IR 05000237/2023402

Security Baseline Inspection Report 05000237/2023402 and 05000249/2023402

ML23241A853
Person / Time
Site:	Dresden
Issue date:	08/29/2023
From:	Steven Orth NRC/RGN-III
To:	Rhoades D Constellation Energy Generation
References
IR 2023402
Download: ML23241A853 (1)

Text

SUBJECT:

DRESDEN STATION - SECURITY BASELINE INSPECTION REPORT 05000237/2023402 AND 05000249/2023402

Dear David Rhoades:

On July 21, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Dresden Station and discussed the results of this inspection with Carolyne Joseph, 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, Steven K. Orth, Chief Security, Emergency Preparedness, and Incident Response Branch Division of Radiological Safety and Security Docket Nos. 05000237 and 05000249 License Nos. DPR-19 and DPR-25

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000237 and 05000249

License Numbers: DPR-19 and DPR-25

Report Numbers: 05000237/2023402 and 05000249/2023402

Licensee: Constellation Energy Generation, LLC

Facility: Dresden Station

Location: Morris, Illinois

Inspection Dates: January 17, 2023 to July 21, 2023

Inspectors: A. Anderson, Physical Security Inspector G. Bonano, Physical Security Inspector K. Maloney, Physical Security Inspector

Approved By: Steven K. Orth, 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 Dresden 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

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.

71130.02 - 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: 02.06 a - d; 02.07 a; 02.08 a, b, f, i Tier III: 02.09

71130.04 - Equipment Performance, Testing, and Maintenance

The inspectors evaluated the security equipment testing and maintenance program through completion of the following inspection elements:

Equipment Performance, Testing, and Maintenance (1 Sample)

(1) Tier I: All requirements Tier II: 02.09 a; 02.10 a; 02.11 d; 02.13 a Tier III: 02.14; 02.15 b, c

71130.05 - Protective Strategy Evaluation

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

Protective Strategy Evaluation (2 Samples)

(1) Tier I: All Requirements Tier II: 02.05 a; 02.06 a, d, f, j - n; 02.07 a - e Tier III: 02.08; 02.09 a, b; 02.11 a

(2) Observed annual Force on Force drill conducted on 04/04/2023

71130.07 - Security Training

The inspectors evaluated the security training program through completion of the following

===procedure elements:

Security Training===

(1) Tier I: All Requirements Tier II: 02.05 b - d; 02.06 a; 02.07 a; 02.08 a; 02.09 b Tier III: 02.10; 02.11 a; 02.12 b; 02.13 a - b

71130.08 - Fitness for Duty Program

The inspectors evaluated the fitness for duty program by completing the following inspection elements (onsite and at licensee corporate office):

Fitness For Duty Program (1 Sample)

(1) Tier I: All Requirements Tier II: 02.05 a - e, i - k; 02.06 a - g; 02.07 a - e; 02.08 a, b; 02.09 a - e Tier III: 02.10; 02.11 a; 02.12 a; 02.13 a - c

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 to the Dresden Nuclear Power Station Security Plan, Training and Qualification Plan, Safeguard Contingency Plan and Spent Fuel Storage Installation Security Plan, in accordance with 10 CFR 50.54(p)(2) since the last performance of this IP.

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) Performance indicator data, April 1, 2022 through March 1,

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

On July 21, 2023, the inspectors presented the security baseline inspection results to Carolyne Joseph, Plant Manager, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71130.02 Procedures SY-AA-101-112 Exelon Security Search Processes 5

SY-AA-101-112-Ion Scanning Explosives Detector (ISED) Search Processes 4

1003

SY-AA-101-112-Protected Area Search Processes 5

1004

SY-AA-101-112-Owner Controlled Area Inspection Processes 4

1005

SY-AA-101-116 Conducting Patrols 18

SY-AA-101-117 Processing and Escorting of Personnel and Vehicles 34

SY-AA-101-120 Control of Security Access Control Devices 10

71130.04 Miscellaneous Security Event Reports 01/01/2023

through

07/01/2023

Security Diesel Surveillance Tests 05/01/2020

through

04/01/2023

Zone Alarm History Reports 01/01/2021

through

04/01/2023

Illumination Test Logs 02/03/2023

Gas Mask Inspection Logs 01/01/2021

through

2/31/2022

Ballistic Vest Inspection Logs 01/01/2021

through

2/31/2022

UPS Vendor Galaxy 3500 Operation 04/01/2016

Manual

Procedures SY-AA-101-122 Testing Security Equipment 23

SY-AA-101-122-Performance of Perimeter Intrusion Detection Camera 0

101 System Tests

SY-AA-150-103 Firearms Maintenance, Testing and Accountability 2

Inspection Type Designation Description or Title Revision or

Procedure Date

SY-AA-500-127 Safety - Security Interface 7

SY-DR-101-103 Weekly Security Barrier Inspections 0

SY-DR-101-122 Dresden Site Specific Testing 0

SY-DR-101-122-Dresden Specific Early Warning Detection System Tests 0

2

SY-DR-101-122-Dresden Specific Access Control Device and Portal Tests 1

103

71130.05 Corrective Action NRC Force-on-Force IRs 04/01/2022

Documents through

04/03/2023

Miscellaneous Force-On-Force 2023 Management Critique Powerpoint Brief

Procedures Force-On-Force 2023 04/06/2023

PI-AA-126-1001-NRC 71130.05, Protective Strategy Evaluation and 02/14/2023

F-01; AR Performance Evaluation Program

04554232

SY-AA-101-133 Integrated Response Plan with Off-Site Response Agencies 18

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

SY-AA-500-127 Safety/Security Interface 07

Self-Assessments AR 04519006 Security NOSA 2023 Audit 02/20/2023

71130.07 Miscellaneous Physical Fitness Test Administrator Certifications for 2023

1108-PP Use of Force Continuum Lesson Plan 05

2102-PP Response Team Member Lesson Plan 04

2104-PP Timelines

2109-PP Insider Mitigation 03

IQT 27N Course Scoresheets for Day, Night and Thermal Rifle 04

Qualification Courses of Fire

Procedures SY-AA-150-101 Exelon Nuclear Security Training 03

WC-AA-101-106 Work Screening and Processing 20

71130.08 Procedures LS-AA-119 Fatigue Management and Work Hour Limits 16

SY-AA-102 Exelon Generation Fitness for Duty Program 22

SY-AA-102-202 Testing for Cause 21

SY-AA-102-204 Random Selection and Notification Process 14

SY-AA-102-222 Handling and Storage of Fitness for Duty Records 13

Inspection Type Designation Description or Title Revision or

Procedure Date

SY-AA-102-230 Work Performance Investigation 5

SY-AA-102-230 Designated Collection Facility 9

SY-AA-102-245-Operators Manual RBT IV 2

1001

SY-AA-102-252 Fitness for Duty Training and Qualification Requirements 5

SY-AA-103-507 Review Criteria for Determining Trustworthiness and 9

Reliability

SY-AA-103-511 Access Authorization In-Processing/Out-Processing of 26

Personnel

SY-AA-103-514 Site Authorization for Unescorted Access 23

71130.09 Miscellaneous Dresden Nuclear Power Station Security Plan, Training and 23

Qualification Plan, Safeguard Contingency Plan and

Independent Spent Fuel Storage Installation Security Plan

71151 Miscellaneous PP01 Physical Protection, Protected Area Security Equipment Data 04/2022

through

03/2023

Procedures 71151 Performance Indicator Verification 04/06/2020

8