ML20137H103

Comments on Security Breakdown at Facility in Response to N Haller 780407 Memo.Security Plan Developed & Approved Based on Interim Guidance Provided by NRC in 1974 as Means of Implementing 10CFR50.34 & 73-40 Requirements

ML20137H103
Person / Time
Site:	Dow Chemical Company, 05000000
Issue date:	05/15/1978
From:	Stello V Office of Nuclear Reactor Regulation
To:	Howard M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20136D183	List: IA-85-256, Requests That Encl Form Be Completed & Submitted by 760915 & Facility Emergency Plan & Implementing Procedures by 761007 in Order for NRC to Prepare Info Packets for Use in Responding to Incidents or Emergencies IA-85-258, Amend 3 Renewing License R-108 & Incorporating Security Plan as License Condition IA-85-261, Documents That Appropriate Corrective Actions Taken by Dow Chemical Co in Response to 780113 Immediate Action Ltr,Per 780207 Enforcement Conference at Facility IR 05000264/1973001 IR 05000264/1975001 IR 05000264/1977002 IR 05000264/1979003 ML20137G383 ML20137G390 ML20137G402 ML20137G410 ML20137G417 ML20137G432 ML20137G437 ML20137G446 ML20137G450 ML20137G460 ML20137G467 ML20137G472 ML20137G478 ML20137G487 ML20137G507 ML20137G524 ML20137G586 ML20137G600 ML20137G614 ML20137G637 ML20137G653 ML20137G750 ML20137G793 ML20137G816 ML20137G854 ML20137G875 ML20137G888 ML20137G896 ML20137G903 ML20137G908 ML20137G916 ML20137G921 ML20137G926 ML20137G931 ML20137G940 ML20137G951 ML20137G972 ML20137G976 ML20137G983 ML20137G990 ML20137G997 ML20137H003 ML20137H022 ... further results
References
FOIA-85-256, FOIA-85-258, FOIA-85-259, FOIA-85-261 NUDOCS 8508280171
Download: ML20137H103 (2)

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UNITkD STATES NUCLEAR REGULATORY COMMisslON -

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%*....+/ Mg 151978 EMORANDUM FOR: Morris Howard, Director \

Division of Safeguards Inspection, IE FROM: Victor Stello, Director Division of Operating Reactors, NRR

SUBJECT:

SECURITY AT THE DOW RESEARCH REACTOR (DOCKETNO.50-264)

In response to Nonn Haller's memorandum of April 7,1978, concerning the recent security breakdown at the Dow Research Reactor, I offer the following:

The security plan developed and approved for this facility is based on " interim guidance" provided by the staff in 1974 as a means of implementing the requirements of 6550.34 and 73.40. The level of protection required was determin,ed principally from the perceived risk of this-facility as a target for theft of SNM although the stated purpose of the interim guidance is to protect against acts of sabotage.

Inasmuch as both types of risks were not considered to be significant at this site, the approved security plan requires only a low level of control of access to and surveillance of the reactor and reactor con-trols. It is obvious that even this degree of protection was not provided during the January 10, 1978 inspection.

A review of the safeguard risks associated with this reactor has been made recently on the basis of current information related to sabotage and theft threats. The information obtained from this review was given to Loren Bush and used as the basis of the " Issue Paper" attached

' to Mr. Haller's memorandum. NRR's position is that a threat of

" radiological" sabotage does not exist at the Dow facility because a release of fission products in amounts equivalent to the limiting doses in Part 100.11 is not possible since there is no realistic means for causing such a release through core melt or destruction. Additionally, there is only minimal threat of theft of SNM because all but possibly a few grams of SNM (20% enriched in U-235) is nonnally l,ocated in the core of the 100KW reactor. Although the 3.4kg of U-235 in the fuel may not have a radiation level that is self-protecting (100 rems /hr at three feet) at all times it is considered to be a very unattractive target for theft of SNM. However, because there is the potential for illicit acquisition of a significant. amount of SNM through multiple thefts, a prudent level of protection must be provided for this, small

. quantity.

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q. Morris Howard -

1 There are obvious hazards associated with the operation of any reactor and many other problems can result from the mere existence of such a

, facility. As part of the current NRR review of non-power reactors it is our intent to reassess the need and authority of the NRC to require a security plan (650.34[c]) under the Commission's mandate to protect the public from dangers associated with radiation where these dangers are less than those provided for in Parts 20 and 100.

1 MR g Victor Stello, Jr., Direct Division of Operating Reactors Office of Nuclear Reactor Regulation cc: E. G. Case J. R. Miller R. A. Clark W. J. Ross L. Bush l

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