IR 05000397/2021401

Security Baseline Inspection Report 05000397/2021401

ML22014A409
Person / Time
Site:	Columbia
Issue date:	01/19/2022
From:	Ray Kellar Plant Support Branch-1
To:	Schuetz R Energy Northwest
References
IR 2021401
Download: ML22014A409 (9)

Text

January 19, 2022

SUBJECT:

COLUMBIA GENERATING STATION - SECURITY BASELINE INSPECTION REPORT 05000397/2021401

Dear Mr. Schuetz:

On November 19, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Generating Station. Additional offsite inspection related activities continued through January 6, 2022, when the results of this inspection were discussed 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 Columbia Generating 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, Ray L. Kellar, P.E., Chief Plant Support Branch 1 Division of Reactor Safety Docket No. 05000397 License No. NPF-21

Enclosure:

Inspection Report 2021403

Inspection Report

Docket Number: 05000397 License Number: NPF-21 Report Number: 05000397/2021401 Enterprise Identifier: I-2021-401-0006 Licensee: Energy Northwest Facility: Columbia Generating Station Location: Richland, WA Inspection Dates: November 15, 2021 to January 6, 2022 Inspectors: D. Holman, Sr Physical Security Inspector Approved By: Ray L. Kellar, P.E., Chief Plant Support Branch 1 Division of Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a security baseline inspection at Columbia Generating 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.

71130.06 - Protection of Safeguards Information

The inspector evaluated material in the possession of the licensee informed by the Jensen Hughes Co. Memo To Appropriate Licensees, dated December 07, 2020, IP 71130.06 and DG SGI-1, Designation Guide for Safeguards Information.

Protection of Safeguards Information (1 Partial)

(1) (Partial)

Reviewed 27 documents related to WPN2 system security engineering, all dated 1994 or 1995.

71130.08 - Fitness For Duty Program

The inspectors evaluated the fitness for duty program by completing the following inspection

elements: Fitness For Duty Program

(1)

• Tier I: All Requirements

• Tier II: 24 Requirements (all but 02.07 and 02.08)

• Tier III: 8 Requirements (all but 02.14 a, b, c)

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71130.08 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: While reviewing Action Request 425019 the inspector noted that Quality Assurance (QA) had identified regulatory requirements being implemented in FFDI-1.2 Drug Chemical Testing and Processing.

Title 10, 26.27(c) requires, in part, that each licensee shall prepare, implement, and maintain written procedures that describe the methods to be used in implementing the FFD policy and the requirements of this part. Contrary to this requirement, from January 1, 2009 to September 7, 2021, the licensee did not prepare, implement, and maintain written procedures to be used in implementing the requirements of part 26. Specifically, regulatory requirements according to 26.31(b) and 26.85(a)(b) and

(c) were implemented in lower tier document FFDI 1.2, Drug Chemical Testing and Processing, Rev 27.

Significance/Severity: Green. When processed through the PPSDP this issue screened out as 1 point, 0-6 being green under the Physical Protection Severity Determination Process.

Corrective Action References: Action Request

EXIT MEETINGS AND DEBRIEFS

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

• On January 6, 2022, the inspectors presented the security baseline inspection results to you and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71130.06 Miscellaneous DG-SGI-1 USNRC Designation Guide for Safeguards Information September

2005

Miscellaneous Memo, 10 pages, Framingham Office Safeguards Information Discover, 12/07/2020

Transfer, and Assessment

71130.08 Corrective Action 361880, 364412, Action Request various

Documents 364704, 365462,

373755, 377350,

373302, 391935,

2208, 425017,

25019

71130.08 Corrective Action 427310, 427311, Action Request 2021 and

Documents 428902 2022

Resulting from

Inspection

Miscellaneous CLIA #: Environmental Services, EMIT Laboratory Quality Assurance 4/20/2017

5000696092 Plan

Miscellaneous Contract 314993 MEDTOX Laboratories, INC., Amendment Document 12/07/2020

Miscellaneous Contract 315193 Elsohly Laboratories, Amendment Document 10/09/2020

Miscellaneous Federal Register / Statements of Consideration, Part 26 3/31/2008

Vol. 73, No. 62

Miscellaneous FFDI-1.2 Drug Chemical Testing and Processing 027

Miscellaneous FFDI-1.3 Random Selection Process and Backlog List Tracking - 020

Random Testing

Miscellaneous Form 26476 FFD Consent/Collection Form - Screening and Specimen 6

Collection

Miscellaneous NEI 03-01 Nuclear Power Plant Access Authorization Program 4

Miscellaneous Pamphlet ENW FFD Policy None

Miscellaneous SALI E 06 Supplemental Analytical Laboratory Instructions 10

Procedures PSM-4.6 Fitness for Duty Policy 005

Procedures SWP-FFD-01 Fitness for Duty Program Requirements 019 and 022

Procedures SWP-FFD-05 Medical Review Officer (MRO and Substance Abuse Expert 000

(SAE)

6