ML20054F604

Testimony of Rf Skelton Re Prairie Alliance Contention 4 Re Adequacy of Security Plan.Prof Qualifications Encl

ML20054F604
Person / Time
Site:	Clinton
Issue date:	06/11/1982
From:	Skelton R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20054F597	List: ML20054F596 ML20054F601 ML20054F604 ML20054F609 ML20054F612 ML20054F615 ML20054F618 ML20054F622 ML20054F627
References
NUDOCS 8206170149
Download: ML20054F604 (9)

Text

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y UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE T E ATOMIC SAFETY AND LICENSING BOARD In the matter of:

• 8 ILLIN0IS POWER COMPANY  : Docket No. 50-461 .

J (Clinton Power Station, Unit 1)

• NRC STAFF TESTIMONY OF ROBERT F. SKELTON (REGARDING ADEQUACY OF THE SECURITY PLAN)

(PRAIRIE ALLIANCE CONTENTION 4)

Ql. Please state your name and position with the NRC.

A1. My name is Robert F. Skelton. I am employed by the U.S. Nuclear Regulatory Commission as a Senior Plant Protection Analyst, Power Reactor Safeguards Licensing Branch, Division of Safeguards. A copy of my professional quali-fications is attached.

Q2. What is the purpose of your testimony?

A2. The purpose of this testimony is to respond to Prairie Alliance Contention 4, which reads as follows:

"The CPS should not be licensed to operate until IP has developed and demon-strated an adequate security plan which complies with 10 CFR 73.55. The FSAR does not give adequate assurance that all regulatory requirements have been or will be met prior to operation. See FSAR, P. 1.8-25, Regulatory Guide 1.17, Revision 1."

8206170149 820611 PDR ADOCK 03000461 T PDR

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Q3. Has the Clinton Power Station developed an adequate security plan which complies with 10 CFR 3.55?

A3. On April 27, 1982, the Division of Safeguards, Office of N clear Material Safety and Safeguards, transmitted a draft license condition and Supplemental Safety Evaluation Report to the Division of Licensing, Office of Nuclear Reactor Regulation, which indicated that Clinton Power Station (CPS) Physical Security Plan satisfied all the requirements of 10 CFR Part 73.55 and there-fore was approved. The draft implementing license condition for CPS was the culmination of a review process that began with a pre-docketing review in June, 1980. The review process consisted of two rounds of Division of Safeguards generated questions requesting clarification of certain matters and that additional information be included in the CPS Physical Security Plan. NRC approval was then granted based on satisfactory resolution of these questions as formalized in plan revisions. The approved plan contains Safeguards Information and is required to be protected against unauthorized disclosure in accordance with 10 CFR Part 73.21 and is collectively entitled,

" Illinois Power Company, Clinton Power Station Physical Security Plan,"

Revision 2, dated November 12, 1981 as revised by Revision 3 dated March 23, 1982. Information contained in the review questions should also be protected as Safeguards Information.

Q4. Does the FSAR give adequate assurance that all regulatory requirements have been or will be met prior to operation?

A4. With regard to Reference 1 in the FSAR, page 1.8-25, information contained in the security plan regarding alarm system quality, line supervision and installation satisfies regulatory requirements. Reference 2 in the FSAR, page 1.8-25 deals with the methods used for granting access to vital equip-ment. We agree that CPS meets the requirements of 10 CFR 73.55 and have approved their plan which incorporates portions of ANSI-18.17-1973, Section 4.3 to establish an effective security program to protect against attempts of radiological sabotage.

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Standard Review Plan NUREG-0800, Revision 2, dated July 981 (enclosed) outlines the generalMed procedure used to review securitA plans. It also lists those documents used as acceptance criteria and the references used during the review.

QS. Does the Clinton Power Station have to demonstrate an adequate security I plan prior to operation? j AS. As described in Question 3 of this reponse, the security plan approval is contained in an implementing license condition which becomes part of their license. The first sentence of that condition reads "the licensee shall maintain in effect and fully implement all provisions of the Commission approved physical security plan... including amendments made pursuant to the authority of 10 CFR 50.54(p)." This statement specifies that the licensee must implement their plan to the satisfication of the NRC Regional inspection personnel prior to receiving their license.

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G. .I U.S. NUCLEAR REGULATORY COMMISSION

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STANDARD REVDEW PLAN Y. !/ ......

OFFICE OF NUCLEAR REACTOR REGULATION y ,

13.6 PHYSICAL'5ECURITY -

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' REVIEW RESPONSIBILITIES Primary' - Physical Security Licensing Branch, Division of Safeguards, NMSS Secondary - Standardization & Special Projects Branch, Division of Licensing,f(RR .

I. AREAS OF REVIEV .

At the prelininary safety analysis report (PSAR1 s_t_ age, the review of this section

~ covers plans for implementing security measures relating to (1) preemployment of

'- personnel employed to work at the prop > sed plant and (2) the layout of the plant and other design features and equipment arrangements intended to provide protection of vital equipment against acts of radiological sabotage '

in accordance with 10 CFR Part 73, 573.55. -

At the final safety analysis report (FSAR) stag'e, the' review involves th'e evaluation of the physical security plan, the Guard Trainipg Qualification Plan, and tfie Con-tincency Plan'which collective'ly describes a comprehensive. physical security. program for the plant site. The review encompasses the physical. security crganization,-

access controls to the plant protected and vital areas including physical barriers, searches of personnel and packages and means of detecting unauthorized intrusions, provisions for monitoring the access to vital equipment, . selection of personnel for security purposes', communications systems for security, intrusion alarm systems, arrangements with law enforc'ement authorities for assistance in responding to secu- -

rity threats, training of security personnel and response to contingencies. The

. implementation schedule for the physical security program is reviewed, including phases for a multiunit plant where applicable.

Specific information' to be reviewed' referenced to ' applicable sections of 10 CFR

' Part 73, 573.55, including 10 CFR Part 73, Apperedices B and C, include the following:

1. Clear diagrams, to approximate, scale, displaying the following:

a. Designated protected and vital areas of the plant site, including physical barriers.

Rev. 2 - July 1981

~.4 USNRC STANDAR'D REVIEW PLAN

-- Standard review plans are p*epared for the guidance of the office of Nuclear Reactor Regulation staff responsible f or the review of

,- applications to construct and operate nuclear power plants. These documents are made available to the put:i;c as part of the Commess.on's policy to inform the nuclear industry and the general public of regulatory procedures and polic:es. Standard review plans are not substitutes for regulatory guides c,r the Commissior.'s regulations and compliance with them is not required. The s

standard review plan sections are keyed to the standard Format and Content of Salety /.nalysis Reports f or 1 Nuclear Povver Plants.

Not att secticns of the standard Format have a corresponding reWew pfan.

Published standard seview plans will be revised periodicatty, as appropriate. to accommodate comments and to ref!ect new informe.

tion and e mperience. ,

Comments and suggestions for Improvement will be considered and shou!J be sent to the U.S. Nuclear Regulatory Commission.

Of fice of Nucle at Reactor Regulation. Washington, o.C. M65. .

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The locations of alarm stations.

b.

c. The locations of access control. points to. protected and to vital areas. .

d. The locations of parking lots relative to the clear areas adjacent to the physical barriers surrounding protected areas. .'

e. Special features of the terrain which may present special, vulnerability . ' T problems. ,

f. The location o( relevant law enforcement agencies nd their geographi' cul--f urisdicti@s.

g. The i,nteraction of plant operations,with.the securi y program.

The response capabilities of local law enforcement agencies, including esti-mates of the number of officers that can arrive at the plant site in the event

.of a secur.ity threat after receipt of a call for assistance. (This response capability bears upon the adequacy of the size of the onsite guard force.) '

Secondary responsibilit,ies will be conducted by,SSPB to assure balance between safety arid safeguards. .

II. ACCEPTANCE CRITERIA ,

At the PSAR stage, preliminary planning for physical security is considered .

acceptable if it provides reasonable assurance that conformance to the applicable

• provisions of 10 CFR Part 73, 573.55 are expected to be achieved, including:

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1. 10 CFR Pa'rt 73, S73:55 in its entirety and Part 73 Appendices B and C

2. 10 CFR Part 25 and 10'CFR Part 95 (if applicable)

3. Regulatory Guide 5.44

• 4.--NUREG-0674 '

5. ANSI N18.17, Paragraph' 4.3 Employee Screening

6. 10'CFR Part 50,550.70(b)(3) -

7. Regulatory Guide 5.12 *

8. Regulatory Guide 5.20 To be considered acceptable, this planning should include commitment to design phase review for physical security and should show how, to the satisfacticn of the staff, this responsibility is to be implemented by the applicant.

At the FSAR stage, the applicant.'s security plan is considered acceptable if -

it conforms to.the requirements of 10 CFR Part 50, 550.34(c), 10 CFR Part 73, 573.55 and 10 CFR Part 73, Appendix -3 and Appendix C. If applicable, 10 CFR Parts 25, 75, and'95 must be addressed. In addition, the requirements and ,,

reccomendations of ANSI N18.17 establish the basis for an adequate security plan for the protecticn of nuclear power plants against radiological sabotage.

Specific acceptance criteria, including staf f positions, regarding sone of 'th'e more general requirements of 10.CFR Part 73, 573.55 and Part 73, Appendices B and C are as follows: .^ .

a. Section.b of 573.55 - Physical sec'urity organization. The licensee'shall -

establish a security organization, including guards, to protect his facility

agai'nst radiological sabotage. ,

b. Section c of 573.55 - Physica' l Barriers. The licensee shall locate. vital.

equipcent only within a vital area, which, in turn, shall be located within ,;

a protected area such that access to v, ital equipment requires passage through at least two physical barriers. ,

~13.6-2 ', Rev. 2 - July 1981

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Sectio'n d of 573.55 - Access Requirements.

. ?, 'c. The licensee shall control all points'of personnel and vehicle access into a protected area. Identifi-r ?- caticn and search of all individuals shall be made and authorization shall

% be checked at such points. - ~

d. S'ectio~n e of S73.55 - Detection Aids. ' All alarms required pursuant to this part shall annunciate in a continuously manned central alarm station located within th protected area and in at least one other continuously

-. manned station, n necessarily onsite, such that a s gle act cannot remove the 'capabil ties of calling for assistance or herwise responding .

., to an alarm.

e. Section f of 673.55 - Communication Requirements. Eachquard,'watchmar$

or armed response individual, or any other individual performing an active

..' security function on duty sha.ll be capable of maintaining continuous com- I munications with an individual'in each continuously manned alarm stations. .

~ f. " Section g of 573.55, - Testing and Maint'enance. Each licensee'shall test and maintain intrusion alarms, emergency ~ alarms, communications equipment, access control equipment, physical barriers, an.d other security related

-- devices or equipment. -

g. Section h of 673.55 - Response Requirements. The liceasee shall maintain

. liaison.with local law enforcement authorities. Each licensee shall main-tain an adequat'e number of guards for response 'and assessment of'possible security threats. Each licensee shall require thr.t those guards take' steps to neutralize the threat when detected with sufficient force to protect .

.the health and safety of the public.

• D.

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h. Part 73, Appendix B - General Criteria ~for Security Personnel. These general criteria establish requirements for the selection, training, equipping, testing, and qualification of individuals who will be responsible for the protecting of special nuclear materials, nuclear facilities, and nuclear shipments. ,

i. Part 73, Appendix C - Licensee Safeguards Contingency. Plans.' A licensee -

safeguards contingency plan is a documented plan to give guidance to licensee personnel in order to accomplish specific defined objectives in the event of threats, thefts, or . radiological sabotage relating to special -

nuclear. material or nuclear facilities licensed under the Atomic Energy Act of 1954, as amended. ,

Implementation of the physical security program should be accomplished 1 to 2 months before fuel loading. Security features required for new fuel in storage prior to loading of the first unit should be implemented as of the, time fuel is onsite.

III. REVIEW PROCEDURES At th'c PSAR stage, the review consists of a careful examination of the .informa-tion submitted and comparison-with the acceptance criteria set forth iii ssb-section II above. The general plant description in Chapter 1 and site-related

.., information in Chapter 2 of the PSAR should be examined to determine. if there g are unique features that should be considered in establishing the physical protecticn program. It will be desirable at this stage to discuss the formula-

- tion of this program with the applicant. ,

13.6-3 Rev. ,2 - July 1981

. At the F5.R stage, the physical security plan 1-s reviewed to determine its conformance with:the ' regulations, the information requirements of subsection I .

ateve, and the acceptance criteria of subsection II abcve. Applicable regula- p[

tions and the requirements and recommendations of industry standards (such as h ANSI 13.17) are used as checklists for this review. The reviewers may also -

use appropriate Division Syegulatory Guides and Review Guidel(nes 1 through -

24 to the extent they are a,plicsble to' physical protect. ion prdgrams at nuclear power plants': -Those havir,g potential applicability are listed in the references.

It is particularly 1mpcrtant that the reviewer assure himself that all items .

of vital ecuipment are contained within vital areas.

Site visits by the reviewers are necessary, during the construction phase, before the evaluation" cf the p'lan can be completed. Upon completion of the instaliation of the i security equipment, a confirmatory site visit is .rade apprcximately 3 'menths before the anticipated feel loading. Only after that final cenfirmatory site visit is the security program approved.

IV. EVALUATION FINDINGS The evaluation finding at the PSAR stage should be substantially equivalent to- -

the'following statement: -

The applicant has prov'ided a general description of plans for. pro-tecting the plant against potential acts of radiological sabotage.

Previsions for the screening of employees at the plant, and for design phase review of plant layouf. and protectico of vital eq'uip- ,

ment have been described and conform to 10 CFR Pai-t. 73, S73.55. We

~~'nd fi there is reasonable assurance that the final physical security plan will meet the requirements of 10 CFR Part 25, 10 CFR Part 73, ,

-and .10 CFR Part 95 by conforming to regulatory positions in regulatory '

guides or equivalent guidance. We conclude that the' applicant's arrmgements for protection of the plant against acts of radiological sabotage are satisfactory for this stage of the licensing prccess.

The evaluation finding at the FSAR stage 'should be substantially equivalent to the folicwing statement: .

The applicant has submitted a comprehensive physical security' plan .,__

for the protection of the plant-against poten.tial acts of radiolog-ical sabotage. This plan has been withheld from public disclosure pursuant to 10 CFR Part 2, 62.7c0(d). .

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This plan has been reviewed, found to contain all fe'atures considered essential for such a program by the staf.f, and is ecceptable. In particular, it has bee'n found to comply with the Commission's regula-tions' including 10 CFR Part 50, 650.34(c), 10 CFR. Par.t 25, 10 CFR ,

Part.75,10CFRPart95,(s'iHio~nsof10'CFRPart 7_3, 93 and Part 73, Appendix 8 and Appendix C', and conforms to the regulatory positions set forth in regulatory guides.. ,

V. IMPLEMENTATION The following reference's are intended to provide guidance to applica ts and-licensees regarding the NRC staff's plans for using this SRP section Except in th'ese cases in which the applicant proposes an acceptable alternative .

method for cceplying with specified portions of the Commission's regulations, 9 C'N ph A d4 p. 9 9. 4 AA9

G.- -

the trethod described herein will be used by the staff in its evaluation of

.. conformance with Commission regulations. *

@; - VI. REFERENCES

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1. 10 CFR Part 73, " Physical Protection of Plants and Mate' rials." '

,- 2. 10CFRPart73,Appe\dixes8.andC.

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3. ~ 10 CFR Part 50, 550.34(c), " Physical Sec0rity Plan."

4. 10 CFR Part 50, 550.34(d), " Safeguards Contingency Plan."

. ' 5. 10 CFR Part 50', $50.54(p), " Safeguards Contingency Plan Procedures."

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6. 10 CFR Part 50, 550.70(b)(3), "Immediate Unfettared Access."

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7. 10'CFRPart2,s2.790(d)(i),"SecurityMeasuresExemptfromDisclosure."

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8. 10 CFR Part 75, " Safeguards on Nuclear' Materia? - Implementation of' US/IAEA Agreement." -

9. 10 CFR Part 25, " Access Authorization for Licensee Personnel." -

10. 10 CFR Part 95, " Security Facility Approval and' Safeguarding of' National Security Information and Restricted Data." . -

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11. Regulatory, Guide 5.12, " General Use o'f Locks in the Protection and Control of Facilities and Special Nuclear Material." - -

12. Regulatory Guide 5.20~, " Training, Equipping and Qualifying .of Guards and -

Watchmen."

13. Regulatory Guide 5.44, " Perimeter Intrusion Alarm Syste'ms." *

14. Regulatory Guide 5.54, " Standard Format and Content of Safeguards Contin- '

. gency Plans for Nuclear Power Plants."

15. NU5EG-0207, " Interim Format and Content for a Physical Security Plan for

, . Nuclear Power Plants."

16. NUREG-0219, " Nuclear Security Personnel for Power Plants:"

17. NUREG-O'220, " Interim Acceptance Criteria for a Physical Security Plan for Nuclear Power Plants." -

18. NUREG-0416, " Security Plan Evaluation Report." -

19. N0hEG-0574, " Security Personnel Training and Qualification Criteria."

20. Review Guidelines 1 thro 0gh 24. -

. . " 21.

ANSI N18.17, " Industrial Security for Nuclear Power Plants."

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13.6-5 Rev. 2 - July 1981

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EDUCATIONAL AND PROFESSIONAL QUALIFICATIONS RobertF.Skelton Division of Safeguards

.S. Nuclear Regulatory Commission 4 My name is Robert F. Skelton. I am a Senior Plant Protection Analyst with fifty-four months experience in the Division of Safeguards, U.S.

Nuclear Regulatory Commission. I am responsible for the review, -

assessment, and approval of physical security plans and site specific

• a measures employed by licensees to protect power rear. tor facilities. I have also participated in the review of security contingency plans and j guard training and qualification plans for reactor and fuel cycle facilities as well as physical security plans for the prntection of special nuclear material. I have evaluated the effectiveness of installed security systems in connection with the NRC safeguards assessment activities.

After receiving a Bachelor of Arts Degree, from Parsons Coliege in 1968, I served as a Police Officer / Radio Operator (summer,1968) and for four years as a Counterintelligence Special Agent and Intelligence Photographer with the U.S. Army. My assignments included conducting personnel security investigations, physical security surveys,Ilassified document inspections, counter-sabotage / espionage investigations, and ' intelligence photographic

~ ~ duties. For thirteen months I was involved in a number of sensitive

"~ assignments in these areas in Korea.

From 1972 to 1977, I was employed as a Senior SNurity Specialist, with-the U.S. Secret Service at The White House. During that time, I pro-vided worldwide, advance security operations for the President and other protectees of the Secret Service, assuming responsibility for all aspects of their technical security. A portion of those technical security duties involved audio and explosives countermeasures; the installation and maintenance of locking mechanisms, protective lighting, and alarm

! systems.

I am also currently serving in a volunteer capacity as a sworn Deputy Sheriff in Arlington County, Virginia.

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