IR 07200020/2022401
| ML22108A303 | |
| Person / Time | |
|---|---|
| Site: | 07200020 |
| Issue date: | 04/21/2022 |
| From: | Ray Kellar NRC/RGN-IV/DRSS |
| To: | Flohr C US Dept of Energy (DOE) |
| References | |
| IR 2022401 | |
| Download: ML22108A303 (8) | |
Text
April 21, 2022
SUBJECT:
THREE MILE ISLAND UNIT-2 INDEPENDENT SPENT FUEL STORAGE INSTALLATION - INDEPENDENT SPENT FUEL STORAGE INSTALLATION SECURITY INSPECTION REPORT 07200020/2022401
Dear Ms. Flohr:
On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Idaho Operations Office and discussed the results of this inspection with you 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, Signed by Kellar, Ray on 04/21/22 Ray L. Kellar, P.E., Chief Physical Security Branch Division of Radiological Safety & Security Docket No.: 07200020 License No.: SNM-2508 Enclosure:
NRC Inspection Report 07200020/2022401
ML22108A303 X SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword By: RLK X Yes No X Non-Sensitive X Publicly Available NRC-002 OFFICE PSI:PSB C:PSB C:DIOR C:PSB NAME CJewett RKellar GWarnick RKellar SIGNATURE /RA/ /RA/ /RA/ /RA/
DATE 4/19/2022 4/19/2022 04/19/2022 04/21/2022
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 07200020 License Number: SNM-2508 Report Number: 07200020/2022401 Enterprise Identifier: I-2022-401-0018 Licensee: Department of Energy Facility: Idaho Operations Office Location: Idaho Falls, Idaho Inspection Dates: March 28, 2022, to March 31, 2022 Inspectors: C. Jewett, Physical Security Inspector Approved By: Ray L. Kellar, P.E., Chief Physical Security Branch Division of Radiological Safety & Security Enclosure
SUMMARY
This report covers a four-day period of an announced routine baseline inspection on security conducted by one physical security inspector from the NRCs Region IV office. There were no findings identified during this inspection.
This inspection consisted of a review and evaluation of the physical security program for the Three Mile Island - Unit 2 independent spent fuel storage installation licensed by the Department of Energy. The inspection consisted of observations of the independent spent fuel storage installation physical security related activities, interviews with personnel, and an examination of procedures and security records. The inspector used Inspection Procedure (IP) 81311 Physical Security Requirements for Independent Spent Fuel Storage Installations to conduct the inspection.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
REPORT DETAILS
IP 81311 Physical Security Requirements for Independent Spent Fuel Storage Installations (ISFSI)
Inspection Scope 02.02 Review of Specific License Requirements a. The inspector verified that spent nuclear fuel (SNF) and power reactor-related greater than class C waste is stored only within a protected area (PA) required by 10 CFR 73.51(b)(2)(i) and (10 CFR 73.51(d)(1).
b. The inspector verified that only individuals who are authorized to enter the PA are granted access to the PA required by 10 CFR 73.51(b)(2)(ii).
c. The inspector verified that the licensee is in compliance with site specific security orders (e.g., additional security measures) for access authorization and fingerprinting; also, that a log of authorized individuals is required pursuant to 10 CFR 73.51(d)(13)(i).
d. The inspector verified the licensee can detect and assess penetrations through the isolation zone required by 10 CFR 73.51(d)(3).
e. The inspector verified the licensee can provide timely communication to the designated response force whenever necessary required by 10 CFR 73.51(b)(2)(iv).
f. The inspector verified that the physical protection system is designed to protect against loss of control of the facility that could be sufficient to cause a radiation exposure exceeding the dose as described in 10 CFR 72.106(b) and 10 CFR 73.51(b)(3).
g. The inspector verified that the licensee has retained a copy of the physical protection plan for a period of 3 years or until termination of the license required by 10 CFR 73.51(c).
h. The inspector verified that the licensee complies with the provisions for physical protection systems, components, and procedures that meet the performance objectives of 10 CFR 73.51(b)(1), 10 CFR 73.51(b)(2), and 10 CFR 73.51(d).
i. The inspector verified the licensee provides illumination sufficient to permit adequate assessment of unauthorized penetrations of or activities within the PA required by 10 CFR 73.51(d)(2).
j. The inspector verified the licensees perimeter of the PA allows for continual surveillance and is protected by an active intrusion alarm system that is capable of detecting penetrations through the isolation zone; and that it is monitored in a continually staffed primary alarm station and in one additional continually staffed location required by 10 CFR 73.51(d)(3).
k. The inspector verified that the primary alarm station is located within the PA; that it has bullet-resisting walls, doors, ceiling and floor; that the interior of the station is not visible from outside the PA; that a timely means for assessment of alarms is provided regarding alarm monitoring; and that the redundant location provided a summary indication that an alarm has been generated required by 10 CFR 73.51(d)(3).
l. The inspector verified the licensees PA is monitored by daily random patrols pursuant to 10 CFR 73.51(d)(4); and a log of all patrols is required in accordance with 10 CFR 73.51(d)(13)(iii).
m. The inspector verified the licensees security organization has written procedures that provides for sufficient personnel per shift to ensure the monitoring of detection systems and the conduct of surveillance, assessment, access control, and communications to assure adequate response; that members of the security organization are trained, equipped, qualified, and requalified to perform assigned job duties in accordance with Appendix B to Part 73, sections I.A, (1)(a) and (b), B(1)(a), and the applicable portions of section II pursuant to 10 CFR 73.51(d)(5).
n. The inspector verified the licensee has a documented liaison with a designated response force or local law enforcement agency (LLEA) to permit a timely response to unauthorized penetration or activities required by 10 CFR 73.51(d)(6).
o. The inspector verified the licensee has a personnel identification system and a controlled lock system that limits access to only authorized individuals required by 10 CFR 73.51(d)(7).
p. The inspector verified the licensee has redundant communications capability between onsite security force members and designated response force or LLEA required by 10 CFR 73.51(d)(8).
q. The inspector verified that all individuals, vehicles, and hand-carried packages entering the PA are checked for proper authorization and visually searched for explosives before entry in accordance with 10 CFR 73.51(d)(9).
r. The inspector verified the licensees written response procedures have been established and maintained for addressing unauthorized penetration of, or activities within, the PA required by 10 CFR 73.51(d)(10).
s. The inspector verified that all the licensees detection systems and supporting subsystems include a tamper indicating system with line supervision; that the system, as well as surveillance/assessment and illumination systems, is maintained in an operable condition required by 10 CFR 73.51(d)(11).
t. The inspector verified the licensee protects safeguards information against unauthorized disclosure required by (10 CFR 73.21 and 10 CFR 73.22).
u. The inspector verified the licensees physical protection program is reviewed once every 24 months by individuals independent of both physical protection program management and personnel who have direct responsibility for implementation of the physical protection program; that the physical protection program review includes an evaluation of the effectiveness of the physical protection system and a verification of the liaison established with the designated response force or LLEA pursuant to 10 CFR 73.51(d)(12).
v. The inspector verified the licensee has retained the following documentation as a record for 3 years after the record is made or until termination of the license: a log of individuals granted access to the PA; screening records of members of the security organization; a log of all patrols; a record of each alarm received, identifying the type of alarm, location, date, and time when received, and disposition of the alarm; and the physical protection program review reports pursuant to 10 CFR 73.51(d)(13)(i)(ii)(iii)(iv)and (v).
w. The inspector verified in accordance with any applicable security requirements and/or security orders that the licensee has implemented measures and processes for vehicle control measures into protected areas.
x. The inspector verified in accordance with any applicable security requirements and/or security orders, that the licensee has implemented an insider mitigation program.
y. The inspector verified that the licensee has developed offsite response coordination with LLEA as applicable to physical security requirements and/or security orders.
INSPECTION RESULTS
No findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On March 31, 2022, the inspectors presented the security baseline inspection results to Connie Flohr, Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
81311 Corrective Action MITS-2021-039
Documents
Resulting from
Inspection
81311 Miscellaneous Personal Key Inventory 03/29/2022
81311 Miscellaneous CPP-1774 Unescorted Access Log 03/14/2022
81311 Miscellaneous QLTMISP2 TMI-2 SPO II Qualifications 03/29/2022
81311 Miscellaneous STI-NLF-SEC- TMI-2 Semi-Annual Lighting Assessment 12/15/2019
FRM-061
81311 Miscellaneous SU-7EESDUS Field Activity Report for Service Request 8852670 01/20/2022
81311 Miscellaneous ZOJTM001 TMI-2 On-The-Job Training Guide and Checklist 02
81311 Procedures 504 Patrol Order 2022-01
81311 Procedures 505/505A Post Orders 2021-01
81311 Procedures 512 Patrol Order 2021-01
81311 Procedures CPP-1674 Central Alarm Station 03/10/2022
81311 Procedures LWP-11301 INL Access Controls 18
81311 Procedures MCP-4663 TMI-2 INTEC Security 0
81311 Procedures MCP-519 INL Protective Force 45
81311 Procedures MCP-533 CAS/SAS Operation and Operator Responsibilities 24
81311 Procedures STI-NLF-SEC- TMI-2 ISFSI Physical Protection Plan 0
20
81311 Procedures STI-NLF-SEC- TMI-2 Perimeter Performance Testing 1
29
81311 Work Orders AR#2379 MFC Preventive Maintenance Justification for Work Control 07/16/2018
6