ML19316B192

Addl Response to Intervenor Sc Sholly 800225 Fourth Set of Interrogatories Re Contention 16.Includes Info Re Security Staffing,Security Audits & Acts of Sabotage.Certificate of Svc & Affidavit Encl

ML19316B192
Person / Time
Site:	Three Mile Island
Issue date:	05/12/1980
From:	Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Sholly S AFFILIATION NOT ASSIGNED
References
NUDOCS 8006120040
Download: ML19316B192 (10)

Text

, . , . LIC 5/12/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ca 0)

In the Matter of ) 4 oc 9 METROPOLITAN EDISON COMPANY eg CK ED (Three Mile Island Nuclear ) $_'

MAY 131980 >

Station, Unit No. 1) )

~

12

[ Office of the Secretary Dccheting & Servico Branch 7

LICENSEE'S ADDITIONAL RESPONSE TO $'

CONTENTION 16 INTERROGATORIES \ Cu N

-(FOURTH SET) OF STEVEN C. SHOLLY Pursuant to the May 6, 1980 status report of Sholly and Licensee, Licensee proffers the following additional responses to Sholly's Fourth Set of Interrogatories, dated February 25, 1980.

Interrogatory 16-008(f)

With reference to ALAB-410 (5 NRC 1398--1977) at pages 1409 through 1410, supply the following information about Licensee's Security Plan:

f. Maximum and minimum staffing requirements for security force on all shifts, including the numbers of Licensee employees and contract security personnel.

Response

Licensee's minimum security staffing requirement at TMI Unit 1 conforras to the NRC requirement contained in 10 CFR 73.55 (h) (3) . . Licensee is committed to have available at all times a minimum response capability of five guards.

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2-Interrogatory 16-008(h)

With reference to ALAB-410 (5 NRC 1398--1977) at pages 1409 through 1410, supply the following information about Licensee's Security Plan:

h. Descriptions of any and all audit methods used to evaluate the effectiveness of security forces at TMI.

Response

Audits on security at Unit 1 are conducted independently by NRC and Licensee's quality assurance personnel. Licensee is not prepared to testify as to NRC's methodology. However, Licensee's security audits are included within the scope of " activities important

^

to safety" in its recently revised TMI/GPU Operational Quality Assurance Plan for TMI Unit 1 (Rev. 8, April 18, 1980). As such, security activities will be monitored and inspected by visual examination, and QA will conduct security audits, as well as security procedure and document reviews. The TMI/GPU Operational Quality Assurance Plan for TMI Unit 1 (Rev. 8, April 18, 1980) will be placed in Licensee's Discovery Reading Room.

Interrogatory 16-010, Provide a listing of any and all attempted acts of sabotage, suspected attempted acts of sabotage, threatened acts of sabotage, and thefts or sus pected thefts of security-related documents with respect to both Units 1 and 2 at TMI. This listing shall be .

arranged in chronological order and shall include the date of occurrence, time of day, a description of the incident, and a description of Licensee's response to the incident. The listing shall be confined to acts perpetrated or threatened by employees of Licensee or employees of Licensee contractors.

Response

Licensee reserves its objection to the relevancy of this interrogatory. In fact, however, to Licensee's knowledge, ,

. , no attempted, threatened, or suspected attempted acts of sabotage or thefts or suspected thefts of security-related documents by employees of Licensee or employees,of Licensee contractors have occurred at TMI.

Interrogatory 16-012 Specify the date by which Licensee will implement the physical search requirements of 10 CFR 73.55 (d) (1) .

Response

Licensee has implemented the search requirements of 10 CFR 73.55 (d) (1) .

Interrogatory 16-013 State unequivocally that all unoccupied vital areas locked and protected by an active intrusion alarm system as

- required by 10 CFR 73.55 (d) (7) . If Licensee cannot make such a statement, explain why not in detail.

Response

While reserving its objection on the basis of relevancy, Licensee states that all unoccupied vital areas within TMI Unit 1 I are locked and protected by an active intrusion alarm system, as required by 10 CFR 73.55 (d) (7) .

Interrogatory 16-014 Specify any and all occasions on which Licensee has been cited for violation of NRC security regulations. Describe'the violations, including date, time, and pertinent facts surrounding the incident, including Licensee's response to the citation and any I

and- all commitments made by Licensee to change or upgrade security plans and/or capabilities in response to each incident. Cite the l

NRC regulations which were violated in each instance.

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i 1 1

Response

Licensee reserves its objection to the relevancy of this interrogatory insofar as it seeks information unrelated to the security barrier between Unit 1 and Unit 2. Licensee will, however, place in the Discovery Reading Room copies of all non-proprietary correspondence with NRC regarding Unit 1 and Unit 2 security violations since the startup of these units.

Interrogatory 16-015 Provide evidence that Licensee's training program for security force personnel includes the following features:

i a. Training in tactics and force which might be utilized by adversary groups;

b. Training in the recognition of sabotage-related devices and equipment that might be used against Licensee's facility;

c. Training in protected area security procedures and practices and the vulnerability of such practices and procedures to being rendered ineffective by insider ,

actions;

d. Training in the vulnerabilities and consequences of industrial sabotage;

e. Training in access control systems and their '

operations, including limitations

f. Training in contraband control techniques and l detection systems; l r i

g. Training in security system operations after component -l failures;

h. Training in the use of and defense against incapactating agents;

i. Training in response to hostage situations;

j. Training in the response to confirmed attempted sabotage; and l

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k. General recognition in all security-related training of the special problems posed by insider-initiated sabotage, including problems posed by intimate familiarity with security procedures and systems and means for their disabling.

Where such training does not exist, explain why and whether such training will be implemented and when. Each of these areas of knowledge is taken from Appendix B to 10 CFR 73.

Response

Licensee reserves its objection to the relevancy of security training to Sholly Contention 16, while proferring the following information. Licensee's TMI Unit 1 security training program includes the following subject areas:

01. Techniques & Mechanics 16. Threat Situations of Arrest

17. Facility Alarm System

02. Search and Seizure

18. Escort & Search of Personnel,

03. Legal Phrase & Defini- Packages & Vehicles

.- tions

19. Legal Powers of Site Protection

04. Multimedia First Aid Officers

05. Fire Fighting 20. Testing of Alarm & Surveillance System

06. Role of Law Enforcement .

21. Security of Protected & Vital

07. Crimes & Elements Areas

08. Patrol Procedures 22. Firearms, Training, Control & Use

09. Response to Crimes in 23. Bomb & Other Overt Threats Progress

24. Entry to TMI - Unit 1

10. Rules of Evidence

25. Access to and within TMI

11. Records and Reports

26. Personnel Control & Accountability

12. Preservation & Handling During a Radiation Emergency of Evidence

27. Interface with the Control Room

13. Communications

28. Civil Disorders

14. Health Physics Training

15. Key Control

. Licensee will place in the Discovery Reading Room non-proprietary security training materials including a copy of its Site Protection Officers Training Program, which outlines a portion of the TMI Unit 1 security personnel training program, as well as a number of its security training procedures.

Appendix B of 10 CFR Part 73, is not yet in effect.

Licensee will conform to all Appendix B requirements as soon as they become applicable to NRC licensees.

i Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE .j

)

By I. Mrd, l Ernest L. Blake, Jr. .

l 1

, Counsel for Licensee '

Dated: May 12, 1980.

J l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f

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) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Additional Response to Interrogatories (Fourth Set) of Steven C. Sholly" were served upon those persons on the attached Service List by deposit in the United States mail, post ge prepaid, this 12 th day o f May, 1980.

Mf. 444 4.

Ernest L. Blake, Jr.

Dated: May12, 1980.

1

• 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 l

Ivan W. Smith, Esquire 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 i

~

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 Outer 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 Fronc and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania 17101 i

James R. Tourtellotte, Esquire Walter W. Cohen, Esquire Office of the Executive Legal Consume r Advocate Director Office of Consumer Advocate l U.S. Nuclear Regulatory Commission 14th Floor, Strawberry Square I Washington, D. C. 20555 Harri'sburg, 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 Harrisburc, Pennsylvania 17110

. Theodore A. Adler, Esquire Widoff Reager Selkowitz & Adler Ellyn R. Weiss, Esquire Post Office. Box 1547 Attorney for the Union of Concer$

Harrisburg, Pennsylv'ania 17105 Scientists Sheldon,.Harmon & Weiss 1725 ' Eye Street, N. W. , Suite 50:

l l Washington, D. C. 20006

. _2-Steven C. Sholly 304 South Market Street Mechanicsburg, Pennsylvania 17055 Gail Bradford Holly S. Keck L>gislation Chairman Anti-Nuclear Group Representing York 245 4est 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 Chaunccy Kepford Judith H. Johnrud Environmental Coalition on Nuclear Power 433 orlando Avenue.

State College, Pennsylvania 16301 Marvin I. Lewis 6504 Bradford Terrace  !

Philadelphia, Pennsylvania 19149 Majorie M. Aamodt R. D. 5 Coatesville, Pennsylvania 19320 l

4 G

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

METROPOLITAN EDISON COMPANY e art (Three Mile Island Nuclear )

Station, Unit No. 1) )

AFFIDAVIT OF ROBERT A. RICE l

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 Corporation: that the infor-mation contained in Licensee's Responses to Steven C. Sholly (Fourth Set)

Interrogatory Nos.16-008(f),16-008(h),16-010, 16-012 through 16-015, j inclusive, are true and correct to the best of his knowledge, information 1

and belief.

Robert A. Rice Security Sworn to and scribed 1

. befort me this fday CATHY L. BREY, Notary Public A .u, . Landonderry Twp., Dauphin County, Pa.

My Comanssion Empires Oct. 24,1983 Notary ublic /

My Commission Expires Ovk,-A f//J l

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