IR 05000298/2023403

Security Baseline Inspection Report 05000298/2023403

ML23123A443
Person / Time
Site:	Cooper
Issue date:	05/04/2023
From:	Ray Kellar NRC/RGN-IV/DRSS/PSB
To:	Dent J Nebraska Public Power District (NPPD)
References
IR 2023403
Download: ML23123A443 (9)

Text

May 04, 2023

SUBJECT:

COOPER NUCLEAR STATION - SECURITY BASELINE INSPECTION REPORT 05000298/2023403

Dear John Dent:

On April 27, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Cooper Nuclear Station 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 NRC-identified or self-revealing findings were identified during this inspection.

A licensee-identified violation which was determined to be of very low security significance is documented in this report. We are treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; the Director, Office of Nuclear Security and Incident Response; and the NRC Resident Inspector at Cooper Nuclear Station.

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 05/04/23 Ray L. Kellar, P.E., Chief Physical Security Branch Division of Radiological Safety & Security Docket No. 05000298 License No. DPR-46

Enclosure:

As stated

Inspection Report

Docket Number: 05000298 License Number: DPR-46 Report Number: 05000298/2023403 Enterprise Identifier: I-2023-403-0004 Licensee: Nebraska Public Power District Facility: Cooper Nuclear Station Location: Brownville, NE Inspection Dates: April 24, 2023 to April 27, 2023 Inspectors: C. Jewett, Sr. Physical Security Inspector T. Weir, Physical Security Inspector Approved By: Ray L. Kellar, P.E., Chief Physical Security Branch Division of Radiological Safety & Security Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a security baseline inspection at Cooper 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. A licensee-identified non-cited violation is documented in report section: 71130.0

List of Findings and Violations

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

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently 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) 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.

71130.01 - Access Authorization

The inspectors evaluated the access authorization program. The following elements were evaluated:

Access Authorization

(1) Tier I: All requirements Tier II: All requirements Tier III: All requirements

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: All requirements Tier III: All requirements

71130.09 - Security Plan Changes

The inspectors evaluated the security plan changes through completion of the following procedure elements:

Security Plan Changes (1 Partial)

(1) (Partial)

The opportunity to apply this procedure was not available in accordance with IMC 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 change in accordance with 10 CFR 50.54(p)(2) since the last performance of this IP and Physical Security Plan dated January 8,

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 02.17) (1 Sample)

(1) April 30, 2022 through April 27,

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71130.01 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: 10 CFR 26.69 (e)(1) states, in part, that if the individual is granted authorization by the same or another licensee, the licensee who grants authorization to the individual shall ensure that any follow-up testing requirements are met and that the individual complies with any treatment plan, with accountability assumed by the granting licensee.

Contrary to the above, from October 2022 to November 2022, the FFD program failed to ensure that any follow-up testing requirements are met and that the individual complies with any treatment plan, with accountability assumed by the granting licensee. Specifically, during the months of October and November 2022, there were four individuals that were placed into a follow-up program from other sites, and they were not placed into the CNS follow-up program.

Significance/Severity: Green. The inspectors assessed the significance of the finding using IMC 0609 Appendix E, Part I, Baseline Security SDP for Power Reactors. (U) The inspector determined that the cumulative total for the finding is one

(1) point. This was calculated by factoring the impact area (vital area) against Tier II, Element

71130.01 - 02.08c. Because the calculated point total did not exceed the range for a Green

determination (0 to 6 points), the inspector determined the finding to be of very low security significance.

Corrective Action References: CR-CNS-2023-02149

EXIT MEETINGS AND DEBRIEFS

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

On April 27, 2023, the inspectors presented the security baseline inspection results to John Dent and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71130.01 Corrective Action CR-CNS-2023- Condition Reports

Documents 00150, CR-CNS-

23-01076, CR-

CNS-2022-00847,

CR-CNS-2022-

05519, CR-CNS-

22-05999, CR-

CNS-2022-06754

71130.01 Corrective Action CR-CNS-2023- Condition Reports

Documents 02149, CR-CNS-

Resulting from 2023-02097

Inspection

71130.01 Procedures 0-CNS-13 Personnel Access Data System 27

71130.01 Procedures 1.1 Site Services Procedure Station Security 72

71130.01 Procedures 3.0 Access Authorization 21

71130.02 Corrective Action CR-CNS-2022- Condition Reports

Documents 03719, CR-CNS-

22-03752, CR-

CNS-2022-03911,

CR-CNS-2022-

05128, CR-CNS-

22-05607, CR-

CNS-2022-05999,

CR-CNS-2023-

01700

71130.02 Corrective Action CR-CNS-2023- Condition Reports

Documents 02119

Resulting from

Inspection

71130.02 Miscellaneous LO-2022-0102- Security Focused Self-Assessment Report 12/01/2022

2

71130.02 Miscellaneous QAD-2021-0008 QA Audit 21-01 "Security Program" 04/07/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

71130.02 Miscellaneous S-12 Perform Testing of Intrusion Detection Equipment and 13

Special Purpose Detectors

71130.02 Miscellaneous ST S-3 Control Personnel Access to Protected and Vital Areas NA

71130.02 Procedures SP 2.10 Local Law Enforcement Agency (LLEA) 17

71130.02 Procedures SP 2.11.2 Access Equipment Testing 36

71130.02 Procedures SP 2.11.4 Equipment Testing Doors 27

71130.02 Procedures SP 2.5 Personnel Access Control 63

71130.02 Procedures SP 2.6 Vehicle Entry/Exit 68

71130.02 Procedures SP 2.7 Material Entry/Exit 50

71130.02 Procedures SP 2.8 Access Control Devices 59

71130.02 Procedures SP 3.14 Non-Security Emergencies 22

71130.02 Procedures SP 3.15 Emergency Entry/Exit 15

71130.02 Procedures SSP 1.1 Station Security 72

71130.02 Procedures SSP 1.15 Visitor/Tour Station Access 62

71130.02 Procedures SSP 1.2 Protection of Unclassified Safeguards Information 49

71130.02 Procedures SSP 3.4 CNS Photo Badge Management 08

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