IR 05000220/2021402

Security Baseline Inspection Report 05000220/2021402 and 05000410/2021402

ML21165A076
Person / Time
Site:	Nine Mile Point
Issue date:	06/22/2021
From:	Fred Bower Decommissioning, ISFSI, and Reactor Health Physics Branch
To:	Rhoades D Exelon Generation Co
References
IR 2021402
Download: ML21165A076 (9)

Text

June 22, 2021

SUBJECT:

NINE MILE POINT NUCLEAR STATION - SECURITY BASELINE INSPECTION REPORT 05000220/2021402 AND 05000410/2021402

Dear Mr. Rhoades:

On June 3, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nine Mile Point Nuclear Station and discussed the results of this inspection with Mr. Adam Schuerman, Plant Manager, 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, Digitally signed by Fred L.

Bower Fred L. Bower Date: 2021.06.22 10:57:54 -04'00'

Fred L. Bower, III, Chief Security, Emergency Preparedness and Incident Response Branch Division of Radiological Safety and Security Docket Nos. 05000220 and 05000410 License Nos. DPR-63 and NPF-69

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000220 and 05000410 License Numbers: DPR-63 and NPF-69 Report Numbers: 05000220/2021402 and 05000410/2021402 Enterprise Identifier: I-2021-402-0038 Licensee: Exelon Generation Company, LLC Facility: Nine Mile Point Nuclear Station Location: Lycoming, NY Inspection Dates: May 24, 2021 to June 3, 2021 Inspectors: D. Caron, Senior Physical Security Inspector S. McCarver, Physical Security Inspector J. Rey, Physical Security Inspector M. Ordoyne, Physical Security Inspector (Training)

Approved By: Fred L. Bower, III, Chief Security, Emergency Preparedness and Incident Response Branch Division of Radiological Safety and Security Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a security baseline inspection at Nine Mile Point Nuclear Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Unless otherwise noted, baseline security inspections were conducted in accordance with the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2201, Security Inspection Program for Commercial Nuclear Power Reactors. 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. Publicly available IPs are located at:

http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), inspectors were directed to begin telework. In addition, regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.

In response to the COVID-19 Public Health Emergency declared on January 31, 2020, by the Secretary of the United States Department of Health and Human Services on the public health risks of the coronavirus, Nine Mile Point Nuclear Station pursued an exemption to security officer training and requalification requirements (ML20218A860). In addition to these exemptions, licensees implemented additional actions or alternatives allowed in response to health concerns within existing regulatory guidance available in RG 5.75 to ensure annual Force on Force exercises were conducted as safely as possible while maintaining the requirements to simulate as closely as practicable site specific conditions and minimizing the number and effects of artificialities associated with these exercises (Part 73, Appendix B, VI.C.3)

71130.02 - Access Control

The inspectors evaluated the access control program through completion of the following

inspection elements: Access Control

(1)

• Tier I: All Requirements

• Tier II: 12 Requirements (02.06 a - d, 02.07 a, 02.08 a, b, d, e, f, g, i)

• Tier III: 1 Requirement (02.09)

71130.05 - Protective Strategy Evaluation

The inspectors evaluated the licensee's protective strategy through completion of the following

procedure elements: Protective Strategy Evaluation

(1)

• Tier I: All Requirements

• Tier II: 14 Requirements (02.05 a, 02.06 a, b, d - m, 02.07 a)

• Tier III: 4 Requirements (02.08, 02.09 a, 02.10 a, 02.11 a)

(2)

• The inspectors evaluated the Security Performance Evaluation Program.

71130.09 - Security Plan Changes

The inspectors evaluated the security plan changes through completion of the following

procedure elements: Review Security Plan Changes (IP Section 02.01)

(1) The opportunity to apply this procedure was not available in accordance with Inspection Manual Chapter 0306. This sample was not available because the licensee did not conduct the activity covered by this IP. Specifically, the licensee has not initiated a physical security plan (PSP) change in accordance with Title 10 of the Code of Federal Regulations 10 CFR 50.54(p)(2) since the last performance of this IP and PSP Revision 13 remains current.

71130.14 - Review of Power Reactor Target Sets

The inspectors evaluated the Security Target Set Program. The following elements were evaluated:

Review of Power Reactor Target Sets

(1) 02.02 (a-d, f), 02.03, 02.04 (a-b),

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

PP01: Protected Area Security Equipment Performance Index Sample (IP Section 03.17)

=

(1) January 1, 2020 through April 30,

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

• On June 3, 2021, the inspectors presented the security baseline inspection results to Mr. Adam Schuerman, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71130.02 Corrective Action AR 04412779

Documents AR04410091 AR

04380683 AR

04379886 AR

04371532

Corrective Action AR 04425399 IR

Documents 04426957

Resulting from

Inspection

Procedures SY-AA-101-106 Control and Classification of Safeguards Information (SGI) Revision 21

and Sensitive Unclassified Non-Safeguards Information

(SUNSI)

SY-AA-101-112- Protected Area Search Processes Revision 4

1004

SY-AA-101-120 Control of Security Access Control Devices Revision 9

SY-NM-101-115- Nine Mile Point Gate Controls Revision 4

1001

71130.05 Calculations Calc No. Cooling Tower Culverts - Increase in Delay Time Revision 1

CNSNM069-002

Calc No. NMP- Nine Mile Point Security Building West Analysis Revision 1

7717012-S01

Calc No. NMP- Nine Mile Point Blast Analysis Update Revision 1

7717012-S02

Calc No. NMP- Nine Mile Point Nuclear Facility - NMP Blast Analysis Revision 0

KC-S00 Summary and Diagram

Calc No. NMP- Nine Mile Point Nuclear Facility - NMP Unit 1 Minimum Safe Revision 0

KC-S01 Standoff Distance Analysis

Miscellaneous NOSA-NMP-20- Security Program Audit Report February 6,

2020

NOSA-NMP-21- Security Program Audit Report February 10,

2021

Procedures NS-843A NMP Adversary and Responder Timelines

Inspection Type Designation Description or Title Revision or

Procedure Date

SY-AA-150-1007 Exelon Nuclear Security Adversary Force Revision 2

SY-AA-150-102 Security Drills and Exercises Revision 0

SY-NM-101-501 NMP Security Defensive Strategy Revision 9

71130.14 Corrective Action AR 04165141

Documents AR 04248972

AR 04369501

Procedures SY-AA-500-127 Safety/Security Interface Revision 7

SY-NM-101-116- Nine Mile Point Patrols and Surveillances Revision 9

1001

SY-NM-101-502 NMP Security Target Set Procedure Revision 0

7