SPENT FUEL STORAGE INSTALLATION, PHYSICAL SECURITY REQUIREMENTS FOR INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS INSPECTION REPORT 07200074/2021401

Dear Mr. Peters:

On February 25, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Comanche Peak Nuclear Power Plant independent spent fuel storage facility.

The NRC inspector discussed the results of this inspection with Mr. T. McCool, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.

No violations of significance were noted and no response to this letter is required.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRC's Public Inspections, Exemptions, Requests for Withholding. a copy of this letter, its enclosure and your response, if you choose to provide one, will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS)

component of NRC's Agencywide Document 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). To the extent possible, your response, if you choose to provide one, should not include

KPeters 2 any security related, personal privacy, or proprietary information so that it can be made available to the public without redaction.

Sincerely, Ray L. Digitally signed by Ray L. Kellar Kellar Date: 2021.03.17 08:38:59 -05'00'

Ray L. Kellar, P.E., Chief Plant Support Branch 1 Division of Reactor Safety Docket No. 07200074

Enclosure:

As stated

Inspection Report

Docket Number: 07200074 License Number: NPF-87 and NPF-89 Report Number: 07200074/2021401 Enterprise Identifier: I-2021-401-0019 Licensee: Vistra Operations Company LLC Facility: Comanche Peak Nuclear Power Plant Location: Glen Rose, TX Inspection Dates: February 23 to February 25, 2021 Inspectors: D. Holman, Senior Physical Security Inspector Approved By: Ray L. Kellar, P.E., Chief Plant Support Branch 1 Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Baseline Security Inspection at the Fort Calhoun Station, in accordance with Inspection Procedure 81311, Physical Security Requirements for Independent Spent Fuel Storage Installations.

List of Violations No violations of more than minor significance were identified.

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 (PSP), and applicable 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.

81311 - Physical Security Requirements for Independent Spent Fuel Storage Installations 1. Inspection Scope The inspector verified the licensee protects the spent fuel against the design basis threat 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.

The inspector verified 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 spent fuel pool required by 10 CFR 73.55.

(10 CFR 72.212(b)(9)(i).

The inspector verified the storage of spent fuel is within a protected area, in accordance with 10 CFR 73.55(e). (10 CFR 72.212(b)(9)(ii).

The inspector verified at a minimum, personnel searches are performed by physical pat-down searches or by firearms and explosives detection equipment prior to admission to the protected area. (10 CFR73.55(h)(3)) and (10 CFR 72.212(b)(9)(iii).

The inspector verified that the protected area assessment capability provides for the assessment of detected activity at the protected area perimeter and the initiation of timely response. (10 CFR 72.212(b)(9)(iv) and 10 CFR 73.55(i)(3)).

The inspector verified the licensee protects safeguards information against unauthorized disclosure. (10 CFR 73.21 and 10 CFR 73.22).

INSPECTION RESULTS

No violations were identified.

EXIT MEETINGS AND DEBRIEFS

The inspector verified no proprietary information was retained or documented in this report.

On February 18, 2021, the inspector presented the security baseline inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

81311 Corrective Action IR 2021-001420, 2021-001421, 2021-001422

Documents

Resulting from

Inspection

Corrective Action TR 2021-001455, 2021-001466, 2021-001467, 2021-001470,

Documents 2021-001471

Resulting from

Inspection

Miscellaneous Entry Access List ISFSI Access List 2/09/2021

Validation List Monthly Vital Area Validation 11/11/2020

Validation List Monthly Vital Area Validation 12/08/2020

Validation List Monthly Vital Area Validation 01/07/2021

Form 8011-1 Escort Guidelines, Linked to SEC-302-3 R16 08/17

Form STA-902-1 Access Level Form, Linked to STA-902 Revision 13

NRC Order EA- ISFSI Order For Implementation of Additional Security 2004

04-187 Measures Associated With Access Authorization

Plan CPNPP Physical Security Plan, ISFSI Annex Revision 12

Procedures SEC 506 Security Equipment and Firearms Testing and Observation Revision 36

SI 3.2 Access Control Revision 65

SI 5.0 ISFSI Access Control Revision 7

SI 5.2 ISFSI Security Revision 6

STA-902 Access To CNPP Site Areas Revision 26