ML20149J455
| ML20149J455 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 07/18/1997 |
| From: | John Miller UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| Shared Package | |
| ML20149J423 | List: |
| References | |
| 70-7001-97-05, 70-7001-97-5, GDP97-0125, GDP97-125, NUDOCS 9707280225 | |
| Download: ML20149J455 (8) | |
Text
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FbCH suSEC 301-564-3210 1997.07-18 17:55 C140 P.02/21
..i United States Gnrichment Corvorabcn j
2 Democracy Center 6903 Rockledge Dnve Bethesda. MD2o817 United States Tel: 901)S64-3200 Enrichment Corpurution Far (<01) 564-3201 July 18,1997 Mr. James Lieberman Director, Office ofEnforcement SERIAL:GDP97-0125 United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 Paducah Gaseous Diffusion Plant (PGDP)
Docket No. 70-7001 AdditionalInformation from NRC Predecisonal Enforcement INFORMATION TRANSMITTED HEREWITH IS PRO PLLi.IC DISCLOSURE AS CONFIDENTIAL COMMER INFORMATION AND/OR TRADE SECRETS PURSUAN 2.790(d)(1) AND 9.17(a)(4)
Dear Mr. Lieberman:
On July 16, 1997, Headquarters building in order for USEC to provide N (5) apparent violations that were identified in Inspection Report 70-e 1997. At the predecisional enforcement conference, USEC committe e
une 27, following information by the care of this letter:
with the A listing of the corrective actions that have been completed a of the corrective actions that were identified in our presentation to A listing of the specific examples that were identified in the appar USEC does not agree with and the basis for our disagreement.
two apparent violations that USEC did not agree with at the conferenc e.
of the three security plans for PGDP.A listing of other self-id ew The above information is provided in Enclosures 1 through 3 r. Additionally, you asked whether t Corrective se n contained in our predecisional enforcement conference presentation n ormation There was no classified 9707290225 970723 PDR ADOCK 0700 0 1 C
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e, prROM USEC 301-564-3210 ggg7,g7 18 17856 18140 P.03/21 Mr. James Lieberman July 18,1997 GDP 97-0125, Page 2 information in the jur.-intion. A subsequent review has detennlaai that pages 16,17,21,and 23 of our presentation should have been labeled as proprietary since they information and they are included in Enclosure 4.is detaile information contained in Enclosure 3 of this letter to be proprietary com l
information pursuant to 10 CFR 2.790(d)(1) and 9.17(a)(4). Therefore, U nandM i
Enclosures 3 and 4 to this letter be exempt from public disclosure.
Further detaib concerning the root causes, corrective actions taken, and co to prevent recurrence will be provided by USEC in our written response to any vio 1
i are issued by NRC.
If you have any questions, please contact Bill Sykes at (502) 441-6796 or R (301) 564-3245. The corrective action due dates in Enclosure 1 to this submit to be regulatory commitments.
4 e ely, es H. Miller ice President, Production Enclosures NRC Document Control Desi:
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Acting Director, Division of Nuclear Materials Safety, NRC Region III (
NRC Office of Nuclear Material Safety and Safeguards (N. Mamish)
NRC Special Projects Branch (R, Pierson)
NRC Resident Inspector - PGDP i
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8pensuscc soi-ss4-s2io 1997.e7-1e 17:ss sitac P.ca 21 ENCLOSURE 1 LISTING OF COMPLETED CORRECTIVE ACTIONS AND SCHEDULE FOR COMPLETION OF CORRECTWE ACHONS TO BE TAKEN CORRECTIVE ACTIONS FOR COMMON ROOT CAUSE
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The Site and Facilities Manager reinforced his expectations y
for total procedural adherence, rigorous attention to detail, Complete and complete regulatory compliance.
4 Site and Facilities Support Manager assembled a team of Subject Matter Experts to concurrently review the three Complete security plans for accuracy, consistency, and completeness.
Took immediate actions to bring PGDP into compliance with Plan.
Efforts initiated on 05/09/97
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and are ongoing.
Plus are being revised.
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Submit to NRC for approval by 09/19/97 Proceduralisg the process utilized dudng review to ensure consistent plan review and change implementation. 08/08/97 Required increased field monitoring by Secudty Management to ensure regulatory commitments are met via 08/01/97 strict procedural adherence.
Will perform independent assessments and self-assessments of plan implementation using NRC inspedon criteria as 03/31/98-Self-assessment end point after NRC approval of guide.
revised plans.
04/30/98-SS&Q Independent Assessment
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l VIOLATION 97005-03: COMPLETE AND ACCURATE INTORMATION
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Organizational Manager reinforced his expectations Complete j,
to the Security stafffor the necessity of attention to detail and complete and accurate information.
1 2.
Completed review ofall three Security Plans withComplete involvement by sub supporting groups. ject matter experts from 3.
Will revise plans in accordance with regulatory 09/05/97 requirements.
4.
Will submit plan revisions requiring NRC approval.
09/19/97 5
Will complete procedure re. cions to conform to approved plans.
Three months after NRC approval ofrevised plans.
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1.
Security plan review requirements and expectations 08/08/97 will be captured in procedure including Subjed Matter Expert coordination and detailed verification.
2.
Plant Change Review process is now in place, This Complete process did not exist when Security Plans were originally developed. This process requires verification ofregulatory requirements and commitmentL l
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e (FROM LJ5EC 301-564-321o 1937*07~18 VIOLATION 97005-01: DIPLEMENTAHON OF SECURITY o a:w m
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(CoiTec'ived. -;..:nes- - - ~.m.ctionsto$chieilelCompliin n. wce y % % w;i 'i.'
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Controlled access area drawings are being revised 08/15/97 pending fmal approval, 2.
Training plan was revised to include training in the Complete i
speciSed subject areas and the required number of hours.
3.
Security response exercises have been initiated.
Complete 4.
Patrol frequencies were increased and randomness Complete implemented.
5 Additional gas masks were obtained for issuance toComplete police officers.
i 6.
The new key control procedure ha.c been 1
implemented by the site locksmith.
Coruplete 7.
Plant Shift Superituendent, with Police Operations Complete Shift Commander, now coordinate entrance of trains..
8.
Secudty personnel will escort mutual aid forces in Complete the event of a response.
9.
PGDP security now coordinates outgoing visits to Complete other facilities.
10.
Unused badge stock was moved into an approvedComplete four-drawer repository.
11.
Request for Application Change (RAC) submitted to change classiSed m:"Iagshipping address.
RAC approval dependent on DOE Facility Data Acquisition Request approval that was submhted on 07/07/97.
12.
Request for Application Change submitted to 08/15/97 correct the organization chut.
13.
Physical checks being perfonned of Area Control Complete Room classified safes.
14.
SF-702 forms idfaed to the classified material t
Complete storage area.
15.
Plant notification check sheet revised to include Complete NRC Division ofSecurity.
16.
Portsmouth Gaseous Diffusion Plant notified of plan Complete issues.
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Organizational Manager reiuforced his expectations i Complete for attention to detail, procedure.dherence, and personal accountability to the Sn.urity stafE 2.
Increased field monitoring by Security management to ensure regulatory ec,rumiLuents are met via suictIncranavi field momtoring initiated.
procedural adherence.
3 hastyplans werereviewed to verify Complete implementation.
4.
InWrd procedure revisions to implement approved 10/01/97 plan changes.
5.
Revising Classified Matter Protection procedure to 10/31/97 clarify process for proteceng classified material.
6.
Performing self-assessments of Security Plans -
03/31/98 - Self-assessment implementation.
after NRC approval ofrevised I
plans.
7.
Will perform independent assessments ofSecurity 04/30/98 Plans.
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e ffROM sVSEC 201-564-3210 1997 07-18 17:58 N140 P.03/21 VIOLATION 97005-05: BfPLEMENTATION OF CLASSIFIED COMPUTER SECU PLANS
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Classified computers relocated to meet spacing Complete requirements. Proper spacing ofothers verified.
1 2.
Training for computer security ef5cers completed.
Complete
'Correcttve Acnons to'PreventRecmrenceQ:d m;;ql;.wo :x.wwvmeemwae=cm as rw fug g!!sgM5 go @ ;i 1.
Security Management reinforced expectations for Complete j
rigorous procedure adherence and attention to detail.
2.
Employee was counseled on necessity for procedure Complete adherence.
3.
Frequency for internal surveillance of classified Complete systems was increased from an annual to quarterly requirement.
4.
Master ADP for Microcomputer Processing Complete Classified Information issued to all custodians of classified computers for required reading / crew briefing.
S.
A checklist is being used to verify the training Complete requirements of the Computer System Secunty Officer.
6 Developing procedure for Conduct of Security 9/30/97 Operatione 7.
Internal assessments are being performed to ensure Complete compliance with Classified Computer Security Plan commitments.
3ot-ss4-221e 1997 07-18 17'58 e
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ENCLOSURE 2 EXAMPLE IDENTDTED IN THE APPARENT VIOLATIONS THAT USEC DOES NOT AGREE %TTH AND THE BASIS FOR OUR DISAGREEMENT
.IAE!C classification labels to a classified computer a Report states, "The inspectors noted that the classification labels affixed t inaccurate. The labels read SECRET-National S is processing SRD.
Basis for Disarreement This issue is directly related to apparent violation 70-7001/97005-0 marking records of combinations to classified security containers as Information. During the en-fer:nce, USEC responded that we did not a concerning the combination records for security containers.
USEC complied with the classification guidance in CO-PGD-5, Joint NRC/ DOE Classificatio pmper classiEcation labels. Safeguards were ensured by a Q<leared POD need to know.
We do not believe the labels were inaccurate since we followed guidance.