IR 05000003/2023401

NRC Security Decommissioning Inspection Report Nos. 05000003/2023401, 05000247/2023401, and 05000286/2023401

ML23123A198
Person / Time
Site:	Indian Point
Issue date:	05/10/2023
From:	Daniel Schroeder Decommissioning, ISFSI, and Reactor Health Physics Branch
To:	Trice K Holtec Decommissioning International
References
IR 2023401
Download: ML23123A198 (1)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION I

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

May 10, 2023

Kelly Trice President HDI Holtec Decommissioning International, LLC Krishna P. Singh Technology Campus 1 Holtec Boulevard Camden, NJ 08104

SUBJECT: HOLTEC DECOMMISSIONING INTERNATIONAL, LLC, INDIAN POINT ENERGY CENTER UNITS 1, 2, AND 3 - NRC SECURITY DECOMMISSIONING INSPECTION REPORT NOS. 05000003/2023 401, 05000247/2023 401,

AND 05000286/2023 401

Dear Kelly Trice:

On April 19, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the permanently shut down Indian Point Nuclear Energy Center Units 1, 2, and 3. On-site inspection was performed April 17-19, 2023. The inspection examined activities conducted under your licenses as they relate to security and compliance with the NRCs rules and regulations and with the conditions of your licenses. The inspectors reviewed select procedures and records, observed activities, interviewed site personnel, and performed site walk-downs. The NRC inspectors discussed the results of this inspection with Richard Burroni, Site Vice President, and other members of your staff on April 19, 2023. The results of this inspection are documented in the enclosed report.

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 NRC s Rules of Practice, a copy of thi s letter will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Current NRC regulations and guidance are included on the NRCs website at www.nrc.gov ;

select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC s website at www.nrc.gov ; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under Related Information). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays). No reply to this letter is required. Please contact Ke n Hussar at 610- 337-5084 if you have any questions regarding this matter.

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

Docket Nos: 50- 003, 50-247, 50-286 License Nos: DPR-5, DPR-26, DPR-64

Enclosure:

Inspection Report Nos.: 05000003/2023 401, 05000247/2023 401, 05000286/2023 401

REGION I==

INSPECTION REPORT

Docket Nos. 05000003, 05000247, and 05000286

License Nos. DPR-5, DPR-26, and DPR-64

Report Nos. 05000003/2023 401, 05000247/2023 401, and 05000286/2023 401

Enterprise Identifier: I-2023-401- 0061

Licensee: Holtec Decommissioning International, LLC (HDI)

Facility: Indian Point Energy Center, Units 1, 2, and 3

Location: Buchanan, NY.

Inspection Dates: April 17-19, 2023

Inspectors: Ken Hussar, Senior Physical Security Inspector Tom Eck, Physical Security Inspector

Approved by: Daniel Schroeder, Chief Security, Emergency Preparedness and Incident Response Branch Division of Radiological Safety and Security

Enclosure EXECUTIVE

SUMMARY

Holtec Decommissioning International, LLC (HDI) Indian Point Energy Center Units 1, 2, and 3 NRC Inspection Report Nos. 05000003/2023 401,

05000247/2023 401, and 05000286/2023 401

This report covers an announced security decommissioning program core inspection of the physical protection program at the Indian Point Energy Center - Units 1, 2, and 3 performed April 17-19, 2023. The objective of the inspection was to determine if activities involving the physical protection program, associated with the samples inspected, provide assurance that the licensees program is designed and implemented in a manner that protects against the design basis threat (DBT) of radiological sabotage. The U.S. Nuclear Regulatory Commissions (NRCs) oversight of the security of a decommissioning nuclear power reactor is described in Inspection Procedure (IP) 81200, Security. Additionally, for reactors that have permanently shut down and entered decommissioning, violations of regulatory requirements are evaluated using the traditional enforcement process described in the NRCs Enforcement Policy. Under traditional enforcement, violations of more than minor significance are assigned a severity level (SL) ranging from I (most significant) to IV (least significant).

Based on the results of this inspection, no violations were identified.

REPORT DETAILS

Inspection Scope

Inspection activities were conducted using the appropriate portions of the IPs in effect at the beginning of the inspection unless otherwise noted.

At the time of this inspection, 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) 2202 Appendix A, Security Core Inspection Program.

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.

Access Control for Decommissioning Nuclear Power Reactors, IP 81200.02

a. Inspection Scope

The inspectors evaluated the access control program through completion of a minimum of 50% of the inspection requirements.

The inspectors conducted walk-downs of protected area portals, last access control, and building walls/ceilings/floors that were part of the protected area barrier, observed vehicle searches, personnel searches, and material searches, reviewed security key and core accountabilities, reviewed procedures for implementation of the two-man rule, alarm response, and access controls.

Access Control for Decommissioning Nuclear Power Reactors (1 Sample)

02.01 a - e, 02.02 a - g, i - k, 02.03 a - d, f, h, 02.04 a, b, 02.05

b. Observations and Findings

Inspectors reviewed the physical security plan, implementing procedures, and a representative sample of documentation and records associated with the access control program. The inspectors verified through the review of the licensees access control program that only those personnel, material, and vehicles that have been properly screened are granted access to the Protected Areas and Vital Areas.

c. Conclusions

The access control program at the Indian Point Energy Center, Units 1, 2, and 3, was in accordance with requirements, appropriately developed, and was being effectively implemented in a manner that protects against the DBT of radiological sabotage. No violations were identified.

2. Access Authorization for Decommissioning Nuclear Power Reactors, IP 81200.01

a. Inspection Scope

The inspectors evaluated the access authorization program through completion of a minimum of 50% of the inspection requirements. The inspectors reviewed acc ess authorization procedures, unescorted access personnel files, and interviewed access authorization personnel.

Access Authorization for Decommissioning Nuclear Power Reactors (1 Sample)

02.01 a - g, 02.02 a - l, 02.04 a - d, 02.06.

b. Observations and Findings

Inspectors reviewed the physical security plan, implementing procedures, and a representative sample of access authorization personnel files. The inspectors verified through the review of a sample of access authorization personnel files that the licensees access authorization program provides assurance for individuals gran ted unescorted access and maintains unescorted access, are trustworthy, reliable and do not constitute an unreasonable risk to public health and safety or the common defense and security.

c. Conclusions

The access authorization program at the Indian Point Energy Center, Units 1, 2, and 3, was in accordance with requirements, appropriately developed, and was being effectively implemented in a manner that protects against the DBT of radiological sabotage. No violations were identified.

Security Plan Changes for Decommissioning Nuclear Power Reactors, IP 81200.09

a. Inspection Scope

The inspectors evaluated the security plan changes through completion of the following inspection elements.

Security Plan Changes for Decommissioning Nuclear Power Reactors (1 Sample)

Since the last NRC inspection of this program area, Security Plan Revision 27 w as implemented based on Hotecs determination, in accordance with 10 CFR 50.54(p)(2),that the changes resulted in no decrease in safeguards effectiveness of the security plan, and that the revised security plan changes continue to meet the requirements of 10 CFR 73.55(b). The inspectors conducted a review of the security plan changes to evaluate for a potential decrease in safeguards effectiveness of the security plan.

However, this review does not constitute formal NRC approval of the changes.

Therefore, these changes remain subject to future NRC inspection in their entirety.

b. Observations and Findings

No violations were identified.

c. Conclusions

The Indian Point Energy Center security plan changes did not result in a non-compliance or violation of regulatory requirements, an adverse impact to the licensees ability to detect, assess, interdict, and neutralize an adversarial force to protect against the DBT of radiological sabotage, or a site-specific vulnerability.

Exit Meeting Summary

On April 19, 2023, the inspectors presented the inspection results to Richard Burroni, 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

Personnel

R. Burroni, Site Vice President

D. Gagnon, Holtec Fleet Security Director

J. Swart, IPEC Security Manager

LIST OF ITEMS OPEN, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

None

Closed

None

INSPECTION PROCEDURES USED

IP 81200.01, Access Authorization for Decommissioning Nuclear Power Reactors

IP 81200.02, Access Control for Decommissioning Nuclear Power Reactors

IP 81200.09, Security Plan Changes for Decommissioning Power Reactors