ML20205E536
| ML20205E536 | |
| Person / Time | |
|---|---|
| Site: | Dow Chemical Company |
| Issue date: | 03/02/1978 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Haller N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20205E202 | List: |
| References | |
| FOIA-85-259 IAL, NUDOCS 8510170322 | |
| Download: ML20205E536 (24) | |
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j MAR 0 21978 MEMORAh'DUM FOR: Norman H. Haller. Director. Division of Safeguards Inspection. IE FROM:
James C. Keppler. Director. R111
SUBJECT:
D0k' CHEMICAL COMPANY - RECOMMENDED CIVIL PENA 1.TY
- During a recent security inspection at the subject licensee's '"RICA Reactor facility, two Rill inspectors gained unchallenged access from outside the licensee's f acility through a limited control access area and into the licensee's reactor building and reactor room, areas which are required to be controlled by the licensee's security plan.
After about ten minutes inside the security area, the inspectors identified themselves to licensee personnel.
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A second item of noncompliance relating to access control was also identified. Noncompliance with this same area of access control was found during the previous security inspection at this facility. Because of the significance of the one item of noncompliance and the repetitive nature of items related to access control, we recommend that a civil
, penalty be issued to the subject licensee.
Upon completion of the inspection we issued an Immediate Action Letter on January 13, 1978 (copy attached).
A reply from the licensee (copy attached) did not indicate a full response, but during the enforcement conference held at the licensee's f acility on February 7,1978, it was confirmed that the licensee did, in fact, take prompt steps to carry out the items set forth in the immediate action letter.
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Attached for headquarters use is a letter to the licensee with the appropriate notice of violation and proposed imposition of civil penalties.
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c35a=es c. xepri'fr Director Attach =ents:
1.
Draft Itr v/ Appended Notice of Violation (Part 2.790(d)
Information) and Notice of Proposed Imposition of Civil Penalties 2.
Draft Inspection Report (Part 2.790(d) Information) 3.
Ic=ediate Action Letter dtd 1/13/78 (Part 2.790(d)
Information) and licensee's response dtd 1/19/78
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E. Volgenau, Director J. C. Davis, Deputy Director t
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Docket No. 50-264 Dow Chemical Company ATIN: James H. Hanes Vice President and General Counsel Building 2030 Midland, MI 48640 Gentlemer.:
During an inspection of the TRIGA Research Reactor facility on January 10, 1978, inspectors froe our Region III (Chicago) of fice entered the security area of the reactor building from outside the limited access area without This constitutes a violation being challenged regarding their identity.
This item and two other items of noncompliance 4
of your security plan.
forth in Appendix A to this identified during the inspection, are set One of the other items also relates to the matter of inadequate letter.
In view of the significance of these items 1
access control pr)cedures.
and the finding of a noncompliance item similar in nature during a previous inspection in January 1976, we plan to impose civil penalties in the In amount of Two Thousand Dollars ($2,000) as set forth in Appendix B.
responding to this letter, you should follow the instructions in Appendix A.
We acknowledge that following the inspection, you took action to limit access to the reactor building according to the steps outlined in the January 13, 1978, letter from Region III. In addition to describing the specific action you have taken to correct the items of noncompliance set forth in Appendix A, your response should focus on the long range management control actions being taken to assure continued compliance with the requirements of your security plan.
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s Dow Chemical Company The information in Appendix A concerns a subject matter which is exempt from disclosure according to Section 2.790 of the NRC's Rules of Practice.
Part 2. Title 10, Code of federal Regulations. Accordingly, our report of the January 10-12, 1978 inspection (50-264/78-01), the enclosed Appendix A and your response ti the items listed in Appendix A, will not be placed in the Public Document Room.
We wish to reiterate the necessity of taking prompt management action to assure full compliance with NRC requirements in the future. We plan to continue to conduct unannounced inspections to determine whether such action has been taken. Our findings and your reply to this letter will determine whether any further enforcement action, such as additional civil penalties or orders, are required.
Sincerely, E. Volgenau Director. IE Enclosurest 1.
Appendix A. Notice of Violation (Part 2.790(d) Information) 2.
Appendix B. Notice of Proposed Imposition of Civil Penalties cc w/encist Dr. Ralph Langner, Chairman Radiation Safety Committee Central Files Reproduction Unit MRC 20b cc w/o encist PDR
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Part 2.700(d) Informatica Appendix A
'm NOTICE OF VIOLATION Docket No. 50-264 Dow Chemical Company This refers to the inspection conducted by representatives of the Region 111 (Chicago) office at the Dow TRIGA Research Reactor Facility Midland, Michigan, of activities authorized by NRC License No. R-108.
During this inspection conducted on January 10-12, the following apparent items of noncompliance were identified. Item 1 is considered to be a violation. Item 2 is considered to be an infraction.
Item 3 is con-sidered to be a deficiency.
10 CFR 73.40 requires that each ifcensee shall provide physical pro-tection against industrial sabotage and against theft of special nuclear material at the fixed sites where licensed activities are conducted.
To this end, security plans submitted to the Commission for approval shall be followed by the licensee after March 6, 1974. The Dow TRIGA Research 1
Reactor Tacility Security Plan was submitted to the Directorate of Licensing by letter dated January 3,1974 and was subsequently found acceptable as amended August 28, 1974. The revised Security Plan for the Dow TRIGA Research Reactor Tacility submitted to NRC by letter dated Tebruary 24, 1976 was approved by NRR on April 2, 1976.
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Fa'HT.790[d] Infarmat102 Appendix A 1.
Section 3.3.7(B) of the revised Security Plan for the Dow TRIGA Reactor Facility which,vas approved April 2. 1976 describes the limited access area and provides that access to this area is con-
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trolled by entry through i
which border the limited access area. Access to lis controlled through the front entrance of the building.
Contrary to the above access to,
,'was not controlled nn January 10. 1978 in that NRC inspectors gained undetected and
'nto the limited unchallengedaccessthroughthe{
i acces.areaandfurtherintothk (andthereactor root.
This violation had the potential for causing or contributing to an occurrence related to security.
(Civil Penalty - $1500) 2.
Section 3.3.7(C)(1) of the revised Security Plan for the Dow TRICA Research Reactor Facility which was approved April 2, 1976 requires that Dow employees, other shan those normally employed in'
,who enter the building, are required to carry identification q.
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Appendix A '
Ladges with photographs and must identify themselves as Dow employees when entering the building. The sign-in procedure at the receptionist's desk at the front entrance to the f_
is the accepted method for other than permanently assigned employees to identify themselves.
Cor.trary to the above, it was observed on January 10, 1978 that a Dow employee in the building.,other than a permanent building employee, was not carrying his Dow photo identity badge and had not identified himself as a Dow employee by signing in as he entered the building.
(Civil Penalty - $500) 3.
Section 3.2.5(5) of the revised Security Plan for the Dow TRIGA Reactor Tacility which was approved April 2, 1976 requires that officers of the plant protection and security force will be requalified on a semiannual basis through review sessions.
Contrary to the above, according to training records and interviews, officers of the plant protection and security force have attended requalification sessions only on an annual basis.
(Civil Penalty - $0)
Part 2.793(d) Information
Part 2.?p0(c) Irfer:sti, ggt Appendix A -
In addition to the above items, it was determined during the inspection that thi untrusion alarm. D the reactor room, while activated, required an by the inspectors to cause the device to alarm, making the detector ineffective. We understand that you had the detectors checked for operability shortly before the inspection, but were not aware of the criteria used to determine the operability of the detectors In your response, please describe your action to assure I
that your intrusion alars system will effestively respond to Include your plans for frequency of testing and criteria for deters ing effective operability.
The " Criteria for Determining Enforcement Action," which was provided to NRC licensees by letter dated December 31, 1974, delineated the enforcement options available to the NRC as including administrative actions in the form of written notices of violation, civil monetary penalties, and orders pertaining to the modification, suspension or revocation of a license. After careful evaluation of the nature and n eber of items of noncompliance and the repetitive nature of one such itas, this office proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954 as amended (42 USC 2282) and 10 CFR 2.205. in the etmulative amount of Two Thousand dollars
($2,000), as set forth in the " Notice of Proposed Imposition of Civil Penalties," enclosed herewith as Appendix 3.
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Appendix A This notice of violation is sent to Dow Chonical Company pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice " Part 2 Title 10, Code of Pederal Regulation. Dow Chemical Company is hereby required to submit to this office, within twenty (20) days of its receipt of this notice, a written statement or explanation in reply, including for each item of noncompliance; (1) admission or denial of the alleged item of noncompliance; (2) the reasons for the items of noncom-pliance, if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further noncompliance; and (5) the date when full compliance will be achieved.
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Appendix B d.
NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES Docket No. 50-264 Dew Chemical Company c
This office proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (42 USC 2382), and to 10 CTR 2.205 in the cumulative amount of Two Thousand Dollars ($2,000) j for the specific items of noncompliance set forth in Enclosure A to 1
the cover letter. In proposing to impose civil penalties pursuant to i
this section of the Act and in fixing the proposed amount of the penalties, the factors identified in the statements of consideration published in the Tederal Register with the rule making action which j
adopted 10 CTR 2.205 (36 TR 16894) August 26, 1971, and the " Criteria for Determining Enforcement Actions," which was sent to NRC licensees
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on December 31, 1974, have been taken into account.
Dow Chemical Company may, within twenty (20) days of receipt of this notice, pay the civil penalties in the cumulative aucunt of TWo Thousand Dollars ($2,000) or may protest the imposition of the civil penalties in whole or in part by a written answer. Should Dow Chemical Company 1
fail to answer within the time specified, this office will issue an l
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order imposing the civil penalties 1n the amount proposed above.
Should Dow Chemical Company elect to file an answer protesting the civil l
penalties, such answer may (a) deny the items of noncompliance listed i
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s 2-Appendix B in the Notice of Violation in whole or in part, (b) demonstrate exten-unting circumstances, (c) show error in the Notice of Violation, or (d) show other reasons why the penalties should not be imposed.
In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g., giving page and paragraph numbers) to avoid repetition.
Dow Chemical Company's attention is directed to the other provisions of 10 CFR 2.205 regarding, in particular, failure to answer and ensuing orders; answer, consideration by this office, and ensuing orders; requests for hearings, hearings and ensuing orders; compromise; and collection.
Upon failure to pay any civil penalty due which has been subsequently l
determined in accordance with the applicable provisions of 10 CFR 2.205, i
the matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Atomic Energy Act of 1954, as amended. (42 USC 2282).
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L U.S. NUCLEAR REGULATORY COMMISSION OTTICE OF INSPECTION AND ENFORCEMENT REGION III Report No. 50-264/78-01 Docket No. 50-264 License No. R-108 Licensee: Dow Chemical Company Building 2030 Midland, MI 48640 Facility Name: Dow TRIGA Research Reactor Facility Inspection at: Dow TRIGA Research Reactor Facility Site, Midland, MI Inspection conducted: January 10-12, 1978 Inspectors:
T. J. Madeda J. J. Dunleavy Approved by:
J. A. Hind, Chief Safeguards Branch Inspection $ramary Inspection on January 10-12. 1978 (Report No. 50-264/78-01)
Areas Inspected: Routine, unannounced inspection of the approved i
security plan and its implementation relative to the protection of SNM; security organisation; access control; alarm systems; key, locks, and hardware; communications; surveillance; procedures; security program review; and protection against radiological sabotage.
Additionally, the inspectors reviewed the licensee's corrective action relative to two items of concompliance identified during the physical protection inspection conducted January 15 and 16, 1976.
The inspection involved 30 inspector-hours onsite by two NRC a
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Results: Of the eleven areas inspected, no apparent ites of noncom-pliance were identified in eight areas; three items of noncompliance were identified in two areas (Security organization - Paragraph 5; and Access Controls. Paragraph 6.a and 6.b. One ites is considered to be a violation, one item is consjdered to be an infraction, and one itec is considered to be a deficiency.
Attachment:
Details (Part 2.790(d) Information)
S-T3 Copy of copies Pages.
THIS DOCUMENT IS NOT TO B REPRODUCED WITHOUT SPECIT APPROVAL OF R111 i
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DETAILS
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Persons Contacted
- R. Westover. Research Manager Analytical Laboratories. Dow Chemical
- 0. Anders. Reactor Supervisor. Dow TRIGA Research Reactor Pacilit;
- M. Kelyman, Manager. Security and Plant Protection. Dow Chemical
- S. Humbyrd. Assistant Manager. Security and Plant Protection, Dow Chemical
- D. Barsten. Health Physicist. Dow Chamical
- T. Quinn. Senior Reactor Operator. Dow TRIGA Research Reactor Tacility V. Turkelsen. Research Chemist. Dow Chemical K. Kelly, Research Chemist. Dow Chemical 4
K. Teaster, Office Assistant. Dow TRIGA Research Reactor Pacility H. Spillers. Journeyman. Refrigeration. Dow Chemical s
L. McJames. Captain. Security and Plant Protection. Dow Chemical J. Thompson Special Services Supervisor. Security and Plant Protection. Dow Chemical V. Sanasran. Lock and Key Supervisor. Security and Plant Protection,
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Dow Chemical K. Compton. Security Officer. Security and Plant Protection.
Dow Cheatcal i
J. Reed. Diapatcher. Security and Plant Protection. Dow Cheatcal D. Langner. Health Physicist. Dow Chemical l
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R. Smith. Captain. Security and Plant Protection. Dow Chemical
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- Denotes those present at the exit interview.
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2.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (050-264/76-01):
Failure of the Security andPlantProtectionDepartmenttomaintainf f
1 By way of response the licensee submitted a revised security plan to NRR reflecting actual security practices at the site relative to this item.
Therevisedsecurityplanwasapprovej en April 2,1976 and is considered, therefore, corrective action.
(Refer to Paragraph 9) Region 111 has no further questions on this item.
(Closed) Noncompliance (050-264/76-01): Theentire(
J is not of controlled access during the in that, the By way of response the licensee submitted a revised security plan to NRR reflecting actual security practices at the site relative to this item.
The revised security plan was approved by NRK on April 2,1976 and is considered, therefore, corrective petinn.
(Refer to Paragraphs 6.a and 6.b) Region Ill has no further questions on this item.
The following ites, which is not an ites of noncompliance, was identified during a previous physical protection inspection (050-264/76-01) as a significant weakness in the security system.
(Closed) As forcible entry through the' a modification to the security plan, to taclude the
\\ under alara protection, should be
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and subsequently approved on April 2, 1976 the revised security Region III
- plan, has no further qdestions on this ites.
3.
Security Plan The inspectors reviewed and evaluated the licensee's revised security plan which was approved by NRR on April 2,1976.
The inspectors determined that no change to the approved security plan has been made subsequent to that date.
The inspectors also reviewed the licensee's security areas and essential equipment to assure that they are properly designated in the approved security plan.
No items of noncompliance or deviations were identified.
4.
Protection of ShH The inspectors determined that the SA! actually possessed by the licensee for the Dow TRICA Research Reactor is below the threshold quantities outlined in 10 CTR 73.1(b).
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No items of noncompliance or deviations were identified.
5.
Security ornanization The inspectors,deterzined that the licensee is conforming to concitments stated in the approved security plan concerning the overall structure and functional responsibilities of the security organization. This was determined through interviews with super-visory and operational staffs of the Dow TRICA Research Reactor and the So.urity and Plant Protection Department and by review of pertinent records.
It was revealed through personnel interviews with members of the Security and Plant Protection Department and confirmed by the Supervisor of the Health Physics Department that fifteen officers of the security and plant protection force are not requalified on a semiannual basis, through review sessions supervised by Health Physics, on the use of radiation monitoring equipment and on the following of the procedures in ef fect pertaining to radioactivity and guarding the Dow TRICA Research Reactor. Such requalification was found to be on an annual basis only.
These findings represent apparent noncompliance with Section 3.2.5(5) of the approved Security Plan for the Dow TRICA Reactor Faciaity which states part: '"Tifteen' officers of the plant protection and security force have received instruction in health physics to use radiation monitoring equipment and follow the procedures in effect pertaining to radioactivity and guarding the Dow TRIGA Research Reactor.
They are requalified on a semiannual basis through review sessions supervised by Realth fji3_h',0. !3; 1. t rr-*! :
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Access Control Evaluation of the access control system in effect at Dow Chemical was based on visual observation, personnel interviews, and physical testing.
Testing of the licensee's access control procedures gov-a.
erning admittance to the limited access area to include-the as detailed in the approved security i
plan, revealed that the inspectors were able to gain i
undetectedandunchallkngedaccessintothelimitedacces area to include the Specifically, the j
inspectors entered the at the perimeter of the limited access area at 1:40 p.m. on January 10, 1978, and proceeded unchallanged and apparently unobserved by the receptionist through the into the 1
interior of the limited access area.
Further, the inspectors were able to proceed across the interior of the fence.d in city block and enter the, at P
papitebeingobservedinthebuildingby no fewer than five authorised individuals, two of whom were near the reactor control room, the inspectors accom-l plished unchallibged access to the raector control room and to the reactor room itself.. Approximately ten minutes t
after entering the and emperiencing un-limited access, the inspectors N ported their presence to an authorized individual working near the reactor control room.
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W E*iD0ld) laterantion EO It should be noteIl that 'the NRC inspectors were refused admittance into the limited access area by a member of the plant protection force when the inspectors initially sought entry into the limited access area through the guard controlled gate north of the These findings represent apparent noncompliance with Section 3.3.7(b) of the approved Security Plan for the Dow TRIGA Reactor Facility which states in part: "The enclosed plan drawings and sketches - - - of the facility depict the limited access area consisting of the fenced-in city block borJered by - - - Austin, Pershing, Barth, and Washington.I Access is gained through the doors of the 1
buildings ~in the limited access area, includingI "ThefrontentranceofthIbuilding is of controlled access.
Other access to the building 7s through the above limited acce.;s area."
b.
During a review of access control procedures, it was observed by the inspectors that a Dow employee other than a perman-ently assigned employee was performing main-tenance on refrigeration equipment in the It was revealed through an interview with the individual that he had not signed-in and he was not carrying his Dow photo identity badge both of which are required for access to the
, It should be noted that the sign-in procedu,re at the receptionist's desk at the front entrance o
to the,
is the accepted method for other than permanently assigned employees to identify themselves.
The receptionist was unaware that the workar was in the
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These findings represer.t apparent noncompliance with Section 3.3.7(C)(1) of the approved Security Plan for the Dow TRIGA Reactor Facility states in part:
"Other Dow employees entering the building are also required to carry identification badges with photographs and must identify themselves as Dow ecployees when entering the building."
7.
Alare Systec During a test of the alarm system on January 11, 1978, it was revealed that the intrusion alarm in the e=
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Reactor Room did not effectively operate in that it failed to detect the presence of the inspector during a series of tests.
Only after by the inspector did the intrusion alarm effecIively operate. *
,The licensee advised that corrective action would 1.
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Keys. Locks, and Hardware The inspectors reviewed lock and key procedures, as they pertain to the licensee's security plan, by visual observations and During interviews with staff and oper-personnel interviews.
security plan ational representatives, it was confirmed that
.and comitments for the issuance of keys to the It was further obse'rved to the reactor room are adhered to.
that such keys are adequately controlled to reduce the probabflit of compromise.
No items of noncompliance or deviations were identified.
9.
Comunications No items of noncompliance or deviations were identified.
10.
Surveillance The inspectors determined that the licensee is conforming to
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commitments stated in the approved security plan.
The licensee's conformance was so determined through visual obser-vation, personnel interviews, and review of associated records and tapes.
No items of noncompliance or deviations were identified.
11.
Procedures
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The inspectors reviewed and evaluated the reactor security pro-cedures outlined in the approved security plan which pertain to the (1) response to unauthorized intrusions of security areas; (2) bomb threats; and (3) acts of civil disorder.
By review of operating procedures and through interviews with operating, supervisory, and security personnel responsible for the initial and/or any backup response in such situations, the inspectors determined that procedures have been implemented and are in effect.
No items of noncompliance or deviations were identified.
12.
Security Program Review The inspectors determined through a review of related correspondence, an evaluation of internal procedures, and through interviews with the reactor supervisor that the security program of the facility, as committed to in the approved security program, has been an ites for review and discussion by the reactor supervisor at the meeting of the Reactor Operations Committee during the past twe years.
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No items of noncompliance or deviations were identified.
- 13. Protection Against Radiological Sabotage J
During the inspection of the Dow TRIGA Research Reactor, the inspectors determined that access to the reactor rabbit tubes is limited to those individuals authorized to be in the The use of the rabbit tubes for experimentation is further limited to individuals who have been duly authorized.
The actual operation of the rabbit tubes is perforced by the control room only upon written authorization.
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14.
Exit Interview The inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on January 12, 1978. The inspectors sunarized the purpose and the scope of the inspection and the findings. The inspectors expressly reemphasized the seriousness of the concern felt over the apparent breakdown in effectiveness of the access control procedures employed by the licensee and advised the licensee that RIII would be in contact with them on this item. The licensee representatives stated that the receptionists monitoring access into the buildings
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forming the perimeter of the limited access area are under the control and supervision of the respective building managers and are not centrally controlled or supervised by the Security and Plant Protection Department.
There was, however, no substantive rebuttal to the apparent l' ems of noncompliance. The licensee t
representatives advised that they would begin corrective action famediately.
An Enforcement Conference to further discuss the findings of t
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the January 10-12, 1978 inspection was held on February 7,
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1978 by C. Morelius, Assistant to the Director, J. Donahue, Chief. Security and Investigation Section Safeguarda Branch, and J. Dunleavy, Physical Security Specialist, Rwgion III and G. Kochanny, Jr., Research Managet. Dow TRIGA Research Reactor, W. Lee, Manager, Health, Safety, and Security, L. Bute Attorney, and J. Dix, Attorney, Dow Chemical Con:pany.
There was no substan-tive rebuttal to the apparent items of noncompliance. The Ifeensee representatives outlined the scope of corrective action and advised that such action had been initiated.
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