ML19305C865

Response to Third Set of Interrogatories.Includes Info Re Persons Responsible for Internal Security,Security Contracts & Incident Repts.Certificate of Svc & RA Rice Affidavit Encl

ML19305C865
Person / Time
Site:	Three Mile Island
Issue date:	03/17/1980
From:	Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Sholly S AFFILIATION NOT ASSIGNED
References
NUDOCS 8004100549
Download: ML19305C865 (15)

Text

'

March 17, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) .

METROPOLITAN E9ISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

LICENSEE'S RESPONSE TO INTERROGATORIES (THIRD SET) OF STEVEN C. SHOLLY INTERROGATORY NO. 1 Provide the name and address of those employees of the Licensee who are responsible for internal security at TMI-l and TMI-2.

RESPONSE

The persons responsible for internal security at TMI-l and TMI-2 are the Security Manager, Robert A. Rice; Unit 1 Security Supervisor, J. F. Stacey, and Unit 2 Security Supervisor, F. J. Maughan. Their address is Metropolitan Edison Company, P. O. Box 480, Middletown, Pennsylvania 17057.

INTERROGATORY NO. 2 Provide the name and address of all persons who presently have contracts with Licensee-to provide plant security.

INTERROGATORY NO. 3 How long have the contracts referred to in your answer to Interrogatory No. 2 been in effect?

INTERROGATORY NO. 4 Please provide copies of all the security contracts presently.

in effect, h 8004100 5 W

RESPONSE (INTERROGATORIES 2, 3, 4)

Licensee has a contract effective July 31, 1978, as amended, with Gregg Security Services, Inc., 825 Electric Avenue, East Pittsburgh, Pennsylvania (having a local office at 4902 Trindle Road, Mechanicsburg, Pennsylvania 17055) to provide security watchmen. A copy of the contract will be placed in the Licensee's Discovery Reading Room.

INTERROGATORY NO. 5 Has Licensee ever terminated a security contract between it and a private contractor?

INTERROGATORY NO. 1 If so, please state each instance that such a contract was cancelled and describe the circumstances.

RESPONSE (INTERROGATORIES 5, 6)

Licensee has not terminated any security contracts with private contractors since March 28, 1979.

INTERROGATORY NO. 7 Who is responsible for selecting the security contractor on TMI?

INTERROGATORY NO. 8 How long has he had that position?

INTERROGATORY NO. 9 What criteria are used in selecting a security contractor?

RESPONSE (INTERROGATORIES 7, 8, 9)

Robert A. Rice has had the responsibility for selection of the security contractors for TMI since December 17, 1973, utilizing the following general criteria in the selection process:

(a) Completeness of bid in response to proposal request.

(b) Experience with nuclear power plants.

l (c) Professionalism displayed by personnel.

(d) Personnel experience (such as number of no shows and attrition).

(e) Adherence to procedures.

(f) Quality and method of training.

1 (g) Did proposal rate.

i (h) Background reference check.

t INTERROGATORY NO. 10

- Does the security contractor make incident reports to the Licensee concerning breaches of security? ,

INTERROGATORY NO. 11 How often are such incident reports submitted?

INTERROGATORY NO. 12 I What employee of the Licensee receives these reports?

RESPONSE (INTERROGATORIES 10, 11, 12) i The security contractor's personnel file an incident report with Licensee's Sergeant following each security incident.

INTERROGATORY NO. 13 Please provide copies of all incident reports filed since the March 28, 1979 accident.

RESPONSE

Copies of Licensee's TMI Nuclear Generating Station Incident /Information Reports since March 28, 1979, will be placed in Licensee's Discovery Room.

INTERROGATORY NO. 14 What is a Type 1 vital' area?

u

RESPONSE

10 CFR 73.2 contains a definition of " vital area" and

" vital equipment." In addition, NRC Review Guideline 17 defines a Type I " vital area" as an area which contains systems or components whose failure or destruction results in a direct radiation release.

INTERROGATORY NO. 15 Who is permitted access to such areas?

INTERROGATORY NO. 16 How are these areas secured?

INTERROGATORY NO. 17 Ilow does one obtain access to these areas?

RESPONSE (INTERROGATORIES 15, 16, 17)

Licensee presently does not have areas designated as. Type 1 vital areas; rather, the entire TMI-l plant structure, except the Service Building, is designated as a vital area. On April 1, 1980, Licensee will designate several spaces within the present vital area as vital areas without further specifying whether they are Type I or Type II.

Access to the Licensee's vital areas will be limited to those individuals who hold appropriate authorization and who have a valid need for access to .such areas to perform work duties.

Access to such vital areas will be positively controlled by security personnel and/or equipment at all points of personnel and vehicular access and will require passage through at least two physical barriers.

O

+,

w-

. _ = . - - . - _ _ - - . . - - . . _ . - - _ _ . .

RESPONSE (INTERROGATORIES 15, 16, 17 ) (cont ' d . )

Access to such vital areas will require an individual to be appropriately badged. There are two types of badges applicable to vital areas - " unescorted" and " escorted." Unescorted

-badges only will be issued to those individuals who are screened i to establish trustworthiness based upon a review of the f

individual's employment record and training'in security 4

and health physics. Escorted badges will be issued to those individuals who are required to be escorted at all times while in the vital areas.

Following badging, those receiving unescorted badges will i

be issued equipment and information for access through mechanical  ;

t security devices which will limit access to only those areas .

of the compartmentalized vital areas necessary to perform work duties. Once an individual is badged and a need for access i is established the individual will gain access by passing  ;

i through security control points where the individual will be 5

l searched and checked with a metal detector and explosive i

l detector. An inspection of all packages also will be per- l fo rmed. The individual will then be required to pass through ,

! additional security points displaying appropriate badging and -

utilizing security access equipment and information.

INTERROGATORY NO. 19  :

l Provide the names and present positions of those individuals presently permitted access to these areas.

RESPONSE

At the time' Unit 1 restarts, approximately 568 employees will have access to the owner protected area with a lesser number

RESPONSE (INTERROGATORY NO. 19) (cont' d. )

having access to some or all of the compartmentalized vital areas based upon a specific need to perform work i

duties. The identity of these employees to be permitted

! access has not yet been determined. However, Licensee maintains a Personnel Compliment / Authorization Summary .

List identifying the job titles of those positions which will have access to the protected area some of whom may be i authorized access to vital areas. A copy of this will be placed in Licensee's Discovery Reading Room. Other employees j or individuals will be granted access to vital areas from time to time based only upon specific need.

INTERROGATORY NO. 20 Has Licensee ever received a security inspection by the NRC?

INTERROGATORY NO. 21 If so, state the dates on which such inspections were made since January 1, 1979.

RESPONSE (INTERROGATORIES 20, 21)

Licensee has had security inspections by the NRC on March 19-23, 1979; April 10-12, 1979 and September 16 -

October 4, 1979.

INTERROGATORY NO. 23 Does the Licensee know when the NRC intends to make a security inspection?

INTERROGATORY NO. 24 Has any employee of Licensee received prior information of any kind that a security inspection by the NRC was to occur?

1 e - -- , , - - -

INTERROGATORY NO. 25 If so, state:

(a) The name and address of each such employee; (b) The date on which the information was received; (c) The source of the information; and (d) The results of the NRC inspection.

RESPONSE (INTERROGATORIES 23, 24, 25)

NRC security inspections are unannounced and, therefore, the Licensee does not know when the NRC intends to make a security inspection. Licensee is not aware of any instances in which any of its employees has received prior information. of any kind that a security inspection by the NRC was to occur..

INTERROGATORY NO. 26 What is the "two-man rule"?

INTERROGATORY NO. 27 Has the two-man rule been implemented?

INTERROGATORY NO. 28 If not, why not?

RESPONSE (INTERROGATORIES 26, 27, 28)

The "two-man rule" is stated in NRC issued Guideline No. 23 as follows: "When two or more individuals are authorized to enter a Type I vital area together, if each person is advised of his responsibility to monitor the activities of his co-workers while in the area, each individual is determined to have the knowledge and acility to identify unauthortzed activities by his co-workers, each individual must have the capability to observe, at any time and for

-, , -- ~ -

- p

as long as necessary to ascertain that activities are authorized, and has the capability to communicate with the control room or CAS/SAS must be available to each individual while in the Type I vital area."

In March 1977, NUREG-0220 detailed interim acceptance criteria for a Physical Security Plan for Nuclear Power Plants. This document in paragraph 6.3.A., page 50, proposed two acceptable methods of monitoring access to Type 1 vital areas -- alternate 1, the "two man rule", and alternate 2, compartmentalization of vital areas. On November 6, 1978, the NRC issued Review Guideline No. 23, which identifies three optional methods of meeting the general performance requirements of 10CFR 73.55 for protection against sabotage.

These three options are:

1. Compartmentalization.

2. The two man rule.

3. Personal reliability, NRC Q Clearance or five years continuous service that required access to a Nuclear Power Plant, Type 1 vital area, and certification of trustworthiness and reliability of employees based on observation of the employer and NRC sponsored NAC investigation.

On Friday, November 16, 1979, NRC published an amendment to 10CFR Part 73 changing the date when pat down searches of regular employees at Nuclear Power Plants, two man rule procedures, and additional compartmentalization have to be

implemented for protection against insider sabotage from November 1, 1979, to November 1, 1980. The delay was granted "to allow the Commission time to evaluate the effectiveness of alternative means of protecting against the insider threat."

Licensee presently requires that no single person can occupy the control room or containment ro'mo of Unit 1. The re-maining vital areas are being compartmentalized.

INTERROGATORY NO. 35 Itave the Licensee's internal security plans been changed since January 1, 1980?

INTERROGATORY NO. 36 If so, (a) What prompted the change?

(b) What changes have been made?

RESPONSE (INTERROGATORIES 35, 36)

(a) Licensee has changed its security plans since January 1,1980 to effect a separation between TMI Unit 1 and 2.

(b) The changes are as follows:

(1) The west side of Unit 2 protected area fence will be relocated 73' west of the present location.

(2) Processing Center for Unit 2 protected area will be relocated.

(3) A pat down search of all persons will be performed prior to entry into Unit 2 protected area.

INTERROGATORY NO. 37 Who has Licensee contracted with to supply security badges?

RESPONSE

Ident-card Co.

INTERROGATORY NO. 38 What are the criteria used in selecting the contractor?

RESPONSE

Criteria used by Licensee in selecting the badge contractor:

(a) Availability.

(b) Competitive cost.

(c) Previous experience.

INTERROGATORY NO. 39 How many types of security badges are there?

PESPONSE Licensee utilizes nine (9) types of security badges at the Three Mile Island Nuclear Generating Station.

INTERROGATORY NO. 40 Describe each type of badge and state what areas persons having each type of badge would have access to.

RESPONSE

Badges for GPU System amployees - Color photo-ident badges (varies with System Company affiliation) for access to owner controlled areas. Color 1 photo-ident badges for Unit 1 pro-

-tected and vital area. Color 2 photo-ident badge for Unit 2 protected and vital area. Contractor Badges - Color 3-for Unit 1 owner controlled area. Color 4 for Unit 1 protected and vital area. Color 5.for Unit 2 owner controlled area.

i i

[

t 5

RESPONSE (INTERROGATORY NO. 4 0) (cont! d. ) i

! Color 6 for Unit 2 protected and vital area. Visitor  ;

Badges-Escort Required - Color 7 for Unit 1 controlled [

1 and vital area. Colc r 8 for Unit 2 protected and vital area.

Respectfully submitted,  !

a SHAW, PITTMAN, POTTS & TROWBRIDGE '

i  ;

I By {xwl.lA*ls.$,

Ernest L. Blake, Jr. ,

Counsel for Licensee _

t  !

i i Dated: March 17, 1980.

I i i

[

) 4 l -

[

. i

(

i i.

t .

6 h

h I

a e 4 w-- , ..en. . - - . > - , - - , . . . - - . , , . . .,, -----m- , . . - , - - - , . - - - . . , , , , ~-- n- w.-

UNITED STATES OF AMERICA t

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD h

In the Matter of )

> )

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

f 4

CERTIFICATE OF SERVICE i

I hereby certify that copies of " Licensee's Response to l

Interrogatories (Third Set) of Steven C. Sholly" were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 17 th day of ,

March, 1980.

i

!. $h! %,h, Ernest L. Blake, Jr.

Dated: March 17 , 1980.

1 i

i

~, y e w - , - y ,,# y-- < - - - y

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

, SERVICE LIST Ivan W. Smith, Esqui e John A. Levin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Comm.

Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington, D. C. 20555

~

Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atomic Safety and Licensing 505 Executive House Board Panel 101 South Second Street

'881 West Guter Ridge Harrisburg, Pennsylvania 17120 Oak Ridge , Tennessee 37839 John E. Minnich Dr. Little W. Little Chairman, Dauphin County Board Atomic Safety and Licensing of Commissioners Board Panel Dauphin County Courthouse 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 James R. Tourtellotte, Esquire Walter W. Cohen, Esquire Office of the Executive Legal Consumer Advocate Director Of fice of Consumer Advocate U.S. Nuclear Regulatory Commission 14th Floor, Strawberry Square Washington, D. C. 20555 Harrisburg, Pennsylvania '17127 Docketing and Service Section Jordan D. Cunningham, Esquire Office of the Secretary Attorney for Newberry Township U.S. Nuclear Regulatory Commission T.M.I. Steering Committee Washington, D. C. 20555 2320 North Second Street Harrisburg, Pennsylvania 17110 Theodore A. Adler, Esquire-Widoff Reager Selkowitz & Adler Ellyn R. Weiss, Esquire Post Office Box 1547 Attorney for the Union of Concern @

Harrisburg, Pennsylvania 17105 Scientists Sheldon, Harmon & Weiss 1725 Eye Street, N. W., Suite 506 Washington, D. C. 20006

Steven C. Sholly 304' South Market Street Mechanicsburg, Pennsylvania 17055 Gail Bradford Holly S. Keck Legislation Chairman Anti-Nuclear Group Representing York 245 West Philadelphia Street York, Pennsylvania' 17404 Karin P. Sheldon,' Esquire

- Attorney for People Against Nuclear Energy Sheldon, Harmon & Weiss 1725 Eye Street, N. W., Suite 506 Washington, D.C. 20006

-Robert Q. Pollard Chesapeake Energy Alliance 609 Montpelier Street Baltimore, Maryland 21218-Chauncey Kepford Judith H. Johnrud Environmental Coalition on Nuclear Power 433 Orlando A' venue.

State College, Pennsylvania 16801 Marvin I. Lewis 6504 Bradford Terrace Philadelphia, Pennsylvania 19149 Majorie M. Aamodt R. D. 5 Coatesville, Pennsylvania- 19320 i

i I.

l

~

r I

I .

, 4., - ,- . - ,. _ ,_ - _.

V UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMIS$ ION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

METROPOLITAN EDISON COMPANY )

)

es[r (Three Hile Island Nuclear )

Station, Unit No. 1) )

AFFIDAVIT OF ROBERT A. RICE Commonwealth Pennsylvania )

SS County of Dauphin )

ROBERT A. RICE, being duly sworn according to law, deposes and says that he is Security Manager with GPU Service Corpceation; that the infor-mation contained in Licensee's Responses to Interrogatory Nos. I through 17, inclusive, Nos. 19 through 21, inclusive, Nos. 23 through 28, inclusive and Nos. 35 through 40, inclusive, are true and correct to the best of his knowledge, information and belief.

.i I Robert A. Rice Security Manager Sworn to and subscribed before me this day of , 1980.

Notary Pi.blic CPn L C.ny, rie in a,e ,c trn wer. ?n s m,rn a ,.c ,,,

My Commissiun Expires 'O'**""#' --