IR 05000264/1976001

Physical Protection Insp Rept 50-264/76-01 on 760115-16. Noncompliance Noted Re Communications & Access Control. Portions Withheld (Ref 10CFR2.790)

ML20205E322
Person / Time
Site:	Dow Chemical Company
Issue date:	02/06/1976
From:	Belanger J, Hind J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20205E202	List: IA-85-259, Notice of Violation from Insp on 780110-12.Portions Deleted (Ref 10CFR2.790) IR 05000264/1976001 IR 05000264/1978001 ML20205E198 ML20205E231 ML20205E245 ML20205E268 ML20205E311 ML20205E335 ML20205E345 ML20205E356 ML20205E536 ML20205E558 ML20205E573
References
FOIA-85-259 50-264-76-01, 50-264-76-1, NUDOCS 8510170263
Download: ML20205E322 (9)

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U. S. NUCLEAR REGULATORY CO*NISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

IE Inr.pection Report No. 050-264/76-01 Licensee: Dow Chemical Comp'any 1701 Building Midland, Michigan Dow TRIGA Research License No. R-108 Reactor Facility Category: F Midland, Michigan Priority: 5 Type cf Licensee: Research Type of Inspection: Physical Protection, Announced Dates of Inspection: January 15-16, 1976 Principal Inspector:

} L O wyl F. L. Belanger

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Accompanying Inspectors: None ,

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Reviewed By* .A. ind, hief ~/ db/ EI(b Safeguards Branch (Date) i f

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Attachment:

Findings (Part 2.790(d) Information)

S-F3-76-216 Copy N El of )I Copfec f Pages THIS DOCUMENT IS NOT TO BE REPRODUCED WITHOUT SPECIFIC APPROVAL OF IE:III ('~'))

Q, 8510170263 851004 PDR FDIA KOHN85-259 PDR

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Part 20 700(d) Inforestion

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SUMMARY OF FINDINGS k -

Inspection Sunnary Physical Protection Inspection on January 15-16, (76-01): Reviewed approved security plan implerentation, observed security activities of facility personnel, reviewed required documentation and records, and inspected and/or tested' physical barriers, alarms, and security-related equipment. Two items of noncompliance were identified relating to communications and access control Enforcement Items The following items of noncompliance were found during the inspection:

Infractions

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Contrary to Section 3.2.5 at Paragraph No. 4 and Section 3.3.7 at Part B of the Security Plan for the Dow TRIGA Research Reac3,or, Plant Protection and Security Department does not maintain (See Report Details, Page 5)

-s Contrary to Paragraph I.B of the Admendments to the Security Plan or the Dow TRIGA Research Reactor Facility, the " entire building" ljs not of contro11e.d aceggs during the day shift, in that, thei_ . ,jfisunlockedandunattende (See Report Details, Page 7)

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Licensee Action on Previously Identified Enforcement Items Not applicable (Initial Inspection)

Other Significant Items, Systems and Components Non Facility Items

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Non r Managerial Items Non '

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Part 2.790(d) Inforr,t!o' n

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Part 2.790(d) Inforestion Items of Noncompliance Identified end Corrected by Licensee ;

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Non . Deviations ,

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Non ! Status of Previously Reported Unterolved Items i Not applicabl (Initial Inspection)

Management Interview The results of the inspection were discussed with laboratory management personnel at the conclusion of the inspection on January 16, 197 Present at this meeting were O. Anders and R. Kolat of Dow Chemical Company and J. L. Belanger of IE:III. The two items of noncompliance were discussed in detail. With respect to the infraction concerning the absence oft

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communication between the facility and'~

' no rebuttal was offered. Mr. Anders objected to the second infraction"which related to the absence of access controls to{ '] It was his interpretation thaT accass to the building is controlled since the unlocked / unattended lItwaspointedoutbytheinspectorthatl /is but one of nine research laboratories within the fenced area, and that it is possible for any of the personnel assigned to these various other laboratories to gain unchallenged access to' ' It was further noted that any individual (employee / visitor / vendor)' granted access to any of the eight other laboratories within the fenced ~7 area could enter through the uncontrolled t_ M Anders in6icated that he would submit a revised security plan"to the Office of Nuclear Reactor Regulation reflecting access controls as they presently exis Messrs. Kolat and Anders were advised that affirmation of the non-compliance items would be unde in our letter to the Chairman of the Radiation Safety Committe .

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Part 2.790(d) Information L r d

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Part 2.790(d) Information REPORT DETAILS I .

Scope The physical protection inspection was conducted on January 15-16, 1976, at the Dow Chemical Company's TRIGA Research Reactor facility to determine if the licensee was complying with. the commitments set forth in their Security Plan submitted by letter dated January 3, 1974, and the security plan amendments dated July 4, 197 Introduction The inspection consisted of a review of Security Plan implementation, observation of security activities of personnel associated with the Dow TRIGA Reactor facility, and inspection end/or testing of physical barriers, alarms and security related equipt .t . Two items of non-compliance were identified during the inspectio Individuals Ccatacted R. Kolat, Pesearch Manager O. Anders, Reactor Supervisor R. Westjohn, Manager, Security and Plant Protecti0n Department S. Humbyrd, Assistant Manager of Security and Plant Protection

Inspection Results i

Security Organization The Security and Plant Protection Department is responsible for security at the Dow Chemical Company Midland plant, to include the Dow TRIGA Research ReaAtor locatgj in Building 1602. The plant protection force consists ofl uniformed, company - employed watchmen supervised by Robert B. Westjohn. The latter reports to William Lee,JHanager of Safety and Health. During non-working hours, ' watchmen are assigned to the Dow research laboratory area which consist's of nine buildings within a limited access area bordered by the fo1}owing streets:

Austin, Pershing, Barth and Washingto (See Exhibit A)

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Part 2.790(d) Informstion

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Part 2.790(d) Information PlantProtectionmaintainsf* . ,

• Contrary to Section 3.2.5 at Paragraph No. 4 and Section 3.3.7 at Pirt B of the security plan for the TRIGA research reactor, there is',"

• ((SeeSummary of Findings, Items of Noncompliance, Infraction No. 1) Mr W estjohn stated that his office formerly maintained 'with the above, but such a capability was discontinued because of ' change Fifteen watchmen have received instruction in health physics to use radiation monitoring equipment as well as procedures pertaining to radio-activity and to required security of the TRIGA reactor. They are qualified on a semiannual basis through review sessions supervised by Health Physic '

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Designated Security Are u The Dow TRIGA Research Reactor is located in

"of the Dow Chemical Company, Mf31and, MichiRa (Note:

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is one of nine researchlabof~atoryTuildings. ,(See Exhibit,A) The' buildings along the outer perimeter, to include are connected by a seven foot chain-link fence (without barb-wire exte'iision) which serves to limit access into the general area. The " ~

"is a modern one-story with basement laboratory of fireproof construction with steel frame and concrete blocks wall security plan designates the following as " essential equipment":

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Part 2.790(d) Information

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i The Reactor Control Console

. Water Purification and coolinst System l Continuous Air Monitor

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Part 2.790(d) Infor::stion ,

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,6 Access controls During the normal working hours (7:30 a.m. - 5:30 p.m., Monday through Friday) access to the research laboratory complex is gained either through the main gate, which is located on the south-central section j of the perimeter fence, or through the doors of the outer-perimeter buildings, f ' Access through the main  !

J, ate is contro11edi

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! Access to the~ main entrance of '

' is con' trolled by E"* receptionis ,

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Paragraph I.B of the Amendments to the Security Plan for the Dow TRIGA Research Reactor states, in part, with reference _t "The entire building is of controlled access." I is accessible to all employees of the research laboratory complex as well as any visitor / vendor admitted at the main gat (See Summary of Findings, items of Noncompliance, Infraction No. 2)

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Duringworkinghoursalltwenty-fiveDowemployeesassignedto[ }

l They are required to carry their Dow identification badge with photograph. Paragraph 2 of Section 3. of the physical security plan states, in part, that "Other Dow employees entering the building are also required to wear identification badges ,

. with photographs and must identify themselves as Dow employees when I i

entering the building." Since the the above ace'ess i

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control coinnitment cannot be me Non-Dow employees are furnished with a signed visitor's badge indicating name, company affiliation, and Dow escort. A copy of the badge with the visitor's signature i.s kept on record by the receptionist at the ent_rance to) ' During non-working hours, all access doors to, Authorized access is possible for the

approximately twenty technical personnel assigned tof

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E Detection Aids -

Section 3.3.7 at paragraph A.4 states that the reactor room and associated  ;

laboratory Js equipped with an intrusion monitoring system which is

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activate Paragraph A.6 of the above section states, in part, that "an electroEic intrusion monitoring system is

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. activated in,_ ]Theinspection i disclosed that the above system consists off

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Part 2.790(d) Information

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Security Program Review The security program till be reviewed by the reactor supervisor at the meetings of the Reactor Operations Committee et least once every two years. At the time of this inspection, the plan had not yet been in effect for a two year perio '

Attachments:

. Exhibits A and B

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Part 2.790(d) Information ,

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