ML20198L259

Insp Rept 70-7002/97-06 on 970902-05.Violations Noted.Major Areas Inspected:Perimeter Security,Storage & Control of Classified Matter,Classification,Communications Security, Computer Security & Physical Security

ML20198L259
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	10/20/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198L216	List: ML20198L213 ML20198L246 ML20198L259
References
70-7002-97-06, 70-7002-97-6, NUDOCS 9710240292
Download: ML20198L259 (12)

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U.S. NUCLEAR REGULATORY COMMISSION i

DIVISION OF FACILITIES AND SECURITY l Docket No: 70 7002 Report No:

70 7002/97006(DFS)

Facility Operator: United States Enrichment Corporation Facility Name:

Portsmouth Gaseous Diffusion Plant Location: 3930 U.S. Route 23 Piketa, Ohlo 45661 Inspection Dates: September 2 5,1997 Inspectors:

J. Everly, Senior Facilities Security Specialist, USNRC R. Skelton, Senior Facilities Security Specialist, USNRC W. Burnside, Senior Information Security Specialist, USNRC N. Fontaine, Information Security Specialist, tJSNRC L. Numkin, Senior Computer Security Specialist, USNRC J. Caldwell, USNRC Contractor J. Knicoley, Physical Security inspector, USNRC Regiori Ill Approved by: Raymond J. Brady, Director Division of Facilities and Security Office of Administration 02[M h 002 y ,

EXECUTIVE

SUMMARY

United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant NRC Inspection Report 70 7002/97006(DFS) l NRC performed a security inspection of the Portsmouth Gaseous Diffusion Plant located in Piketon, Ohio on September 2 5,1997. The broad objective of this inspection was to ensure comolianco with the certificate holder's Protection of Classified Matter Plan that was submitted and opproved by the NRC in August 1996, and the Physical Security Plan. The inspection team, with the assistance of the NRC resident inspector, reviewed six core areas of the Portsmouth security program. Those areas were perimeter security, storage and control of dassified matter, classification, communications security, computer security, and physical security. Two violations were identified as follows:

1.

In nine instances, USEC failed to implement the security plan in accordance with the Certificate of Compliance (Section 2 (three examples), Section 3 (four examples),

Section 4 (one example) and Section 6 (one example)). Violation 70 7002/97006 01a !.

2.

In five instances, USEC failed to provide the Commission complete and accurate information (Section 3 (one example), Section 4 (one example) and Section S (three examples)). Violation 70 7002/97006-02a f.

In addition, one non-cited violation (NCV) was identified (Section 3) which is not being cited consistent with Section IV of the NRC Enforcement Policy because the viola'icn is considered minor.

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4 Report Detalls

01. InspectionScope Areas examined during this security inspection covered the commitments contained in the Protection of Classified Matter Plan that was submitted by USEC and approved by the NRC in August 1996, and the Physical Security Plan. The inspection centered on detailed reviews of six core areas of the security plan: Perimeter Security (e.g.,

protective personnel, physical barriers, and personnelidentification and control),

Storage and Control of Classified Matter (e.g., security containers, monitoring of classined storage areas, and maintenance of classified combinations), classincation (e.g., proper marking of and accounting for classl0ed material), Telecommunication of Classified Information (e.g., protection of classified information transmitted as facsimiles, accounting for secure telephone units (STU llis) and other equipment used to facilitato i

secure communications of classified information), computer security, and physical security. The inspection included discussions with cognizant personnel and examinations of records to ensure compliance with the commitments contained in the Protection of Class 10cd Matter Plan and Physical Security Plan.

02. Ecrimeter_SecurityJEdB20)

a. Inspection _Scopo In accordance with Sections 2.1,6.1,6.2,6.8, and 8.18.6 of the certificate holder's Protection of Classified Matter Plan, the inspectors examined Portsmouth's physical security and access control practices to ensure adequate protection is being provided for classi0cd matter being used, processed, stored, reproduced, transmit'ed, or handled in connection with the gaseous diffusion process. The inspection included a review of the physical barriers, alarms, locks and keys, Police Operations staffing and training, and vehicle and personnel access controls and badges.

The inspectors also reviewed the plant's Lock and Key Procedure XP2-SS SS 1037 and Portsmouth's Badge issuing Procedure XP4 SS SE1200.

b. Observations.and Eindings ,

Condition 8 of the certificate of compliance for the Portsmouth Gaseous Diffusion Plant stated that the United States Enrichment Corporation (U3EC) shall conduct its operations in accordance with the statements and representations contained in the certification application dated September 15,1995, and subsequent revisions thereto.

A review of the site security protective force consisted of interviews with supervisors and individual guards, observations of activities, tests, and reviews of records. Guard force shift assignments and staff levels were confirmed to include rotational assignments noted in the approved plan, Six randomly selected medical records wero reviewed and found to confirm that protective personnel received a pre employment ' Multi Phase Personality Inventory Test" and were given a graded exercise stress test, State of Ohio Special Police commissions were confirmed for guard force supervisors. Special response security equipment was inventoried in both vehicles and at guard posts. All equipment was accounted for. A review was also conducted of the Portsmouth Guard Force Posts and Patrol Assignments. No deficiencies were noted.

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Security vehicles were observed to meet the commitments detailed in the plan. Security radio operations were observed to include an operational test of the duress function on a randomly selected radio. Protective force uniforms and personal equipment were

..sentoried on several personnel. Training records for the protective force were reviewed for pre-employment training and annual training requirements. All records reviewed were found to be in order. An unannounced alarm response test was conducted by the security testing officer to confirm response times and procedures. The protective force responded well within the required time frame.

The Controlled Access Area (CAA) perimeter fencing and related patrols were observed to meet the commitments contained in the approved plan except as noted in Section 8.1.3 and Figure 8.1. The description of the CAA barrier was not accurate as it relates to the GCEP area and Buildings X-3001 and X-3002. Plant personnel interviewed were not able to explain where the exact CAA barrier was in relation to Buildings X 3001 and X 3002. (01a) l Activities related to a railroad shipment were observed within the CAA and exiting the CAA. Procedures related to Emergency Mutual Aid access to the CAA were also reviewed and found to be consistent with the approved security plan commitments.

The Central Alarm Station (CAS) and the Secondary Alarm Station (SAS) were observed by the inspectors for proper operations. Specific ahrm system equipment was reviewed to confirm commitments in the approved plan. Sect.on 6.1.2 of sne plan states that a complete listing of active alarm zones is included in Acdendum 2. A review of Addendum 2 dated June 1995 showed that it contained obsolete information in that many of the alarm zones no longer existed or had received equipment upgrades. (01b)

Section 6.1.4 of the plan listed four alarm annunciation systems for Portsmouth along with the statement that

• Work is now in progress to replace the CBISS with the new Portsmouth Access Control System (PACS)." A plant Project Managers Report dated 6/10/96 stated that this project is scheduled to be closed out before completion.

Interviews with security staff indicated that no activity was underway to complete this alarm equipment upgrade. (01c)

Lock and Key Procedure XP2-SS SS1037 was requested and reviewed on site with plant personnel responsible for the key program. Records, forms, hardware, and storage were reviewed for consistency sith the procedure. No problems were noted.

Visitor control procedures were verified through observations and interviews. Forms listed in the plan were being properly used. An uncleared visitor security plan (required for visits over 5 days) was reviewed and the records retenthn periods for those plans were validated.

The types, design, fabrication, storage, and destruction of security identification badges were found to be consistent with the approved security plan commitments. Procedures for lost badges were reviewed and found accurate. Use of proper forms, retention periods for records and inventory of materials were also confirr0ed. The badge insert log book and computer database were reviewed and found to be consistent with

] procedure XP4 SS-SE1200,'Portsmouth Badge issuing Procedure."

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c. Conclusions Condition 8 61 the certiilcate of compliance for the Portsmouth Gascous Diffusion Plant stated that the United States Enrichment Corporation shall conduct its operations in accordanc., with the statements and representations contained in the certifications application dated September 15,1995, and subsequent revisions thereto. Contrary to that requirement, several aspects of the Protection of Classified matter Plan were not implemented in accordance with the approved plan and are considered a Violation (70-7002/97000-01a thru c).

Specifically, the inspectors' review identified that the certificate holder failed:

1) to identify the CAA barrier,

2) to identify active alarm zones, and

3) to continue working to replace the Computer Based Integrated Security System (CBISS) with the new PACS.

03, Storage _and_ControtoLClassified. matter _{B1820)

a. Inspection _ Scope in accordance with Sections 1.2.3,1,3, 2.3, 3, 4, 5, 6, 6.3, 6.4, 6.5, 6.6, 6.7, 9,10, and 17 of the certificate holder's Protection of Classified Matter Plan, the inspectors examined Portsmouth's storage and ccmrol of classified matter practices to ensure that adequate protection was provided for classified matter being used, processed, stored, reproduced, transmitted, or handled in connection with the gaseous diffusion process.

The inspection included a review of the current classified mailing address for Portsmouth; personnel security procedures; physical checks of classified containers / vaults / cages; classified lock combinations; and reports to the NRC (e.g.,1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> notifications).

The inspectors also reviewed Procedure UE2-RA-RE1030, Revision 2 *Nudear Regulatory Event Reporting."

b. Observations.andfindings Condition 8 of the certificate of compliance for the Port 3 mouth Gaseous Diffusion Plant stated that the United States Enrichment Corporation (USEC) shall conduct its operations in accordance with the statements and representations contained in the certification application dated Septernber 15,1995, and subsequent revisions thereto.

The inspectors reviewed the process by which classi6ed material was used, processed, stored, reproduced, transmitted, and handled at the Portsmouth plant site. While reviewing various classified security containers / vaults / cages in Buildings X-326, X-333, and X-720, the inspectors noted that some of the Standard Form 700's,

• Security Container Information," indicated that the combinations to these storage facihties were not changed within a 12 month period, as required in Section 6.5.2 of the approved plan.

Plant personnel interviewed explained that all classified combinations have been changed within a year, however, not all SF 700 forms have been updated to reflect the 4

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combination changes as of yet. Many of the outdated SF 700 forms were updated during the inspection. (01d)

With regard to the SF 700 form Section 6.0.1 of the plan stated that SF 700 forms are posted on the outside of security containers when in fact Portsmouth is posting them on the inside as required by 10 CFR 95.25(g). Plant personnelinterviewed agreed to amend the security plan to be consistent with the requirements in 10 CFR 95.25(g).

(010)

Section 6.2.1.4 of the approved plan stated in part that classified documents are stored within GSA approved repositories or vaults / vault type rooms. However, Section 6.3 states in part that classified information is stored in security containers fitted with locking bars secured by three-position combination padlocks. Locking bar containers with padlocks are not GSA approved for storage of classified information. Interviews with plant personnel revealed that Portsmouth does not store classified documents in repositories fitted with locking bars and padlocks. (01f)

Section 6.7 of the plan stated in part that a report reflecting all actions taken when a security container is found unsecured by guard force personnel will be submitted to the NRC Division of Security (now the Division of Facilities and Security). Plant proceduto UE2 MC RE1030 Rev. 2,

• Nuclear Regulatory Event Reporting," requires that the NRC Division of Facilities and Security be notified within 30 days of actions taken when an unattended security container that contains classified matter is found open and unattended. Since May 1997, there have been severalinstances at Portsmouth where guard force personnel have found classified repositories unsecured and unattended.

However, the NRC has not received any reports reflecting actions taken regarding these instances. (01g) 10 CFR 76.9 requires that information provided to the Commission be complete and accurate in all material aspects.

While reviewing Section 4.1 of the approved plan, the inspectors noted a minor inaccuracy in that the plan incorrectly referred to Form UCN-17494,

• Request for DOE Access Authorization and Security Clearance Justification," as Form UCN-1794,

• Request for DOE Access Authorization Form." This failure constitutes a violation of minor significance and is being treated as a Non-Cited Violation, consistent with Section IV of the NRC Enforcement Policy, Section 6.5.3 of the approved plan states that computer diskettes and paper re ords of combinations are marked with the highest classification level of the materialin the respective classified containers. This statement says that classified combination records are kept on computer diskettes. This is not the practice at Portsmouth. Only paper records of classified combinations are maintained. (02a)

c. Conclusions Condition 8 of the cenificate of compliance for the Portsmouth Gaseous Diffusion Plant stated that the United States Enrichment Corporation shall conduct its operations in accoroance with the statements and representations contained in the certifications application dated September 15,1995, and subsequent revisions thereto. Contrary to that requirement, several aspects of the Protection of Classified Matter Plan were not 5

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implemented in accordance with the approved plan and are considered additional examples of a Violation (70 7002/97006-01d thru g).

Specifically, the inspectors' review identified that the certificate holder failed:

4) to update SF 700 forms to indicate the new date of combination change,

5) to affix SF 700 forms to security containers in accordance with the approved plan,

0) to identify the correct security container for the storage of classified matter, and

7) to provide reports regarding unattended security containers found open and l unsecured.

10 CFR 76.9 requires that information provided to the Commission be complete and accurate in all material aspects.

Contrary to that requirement, the certificate holder biled to provide the NRC with an accurate description of how classified combination records are maintained and is an example of a Violation (70 7002/97000-02a).

04. Classification

a. laspection_ Scope in accordance with Section 12 of the certificate holder's Protection of Classified Matter Plan, the inspectors examined Portsmouth's policies and procedures for the classification of information to ensure compliance with commitments in the approved plan and appropriate Executive Orders (E.O.s). The inspectors reviewed the procedures for classifying information, preparation of classified documents for transmittal, document accountability, and classified destruction and reproduction. In addition, the inspectors reviewed Portsmouth's procedures concerning E.O.12958,

" Classified National Security information," foreign travel, and visits to Portsmouth by foreign nationals.

b. Obsentationsand_Eindings in the area of classification, Section 12.3 of the approved plan required Portsmouth personnel to portion mark National Security information (NSI) to delineate classified ponions from unclassified portions in a document. The inspectors noted that most Portsmouth Authorized Derivative Classifiers were portion marking NSI as required.

However, the inspection revealed that one group within the Nuclear Materials Section of the plant was not applying portion markings to NSI as required by 10 CFR 95.37(f) and as committed to in the approved plan. According to plant personnelintervlowed, this group had no knowledge of the portion marking requirement. This deficiency was corrected by plant personnel during the inspection. (01h)

Section 16 of the approved plan identifies shredders approved for destruction of classified information. During the review of these shredders, the inspectors found at least one classified shredder that was not listed in the approved plan. Plant personnel 1

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Inte viewed explained that the list of shredder locations is subject to frequent change, therefore, they plan to remove the listing during the plan's next update. (02b)

c. Conclusions Condition 8 of the certificate of compliance for the Portsmouth Gaseous Diffusion Plant stated that the United States Enrichment Corporation (USEC) shall conduct its operations in accordance with the statements and representations contained in the certification application dated September 15,1995, and subsequent revisions thereto.

Contrary to that requirement, the certificate holder failed to apply portion markings to classified National Security Information and is an example of a Violation (7007002/97000-01h).

10 CFR 76.9 requires that information provided to the Commission be completa and accurc's in all material aspects.

Contrary to that requirement, the certificate holder failed to provide the NRC with a complete and accurate listing of chredders approved for destruction of classified intormation and is considered an example of a Violation (70-7002/97006-02b).

05.

Iciccommunications_oLClassifiedJnfonnation

a. Inspection.Scopo in accordance with Section 18 of the certificate holder's Protection of Classified Matter Plan, the inspectors verified Portsmouth's telecommunications requirements and equipment to ensure classified matter was adequatel) protected while being telecommunicated. The inspectors reviewed Portsmouth's Communication Security (COMSEC) program (including accounting procedures, physical sighting of COMSEC holdings, and physical security controls); Cryptographic /COMSEC Access Program; Protected Transmission Systems Program; and Emanations (TEMPEST) Program.

b. Observations _andfindings 10 CFR 76.9 required that infomiation provided to the Commission be complete and accurate in all material aspects.

Section 18.4 of the plan, which was revised on August 27,1997, and provided to the inspectors upon their arrival at Portsmouth, did not provide enough complete information to determine what equipment comprises the Portsmouth secure telecommunications systems and how they are used. The NRC concluded that this change decreased the effectiveness of the plan in the telecommunications area. (02c)

Section 18.7 of the plan makes an inaccurate reference to Section 5 of the Portsmouth Cryptocenter Standard Operation Procedure (SOP)in connection with classified facsimiles. The correct reference is Section 7 of the Portsmouth Cryptocenter SOP.

(02d)

Figure 18.3 of the plan, which was revised on August 27,1997, and provided to the inspectors upon their arrival at Portsmouth, did not provide enough information to accurately describe the Portsmouth secure telecommunications structure. Too much i

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1 detail was omitted from the previous version, thus, the NRC concluded that this change decreased the effectiveness of the plan in the telecommunications area. (020)

c. Concluslaas 10 CFR 70.9 requires that information provided to the Commission be complete and accurato in all material aspects.

1 Contrary to that requirement, the certifichte holder failed to provide the NRC with a complete and accurate listing of equipment that comprises the Portsmouth secure i

telecommunications systems and is considered another example of a Violation (70-7002/97006-02c).

Contrary to that requirement, the certificate holder failed to provide the NRC with an accurate reference to a section of the Portsmouth Cryptocentar Standard Operation Procedure regarding classified facsimiles which is another example of a Violation (70-7002/97000-02d).

Contrary to that requirement, the certif"mte holder failed to provide the NRC complete and accurate information that describt a the Portsmouth secure telecommuaication structure which is another example 'f, a Violation (70-7002/97006-020).

06. JomputeLSecurity

a. Inspection. Scope in accordance with Section 19 of the certificate holder's Protection of Classified Matter Plan, Master ADP Security Plan for Microcomputer Resources Processing Classified Information, and DOE Order 5639.6, " Classified Computer Security Program," the inspectors reviewed Portsmouth's methods for processing classified data on mainframe computer systems, local area networks, and stand-alone personal computers to ensure that the data was being adequately protected while being processed,

b. Observations.andfindings The inspectors reviewed Portsmouth's Computing and TelecoMJulCat}on ScCurity Program to ensure that there are measures in place to control access and protect the classified systems operating at Portsmouth. Portsmouth currently has four classified mainframe computer systems, two classified local area networks, and 21 classified stand-alone microcomputer systems in operation. Each system is operating under an approved DOE security plan which formally documents the measures used to control access and protect the classified systems and its information. These plans are reaccredited at 3 year intervals to ensure that the ADP systems continue to be in compliance with the applicable DOE orders; that they meet any applicable new requirements; and that the protective features and assurances continue to be effective.

While reviewing the classified Computer Based Integrated Security System (CBISS) and the Safeguards Alarm System (SAS) located in the X-104 Building, the inspectors noted that neither system had been recortified within the required 3-year period from the original certification date. These two systems (CBISS and SAS) were both tested and certified to have implemented the security requirements outlined by their apptcved security plans. However, the certification process had not been consummated because 8

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USEC was confused about the identity of the Designated Certifying Authority and therefore, sent the certification package to DOE. During the inspection, USEC sent a new certification request regarding CDISS and SAS to the NRC. The request was dated September 5,1997. (011)

c. Conclusions Conditien 8 of the certificate of compliance for the Portsmouth Gaseous Diffusion Plant stated that the United States Enrichment Corporation (USEC) shall conduct its operations in accordance with the statomonts and representations contained in the certification application dated September 15,1995, and subsequent revisions thereto.

Section 19.2 of the certificate holder's Protection of Classified Matter Plan described the nature and duration of use for each classified ADP system at Portsmouth.

Contrary to that requirement, the certificate holder failed to have two classified computer sys%ms recortified within the required time period from original certification dato and is Nnsidered a Violation (70-7002/97006-011).

07. Safegua@.JrogramJmplementatiort.(8140L81402 81431)

a. InspectionEcope The inspector reviewed the Portsmouth Safeguards Program to determine whether physical security requirements were implemented in accordance with the requirements of the Physical Security Plan (PSP), Chapter 5,

• Fixed Site Requirements for Special Nuclear Material of Low Strategic Significance."

The inspector also reviewed implementation of site security procedures,

b. Observations _andBndings To determine if adequate protection was being afforded the low enriched uranium (LEU), the inspector toured the Controlled Access Area (CAA) and observed the integrity of the fence, gates, and the vehicle barrier. Fences, gates, and the vehicle barrier were intact and adequately maintained. Personnel were identified, registered, badged, and escorted as required. Clearances and the need for access were being verified. Packagus were visually inspected by security officers at the entrance to the CAA as required by the Physical Security Plan (PSP). Officers at the CAA vehicle gate adequately performed random entry / exit search of vehicles.

All the officers were armed with a handgun and equipped with a radio. The inspector witnessed radio tests and concluded that there was appropriate communication capability within the CAA.

The use of locks and seals was adequate. The inspector also interviewed officers posted and on patrol and found them to be knowledgeable of their duties and responsibilities. Security procedures were located at the appropriate locations.

The inspector reviewed security procedures and determined that they provided adequate guidance for security officer duties and were reviewed at the required frequency.

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4 The inspector toured the CAA for the purpose of observing the storage of LEU and determined that the LEU is stored or used only within a CAA.

c. Conclusions Through observation, interview, independent verification and records review the inspector verified that the protection being afforded the LEU at Portsmouth is in compliance with Physical Security Plan commitments.

08. ExitMeeting. Summary l

The inspectors discussed the preliminary inspection findings with the plant management during a telephonic exit briefing on September 9,1997.

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4 KEY.EERSONNELCONTACIED D. Allen General Manager, LMUS

• B. Stapleton Safeguards and Security Associate, USEC

'D.Hupp Manager, Security Department, LMUS

'J. Snodgrass Manager, Police Operations, LMUS

• E. Smith Security Section Manager, LMUS J. Parker Plant Support Manager, LMUS

• T. Bonner Security Specialist, LMUS

• C Stollings Computer and Telecommunications Security Specialist, LMUS

'M. Kotly Security Specialist, LMUS

'G. Lang Telecommu'iications Group Manager, LMUs l H. Thomas Classificat'on Officer, LMUS

- S. Martin Nuclear Regulatory Affairs, LMUS -

R. Gaston Nuclear Regulatory Affairs, LMUS l M. Sampson Security Assistant, LMUS I OthetExit.MeetingAttendees

• N. Mamish NRC Enforcement Coordinator

'R.Dopp Deputy Director, Division of Facilities and Security, NRC

'L. Silvious Chief, Information Security Branch, NRC

• J. Knicoley NRC Region 111

• W. Yoder DOE Safeguards and Security Representative

'M. Lombard Nuclear Regulatory Affairs, USEC HQS

• R. Wells Nuclear Regulatory Affairs, USEC HQS

' Denotes Exit Meeting Attendance 11

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