ML20235W057

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Partially Deleted Safeguards Review Rept Re Licensee 840710 Amend 7 to Physical Security Plan for Protection of SNM of Moderate Strategic Significance Dtd Mar 1980
ML20235W057
Person / Time
Site: 05000142
Issue date: 10/18/1984
From: Mcqueen A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Schuster M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20235V882 List:
References
FOIA-85-196 RV-SEPL-00028, RV-SEPL-28, NUDOCS 8903100478
Download: ML20235W057 (6)


Text

- _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _

i t

/yo escg'o UNITED STATES

  • y ( [)

'g NUCLEAR REGULATORY COMMISSION e

REGION V A

-d uso MARIA LANE.SulTE J1o VD g..w.h.. /

WALNUT CRE E K. CALIFORNIA 94f 9b October 18, 1 984

-l MEMORANDUM FOR:

M. D. Schuster, Acting Chief, Safeguards and Emergency Preparedness Branch, RV /TMS e///;/f'/

FROM:

A.

D. McQueen, Region V Security Licensing Reviewer

SUBJECT:

SAFEOUARDS REVIEW REPORT - LICENSEE SECURITY PLAN REVISION:

DN 50-142 RV CASEWORK CONTROL NUMBER:

RV-SEPL-00028 Backgrounds With a letter dated July 10,

1934, the University of California at Los Angeles (UCLA) submitted Amendment 7 to the approved Physical Security Plan for the Protection of Special Nuclear !!a-terial of Moderate Strategic Significance, dated March 1980.

By lette.r dated June 14, 1984, to NRC Chairman Nunzio J. Falladi-no, UCLA Chancellor Charles E.

Young notified the NRC that UCLA was withdrawing their application for renewal of the license for' the UCLA research reactor (DNf 50-142, License i R-71).

This L

change submitted subsequent to that notification appears to im-plement security for the reactor and nuclear materials pursuant to'the decommissioning process.

A telephone discussion of changes in this licensee submittal was conducted between the NEL security officer and the undersigned on October 18, 1984, to clarify minor questions regarding change items not fully clarified within the submittal.

This amendment involves several word, procedural, and hardware changes in the plan.

A description of the changes and an evalua-tion of their acceptance is presented below.

Evaluation (Page 1 4,-

Section 1.4)

The phrase

"... fuel 1.

Revision plates are stored in an Insalated Record Safe..." is amended to read a... fuel plates can M stored in an Insulated Record Safe.."

Further down in the same paragraph, a phrase

"..is stored.."

is change to read "..can be stored.."

Comment This change is cosmetic it that there are no longer any new fuel plates at the licensee 2s site for storage in the safe.

Licensee nonetheless retains the, capability to do so I

Informatica in this record was deleted h mtnce y ah the recera of Inictmation AcL RCphs -

nn :M-194-8 3100478 870306 gM-FOIA ~

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should they again have cause to receive fuel plates, which is not their intent.

This change is acceptable.

(Page 1-5, Section 1.4)

Sentence.1,s changed 2.

Revision from

"..and a Kaman 1001-A neutron generator." to read "..and a

one Curie CO-60 radioisotope source."

In a subsequent paragraph, a

4 curie Co-60 radioisotope is deleted as stored in the reactor high bay full storage pits.

A sentence formerly covering permissive entry by A-Level access as being regarded neglible is i

l deleted.

UCLA has disposed of the Kaman generator and one of' Comments the Co-60 radioisotope

sources, therefore these changes are cosmetic updates to reflect what exists in fact. The deleted sen-tence was not a substantive part of the security system, there-
fore, its deletion does not appear to detract from the system.

This change is acceptable.

(Page 2-1, Section 2.1)

Sentence is chan ed to 3

Revision indicat whereas the plan.formerly read Also a subparagraph is added at the bottom f

thi e indicati

" Reactor Hi h B

doors have

~

These changes apparently enhance the plan by adding Comments security system is apparent.

This change is acceptable.

(Page 2-2, Section 2.2.1)

Accountability for 4.

Revision lockup and reactivation of the alara system is altered by indicating the signup clipboard is at a position near the master alarm control unit instead of the " control room electric strike

"...who unlocks the con-key control master unit."

The

phrase, trol room electric strike key control system..." is deleted from the accountability sentence.

Location of the signup clipboard appears irrelevant Comments so long as it is accessible *to the accountable persons.

The

" control room electric strike key control system" which formerl functioned du working hours is no lo er used The change does not egrade the security system and is therefore cosmetic.

This change is acceptable.

2

(Page 3-1, Section 3 1.1.1)

The phrase "a full 5.

Revision time NEL staff employee or faculty member," is changed to read "a full time University employee."

This represents a change of one condition of eight Comments required-for A-Level key issue.

All other conditions are ancillary and must still be met as before.

With..the major changes taking place in planning for decommissioning of the reactor, more flexibility was deemed needed by the licensee..The only persons thus far affected by this condition change have been engineering faculty members who have been appropriately authori-zed access to the NEL.

Key control is still tightly managed by the NEL security officer, therefore no notable degradation of security measures or procedures is apparent in this condition re-wording.

This change is acceptable.

6.

Revision (Page 3-2, Section 3 1.1.4)

The words "

..or Tokamak.."

is added to the NEL staff consultant as a

condition for issue of B-Level keys at the Laboratory.

Comments The Tokamak facility is directly adjacent to the reactor F96m" (see figures 4 and 5) and B-Level keys are noW*

scShridered security areWFYeys by plan definition, therefore this

'clange appears cosmetic.with no substantive inpact on the reactor o,r SNM security system.

57 tis change is acceptatie.

(Page 3-2, Section 3 1.2)

The criteria ewhile

~

7.

Revision he'is in the CAA's, he will be escorted" is deleted for visitors hot issued keys.

e 4

Comments Deletion of this statement here does not appear to impact since section 3 5 of the plan eequires that "All indivi-duals not authorized unescorted access (visitors) shall be escor-ted by an authorized escort."

Its mention here (section 3 1.2) was redundant.

This change is acceptable.

B.

Revision (Page 3-2, section 3 1 3 1)

This change adds

" social security number or passport number, and driver's license number" to the data in the Laboratory Security Officer card file for key issuance.

The criteria " status" is deleted from to the data.

Comments This change represents an apparent upgrade in the security system since a form of positive ID is noW required by the security officer for key issue, whereas none was necessany

  • before.

Deletion of " status" does not' appear to degrade since the Nuclear Engineering Laboratory (NEL) Director must still 3

c l

l

approve access by his signature.

This is an administrative / pro-cedural form of control.

Further, " status" is undefined here.

This change is acceptable.

(Page 3-2, Section 3 1 3 2)

The phrase "An 9.

Revision issued photo ID card (Building Use Permit) signed by the Laboratory Security Officer" is restated as "A photo I6 card."

Criteria for the University photo ID card, subse*-

Comments qently described in section 32, appears identical to the Building Use Permit card, therefore the system substantially re-mains the same. In that such ID card and its issue can be reddily substa'tively degrade verified, this change does not appear to n

the security system.

See also the discussion of the University ID card in item 10 below.

This change is acceptable.

(Page 3-3, Section 3 2)

The phrase

..a 10.

Revision Building Use Permit card (ID Card)" is changed to read

" Building Use Permit or University ID card."

Also, the Campus Police De-partment is added to the Laboratory Security Officer as an issue -

auth'ority for ID cards.

The term " completion of the health physics orientation session" replaces "an examination" as a

condition for entry at the facility.

Comment's This enange reflects an updating of the UCLA identification system in general.

All campus ID cards are now issued by the Campus Police.

They can therefore be revoked or cancelled immediately by computer based on a phone call for reason.

All ID cards issued to faculty members cleared for the NEL or Tokamak facilities so indicate on the face of the card.

The NEL security officer still issues Building Permit Use ID cards to students having a legitimate need for access.

This change appears to enhance the security system This change is acceptable.

(Page 3-5, section 3 4.1)

For issue of B-Level.

11.

Revision

keys, criteria is changed from ".. laboratory health physics course and who have passed.the health physics and laboratory procedures test" to ".. health physics orientation session."

In that the rea.ctor has been unloaded of fuel and Comments will no longer operate, the former health physics course is no longer applicable to facilit,y operations (e.g.,

no criticality, no argon gases, etc.)

The " health physics orientation sessions" were developed to address the situation and safety as it

truely, currently exists.

This change appears to have been necessary for health safety reasons and is therefore cosmetic.

This change is acceptable.

4

m (Page 5-1 Section 5.0)

The logging of alarm 12.

Revision status is changed from " recorder" to " dispatcher or recorder."

So long as the commitment to log alarm status Comments remains in

tact, there appears no degradation in either the dispatcher or the recorder doing the logging.

In this case, the change appears to offer flexibility in accomplishing;the task by more than one means.

This change is acceptable.

(Page A/4, Figure 4) 13 Revision s deleted from the fi ure.

This had involved These do now appear as The door Two reactor room doors have been sealed.

to be an improvement in that it reduces the total number of doors involved by two and shor the ese ency exit path from the reactor room to saf s an apparent security upgrade.

l This change is acceptable.

(Page A/S, Figure 5) 14.

Revision is added to the 1 nd to the These changes adding epresent Comments urin o

n tha In that is not in cat as a security or as providing access to a security area th pparent downgrade of security in addition of a This change is acceptable.

(Page A/6, Figure 6)

Stairwell doors at the 15.

Revision entr t

onctive Stora R

ar en chan ed by The addition of a as Comments well as the a

lan a rit u

rade.

The tr e off of one appears to be a substitut on of 5

0 one security entry way for another in a situation where neither door allows direct access to a security are in any respect.

This change is acceptable.

(Page A/8, Table 1)

Stored nuclear materials 16.

Revision

)

on site shows a reduction of 5 grams in the amount of,U-235 in MTR fuel plates in the reactor.

The table further ' indicates licensee has disposed of one of the former two (32 sm)

Plutonium Beryllium sealed sources previously reported.

A review by a RV MC&A inspector of this c h a n g e,.

Comments indicated it,.ap. pears the 5 sm loss is reasonable as aburg-up="

given the time period involved (April 1981 to July 1984), feels this arall diffgerence poses no apparent prob g in ac,ceptatt,Q ( g oA this change notification.

'I,

h an This change is acceptable.

(Page A-Table 2)

(a 1

Revision to Comments (a)

As indicated in item 15 above, this change represento a plan and security upgrad end its a arance here is cosmetic.

(b)

Again, addition o a system u -

rade.

(c)

Addition of represents a plan and system upgradeg efP #

.g This change is acceptable.

O s

s Arthur D. McQueen q'

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.. sp Physical Security Inspector cc Chief, SGPR, NMSSV e..

y Chief, SMPB, IE File L-2-5 w

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