IR 05000445/2020410

Security Baseline Inspection Report 05000445/2020410 and 05000446/2020410

ML20254A349
Person / Time
Site:	Comanche Peak
Issue date:	09/10/2020
From:	Ray Kellar Plant Support Branch-1
To:	Peters K Vistra Operations Company
References
IR 2020410
Download: ML20254A349 (8)

Text

September 10, 2020

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT - SECURITY BASELINE INSPECTION REPORT 05000445/2020410 AND 05000446/2020410

Dear Mr. Peters:

On August 27, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Comanche Peak Nuclear Power Plant. The NRC inspectors discussed the results of this inspection with Mr. T. McCool, Site Vice President, 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,

/RA James R. Larsen Acting for/

Ray L. Kellar, P.E., Chief Plant Support Branch 1 Division of Reactor Safety

Docket Nos. 05000445 and 05000446 License Nos. NPF-87 and NPF-89

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000445 and 05000446

License Numbers:

NPF-87 and NPF-89

Report Numbers:

05000445/2020410 and 05000446/2020410

Licensee:

Vistra Operations Company LLC

Facility:

Comanche Peak Nuclear Power Plant

Location:

Glen Rose, TX

Inspection Dates:

August 24, 2020 to August 27, 2020

Inspectors:

D. Holman, Sr Physical Security Inspector

Approved By:

Ray L. Kellar, P.E., Chief

Plant Support Branch 1

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a security baseline inspection at Comanche Peak Nuclear Power Plant, 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.

71130.02 - Access Control

Access Control (1 Sample)

(1)

• Tier I: All Requirements

• Tier II: 6 Requirements (02.08 a-e and g)

• Tier III: 1 Requirement (02.09)

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 Sample)

(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 change in accordance with 10 CFR 50.54(p)(2)since the implementation 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)

=

The inspector verified performance indicator data listed below:

(1) October 2019 through June

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

• On August 27, 2020, the inspectors presented the security baseline inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71130.02

Corrective Action

Documents

2019-007675

Keys in emergency vehicles

10/2/19

2019-008490

Discovered contraband in x-Ray

11/4/19

Corrective Action

Documents

Resulting from

Inspection

20-006290

NRC observation about FAC entry sign

8/27/20

20-006322

NRC observation, exit side PCMs have gaps that can be

circumvented

8/27/20

20-006324

Minor violation of 10 CFR 73.22 protection of safeguards.

8/27/20

20-006325

Minor violation for rusted security padlocks not included in

the maintenance program.

8/27/20

20-006327

NRC observation, SFRs lack necessary details

8/27/20

20-006337

Form SEC-506-12 verbiage does not match verbiage used in

body of procedure.

8/27/20

20-006360

Minor violation of 10 CFR 73.55(c)(7)(i) security procedures

with "should" instead of "shall"

8/28/20

Miscellaneous

Email to Security

Supervisors

From:

J. Jurado, Subject: SFR and IRs

8/20/20

Email to Security

Supervisors

From:

R. Brock, Subject: Post 13 Presentation

3/29/18

SAS Key Cabinet

Issue/Turn-in Log

SGI Key

10/22/18 to 10/25/18

and

11/17/18 to 11/29/18

See

Description

SFR 0011-20

Unsatisfactory Job performance

1/8/20

SFR 0020-20

On Duty without all Equipment

1/13/20

SFR 0145-20

Unsatisfactory Job Performance

4/26/20

SFR 0146-20

Unsatisfactory Job Performance

4/26/20

SFR 0147-20

Assumed post without duty equipment

4/26/20

SFR 0171-20

For Cause Hold

5/7/20

SFR 0465-18

SGI Safe

10/25/18

Procedures

CPNPP SI 1.0

Common Instructions

Revision 41

CPNPP SI 3.11

Key Control

Revision 24

CPNPP SI 3.13

Key Card Control

Revision 52

CPNPP SOP

SEC-120

Unescorted Access Authorization

Revision 11

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CPNPP SOP

SEC-302

Personnel Identification, Key Card Badge Issuance, and

Access Control

Revision 19

CPNPP SOP

SEC306

Lock, Key, Password, Combinations and Key Card Badge

Control System

Revision 27

CPNPP STA-902

Access To CPNPP Site Areas

Revision 26

Work Orders

5847504

Monthly Inspection, CPX-SCEQPD-03

2/4/20

5908056

Monthly Inspection, CPX-SCEQPD-03

6/22/20

5918090

Monthly Inspection, CPX-SCEQPD-03

7/20/20