ML20212D283
| ML20212D283 | |
| Person / Time | |
|---|---|
| Site: | 07007001 |
| Issue date: | 10/27/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212D281 | List: |
| References | |
| 70-7001-97-13, NUDOCS 9710310056 | |
| Download: ML20212D283 (31) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION lli Report No: 70-7001/97013 (DNMS)
Certificate No: GDP-1 Docket No: 70-7001 Certificate Holder: U.S. Enrichment Corporation Two Democracy Centsi 6903 Rockledge Drive '
Bethesda, MD 20817 Facility: Paducah Gaseous Diffusion Plant Dates: October 9,1997 Meeting Location: Region lli Office 801 Warrenville Road Lisle, IL 60532-4351 Type of Meeting: Predecisional Enforcement Conference Inspection: Routine Resident inspection July 15 through September 12,1997 Inspectors: Kenneth G. O'Brien, Senior Resident laspector John M. Jacobson, Resident inspector Approved by: Patrick L. Hiland, Chief Fuel Cycle Bianch 9710310056 971027 PDR ADOCK 07007001 C PDR
9 Meetina Summary B.edgcisional Enforcement Conference on October 9.1997 Areas Discussed: The apparent violation discussed involves the discovery of uncont' rolled classified matter in areas outside the Paducah Plant control access area or available to individuals without "Q" or "L" access authorization. The apparent violation involves the following: 1) uncontrolled drawings that contained matter classified as confidential-restricted data available to individuals without "O" or "L" access authorization: 2) a videotape that contained uncontrolled classified matter stored in a building outside the i
. controlled access area; and 3) document containing uncontrolled classified matter stored in an unclassified repository in a cascade building. The certificatee identified the root causes, near and long-term corrective actions, and mitigating factors involved with the apparent violation. In addition, the licensee acknowledges the areas of concern and the apparent violation of 10 CFR 95.35.
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Reoort Details
- 1. Persons Present at Conference U.Si Enrichment Corooration George Rifakes, Executive Vice President of Operations James Miller, Vice President of Production Steve Polston, Paducah General Manager Steve Toelle, Corporate Nuclear Regulatory Affairs Manager Charles Hicks, Paducah Site and Facilities Support Manager Bill Sykes, Paducah Nuclear Regulatory Affairs Manager U. S. Nuclear Reaulatorv Commission .
James L. Caldwell, Deputy Regional Administrator, Rill Roy J. Caniano, Deputy Director, Division of Nuclear Materials Safety, Rill Patrick L. Hiland, Chief, Fuel Cycle Branch, Rill Toye Simmons, Enforcement Officer, Rill Kenneth G. O'Brien, Senior Resident inspector at Paducah John M. Jacobson, Resident inspector at Paducah Courtney Blanchard, Fuel Cycle inspector, Rlli Lynn Silvious, Chief, Information Security, NRC Headquarters Charles L. Cox, Special Projects Branch (FCSS), NRC Headquarters
- 11. Predecisional Enforcement Conference.
A Predecisional Enforcement Conference was held in the NRC Region ill office on October 9,1997. This conference was conducted to discuss an apparent violation identified in NRC inspection Report No. 70-7001/97007(DNMS) (transtaitted to the certificatee by letter dated September 24, 1997).
The purpose of this conference was to discuss the discovery of uncontrolled classified matter in areas outside the Peducah Plant control access area or available to individuals without "O" or "L" access authorization and the corrective act!ons to ensure these problems do not recur. In addition, the certificatee discussed root causes and factors that caused the lack of confidential restricted data control. A copy of the certificatee's handout is attached to this report.
During the Predecisional Enforcement Conference, the certificatee acknowledged
) the lack of confidential-restricted data control as an apparent violation of 10 CFR 95.35 of the NRC "Smurity Facility Approval and Safeguarding of National Security information and Restricted Data," Part 95, Title 10, Code of Federal Regulations.
Attachments 1: Enforcement Conference Slides 2: Agenda 3
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PADUCAH GASEOUS DIFFUSION PLANT :
i PRE-DECISIONAL ENFORCEMENT CONFERENCE ,
i October 9,1997 :
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AGENDA A. Introduction S. Polston B. Ilistoraal Perspective S. Polston C. Sequence of Key Events and Actions Taken C. Ilicks D. Root Causes and Corrective Actions C. Hicks E Mitigating Factors S. Toelle F. Implications for Portsmouth J. Miller G. Closing Remarks J. Miller M """""""""~"'~"'""""
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INTRODUCTION
. USEC acknowledges the three instances where uncontrolled classified matter was found outside the Controlled Access Area (CAA) as noted in NRC Inspection Report 97-007.
. To date, we have identified 3 additional events of uncontrolled classified matter outside the CAA; however, one of the events has been subsequently determined to not involve classified information.
. We have also identified 18 events inside the CAA which we also consider important to address.
. All of these events were self-identified by USEC and immediately reported to NRC as part of our ongoing effort to locate uncontrolled classified matter.
. Classified document control at PGDP is a complex issue that involves both existing program weaknesses and legacy issues which have made identification of classified matter confusing. l
- We recognize that our efforts to identify uncontrolled classified matter could have been initiated earlier because of missed opportunities.
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i INTRODUCTION
. .1-lowever, the nature and significance of this issue was not fully recognized until mid-August 1997:
when we discovered uncontrolled classified matter outside the Controlled Access Area.
- We will describe the sequence of key events and actions taken, our analysis of the root causes for the apparent violation, the corrective actions taken and planned to achieve compliance and prevent recurrence. Additionally, we will discuss the actions we took at the PORTS facility to assess whether similar violations exist there.
- We will also discuss the status of the purge effort as requested in NRC letter dated September 24, 1997.
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HISTORICAL PERSPECTIVE 1949-1953 "Oflicial Use Only (OUO)" and " Restricted" classification categories established by the Atomic Energy Commission (AEC).
1959-1960 Re-classification of documents distributed as unclassified in the 1950s was directed by AEC (this was not fully implemented).
1971-1978 Major efTort for declassification of documents conducted and later determined to be in error.
'1985 DOE Order 5650.2A issued, stated all documents marked OUO or Restricted be handled as confidential until they were reviewed to determine their classification status (this was not fully implemented at PGDP).
1994 Memo from DOE issued which requested that OUO and Restricted documents'be treated as classified and documents de-classified prior to 1978 be considered as classified. (Note: USEC obtained a copy of this memo in August 1997 during the course ofour investigation into the discovery of uncontrolled classified matter)
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SUMMARY
OF EVENTS A total of 24 events of potential compromise were self-identified where classified information was found improperly marked and/or uncontrolled. The following is a breakdown of the 24 events:
20 Involved legacy material that was not properly classified (5 outside CAA) 3 Involved failure to recognize improperly classified documents or to properly classify newly generated documents (I outside CAA) 1 Involved a failure to follow procedure in that classified material was given to an individual who did not have the proper clearance The apparent violation is for " classified matter outside the Controlled Access Area (CAA) and access thereto was not properly controlled in accordance with 10CFR95.35(a)."
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SEQUENCE OF KEY EVENTS AND ACTIONS TAKEN Date Selected Events Actions Taken Classified information discovered accessible by unc! cared Retrieved document and initiated scarch for additi:>nal drawings on 4/14/97.
4/14/97 personnel (Problem Report written) 4/17/97 Classified infonnation discovered accessible by uncleared PGDP Management reali/cd that the Compliance Plan did not adequately personnel. address legacy classified matter control issues on 4/17/97. (REDIRECTED ACrlON) 5/30/97 NRC Inspection Report 97002 issued with NOV for 4/14 and Problem Report made a Significant Condition Adverse to Quahty (SCAQ) on 4/17 crents. 6/2/97 Senior Manager appointed to lead effort on 7/I/97 after 97002 response sent to NRC.
Classified Matter unprotected in vault area Bulletin issued 6/20/97 on Contiol of Media denying uncleared personnel access 6/18/97 to electronically generated documents on interim basis.
Site & Facilities Manager became aware of the DOE 1994 Presentation made to PGDP Senior Managers on problems by Site & Facilitics 8/12/97 memo. Manager on 8/14/97 (REDIRECTED ACTION) 8/13/97 First discovery outside CAA Suspect facility area outside CAA put under guard on 8/13/97 until potentially classified matter was confiscated Completed on 8/15/97.
8/22/97 Discussion held with Senior Resident on pilot effort and plan Started Pilot EITort in cascade process building on 8/26/97.
des clopment.
9/11/97 Discovery of unprotected classified matter outside plant Retries ed suspect information from location and initiated scarches in other property. locations on 9/12/97. (REI)IRECTED ACFION)
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. ROOT CAUSES l
- 1. Inadequate identification of the extent of the pre-existing problems until August 12,1997, due in part to missed opportunities before NRC assumed regulatory oversight.
- 2. In some instances, inadequate knowledge to recognize improperly classified documents'and to properly
) classify newly generated documents.
- 3. Coiitrols relating to preventing uncleared personnel from gaining access to classified information were.
inadequate.
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- 1. Classified information was removed from the area and placed under proper control.
- 2. Employees were notified through their organizations and the site newspaper that all uncleared individuals were to be denied access to electronically generated documents as well as hard copies of process related documents until these documents could be reviewed by an Authorized Derivative Classifier (ADC).
- 3. A plant bulletin was issued that reiterated the procedural requirements for ADC reviews.
- 4. The functional organization managers reviewed their responsibilities for document classification.
- 5. A new procedure was developed and implemented to provide additional controls to prevent uncleared individuals from gaining access to classified information.
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Near-Term Corrective Actions
- 6. The ADC training program was upgraded.
- 7. Sanitized areas outside CAA where classified material was found.
- 8. Planning began ihr perfbrming comprehensive walkdowns/ verification of uncontrolled classified information on site. These plans were discussed with the NitC Senior ltesident inspector on August-22, 1997.
- 9. As part of the " Purge Campaign," a pilot walkdown/ verification was initiated in the C-331 cascade process building on August 26,1997. Additional searches on plant property inside and outside CAA were subsequently started.
- 10. Plant staff reviewed their files and reported to security any examples of potential compromises for further evaluation.
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Long-Term Corrective ' Actions Identification ofpre-existing problems
- 1. A walkdown/ verification plan to review procedures containing potentially classified material was
' developed. This plan identified those procedures needing ADC review.
L2. " Purge Campaign" activities were initiated on August 26,1997. The status to date includes: C-331 Pilot Efiort is complete, searches outside~ CAA on plant property are complete, scarches inside CAA are .
continuing.
- 3. Plans fbr review of nuclear safety engineering documents, engineering service order files, anil problem report and corrective action databases will be developed and implemented by October 31,1997.
- 4. Field monitoring by security management has been increased to ensure re;.;ulatory commitments related to control of classified intbrmation are met via strict procedural adherence.
- 5. An independent assessment will be perfbrmed of the eff'ectiveness of Classified Matter Protection Program by April 30,1998.
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Long-Term Corrective ~ Actions hnproving Plant StaffKnowledge :
- 1. Security training for personnel who may handle classified information and for custodians of classified safes will be completed by December 31,1997. -
- 2. Special briefings are being given to cleared PGDP personnel delineating what is classified. These briefings -
are expected to be completed by November 18,1997. j
- 3. Additional ADCs have been trained using CG-PGD-5 Joint NRC/ DOE Classification Guide as the standard.
- 4. Management has stressed to all cleared PGDP personnel that they are individually responsible for the safeguarding of classified matter.
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.Jang-Term Corrective Actions ,
hnproving Controisfor the Protection ofClassified Afatter j
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- l. Tine classified matter protection procedure was revised to alarify instructions for protection of classified matter. q
- 2. The security education program will be revised by November 21,1997, to provide for a brieling on sensitive j technology / processes prior to issunnee of" cleared" picture badges.
- 3. The security briefing requirements in the General Employee Training program will be revised by No'vember 21,1997, to stress the responsibilities oi cach cleared individual.
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MITIGATING FACTORS Identification
- a- Elliorts to locate uncontrolled classified matter have resulted in findings both inside and outside the CAA.
All potential compromises of classified information have been self-identified.
. All discoveries of uncontrolled classified matter have been promptly reported to NRC per 10 CFR 95 (24 notifications made).
Corrective Actions
. USEC has promptly taken comprehensive corrective actions in areas of our responsibility. i
. USEC initiated an effort to review and purge classified information at the plant site. This effort was documented in our supplemental response to NOV 97002-31.
. Near-term and long-term corrective actions have been initiated to prevent recurrence within a reasonable time frame. The corrective actions have been thorough and comprehensive and address broader issues.
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MITIGATING FACTORS Other Considerations a This violation was not likely to be identified by outine USEC efforts such as .armal assessment, surveillance or QA activities in that the examples of the violation pr' narily involved legacy materialihat was not properly classified or handled.
. Compromises were not willful.
. This apparent violation has parallels with the subject of"old design issues" addressed in Section VII.B.3 of the Enforcement Policy.
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IMPLICATIONS FOR PORTSMOUTH Risk for compromise of OUO/ Restricted classified information significantly lower at PORTS:
a PORTS not part of Consolidated Classified Review Project (1978) which improperly downgraded documents at PGDP.
a Procedures historically identified OUO/ Restricted documents as classified.
.a OUO/ Restricted documents maintained in a classified vault.
a Walkdown verifications of PORTS documents (~ l80,000).
a Some potential compromises of regular classified documents did occur:
- Six examples of potential compromises were reported.
- Corrective actions being taken r U
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CLOSING REMARKS.
- USEC recognizes the significance of the apparent violation.
. Identification of classified material has been complicated by historical events.
. USEC cannot alone solve the legacy problem such that we can assure 100% of any material compromised over the last 45 years is identified and recovered.
. When we discovered the uncontrolled classified matter in April of this year, the actions we took were appropriate based on available information.
. While there were some " missed opportunities" to fully recognize the nature of this issue, as we discovered >
more problems with the control of classified matter we redirected our actions appropriately.
. All of the examples of uncontrolled classified matter have been self-identified by USEC and formally reported to NRC.
. We have looked at the implications of this apparent violation at the PORTS facility.
. We believe that a civil penalty is not appropriate in this situation.
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PRESENTATION APPENDIX CHRONOLOGY OF EVENTS AND ACTIONS TAKEN l l
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i i I CIIRONOI.OGY OF EVliNTS 'AND ACTIONS TAKEN Date - Description -
4/14/97 Classified information discovered accessible by uncleared persennel. ' Retrieved documents and 'scarched for additional drawings.
4/17/97 Classified Information discovered accessible by uncleared personnel.
4/17/97_ PGDP management realized that the Compliance Plan did not adequately address legacy classified matter control issues. ,
5/29/97 Secret-restricted information accessible to personnel without the appropriate level of security clearance.
5/30/97 NRC Inspection Report 97002 issued to USEC.
6/2/97 Problem Report made a Significant Condition Adverse to Quality (SCAQ).
6/4/97 Confidential-Restricted Data accessible to personnel without appropriate level of security clearance.
6/18/97 Confidential-Restricted Data accessible to personnel in vault without appropriate level of security clearance.
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' CllRONOI OGV OF liVENTS' AND ACTIONS TAKEN -
Date Description 6/20/97 Ilulletin issued denying uncleared personnel access to electronically generated documents un'il wor' areas reviewed and sanitized by an Authorized Derivative Classifier (ADC).l Also, denied uncleared personnel access to decuments from Records Management vaults until reviewed by ADC.
7/16- Consuli::nt from a fuel cycle facility subject to 10 CFR 95 performed a review ofimplementation of PGDP security 18/97 program.
7/31/97 Ilulletin issued stating policy / procedures associated with required ADC review ofdocuments.
7/31/97 Functional organization managers re.iewed current procedural requirements regarding document classification.
7/31/97 Procedure developed requiring security plans for unc! cared personnel.
8/6/97 Possible compromise of Confidential - Restricted Data. This was identified through an ongoing review oflegacy documents held at the plant.
l 8/6-8/97 Technical Security Manager from 10 CFR 95 licensee conducted review of PGDP classified matter program.
8/12/97 Possible compromise of Confidential-Restricted Data. This was identified through an ongoing review oflegacy documents held at the plant.
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CilRONOLOGY OF EVENTS AND ACTIONS TAKEN-Date Description S/12/97 Site & Facilities hianager became aware'of the DOE 1994 memo.
8/13/97 Document identified as "Ollicial Use Only" found outside the Controlled Access Area (CAA).
8/13/97 Suspect facility in property protection area guarded until potentially classified matter could be confiscated.
8/13/97 Document identified as "Oflicial Use Only" found outside the CAA. Suspect area secured unt;l potentially classified matter could be confiscated 8/14/97 Site & Facilitic; Flanager made presentation to Senior hianagers on thm problems.
8/14/97 Video cassette containing Confidential-Restricted Data found outside the CAA.
8/15/97 Walkdown of training facilities for any training video tapes containing classified information.
8/15/97 13egan planning / implementation of comprehensive walkdown of PGDP site ihr potential uncontrolled classified information.
8/22/97 Discussed pilot program effort and plan development with Resident inspectors.
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Date Description 8/26/97 Started formal pilot program in cascade process building.
8/27/97 Booklets marked " Official Use Only" containing Confidential-Restricted Data not properly controlled.
9/3/97 17 documents (misc. correspondence) and 36 drawings with various old clasJication markings (such as "Ollicial Use Only" and " Confidential") discovered in an area where not properly controlled.
9/8/97 One document with " Confidential - Restricted Data" markings found in an uncontrolled file cabinet.
9/11/97 A drawing with an old classification marking discovered where it was not properly controlled 9/11/97 Three docu.nents discovered to have been issued to olT-site personnel which did not h:. e proper security clearance.
9/l I/97 Confiscated potentially classified drawings from offsite contractor llegan review of potential for classified matter at contractor's other facility.
9/17/97 Material marked Secret and Confidential was discovered in a cabinet in the C-335 building.
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CilitONOI.OGY OF EVEn fS AND ACTIONS TAKtiN Date Ducription 9/17/97 Authorized Derivative Classifitt review of a document that was created by a m ultant outside the controlled access area found to contain classified matter and uncontrolled. Confiscated a.: epected matter por ntially containing classified information.
9/19/97 Document discovered within the CAA containing classified information, was not properly marked as to its classification or contro%I 9/19/97 Document discovered within the CAA which contaiaed pote ,tidly classified Liformation.
9/22/97 An employee discovered a document in a file cabinet in his ollice that he suspected might be classitied.
9/22/97 An employee discovered a document in a file <abinet in his ollice that be suspected might be classified.
9/24/97 Classified infinmation was inadvertently disseminated via an unclassified computer system within the CAA 9/25/97 Document found outside the CAA was discovered to be classified-
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ErrEol DP 812:Marciante 8*8Ch RECDENII1NS ADEQUATE DOCUMENT DECLA551FICAT10N AEVIEPs .
to. Distribution ,a In support of Openness, incre and more Oak Ridge Dperations (CRO) organizations are handling old classified ano fomerly classified documents, and preparing them for dissemination to the pubite. Openness is an importan*. initiative, yet, as the Secretary DDE)(made have aclear in her June press continuing Conference, we in the Department of Energy obligation to protect information that is vital to the national security.
Classified information and Unclassified Controlled Nuclear InforsationMany older cla (UCN1)information contain are two classes of such that would inforrf*
assist ion. weapens proliferant. The a nuclear earlier nuclear tec.velogies are all the more implementable for an emerging nuclear power.
Of course, the more ref8ned Unites States technologies are~ ,
attractive, too. Dissemination of such documents Therefore would be it is it.portant detrimental that all to the interestsand emoloyees of the ourUnited $tstes. including our non management and operating contractors, recognize what constitutes a properly declassified (Mn0) document. contractors, Please disseminate this notice accordingly,in Marietta Energyto your employees, nnn-M&O contractors and M&O contractors excluding Mart Systems. The purpose of this memorandum If at any timeis toyou deserthe have anythe samarks doubt as of toa properly declassified document. document whether a document is properly declassified, or if you coide upon a that does not have classification markings on it but seems to contain classified infomation, please protect it as if it was classified and c my office insnediately.
and information in your organization's pensession rests with you.
releasability of documents, including Privacy Act review, prop ATTRIBUTES OF A PR0ptRLY DEtt.A55!FIED DOCUMENT If the following attributes are not present, treat the document as still classified.
- 1. There Will be evidence reviewed on the face cf and the document the ruled document it to noYou that an look should autho for derivative declassifier(s)information.
longer contain classified
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. Noveeer 21, 1994
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Distribution A signature reviewer (s).
of at least one Authorized Declassifier and the title of theLook for ,
or equivalent. Over time, the requirement as to the number of reviewers i
needed to declassify a document has varied. The following table provides the esquirements. If the necessary number of reviewers is not evident on a document, treat it as if it was still classified.
EFFECTIVE DATE OF DECLA5Str1 CAT 1oM Rt00!REMENT OttLA531F1 CAT 10N ACTION One signature declassification _
Prior to Moven6er 1979 '
July 1982 Two signature declassification December 1979 April 1985 One signature declassification August 1982 Two signature declassification
[May 1985 Present _
- 2. Classification markings, the level and category stamps, will have beenIf this ha crossed out on all pages.
If you find a document with the classification markings crossed out, but lacking the attributes described in item 1. above, treat it as classified. 4 OTHER COMsIDERATIONS AND CONCERNS A. Funky File Folders Type 1. their Some declassifiers decision on the in the past exterior of were in the without file folders, habit oftransferring documenting evidence of their* All ORD decision to documents organizations, contained except for the Ost Ridge in t.he intertor af the file folder.
Records Holding tres, art requested te call my offica in any instance wherein tney find the kind of file folders discussed at the head of this paragraph, All ORD organizations, including the Oak Ridge Records Holaing area, are requested to call my office if they come upon such folders, and there is an intention to diss photocopies. '
Type 2. Some organizations in the past were in tb habit of collect had not had individually marked with classified markings, and storing them in a file folder which had classified markings on the outside of 11 documents in the folder as classified and call my offica as soon as possible.
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' Distribution A B, Consolidated Classification Review Program (CCRP) Documents
- l From 1971 throveh 1978 the Atomic Energy Commission (AEC) and its' contractors declassified a large volume of documents then held in record
. centers. That task, which was carried out at Hanferd, Los Alamos, known andas oak the Ridge (K-25, ORNL, Y.12 and the AEC's records holding area) 13 Consolidated Classification Review Progree (CCRP).
Many people were assigned to, this task and 'given total authority toHowever, not all r dec11ssify documents.
As a result, mistakes were made.
with the subject area they were reviewing.
Weapons documents were declassified in error and ended up in the hands s of uncleared persons.
The AEC took steps to recover. All CCRP declassifications were cancelled However, and organizations were asked to again review their CCRP holdings.A CCRP it is clear that not all documents have been reviewed again.
document will usually contain a stamp ')' Declassified by DOE" and an individual's initials, (or no initials , or it wi11 have notification from the DOE Office of Scientific and Technical Information (formerly Technical Information tenter) known as TID's (TID Nos.1380 through 1401 should beOther va assumed to be CCRP notices).
followed initials, orbynoinitials, initials.or no initisist or " Declassified by" followed byIf a document is s post-1978 revalidation of declassified status, and have the Prompt attributes steps described in item 1, above, it must be treated as classified.
need to be taken to have it revieweci again by my office.
C. Obsolets Classification Level Markings Two special mar'*ngs apply to the Manhattan Engineering District or earlyThesa w Atomic Enertry Commission time period.
one time BUT keep flowever, ARE NOWthatOBSOLETE in mind a document with FOR USE either of theON CONTEMPORANEQUS 00Ct!MENTS.
following markings. generated in the indicated time periods must be treated today at the CONFIDENTIAL 1evel (can be Restricted Data or National Security Information, be conservative), and should be reviewed for declassification, by my office, if it is desired to disseminate it to the public
'This marking is a classification level that was once used Any in
- RESTRICTED the United States and is still used by certain foreign countries.should be 12/15/53 United States document marked restricted orier toALL foreign documents with this handled as a Confidential document.
marking should be protected as Confidential.
= OFFICIAL USE ONLY22.(000) 1951.
- This marking was a classification level fromSuch July 18, 1949. to OctoberThis marking on a document from any other time tct.fidential document. However, such documents may be withholdable pericd is 221 classified. - ,
under the freedom of Information Act.
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' 4 L ' Distribution A My office stands ready to answer all your If youclassification er your customers questions have a and meet *
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your classification related requirements.need to have *
, a document declassified, pleas
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declassification or sanitization service.
L If there art any questions, please contact me on (615) 576-0754, a,.I k,,[4x, -
Gabriel Marciant's ORO Classification Officer ,
f CC:
A. A. 5inisgalli, NN 522.2, GTN J. Towler, CC 10, CR0 C. Cox, CC 10. ORO L. Chapman, CC 10, ORO C. Marciante, AD-41: ORO .
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B. Hatmaker, AD-411, ORO S. L. Elkins, 21dg. C 200. Trailer A, PAD MS 8175, Y-12 L. G. Porter. S1dg. 9731,7307 K 25 '
A. S. Quist, K 303 7, MS H. Thomas, B1dg. X-710, P.5 2209, PORTS Z. Hardin, Analysts, CR0 Records Holding M. Theisen. . Analysas, ORO J. Wilder, Analysts, ORO R. Anderson, Analysas (c/o J. Wilder)
- 8. Burditt, Analysas (c/o 0. kilder)
P.. Ferguson, TREsp, Central Librnry All SSD staff .
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6 Attachment 2 CLOSED PREDECislONAL ENFORCEMENT CONFERENCE AGENDA 4
CERTIFICATE HOLDER:
UNITED STATES ENRICHMENT CORPORATION (USEC)
CONFERENCE DATE: THURSDAY, OCTOBER 9,1997; 2:00 P.M.
I.
OPENING REMARKS AND MEETIM th& TATIONS - ROY J. CANIANO INTRODUCTION OF PARTICIPANTS 11.
OPENING REMARKS - USEC REPRESENTATIVES lil.
ENFORCEMENT POLICY OVERVIEW- TOYE SIMMONS IV.
PRESENTATION OF APPARENT VIOLATION - KEN O'BRIEN & JOHN JACOBSON V.
RESPONSE TO VIOLATION - USEC REPRESENTATIVES VI. REGIONAL OFFICE STAFF CAUCUS VII.
ADDITIONAL DISCUSSION - NRC AND USEC REPRESENTATIVES Vill.
SUMMARIZE ENFORCEMENT PROCESS - TOYE S:MMONS IX.
CLOSING REMARKS - JAMES L CALDWELL
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