ML20205A963
| ML20205A963 | |
| Person / Time | |
|---|---|
| Site: | 05000433 |
| Issue date: | 04/19/1985 |
| From: | Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19269B439 | List: |
| References | |
| 50-433-85-01, 50-433-85-1, NUDOCS 8504260209 | |
| Download: ML20205A963 (2) | |
See also: IR 05000325/2004010
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APPENDIX A
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University of California
Docket No. 50-433
Santa Barbara
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As a result of the inspection conducted March 25 - April 10, 1985, and in
accordance with NRC Enforcement Policy, (10 CFR Part 2, Appendix C) the
following violations were identified:
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A.
10 CFR 50.54(p) states in part, "The licensee may make changes to the
security plan...without prior Commission approval if the changes do not
decrease the safeguards effectiveness of the plan. The licensee...shall
furnish to the. .. Director of Nuclear Reactor Regulation. . .with a copy to
the appropriate NRC Regional Office...a report containing a description
of each change within two months after the change is made."
Contrary to the above, the licensee failed to submit changes to their
security plan prepared pursuant to 70.22(h) within the two month period.
Changes made to the licensee's security plan prior to March 1, 1984,
regarding the placement of intrusion detectors and the designation of
alarm response responsibility had not been reported to the Commission as
of March 26, 1985.
This is a Severity Level V Violation (Supplement III)
B.
10 CFR 73.67(d)(ll) states in part, "Each licensee who possesses special
nuclear material of moderate strategic significance shall... establish and
maintain response procedures for dealing with threats of thefts or thefts
of such materials." The licensee's approved security plan dated May 1980
states in part on page 11: " Procedures have been established to deal with
the following incidents at the facility:.. 5) Threat of theft of special
nuclear material (and) 6) Thef t of special nuclear material. .. . The
response procedures describe the type of response to be made, duties and
responsibilities of the organizations and personnel involved. . . ."
Contrary to the above, the inspector determined through interview on
March 27, 1985, that the licensee has not prepared response procedures
for dealing with threat of theft or theft of special nuclear material.
This is a Severity Level V Violation (Supplement III)
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C.
10 CFR 73.67(d)(10) states in part: Each licensee who possesses special
nuclear mat.: rial of moderate strategic significance shall..." search on a
random basis... packages leaving the controlled access areas." The
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licensee's approved security plan dated May 1980 states in part on
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page 10: "It would be impractical to search packages....
Instead the
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cabinet (in which space fuel solution is stored) shall be sealed and the
seal inspected as part of the weekly intrusion alarm check."
Contrary to the above, the inspector observed on March 26, 1983, that the
cabinet was unsealed and no record existed of past inspections for a seal
or for the continued presense of the spare fuel solution.
This is a Severity Level IV Violation (Supplement III)
Pursuant to the provisions of 10 CFR 2.201, The Regents of the University of
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California is hereby required to submit to this office within thirty days of
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the date of this Notice, a written statement or explanation in reply,
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including: (1) the corrective steps which have been taken and the results
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achieved; (2) corrective steps which will be taken to avoid further
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violations; and (3) the date when full compliance will be achieved for these
violations. Consideration may be given to extending your response time for
good cause shown.
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APR 191985
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Dated
James L. Montgomery, Chief
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Nuclear Materials Safety and
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Safeguards
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