ML20212F118

Insp Rept 70-7001/99-12 on 990830-0902.No Violations Noted. Major Areas Inspected:Security Insp Including Physical, Storage & Control of Classified Matter,Classification, Communications Security & Computer Security

ML20212F118
Person / Time
Site:	07007001
Issue date:	09/22/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212F101	List: ML20212F098 ML20212F118
References
70-7001-99-12, NUDOCS 9909280033
Download: ML20212F118 (11)

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U.S. NUCLEAR REGULATORY COMMISSION REGIONlil AND THE DIVISION OF FACILITIES & SECURITY Docket No: 70-7001 Certificate No: GDP-1 Report No: 70-7001/99012(DNMS) l Facility Operator: United States Enrichment Corporation l

Facility Name: Paducah Gaseous Diffusion Plant Location: 5600 Hobbs Road Paducah, Ky 42001 l

Date: August 30 - September 2,1999 Inspectors: J. R. Kniceley, Physical Security inspector, USNRC, Rlli J. K. Everly, Senior Facilities Security Specialist, USNRC l L. M. Numkin, Senior Computer Security Specialist, USNRC R. C, Bethea, Information Security Specialist, USNRC Approved By: Monte P. Phillips, Acting Chief Fuel Cycle Branch Division of Nuclear Materials Safety A. Lynn Silvious, Chief Information Security Branch Division of Facilities and Security Office of Administration

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l 9909290033 990922 PDR ADOCK 07007001 C PDR

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l EXECUTIVE

SUMMARY

United States Enrichment Corporation Paducah Gaseous Diffusion Plant NRC Inspection Report 70J001/99012(DFS/DNMS) l NRC performed a security inspection of the Paducah Gaseous Diffusion Plant located in Paducah, Kentucky on August 30 - September 2,1999. The main objective of this inspection was to ensure compliance with the certificate holder's Protection of Classified Matter Plan. The inspection team reviewed five core areas of the Portsmouth security program. Those areas were physical security, storage and control of classified matter, classification, communications security, and computer security. No violations of NRC requirements were identified.

This inspection was conducted through a review of selected records, interviews with personnel,

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and direct observation of work activities. -

1 Implementation of the Classified Matter Plan and associated implementing procedures I was in compliance with NRC criteria.

Security event reports were adequately reviewed and reported to the NRC.

! Security Plan revisions, which did not decrease the effectiveness of the security plan, were adequately implemented and submitted to the NRC.

a i Security personnel were knowledgeable of their duties and responsibilities.

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Report Details 01 lDagection Scope Areas examined during the security inspection covered the commitments contained in ,

the Protection of Classified Matter Plan (CMP). The inspection centered on detailed reviews of five core areas of the security plan: Physical Security (e.g., protective personnel, physical barriers, site security procedures, and personnel identification and control); Storage and Control of Classified Matter (e.g., security containers, monitoring of classified storage areas, and records of classified combination changes);

Classification (e.g., proper marking of and accounting for classified material);

Telecommunications of Classified Information (e.g., accounting for secure telephone units (STU-Ills) and other equipment used to facilitate secure communications of classified information); and Computer Security.

02 Physical Security

a. Inspection Scone The inspectors examined Paducah's physical security and access control practices to ensure compliance with the requirements of the Paducah CMP. The inspection included a review of the physical barriers, alarms, locks and keys, and personnel access controls and badges.

b. Observations and Findinas A review of the site physical security posture consisted of interviews with plant personnel and individual guards, observations of activities, tests, and reviews of procedures.

Gates, vehicle barriers, and guard portals were observed to be intact and adequately manned. Plant personnel and visitors were properly identified, registered, badged, and escorted as required. Personnel security clearances and the need for access to the Controlled Access Area (CAA) of the plant were being verified and packages / briefcases were visually inspected by security officers at the entrance to the CAA as required by the CMP.

The types, design, fabrication, and destruction of security identification badges were found to be consistent with the approved secunty plan commitments. Procedures for lost badges were reviewed and found accurate. Use of proper forms, retention periods for records, and inventory of badging materials were also confirmed. The badge computer database was reviewed and found to be consistent with procedures.

To determine if adequate protection was being afforded the low enriched uranium (LEU), the inspectors toured the CAA and observed the integrity of the fence, gates, and l vehicle barriers. The fences, gates, and vehicle barriers were intact and adequately maintained.

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

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The inspector also interviewed officers posted and on patrol, and found them to be knowledgeable of their duties and responsibilities. Security procedures were reviewed and updated as required and located in the appropriate locations.

The inspector reviewed security procedures and post orders and determined that they

, provided adequate guidance for security officer duties.

l The inspectors toured the CAA for the purpose of observing the storage of LEU and determined that the LEU was stored or used only within the CAA.

c. Conclusions The inspectors were able to verify that no violations of commitments were identified with

. respect to the Paducah CMP in the area of physical security.

l Through observations, interviews, independent verification and records review, the inspectors verified that the protection being afforded the LEU at Paducah was in compliance with the CMP requirements.

The inspectors concluded that security measures were effectively in place, procedures

were adequate, training was effective and the certificate holder was meeting security plan requirements.

03 Storace and Control of Classified Matter

a. J.nsoection Scooe (81820)

The inspectors examined Paducah's storage and control of classified matter practices to ensure adequate protection for classified matter being used, processed, stored, reproduced, transmitted, or handled in connection with the gaseous diffusion process. l The inspection included a review of the Paducah Foreign Ownership, Control or influence Program (FOCl); physical checks of classified containers / vaults / cages; records of lock combination changes; reports to the NRC (i.e.,30-day logable security

! event notifications); and a new security container for classified barrier material storage.

The inspectors also reviewed Procedures CP2-SS-SE1036, " Classified Matter Protection and Control."

b. . Observations and Findinas

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A ' review of the process by which classified material was used, processed, stored, reproduced, transmitted, and handled consisted of interviews with plant staff, observations of activities, and reviews of procedures. While reviewing various classified

security containers / vaults / cages in Buildings C-720, C-710, C-400, C-337, C-333, C-331, and C-300 the inspectors were able to confirm that Standard Form 702's,

" Security Container Check Sheets," were being utilized in accordance with the commitments contained in the approved CMP. However, the inspectors did note that i several Standard Form 700's, " Security Container Information," reviewed indicated that the combinations to these classified storage containers were in noncompliance with the CMP commitments in that the combinations were overdue to be changed. Upon further review, the inspectors discovered that two sets of the SF 700 forms were placed in L 4 l

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these classified security containers. One set indicated the combination change dates were in compliance and the other set did not. It was determined by the plant staff and confirmed by the inspectors that the outdated set of SF 702 forms were not properly removed from the containers when a new combination was set thus causing the confusion. The plant staff was cautioned that this practice could lead to a violation of their CMP if only the outdated SF 702 form can be located during future inspections.

While reviewing classified components in the C-710 Laboratory, the inspectors, at the request of USEC by letter dated February 12,1999, reviewed a new specially designed security container to be used as a repository for barrier material storage. The inspectors evaluated the proposed design of the new container and determined that it met the requirements for the protection of classified matter in storage as described in 10 CFR Part 95.25.

The inspectors also reviewed the Paducah FOCl program and found that the plant was in compliance with the commitments contained in the CMP. The inspectors also noted that the plant has adequately conformed to the NRC assuming from the Department of Energy cognizant security authority for all FOCl actions associated with the Paducah and Portsmouth Gaseous Diffusion Plants.

Security Event Reoorts The certificate holder provided the following security-related logable events for the period June 17 - July 28,1999. The inspectors reviewed any immediate security concems at the time of the initial receipt of the events. There were no significant issues or compromises of classified information identified from these reviews. The root cause j for these events was determined to be personnel error and legacy policy. It was i determined that appropriate corrective actions have been taken. l Number Qalg Title 99-3641 6/17/99 Obsolete markings on document.

99-3744 6/22/99 Classified storage cortainer not properly marked.

99-3769 6/23/99 Classified storage container not properly marked.

99-3887 6/29/99 Classified material not correctly marked as CRD.

99-4213 7/19/99 Obsolete markings on document. Document not controlled according to markings.

99-4409 7/28/99 Compromise of CRD.

With respect to reporting events to the NRC, the inspectors noted that specific reporting requirements as described in 10 CFR Part 95.57 were recently removed from Section 17 of the Paducah CMP as part of a 10 CFR Part 76.68 change. In lieu of the specific reporting requirement, the certificate holder references Section 6.9 of the Paducah SAR regarding reports to the NRC required by 10 CFR Part 95. This change is considered a decrease in the effectiveness of the CMP and was brought to the attention of the certificate holder.

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c. Conclusions j The inspectors verified that no violations of commitments existed with respect to the ,

Paducah CMP in the area of storage and control of classified matter.

l 04 Classification i

a. Insoection Scope  :

The inspectors examined Paducah's policies and procedures for the classification of I information to ensure compliance with the commitments in the approved CMP and appropriate Executive Order. The inspectors reviewed classification guidance and how it was applied to documents. In addition, the inspectors reviewed an Authorized i Derivative Classifiers (ADCs) training class being conducted at the Paducah site to determine if the requirements of E.O.12958, " Classified National Security information,"

were being adequately covered. Lastly, the inspectors reviewed the Paducah ADCs activity for the last 12 months to determine the frequency of the ADC activity and the need for the current number of ADCs at the site.

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b. Observations and Findinos l A review of the Paducah classification program consisted of an interview with the Site )

Classification Officer, observance of an ADC training class, and interviews with various  !

ADCs regarding their classification activity. The inyectors were able to confirm that the Site Classification Officer was knowledgeable of the requirements of E.O.12958, the new marking requirements of 10 CFR Part 95.37, and appropriate classification l guidance. It was also verified that the Paducah plant was equipped with the proper j stamps for marking classified documents in n cordance with E.O.12958. A review of the Paducah ADC Training Program showed that the program adequately covered the  ;

requirements of E.O.12958, the new marking requirements of 10 CFR Part 95.37, and j appropriate classification guidance. The inspectors were also able to confirm that Paducah ADCs are performing their review functions as required but, are not classifying a large number of documents, thus, giving the appearance that ADC activity is minimal.

c. Conclusions i The inspectors verified that no violations of commitments existed with respect to the Paducah CMP in the area of classification.

05 Telecommunications of Classified Information

a. Inspection Scooe The inspectors examined Paducah's telecommunications requirements and equipment to ensure classified matter was adequately protected while being telecommunicated.

The inspectors reviewed Paducah's Communication Security (COMSEC) Program including sighting of COMSEC equipment and physical security controls.

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b. Observations and Findinas A review of Paducah's Telecommunication of Classified Information Program consisted of an interview with the Paducah COMSEC Custodian, reviews of procedures, and observations of COMSEC holdings. The inspectors examined a random number of STU-llis and confirmed that the units were handled and operated in accordance with the commitments contained in the approved CMP. It was also confirmed that the encrypted keys used in connection with the STU-ills were being secured in classified storage containers when not in use, as required. In addition, the inspectors informed the Paducah COMSEC Custodian that all STU-llis were scheduled to be phased out in the i near future and replaced with the new " Secure Terminal Equipment (STE)." The i inspectors noted that if the Paducah plant plans to continue telecommunicating classified information, all plant STU-liis will eventually have to be replaced with the STE.

The inspectors also confirmed that Paducah's secure facsimile is Y2K compliant.

i c. Conclusions The inspectors verified that no violations of commitments existed with respect to the Paducah CMP in the area of telecommunication of classified information.

06 Computer Security

a. Insoection Scope i

The inspectors reviewed Paducah's methods for processing classified data on I designated stand-alone personal computers to ensure that data being processed was adequately protected.

b. Observations and Findinas The inspectors reviewed Paducah's Computing and Telecommunication Security Program to ensure that there are measures in place to control access and protect the classified systems operating at the plant. Paducah currently has three classified stand-alone microcomputer systems in operation. Each system is operating under an approved computer security plan which formally documents the measures used to l control access and protect the classified systems and their information. These plans were accredited at 3-year intervals (or more frequently if significant modification occurred) to ensure that the systems continue to be in compliance with the requirements contained in the " Master ADP Security Plan for Microcomputer Resources Processing Classified Information" and that the protective features and assurances continue to be effective. All systems' plans were found to be current.

While reviewing the Master ADP Security Plan the inspectors noted that the current version was last revised November 2,1993, and is in need of updating. The following i

are some examples of items in the Master Plan that need to be addressed:

Page 7 lists obsolete designations for security areas: Property Prctection Area l (PPA) is acceptable but reference to " Limited Area (LA), Exclusion Area (EA), and Protected Area (PA)" have now been replaced by " Controlled Access Area (CCA)."

These terms are found throughout the document and are no longer used, and could be confusing.

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Page 11, Item 2. " Access Lists" does not include any frequency of list validation which could conceivably leave names which should have been removed on the list.

Page 12, Item 3. " Protection of ADP Storage Media." The Portsmouth GDP guidance no longer requires sanitizing laser toner cartridges but Paducah's still does. This also applies to Page 18, item 2.

Page 13, item C.1. " Protection of Communication Lines" second paragraph, references Terminal Connection Boxes (TCB) which are not employed at Paducah.

Page 17. The list of why a clas:ified system needs to be sanitized does not include the basic case of "When no longs; required for Classified processing."

Page 17, item b. " Sanitization Procedures" references that "the microcomputer is attached to a classified network" which is not the case at Paducah.

Attachment 1 shows an obsolete " Master ADP Security Plan for Microcomputer Resources Processing Classified Information," format dated November 2,1993.

This security plan format was last updated on June 19,1996.

While reviewing the classified system in the C-710 Laboratory Room B-12, the inspectors learned that the actual usage of CRD on the computer was 25% not 50% as originally recorded in the security plan. The security plan was corrected during the course of the inspection. Also, while reviewing the list of Altemate CSSOs for the C-710 Room B-12 system, the inspectors found that one individual on the list no longer worked at the plant. The CSSO for the system corrected the alternate CSSO list immediately.

This also applied to and was corrected by the CSSO for the C-710 Room B-6 system.

As for the C-102-T2 classified system, the computer security plan dated April 23,1997, under the section " Percent of Information Processed by Classification and Category" contained an arithmetic error. CRD usage was listed as 84%, SNSI usage was 10%,

and SRD usage was 17%, which equals 111%. The plan was modified during the course of the inspection to show a total of 100%.

Lastly, the inspectors noted that all CSSOs/Altemate CSSOs are required to receive training, which includes reviewing the video entitled, " Classified Microcomputer Systems," as stated on page 10 of the " Master ADP Security Plan for Microcomputer Resources Processing Classified information" format. The training video was created in 1990 and the inspectors noted that some references to position titles have changed and ,

certain procedures are no longer being performed at Paducah. Overall, its guidance for )

handling classified computers and data is transportable to the present day, however, the j video tape is in need of updating / revision. I

c. Conclusions The inspectors concluded that the overall implementation of the computer security program was adequate. When concerns were identified, corrective actions were immediately taken, when possible. Plant staff were knowledgeable of requirements and procedures, and generally performed duties well. The issues regarding the Master ADP Security Plan will be reviewed during future inspections.

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07 Exit Meetina Summary The inspectors presented the preliminary inspection results to members of the plant's management at the conclusion of the inspection on September 2,1999. Although classified information was used during this inspection, no classified information was removed from site.

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PARTIAL LIST OF PERSONS CONTACTED S. Bell, Security Section, United States Enrichment Corporation (USEC)

R. Coriell, Headquarters Security, USEC J. Feezor, Security Section, USEC C. Hicks, Manager- Wie and Facilities, USEC L. Jackson, Manager- Nuclear Regulatory Affairs, USEC P. Jenny, Manager- Security Section, USEC J. Morris, Security Section, USEC H. Pulley, General Manager, USEC D. Stadler, Regulatory Affairs, USEC B. Stapleton, Headquarters Security, USEC 2

INSPECTION PROCEDURES USED IP 81820: Physical Protection Facility Approval and Safeguarding of National Security information and Restricted Data IP 81431: Fixed Site Physical Protection of Special Nuclear Material of Low Strategic Significance i

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LIST OF ACRONYMS USED ADC Authorized Derivative Classifier CAA Controlled Access Area CFR Code of Federal Regulations CMP Classified Matter Plan CRD Confidential Restricted Data COMSEC Communication Security DNMS Division of Nuclear Materials Safety EA Executive Order FOCl Foreign Ownership, Control or Influence LEU Low Enriched Uranium NRC Nuclear Regulatory Commission STE Secure Terminal Equipment STU Secure Telephone Units USEC United States Enrichment Corporation l

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