ML20206U802
| ML20206U802 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 05/13/1999 |
| From: | Devault R ENERGY, DEPT. OF |
| To: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| NUDOCS 9905260017 | |
| Download: ML20206U802 (11) | |
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[gxt o,j ', k Department of Energy 7
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Post Office Box 62 Oak Ridge, Tennessee 37831 -8651 May 13, 1999 Mr. Steven A. Toelle Nuclear Regulatory Assurance and Policy Manager United States Enrichment Corporation l
2 Democracy Center 6903 Rockledge Drive Bethesda, Maryland 20817 l
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Dear Mr. Toelle:
l PADUCAH GASE0US DIFFUSION PLANT - ISSUANCE'0F WEAPONS AUTHORIZATION CARDS PROTECTIVE FORCE ASSESSMENT l
As you are aware, members of the Department of Energy's (DOE) Regulatory Oversight'(R0) staff performed an assessment of the Paducah Gaseous Diffusion Plant (PGDP) Protective Force from April 26 thru 30,1999, regarding the issuance of Weapons Authorization Cards (WAC) by D0E.
DOE will issue the PGDP WACS under the requirements of the United States Enrichment Corporation (USEC) and DOE. Regulatory Oversight Agreement (ROA) as revised in my letter to you dated April 27, 1999.
Enclosed are the results of the R0 staff's assessment of PGDP's Protective Force. These results indicate the lack of an overall program that establishes and directs-the implementation of the R0A requirements for issuance of the WACS'at PGDP. Also, this assessment provides detailed observations from the R0 Subject llatter Expert that reflect positive and negative aspects of the existing partial program at PGDP.
It should be noted that this assessment represents a sample review of the PGDP Protective Force; as such a further review by USEC is necessary to ensure that all aspects of the R0A have been met.
At the out-briefing on April 30, 1999, this information was provided to your j
staff. Also, during the week of the assessment detailed discussions were held l-with members of the USEC staff to ensure that this information was available for initiation' of.-resolution as soon as possible.
Due:to the priority being placed on this effort by USEC and 00E, it is
/O recommended that USEC provide a pre-decisional package regarding the resolution of the concerns identified from the DOE assessment as soon as
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N H53 IcU 9905260017 990513 c
PDR.ADOCK 07007001 C
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'Mr. Steven A. Toelle. May 13, 1999 s
possible. -This will allow DOE the opportunity to provide feedback early in
- the process and will allow time for adjustment if needed.
Upon completion of
.USEC's effort to resolve DOE's concerns, DOE will perform a final inspection to ensure that the R0A requirements have been met.
If there are any questions or comments on this item, please contact me at
~(423) 576-0802, or Mr. Wayne Yoder at (423) 576-2253.
Sincerely, h'
s
[RandallM.DeVault Regulatory Oversight Manager Office of Assistant Manager for Uranium and Engineering Services Enclosure ccw/ enclosure:
E. Q. Ten Eyck, NRC, White Flint C. D. Pederson, NRC, Region III E. A. Connell, NE-1, FRSTL D. J. Solich,.NN-513, GTN
-R. M. George, NE-40, GTN J. C. Hodges, UE-55, C-103, PAD L. L. Jackson, LMUS, PAD J. H. Ware, AD-43 P. J. Miner, MS-1212, PORTS E. W.'Gillespie, UE-54, PORTS G. G. Pennington, BJC, K-1550V, MS-7239 J.R.McNeely,BJC,UE-53/0STI,MS-8651 W. D. - Sheridan, SE-31 J.-C. Massey, BJC, PAD J. R. Shoemaker, BJC, PORTS G. W. Benedict, UE-50 J. D. Jackson, UE-53
.T. T. Slack, CC-10 W. M. Yoder, AD-431~, 2714-J 1
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ENCLOSURE
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PADUCAH GASEOUS DIFFUSION PLANT PROTECTIVE FORCE ASSESSMENT BACKGROUND Section 310 of the FY 1999 Energy and Water Development Appropriations Bill amends Section 3107 of the United States Enrichment Corporation (USEC)
Privatization Act (42 U.S.C. 2297h-5(h)), which requires armed protective forces at the Paducah and Portsmouth Gaseous Diffusion Plants. The Department
- of Energy (DOE) will issue Weapons Authorization Card's (WAC), granting arming and limited arrest authority pursuant to Section 161k of the Atomic Energy Act of 1954, as amended.
DOE will implement this program through the requirements containedintheDOE/USECRegulatoryOversightAgreement(ROA).
EXECUTIVE
SUMMARY
Members of the DOE Regulatory Oversight (RO) staff conducted a Paducah Gaseous Diffusion Plant (PGDP) protective force assessment from April 26 through April 30,1999. The' purpose of the assessment was to conduct a management review of the current protective force program and the extent to which it meets DOE requirements for the issuance of WACS. Under the terms of the R0A, the protective force program must meet DOE requirements in the following functional areas:
Firearms qualification and safety; medical screening and pnysical fitness; arrest authority and use of force; and, training programs associated with implementing these functional requirements.
A substantial amount of information was available for review; however, this information for the most part was out of date and was provided in a fragmented form.
In order to ensure that the R0A requirements are met initially and in the future for issuance of the PGDP WACS, a program must be developed. This program must provide an effective straightforward package of procedures, training, and data that satisfies the R0A reauirements.
The PGDP protective force information provided for review did contain to varying degrees all of the functional areas required by ROA.
In general the information that was provided reflects a level of training and qualifications that is very close to meeting the R0A requirements.
Some of the areas, such as the medical and fitness programs, require relatively minor procedural improvements to achieve compliance. Other areas such as arrest authority and use of force and firearms qualification require more detailed improvements in
. procedures. Compliance in the area of training will require a completed Job 1
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p and Task analysis'. This is necessary to ensure that required knowledge, skills dnd abilities required for issuance of the WACS are identified, and a i
curriculum is developed to address the functional area training requirements.
Review of the firearms safety program revealed several issues of concern.
First, there is no Annual Firearms Safety Appraisal' Program. This is critical to ensure that new safety issues are identified and that all equipment and operations remain in compliance with approved procedures.
Second, devices intended to trap bullets resulting from accidental discharges during firearms
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loading and unloading operations were not properly' designed.
Under certain conditions, an accidental discharge could exit the rear of the equipment, with potentially serious results.
i A comprehensive contractor protective force management review is required to ensure that policies, procedures and training in the required functional areas are developed or updated as necessary, and are in compliance with the R0A.
INTRODUCTION AND SCOPE This assessment, conducted by members of the DOE R0 staff was designed to obtain an overview of the PGDP protective force program and a preliminary
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status of compliance with the ROA requirements identified in the letter from Randall M. DeVault (D0E)- to Steven A. Toelle (USEC) dated April 27, 1999.
Specifically, compliance in the following functional areas is required to enable DOE to issue WACS pursuant to the Atomic Energy Act of 1954, as amended:
Firearms and Firearms Safety; medical screening and physical fitness programs; arrest authority and use of force; and, training programs associated with implementation of these functional areas.
Information was obtained during the assessment through in.terviews, document reviews and physical inspections. Analysis of the information resulted in both' positive and negative observations. These observations are not all inclusive, but rather a sample review of the information provided by PGDP
. personnel. They are intended to provide DOE and USEC management with an idea of the general status of the program.
GENERAL The information provided to the R0 staff for review reflected a fragmented i
effort, which for the most part was out of date. As such, it is recommended that.USEC take the R0A requirements, the results of this' assessment, and any further results from USEC's review of this assessment and develop a simple program that clearly delineates each of the R0A requirements and directs the implementation of these requirements.
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'The following general. observations were identified during the R0 assessment:
s USEC's efforts in the areas of training and qualifications for the most part are of a level necessary for DOE approval.
However, from a programmatic perspective DOE's review has found a fragmented effort that is for the most part out of date.
USEC needs a simple straight-forward program for DOE to initially review and inspect to in the future.
USEC's program needs to isolate the WAC program such that it is easily recognized and understood (i.e., the program is for WAC issuance only).
USEC's program can be a part of the existing security program but it must be uniquely identified and be kept simple.
USEC's program must include the following elements at a minimum:
Procedures that establish / direct the R0A requirements.
l A training program that implements these procedural requirements and certifies each individual proposed by USEC to receive a WAC.
Certified data from the Medical, Physical Fitness, and Firearms Safety efforts to assure DOE that the R0A requirements have been
- met, i
f USEC's effort to meet the elements of the ROA requirements may utilize j
existing efforts and data; however, this information must be properly certified to R0A requirements and must be current (i.e., use of existing medical records would be acceptable provided that the Designated Physician has reviewed and approved the records in accordance with the
-ROA).
USEC should provide a pre-decisional package to DOE R0 that resolves concerns identified from this assessment as soon as possible.
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FIREARMS QUALIFICATION AND. SAFETY Firearms Oualification R0 assessment personnel conducted interviews and a review of firearms procedures. This review resulted in the following positive observation:
The course of fire that instructors indicate they use is the same as that required by DOE M 473.2-1, FIREARMS QUALIFICATION COURSES MANUAL.
The review of firearms procedures resulted'in the following negative observations:
Procedures do not--specify that the course of fire for handguns found in DOE M 473.2-1 will be used.
Procedures do not cover all General Instructions found in DOE M 473.2-1, II, such as drawing weapons from a snapped holster, reloading from a belt pouch, etc.
Procedures do not.specify appropriate light levels for low light and night conditions.
Procedures have not been reviewed since 1997.
Firearms procedures do not provide assurance that personnel are qualified according to requirements found in DOE M 473.2-1.
Firearms Safety Procram Assessment of the firearms safety program consisted of interviews, document reviews and physical inspections of range facilities and ammunition storage facilities.
The following positive observations were.noted:
A safety analysis of indoor range facilities was completed and approved in 1990.
In April 1999, the DOE Central Training Academy certified armorer from the Portsmouth Gaseous Diffusion Plant (PORTS) performed a limited safety analysis and-identified several minor deficiencies.
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r The PORTS armorer checked and certified all PGDP weapons during his inspection.
The following negative observations were noted:
Firearms procedures do not cover the four basic firearms safety rules as required by DOE M 473.2-1.
There is no documented Annual Safety Appraisal program.
There is no plan for Cardio Pulmonary Resuscitation certification for range safety officers or instructors, or an alternate plan for the use of Emergency Medical Technicians.
There is no emergency plan for evacuation of casualties from the range.
Testing for airborne lead concentrations is not being performed on a semi-annual basis.
Ammunition handling and storage procedures do not include all safety requirements i.e., placarding for safe open flame and smoking distances and requirements to protect ammunition from shock, excessive heat, etc.
Current procedures do not provide adequate information for handling misfires and duds. The current procedure does not discuss the actions of the range safety officer or range master after the student notifies them of a malfunction.
The PGDP armorer's certification is dated November 17, 1993.
He has not been re-certified every two years as required, Armorer's procedures do not specify individual weapon record requirements nor do they specify what standards are used for maintenance and repairs, i.e., Smith and Wesson owners manual or the DOE Central Training Academy armorer's manual.
Clearing barrels at the range and weapons issue point are constructed in j
i a manner which would permit a discharged round to penetrate the rear of the barrel. The design must be modified to ensure that all rounds impact the sand containment media. Any other clearing barrels of the same design must be modified or removed from service.
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' The clearing barrel ' deficiencies are serious in nature.. Engineering controls thought to be designed into the barrels will fail under certain conditions depending upon the angle of.the weapon when aimed into the
. device. Administrative' controls should be modified immediately to ensure that the muzzle'of'the weapon is properly aimed into the barrel until physical deficiencies are remedied.
Failure to do so could result in a serious accident.
During the range inspection, PGDP personnel pointed out several exposed steel bolt heads that extend out of'the concrete floor just short of the bullet trap. During a previous safety inspection these exposed bolt heads were a concern,.and an attempt was made to cover the heads with a type of epoxy material. The attempt failed and the heads are still exposed. There is a standard metal industrial door emergency exit approximately 10 feet to the left, and at approximately a ninety degree angle from the bolt heads.
Due to the time'and equipment constraints of the current assessment, it could not be determined whether the exposed bolts represent a deflection hazard to the exit door if struck by a bullet. The' deflection pattern of the soft exposed lead nose of the semi-jacketed hollow point bullet'used in range qualification ~is not as predictable as that of a full metal jacketed bullet. An attempt should be made to add additional epoxy material' to cover the exposed bolt heads, or they should be ground flat and eliminated.
- The current firearms safety program does not provide assurance that all safety requirements-found in DOE-STD-1091-96 FIREARMS SAFETY are implemented.
Several of the above issues are a cause <for concern and should be addressed in the; near term, irrespective of the re-arming schedule.
l MEDICAL SCREENING AND PHYSICAL FITNESS PROGRAMS Medical Screeninq_
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- A review of the medical screening program for protective force personnel
-resu ted in the following positive observation:
l A~ letter requesting that a PGDP physician be _ approved as a designated physician has been drafted. Also, exam procedures reference medical e
requirements in 10 CFR Part 1046.
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The following negative observations were noted.
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.c Procedures for the medical exam are. dated April. 30, 1992, and were developed by Martin Marietta Energy Systems.
The medical screening program requires minor improvements to ' reach full I
l' compliance..Most important~ is DOE-0R0 approval of the PGDP doctor as a designated physician.
Physical Fitness 1
Review of the physical' fitness program consisted of a review of procedures' and i
observation of a physical assessment. The PGDP-procedure for physical fitness i
testing is in compliance with the ROA.
Periodic physical assessments,
. designed to assist protective force personnel in maintaining physical readiness, were in the process of being completed during the assessment.
The following positive observation was noted:
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I USEC obtained the services of a certified exercise physiologist to conduct periodic physical assessments.
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The following negative observations were noted:
. A PGDP procedure that implements physical fitness assessment requirements was not provided.
The physical ~ fitness program requires minor improvements to reach full
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.dompliance..Specifically, PGDP must approve.an acceptable fitness assessment procedure and complete assessments of all personnel.
LIMITED =ARRES1 AUTHORITY AND USE OF FORCE
. Arrest Authority A review was conducted of the arrest authority policy, resulting in.the following. negative' observation:
The: arrest.. authority policy is inadequate.
It does not contain references to federal misdemeanors and felonies as required by 10 CFR
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sPart-1047.
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p Mie of Deadly Force A review of the. PGDP deadly force policy resulted in the following positive observation:
i The deadly force policy conforms to requirements for a facility that does not contain Category I or II quantities of Strategic Nuclear Materi al ' (SNM).
The following negative observation was noted:
The: deadly force policy has not been reviewed since 1997.
TRAINING A review was conducted of the Paducah " Training Development and Administrative Guide (TDAG)", dated July 31, 1998, and the " Job, Task, Training Needs Analysis Executive Report" dated March 21, 1997. Section 1.0, para. 1 of the TDAG states that the training program mission is to " develop and maintain the knowledge, skills and abilities of the protective forces ". The Executive Report contains a Task List for security police officers, but it does not identify the knowledge skills and abilities required for a complete task analysis.
Interviews with selected personnel indicate that the Executive Report is the only task analysis available.
In addition, a task-to-training matrix was not available to assist in determining what tasks were incorporated into treining lesson plans.
The following negative ~ observations were noted:
The tasks associated with Security Police Officer I duties required for issuance'of the WACS are not incorporated into the Supervisor tasks as required in DOE 0 5632.7A.
The Task Analysis is incomplete.
It does not identify the knowledge skills and abilities required to perform tasks required for issuance of the WACS.
A complete-Job and Task Analysis (JTA) is required to ensure that all necessary knowledge, skills and abilities required to perform tasks required for issuance of the WACS have been systematically identified so that they can be incorporated into an appropriate curriculum.
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addition, an annual training plan must be prepared and approved by DOE j
on' an annual basis that is in compliance with the requirements of DOE O 5632.7A.
CONCLUSION Each functional area required for issuance of WACS is addressed to some degree at the PGDP.
However, an overall program that captures the R0A requirements and directs the implementation of these requirements does not exist.
A fragmented and for the most part out of date partial program does exist.
In some cases, such as the medical and fitness portic of the program, relatively minor improvements are required to achieve full programmatic compliance with the R0A.
Elements from other portions of the current partial program such as firearms qualification and safety require more extensive work.
The current training program documentation does not provide adequate assurance that all required training associated with the functional areas of interest to 00E is being addressed.
To achieve compliance with the terms of the ROA for issuance of WACS, a contractor management review of the protective force prograra is required.
All elements of each functional area that are required unoer current DOE directives must be identified for upgrade or development, as needed, and incorporated into a comprehensive program.
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