ML20195E588

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Forwards Memo to CE Ashbaugh Advising of Rev to Security Plan.Campus Police Will Receive Annually Abreviated Course Including,Radiation & Emergency Procedures
ML20195E588
Person / Time
Site: 05000142
Issue date: 06/16/1975
From: Brown H
CALIFORNIA, UNIV. OF, LOS ANGELES, CA
To: Engelken R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20195E559 List:
References
FOIA-85-196 NUDOCS 8806240087
Download: ML20195E588 (1)
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,, i UNIVERSITY OF CALIFORNIA, LOS ANGELES Sta12LE'T

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  • 1AM rmApruco; LAf*TA 94AadA * & ANT A Citt/E OFFICE OF LVe'tAOutENTAL HE ALTH OD SAFETY TME CENTER FOR THE MEALTH Sc**%E.8 LOG .WCELE.8. CAUTOAALA 90024 June 16, 1975 {

Ro H. En691Xen i U. S. Nuclear Regulatory Camission Region Y j

Suite 202, Walnut Creek Plars 19)0 N. California Boulevard Dalnut Creek, California 94596 Docket No. 50-142

Dear H.r. Dgelien:

Enclosed is a mencesadtaa to me from C. E. Ashbaugh, the Re40 tor Supervisor at the UCLA Nuclear Diergy Laboratory.

As indicated, va sl:an cMrtly (by June ?o,1975) submit a revised security plan to the Nuclear Regulatory Cocaission.

Theviu vM revised plan viu be provided thediffer from the prescnt one in that the campus Police, "B" key, we to receive annual.ly an abbr:viated eMrse on radiation, caergency procedures etc. instead of the regular health physics and of greaterlaboratcry procedures course required of students end others who have need knowledge.

This training for our polica officers viu be instituted tfMhin thirty days after approve.1 of the revised security plan by the URC .

I If you have say questions about this matter, please contact 29.

Sincerely,

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Hamid V. Brown, Dr. P.H.

Diritornental Health & Safety Officer HVB/14 l

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REClON V SulTE 202, W ALNUT CREEK PLAZ A 1990 N. C ALIFORNI A TOULEVARD W ALNUT C REEK. C ALIFORNI A 94596 MM 2 0 iW5 The Regents of the University Docket No. 50-142 of California Nuclear Energy Laboratory Los Angeles, California 90024 Attention: Harold V. Brown Environment, Health and Safety Officer Gentlemen:

This letter refers to the inspection of your activities authorized under NRC License No. R-71 conducted by Mr. M. D. Schuster of this office on May 20, 1975. It also refers to the discussion of our inspection find-ings held by the inspector with you and members of your staff on May 20, 1975.

The inspection included examination of activities related to physical protection against industrial sabotage and against theft of special nuclear material in accordance with applicable requirements of Title 10, Code of Federal Regulations, Part 73, "Physical Protection of Plants and Materials," your Security Plan, and license conditions pertainirg to physical protection. Within these areas, the inspection consisted of selective examinations of procedures and records, interviews with facility personnel and observations by the inspector.

Based on the results of this inspection, it appears that one of your activities was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A.

The item of noncompliance is categorized into the level as described in our correspondence to you dated December 31, 1974.

This notice is sent to you pursuant to the provisions of Section 2.201 l

of the NRC's "Rules of Practice,", Part 2, Title 10, Code of Federal l Regulations. Section 2.201 requires you to submit to this office within 20 days of your receipt of this notice, a written statement of expianation in reply, including: (1) steps which have been or will be taken by you l to correct the violation, and the results achieved; (2) steps which will be taken to avoid further violations; and (3) the date when full com-l pli'ance will be achieved.

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The Regents of the University gy.3- 2 .

of California ,

1 in accordance with Section 2.790(d) of the NRC's "Rules of Practice,"

Part 2, Title 10, Code of Federal Regulations, documentation of findings of your control and accounting procedures for safeguarding special nuclear materials and your facility security procedures are exempt from disclosure, therefore, the enclosure to this letter, the inspection report, and your response to tne item listed in the enclosure to this l letter will not be placed in the Public Document Room and will receive limited distrioution. l Should you have any questions concerning this letter, we will be glad to I discuss them with you.

Sincerely, Original (r9 E7  !

R.H.Er"'n 1 R. H. Engelken Director )'

Enclosure:

Appendix A - Notice of Violation l bec w/ encl.

IE Chie#, FS&EB IE Chief, M& PPB IE:HQ (4)

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APPENDIX A Docket No. 50-142 License No. R-71 NOTICE OF VIOLATION Based on the results of the NRC inspection conducted on May 20, 1975, it appears that one of your activities was not in full compliance with applicable NRC regulations and conditions of your license, as indicated below.

10 CFR 73.40 requires, in part, that security plans submitted to the Comission for approval shall be followed by the licensee. Your Security Plan, dated August ?l, 1974 as amcr.ded August 29, 1974 states "Level B keys are given to qualified individuals who have taken our health physics course, and who have passed the health physics and laboratory procedures test."

Contrary to 10 CFR 73.40 and your Security Plan a Level "B" key was issued to the UCLA Police Department without the required training or testing.

This infraction had the potential for causing or contributing to an occurrence related to health and safety.

IE-V-37 Copy 10

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r, NUCLEAR REGULATORY cOMMisslON A '

REGION V SULTE 202. W ALNUT C REEK PL AZ A 1990 N. C ALtFORNI A 80VLEV ARO W ALNUT CREEK, C ALIFORNI A 94596 rJUN 4 ', :

H. D. Thornburg, Chief, Field Support and Enforcement Branch Office of Inspection and Enforcement, Headquarters UNIVERSITY OF CALIFORNIA AT LOS ANGELES (UCLA)

DOCKET N0. 50-142 Enclosed is the subject report of the physical security inspection 1 conducted on May 20, 1975.

With exception of the one infraction described in the report, the l licensee is in ccmpliance with the Security Plan. However, you will note I in the report that two significant items were identified during the inspection which decrease the effectiveness of physical protection.

These were discussed with licensee management who stated that they would "look into" possible solutions. Meanwhile, I feel that the matter should be referred to Reactor Licensing who could request the licensee to revise the Security Plan to include correction of the problem areas.

- /2kkpA V. N. Rizzol6, Chief Materials and Plant Protection Branch

Enclosure:

- IE Inspection Report No. 50-14%/7502 (IE-V-60) cc w/ encl.

IE Chief, M&PP IE:HQ (4)

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U. . NUCLEAR REG 1JLATORY C0!CitSSIO!

s.0FFICE OF INSPECTZON AND ENTORCEME!G REGION V s J)! Inspection Report No. en.la? / 7cn? (TE_v_gn)

University nf califnenia at Docket No. en y g 1,,censee 1

Los Anoples - License No. R_71 Priority F l

UCLA Category 5 ,

F.acility l 1,ocation L;,. ny 1c; y jfernj; 900 3 l

Type of Facility Argonaut Training Reactor I Type of Inspection Annnunced phycical Sarnrity and va+or4=le pptes of Inspection May 20. 1975 l

pages of Previous Inspection tbne Principal Inspector

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- Physical Protection Inspector Date Ascompanying Inspectors l Date l Date Other Accompanying Personnel:

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Materials and Plant, Protection Branch Date i

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SUMMARY

OF FINDINGS

1. Enforcement Action A. Violations None B. Infractions l

Contrary to 10CFR73.40 and the licensee's security plan a level "B" key was issued to the UCLA Police Cepartment without the required training in the health physics course and testing in health physics and laboratory procedures.

C. Deficiencies None II. Licensee Action on Previously Identified Matters Not applicable III. Design Changes Not applicable l 1

IV. Unusual Occurrences l On May 20,1975 at 1343 hours0.0155 days <br />0.373 hours <br />0.00222 weeks <br />5.110115e-4 months <br /> the alarm for the radioactive storage area was received by the UCLA central station, without prior notification from the reactor supervisor. A police unit was dispatched and arrived at 1345 hours0.0156 days <br />0.374 hours <br />0.00222 weeks <br />5.117725e-4 months <br />. Investigation revealed

. that the reactor supervisor, when exiting the radioactive storage area, had reset the alarm and had not notified the police department.

This was observed by the inspector.

V. Other Significant Findings A. The Reactor High Bay Area is vulnerable to unauthorized access through the ventilation duct from either the third or eighth floors. This is not recognized in the Security Plan. (See Section VII, Paragraph C.3., Physical Barriers.)

B' . The inspector determined that the Acoustic Alarm System in the Reactor High Bay Area can be defeated, thus permitting intrusion without detection. (See Section VII, Paragraph C.S., Alarms, Response and Surveillance.)

2-VI. Management Interview Conducted on May 20, 1975 with Messrs: l Harold V. Brown, Environment, Health and Safety Officer C. E. Ashbaugh, Reactor Supervisor Jack Hornor, Resident Health Physicist The findings of this inspection were discussed and there was no disagreement with the findings or with the item of 'c.nliance.

Mr. Brown agreed to pursue possible solutions for the <; arm system and additional protection for the ventilation duct.

VII. Details l l

A. Scope l This inspection encompassed physical security and accountabilty of the training reactor located at the University of California at Los Angeles (UCLA) and evaluates compliance with the security plan of August 1974 approved by the Directorate of Licensing i on January 8, 1975. l B. Individuals Contacted Harold V. Brown, Environment, Health and Safety Officer C. E. Ashbaugh, Reactor Supervisor John C. Evraets, Radiation Safety Officer Lt. Jymes Carter, UCLA Police Department Jack Hornor, Resident Health Physicist C. Inspection Audit Program

1. Physical Security Plan l The licensee possesses an approved security plan and no changes have been made in the plan which decreases its effectiveness. ,
2. Security Organization l

The security organization as described in the licensee's security plan was verified. The UCLA police department includes 55 sworn, uniformed and armed police officers with a minimum of 6 officers in radio-equipped cars on i duty per shift. Twenty-four hour, 7-days a week coverage is provided the University and is responsive to the needs of the Reactor Supervisor.

l The training) job training received of by members (4this months plus 2corrplies department months on-the-with the California Police Officers Standards and Training course taught other major police departments within the State of California.  ;

The licensee's security plan states "Level "B" keys are given to qualified individuals who have taken our health physics course, and who have passed the health physics and laboratory procedures test". One level "B" key was issued to the UCLA police department without the required training or testing. This was identified as an infraction.

In addition to the UCLA pol ce, response and back up is I available from the West Los Angeles Police Department. A mutual aid agreement has been signed.

3. Physical Barriers l The training reactor is located in Room 2567, a north- .

south wing, connecting the Mathematical Sciences and l Boelter Hall buildings. These buildings are centrally located within the UCLA campus.

The physical barriers, e.g., walls, floors, are as described in the licensee's security plan.

- Overall physical barrier protection is deemed inadequate to prevent an act of sabotage. Figure 11 of the licensee's security plan delineates a ventilation duct. Inspection of that duct revealed the grill work, covering an opening approximately 3x4 feet, was secured by four 1/8" diarreter rews. Examination of the grill work also revealed that is appeared it could be removed with a minimum of effort.

Two entrances to the unprotected ventilation duct are possible through the 3rd and 8th floors. The 3rd floor entrance is possible from the patio via the ventilation inspection room. Door construction and lock hardware are insufficient to prevent picking or rapping. The 8th floor entrance is possible from the roof through an adjoining building. The ventilation shaf t on the roof was secured by

. a padlock insufficient to prevent picking or cutting.

4. Access Controls The licensee controls access by means of escorts, visitor's register, alarms and key control systems.

4 All visitors are escorted within the protected and vital areas, and required to sign a visitor's register. All doors leading into and within the Nuclear Energy Laboratory are under a lock and key system comprised of three levels:

A, B, and C. The degree of access permitted by those keys is shown in Figures 11 and 12 of the licensee's security plan. Level A keys are master keys and are given to only permanent, full-time employees. Level B keys are issued to qualified students, police department, secretary

-and custodian. Level C keys are issued to unqualified students for office space or use of the library. Key control records are maintained by the Reactor Supervisor and all keys were accounted for. No key inventories have been conducted.

The reactor high bay and the radioactive storage have been designated as security (vital) areas. The. door to the reactor high bay can be opened only with an "A" level key. The door of the radioactive storage room can be opened only with an "A" level key and the combination to the Sargent and Greenleaf mr.bination padlock. Only the Reactor Supervisor and the Health Physicist have both.

5. Alarms, Response and Surveillance (See also Section IV, Unusual Occurrences.) The location and type of the alarm system described in the licensee's security was verified. The ultrasonic motion detector, model ICMC 132, manufactured by Walter Kidde and Company, Inc., Belleville, New Jersey, failed to alarm during the three tests conducted. (Two tests were performed by the inspector and one test by the Reactor Supervisor.)

Simulating access through the ventilation duct, the inspector was able to reach the reactor and return to the ventilation duct without detection. The test was repeated by both the inspector and the Reactor Supervisor, with the same results. .

In July 1971 a technical evaluation of this equipment (Kidde ICMC-132) was published by the Technical Branch, Division of Security, AEC. They concluded in part that:

. a. Did not meet the requirements of AEC Manual Chapter Appendix 2401, Part III and

b. Interim Federal Specifications W-A-00450A (GSA-FSS),
c. Disapproved its use for AEC insta.llations.

All alarms annunciate in the UCLA Dispatcher's Office (manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day).

Surveillance of essential equipment is performed during working hours by the permanent employees , level "A" key holders. Surveillance during nonworking hours is performed by a combination of the alarm system (considered inadequate) and the UCLA Police Department.

6. Special Nuclear Material 1

Fuel for the Argonaut-type research reactor is in the form I of aluminum clad ~93% EU-Al alloy fuel plates assembled into l MTR type fuel assemblies.

The inventory of special nuclear material is as follows:

U (G) U-235(G)

Fuel - In Core 3,805 3,540 Irradiated - In Cooling Basin 793 738 Other unused materials 4,909 4,571 9,507 8,849 In addition to the reactor fuel, the University also possesses two plutonium beryllium neutron sources in conjunction with the operation of the reactor. One source is licensed under the reactor license R-71; the other is licensed under SNM-974 The inventory was as follows:

Plutonium (G) Fissile Isotoce (G) l Pu-Be Sources 64 60 The bulk of the unused materials noted above, 4,0229 U and 3,7459 U-235, consists of unused f0el assemblies on hand since 1971 (fabricated by Atomics International).

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