ML20127K042

Affidavit of R Skelton Re Requirements Per 10CFR73.1 for Licensee to Design Physical Security Program to Protect Against Design Basis Threat of Radiological Sabotage

ML20127K042
Person / Time
Site:	Braidwood
Issue date:	05/20/1985
From:	Skelton R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML19297G757	List: ML20127J993 ML20127K042
References
OL, NUDOCS 8505220021
Download: ML20127K042 (4)

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UNITED STATES OF AMERICA NUCLEAP DEGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l

In the Matter of )

COMMONWEALTH EDIS0N COMPANY Docket Nos. 50-456 50-457 (Braidwood Nuclear Power Station, Units 1 and 2)

AFFIDAVIT OF ROBERT SKELTON I, Robert Skelton, first being duly sworn, hereby depose as follows:

1. That I am employed by the United States Nuclear Regulatory Commission j as a Plant Protection Analyst in the Division of. Safeguards. A copy of my professional qualifications is attached as an appendix to this

! affidavit.

2. The Division of Safeguards is responsible for ensuring that a licensee's physical security program satisfies the requirements set forth in 10 C.F.R. Part 73, which requires a licensee, inter alia, to design a physical security program to protect against the design basis threat of radiological sabotage stated in 10 C.F.R. 9 73.1(a).

3. In evaluating a licensee's physical security program, the Division of Safeguards adheres to 10 C.F.R. I 73.55 (b)-(h) and Section 13.6 of the Commission's Standard Review Plan (NUREG-0800).

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4. Subsection:(b) ~of section 73.55 directs the licensee to establish a

. security organization -- including amed guards who must be trained, equipped, qualified and annually requalified -- and a management system which must develop, implement and enforce all necessary

' security. procedures..~ Subsection'(c) dictates that the safeguards system incorporate various physical barriers, zones and lighting requirements to aid in detecting, delaying and resisting unauthorized entry into.the facility.. Subsection (d) spells out the various

, requirements for controlling access to the facility and for identi-

' fying and evaluating personnel and physical items moving into the -

facility as well as moving from one are to another within the facility.

The requirements for detecting unauthorized intrusions into the facility are outlined in subsection (e). Among other things, this part requires that all alarm equipment be self checking and tamper indicating and that alarms annuciate in two continuously manned alarm stations indicating the type and location of the alarm. The

.communicationrequirementsofsubsection(f)directthatall-facility guards have the capability of continuous communication with both alarm stations and that the alarm stations have conven-tional telephone as well as backup emergency powered two-way radio i

or microwave. voice communication with local law enforcement authori-ties. Subsection (g) establishes the testing and maintenance schedules for the various system components and mandates an annual  ;

independent security audit of the safeguards system.

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1 Subsection (h) details certain responsibilities of the security organization: to execute a contingency plan; to establish a liaison with local law enforcement agencies; to provide that ten amed and trained security personnel shall be available at all times to respond

.to safeguard incidents unless the Commission determines otherwise (but that' number may never be reduced to less than 5 guards); and, to assure that in the even of a security emergency, the threat be effectively assessed and then neutralized by the deployment of armed response personnel between vital areas and the intruders.

5. If the requirements listed in paragraph (4) are met, the Division of Safeguards will conclude that the licensee's physical security program satisfies the general performance requirements in 10 C.F.R. 9 75.55(a) and therefore meets the radiological sabotage design basis threat stated in 10 C.F.R. 6 73.1(a)(1). The Division of Safeguards does not consider actual design basis threats or postulated sabotage scenarios during its review of the licensee's physical security plan.

The foregoing statt.ents are true and correct to the best of my personal knowledge.

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Robert Skelton Subscribed and sworn to before me this JCMday of May,1985 M .n h k Mw at_ I Notar) Public My Commission expires: 7/s/pt

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i EDUCATIONAL AND PROFESSIONAL QUALIFICATIONS Robert F. Skelton Division of Safeguards U.S. Nuclear Regulatory Commission My name is Robert F. Skelton. I am a' PikhtDProtection Analyst

with eighty-five 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 measures employed by licensees to protect power reactor facilities. I have also participated in the review of security contingency pla.ns and guard training and qualification plans for reactor and fuel cycle facilities as well as physical security plans for the protection 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 College 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, cla~ssified 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 Security Specialist, with th'e 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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