Safeguards and Security

When all of the groups have finished their reviews and initial drafts of their topical areas, the drafts will be combined and reviewed by an implementation focused "red team." A review of the approach DOE uses for safeguards and security planning, which began in late 2007, delayed the final draft and review of the by the "red team". It is anticipated that the new planning document will be accepted in early July and work on the Manual will resume in mid-summer.

Q: Several DOE 470.4 series Manuals use the term "Departmental element." What does that term mean?

A: The term "Departmental Element" is a common-use term from the DOE directives system. DOE M 251.1-1B, Departmental Directives Program Manual defines Departmental Element: "First-tier organizations reporting directly to the Secretary, Deputy Secretary, or Under Secretaries. The National Nuclear Security Administration is a Departmental element. First-tier organizations at Headquarters include the Secretary, Deputy Secretary, Under Secretaries, and Secretarial Officers (Assistant Secretaries and staff Office Directors). First-tier organizations include managers of the field offices and Administrators of the Power Marketing Administrations." The latest list of Departmental Elements can be found at: http://www.directives.doe.gov/pdfs/reftools/org-list.pdf.

Q: Are there any resources available within DOE for people involved in developing and managing a security awareness program as required in DOE M 470.4-1?

A: Yes. The National Training Center (NTC) offers a four and one-half day introductory course, Safeguards and Security Awareness Coordinators' Training, for individuals who are involved in developing, implementing, and maintaining security awareness programs. More information on the course is available on the NTC website at http://www.ntc.doe.gov/docs/NTCCourseCatalog_Final.pdf. The Security Awareness Special Interest Group (SASIG) is an active networking group of Federal and contractor personnel involved with safeguards and security awareness programs. The members of SASIG work to promote safeguards and security awareness within the DOE, assist sites and facilities in carrying out the security awareness program requirements and share security awareness resources. Membership is open to anyone with a work-related interest in promoting security awareness, and there is no membership fee. More information about SASIG, including how to join the group, is available on the SASIG website at http://www.orau.gov/sasig/.

Q: What is expected of an organization which assumes security cognizance for another site? Are there specific duties and services that the organization with security cognizance has to provide?

A: An organization which is listed as the cognizant security authority for another location is expected to be able to perform specific security functions on behalf of the client location. Those security duties and services include but may not be limited to surveys to determine security requirements, review and storage of safeguards and security plans and other documents, oversight activities, FOCI considerations, registration of a facility clearance, personnel security clearance activities, and SSIMS entries. In accordance with DOE M 470.4-1 and the requirements of the NISPOM, the security authority must possess a facility security clearance at the same level or higher as an office over which it exercises responsibility. This means that the cognizant security organization must be surveyed and registered in SSIMS, and must set up a limited area and classified processing capabilities. The organization must meet the requirements and be capable of undertaking the security activities itself; there is no provision for establishing a Memorandum of Agreement or other vehicle as a "paper" designation to allow the security activities to be performed by another organization on behalf of the organization with security cognizance.

Q: Some forms that DOE uses in connection with various activities (such as the Visit Request form and the Security Acknowledgement and Termination Statements) are really outdated. Are there any plans to revise these forms and bring them up to date?

A: As the zero-based policy review proceeds, some review of the forms used in connection with specific activities is being conducted. The Security Acknowledgment and Terminations Statements, which are used primarily in connection with the DOE personnel security program but which also have security awareness applications, are currently being revised to reflect changes to the DOE personnel security program (new drug testing requirements, revised personnel security and foreign travel reporting requirements), and to reflect current requirements pertaining to prepublication review of materials prepared by individuals who hold or previously held a DOE security clearance. Since questions have been raised concerning the Visit Request form, used in the classified visits program, we will review this form and update it as necessary. Questions pertaining to other forms which are referenced in the security directives may be addressed to HS-71.

Q: I have a question regarding the Outside Director (OD) for a company under a Security Control Agreement. Can the OD do consultant work for one of the foreign owners after he has been approved by the Office of Security? DOE M 470.4-1 Part 2, Section H, Chapter IV, FOCI Mitigation Action Plans, 3.,c.,(2) Security Control Agreement, (b) 1: "Appointment of one or more outside directors who must meet the eligibility requirements set forth in paragraph 3.b(1)(b), above. This reference reads: "Be completely disinterested individuals with no prior involvement with the cleared U. S. organization, its foreign-owned tier parent(s), or any of its foreign-owned affiliate(s). This reference, as stated, applies to "before" approval, but, what about after approval? Is this a conflict of interest? We have been told that one of our ODs has been doing consulting work for one of the parents in his company.

A: Based on the situation you've described, it appears there may be a conflict of interest here. As you have stated above, the Manual requires that when setting up the Security Control Agreement one of the stipulations for the Outside Director (OD) is that he/she must, "Be completely disinterested individuals with no prior involvement with the cleared U.S. organization, its foreign-owned tier parent(s), or any of its foreign-owned affiliate(s)." If the OD is getting paid to do work for a foreign parent, he/she is no longer a "completely disinterested individual." I think the term completely disinterested is the key to the requirement. "No prior involvement" is one characteristic of being completely disinterested. However, I don't believe it is the sole characteristic. The key to being disinterested is that the person must be unbiased by personal interest. If the OD is hired by the foreign parent, he/she is no longer disinterested.

Q: What is meant by the term cognizant security authority used in the DOE 470.4 series? Can this authority be further delegated? Does this need to be a formal appointment?

A: As used in the Manuals in this series, the term Cognizant security authority refers to DOE and NNSA Federal and contractor employees who have been granted the authority to commit security resources or direct the allocation of security personnel or approve security implementation plans and procedures in the accomplishment of specific work activities. "DOE cognizant security authority" is used when intended to apply specifically to a Federal authority. When specifically requiring a contractor to fulfill the role, the phrase "contractor cognizant security authority" is used, and when neither DOE nor contractor is specified, the authority may be assigned to either. Further delegation is typically acceptable by definition (Federal/Contractor constraints maintained) since DOE and contractor line management designate their cognizant security authorities. Any exceptions to this will be specified in the corresponding sections of the manuals. Likewise formal appointment is not required, although delegations of authority must be documented in the appropriate safeguards and security management plan. Whether the cognizant security authority role can be delegated or requires formal appointment for any particular action is determined on a Program/site-specific basis according to applicable contracts, directives, and/or security plans. Under DOE O 470.4A, the Under Secretary for Science, the Under Secretary for Energy, and the Associate Administrator for Defense Nuclear Security are designated as the DOE cognizant security authorities for their organizations and may delegate this authority as necessary to carry out the associated responsibilities.

Q: Why does the Office of Security Policy (HS-70), Office of Health, Safety and Security, need a copy of our approved S&S deviations?

A: HS-70 is responsible for establishing the requirements and responsibilities found in S&S directives, including the requirements for the deviations process. HS-70 must be aware of deviations from these provisions for the following reasons: 1) to assure that the deviations process is being implemented correctly; e.g., that a deviation is not labeled a "variance" because of its easier requirements, when, in fact, it is a waiver or an exception; 2) to assure that the provision is one from which a deviation is allowed; e.g., that it is not a statutory, regulatory, Executive order, or Presidential directive requirement from which no deviation is allowed without further process; and 3) to evaluate the portion of the directive from which a deviation is requested to determine if the directive needs to be revised or canceled.

Q: Former policy addressed recurring classified visits by local FBI personnel; however, current policy does not. Why was this language removed? Can we establish local procedures to allow such recurring classified visits?

A: Current policy for the Classified Visits provisions is found in DOE M 470.4-1, Section L. Under this section "continuing visitor access approval" is now required when it is known that an individual's classified visits will be frequent. DOE M 470.4-1, Section L, paragraph 2.a.(3) reads: "Line management must establish local procedures for the control of classified visits. Procedures must ensure... (3) Continuing visitor access approval is necessary for individuals who frequently visit DOE facilities. However, the locally approved access approval cannot exceed a period of 1 year or the final day of a contract, whichever is less. The approval may be renewed annually (at least every 12 months)." This provision would apply to recurring visits by local FBI personnel.

Q: Can local implementation be more restrictive than DOE S&S policy?

A: The S&S directives establish the minimum requirements. Local implementation may be more restrictive, but any action beyond what is required may have to be justified by a cost/benefit analysis to satisfy financial requirements.

Q: Can a DOE Site/Office receive a deviation from an Executive Order or a regulation?

A: If there is a process for deviating from the requirements of a higher directive, that process must be followed. The deviations process in DOE M 470.4-1 covers only deviations from a DOE S&S policy requirement. When the S&S requirement is also an Executive or regulatory requirement from which a deviation is not authorized, the DOE M 470.4-1 process can be used in a limited manner only. A deviation may be considered from a DOE-originated requirement that is intended to implement a general requirement of a national-level directive, so long as the modified implementation achieves the full implementation of the national-level requirement. A deviation from an Executive or regulatory requirement can only be considered under the specific processes, if any, included in the Executive or regulatory language

Q. When the Office of Health, Safety and Security was established, the Office of Security no longer existed organizationally. Who should I contact to complete actions required in the DOE 470.4 directive series since there is no longer a position identified as the Director of Security?

A: The Office of Security Directors' responsibilities, with the establishment of the Office of Health, Safety and Security, fall under the Chief Health, Safety and Security Officer, Glenn S. Podonsky and the Deputy Chief for Operations, Michael A. Kilpatrick.

Q: If there is a change in policy, will official documentation be sent through the proper channels and forwarded to all NNSA and DOE sites?

A: Any changes to DOE S&S policy will be made through the DOE Directives System, which is established by DOE P 251.1A, Departmental Directives Program Policy, DOE O 251.1, Departmental Directives Program, and DOE M 251.1-1B, Departmental Directives Program Manual. Notifications can be received when actions are taken on DOE directives of interest by signing up for E-Mail Notification in the middle of the Directives Home Page. The web address is http://directives.doe.gov/alertmain.html. You may also want to let your Directives Point of Contact (DPC) know of your interest in particular directives. The DPC list is found on the Directives Home Page under "References" (bottom of the left side). The web address is http://www.directives.doe.gov/pdfs/doegeninfo/final/dpclist.pdf.

NNSA has statutory authority to establish NNSA-specific policy (including changes to DOE policy), unless disapproved by the Secretary. If you have questions concerning the process for changes in policy by NNSA, you may wish to contact NNSA. NNSA Policy Letter (NAP)-1 describes the process, and it is available on the NNSA website http://hq.na.gov/default.aspx?L=ITEM&ITEM=2375&CA=30&OT=86&PI=2317.

Q: On December 3, 2007, the DOE Chief Health, Safety and Security Officer signed out a memorandum establishing policy panels to increase feedback from the implementers of DOE policy. How will the PPM policy panel be organized?

A: The PPM panel will be a new policy panel, as there has not been a quality panel in this topical area. Because so many possible topics fall under the broad topic of "program planning and management" (safeguards and security planning, surveys and assessments, facility clearances and FOCI, awareness and training, etc.), it will probably be necessary to organize sub-panels or interest groups within the larger panel. One organization which may serve as a model is the existing Security Awareness Special Interest Group (SASIG). The steering committee for that group also serves as the quality panel for security awareness, and it is planned that this group will continue to fill its traditional policy assistance role. HS-70 will provide additional information as we continue to develop this new topical policy panel.

Q: The terms "critical system element" and "essential element" are used in many contexts in DOE M 470.4-1, Safeguards and Security Program Planning and Management. When these terms are used in the context of vulnerability analyses and performance assurance program evaluations, what is the difference between them, or are they interchangeable?

A: The connection between planning and the performance assurance program is important to understand. As we plan, we have the opportunity to identify protection system elements that are of greatest importance to the overall success of the site/facility protection system. If additional testing of these elements, beyond that required for topical compliance, would provide additional assurance that these elements will perform as expected, these additional tests are incorporated into a formal Performance Assurance Program Plan. The terms "critical system element" and "essential element" used in DOE Manual 470.4-1 Chg. 1, Safeguards and Security Protection Program Planning and Management, to establish requirements governing this process are broadly synonymous. HSS believes that, to eliminate confusion, it is acceptable to use a single term, "critical element," when discussing system elements identified during vulnerability analyses that are then required to be tested under the performance assurance program. The use of this term will be incorporated into the re-write of DOE M-470.4-1 to replace the two existing terms.

Q: There are all kinds of testing of security system elements required to meet compliance requirements under Protective Force, physical protection, and other programs. Isn't the testing required by the Performance Assurance Program (PAP) redundant?

A: The PAP has been established specifically to provide for additional testing above compliance-level requirements. The purpose of testing done under the PAP is to demonstrate effective performance of protection measures that have been determined to fall into the category of "critical elements" as described above. Tests conducted under the PAP are intended to ensure that all identified essential elements are performing as represented in safeguards and security plans and in any supporting analyses for those plans. The intent is to demonstrate that the elements identified as "critical elements", separately and together, do in fact provide the required levels of performance.

Q: Why should DOE field activities be required to conduct comprehensive periodic surveys of their security activities and those of their contractors, if they and their contractors are already subject to testing, special surveys, self-assessments of specific activities, and reviews or inspections by other DOE elements?

A: The periodic survey provides an opportunity for local DOE management to form a comprehensive view of a site's entire security posture and to understand the mutual dependencies among the various components of its protection program. The survey is designed to identify areas of redundancy which will allow better use of resources, identify conflicts between components that may lead to weaknesses not readily apparent when only one of the components is considered, and identify areas in which correction of identified problems in one component creates unexpected performance issues in another component. While reports of special inspections and reviews may be useful in developing the comprehensive periodic survey and evaluating the survey results, taken individually they do not provide the "big picture" overview of a site's security posture which allows identification of a program's overall strengths and weaknesses and produces results which can correct and improve the program as a whole. Even when "continuous" or "rolling" special surveys are conducted to spread the survey activity more uniformly over a survey period, a comprehensive review and analysis of these "point-in-time" data points should be made to complete each required survey period to provide a truly integrated review of site protection.

Q: In processing a request for a facility clearance (FCL), must personnel security clearances be in place for company officials designated as key management personnel (KMPs) before the FCL is granted?

A: Certain company officials must be in process or possess active security clearances in order for a company to be eligible for an FCL involving classified information or matter or special nuclear material (SNM). These company officials include the owners, officers, directors, partners, regents, trustees, or executive personnel (i.e., those individuals considered to be KMPs.) The clearances held by these individuals may be pre-existing from another classified contract, or the individuals may be submitted for security clearances concurrently with the processing of the FCL.

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Physical Protection:

Q: If an error is made while dialing the X-07 combination lock and it will not power up, is it broken?

A: Not necessarily. After 10 successive failed attempts on the X-07, the LCD will blank out. Wait a few minutes for the unit to power down and try again.

Q: What does a lighting bolt on the LCD of an X-07, X-08, or X-09 lock mean?

A: A lighting bolt is caused by any of the following improper techniques:

• Entering the combination too quickly (in less than 10 or 15 seconds).

• Turning the dial more than 1-1/3 revolutions without pausing at least ¼ second.

• Reversing the dialing direction without pausing at least ¼ second.

• Entering an incorrect combination.

Q: I am having a problem with my X-09 lock. I correctly entered the combination and turned the dial to the right and the "OP" is displayed on the LCD. However, continued dialing to the right indefinitely does not open/unlock the lock. What could be the problem and what can I do about it?

A: The "OP" display means you have entered the correct combination. Remember to turn the dial with full wrist turns. This will keep the lock fully powered. The problem may be that the combo motor is an early version, which should be replaced. Try varying the speed of dialing after achieving the "OP" display. Dialing either more rapidly or more slowly will often retract the bolt.

Q: Are Level III locks/keys (DOE M 470.4-2 C1, Physical Protection) required for doors to offices/areas that contain a GSA-approved security container(s) that store classified matter?

A: No. An additional level of locking protection is not needed if the classified matter is stored in a GSA approved security container and the office/area is within a Limited Area or higher.

Q: What is the date upon which the requirements, described in Appendix C, DOE M 470.4-2-2 Chg1, Safeguards and Security Alarm Management and Control Systems (SAMACS), must be implemented?

A: The appendix applies to all new physical protection systems installed or made operational after January 1, 2008, that protect Category I and II quantities of SNM.

Q: Has Underwriter's Laboratory (UL) revised the balanced magnetic switch (BMS) standard, UL 634, Connectors and Switches for Use with Burglar-Alarm Systems, to establish a Level 2 standard to define more stringent requirements?

A: Yes. The requirement evolved from requests from certain government departments and agencies for an improved version for high security applications but existing BMS will not necessarily have to be replaced. It depends on the results of a vulnerability analysis and the existing and/or offsetting security measures to mitigate the vulnerability. If the asset is located in an area where there are no other protection measures present, then the Level 2 BMS would be appropriate. The BMS is manufactured by a single source and costs considerably more than prior generation BMSs, so a judicious approach should be taken before making an arbitrary decision to replace existing high security BMSs.

Q: Is the Secondary Alarm Station (SAS) to be fully redundant to the Central Alarm Station (CAS)?

A: No. However, without advance notice, it must be capable of assuming the command and control functions should the CAS become unable to fulfill its security monitoring and control role. The SAS does not have to receive all of the alarms and perform complete assessment of the intrusion detection alarm zones/devices. It must be capable of providing command and control of site response forces and provide security status reports to the facility's Emergency Command Post/Operations Center. The CAS and SAS requirements relate to the protection of Category I and II SNM and other high consequence assets.

Q: What is a SF-700?

A: The first part of this two-part form contains information on the responsible organization, container, type of lock, and names, addresses, and telephone numbers of employees who are to be contacted if the container is found open and unattended. This portion is attached to the inside of the control drawer or vault door. The second part (comprised of Parts 2 and 2A) is a sealed combination record that is turned over to the designated person responsible for the central storage of the SF-700 forms. Parts 2 and 2A of each completed SF-700 must be classified and marked front and back with the highest classification level (and category, if RD or FRD) of information authorized for storage in the security container. These parts are to be stored in a different security container that only permits access to individuals who possess the same security clearance, any required formal access approval, and need to know for all of the information that may be protected by the enclosed combination.

Q: Why do I need to use SF-700?

A: Title 32, Code of Federal Regulations requires that the SF-700 be used in all situations that call for the use of a security container information form. Aside from being required by DOE policy, there is always a possibility with any combination lock that the combination could be lost or forgotten. If this ever happens, you can easily recover the combination if you have a SF-700 on file. Having this combination record readily available may save you the cost of forcibly opening the container and having to spend money to protect the classified information while the container is being repaired.

Q: Must I install high-security padlocks on gates providing access to public and property protection areas?

A: No, high security padlocks are not required; but, DOE M 470.4-2, provides security criteria for Level III security locks and keys that are required for use on gates in fences, cargo containers, and storage areas for the protection of Government property.

Q: Where can I find information about the Levels of federally approved locks and keys?

A: Federal specifications, appropriate for high security locks and keys securing public and property protection areas, are available at the Department of Defense Lock Program Technical Support organization. They provide information to DOE on security hardware and are available by accessing their web site at https://portal.navfac.navy.mil/go/locks or by calling (800) 290-7607 or (805) 982-1212.

Q: Is there an inventory requirement for Level IV locks and keys?

A: No. There are no DOE requirements to inventory Level IV locks and keys. However, a locally developed procedure addressing the issue, turn-in, loss, compromise, and control of Level IV locks and keys is a sound business practice.

Q: I know that there is a new badge being issued - when can I expect to receive my new badge and how long will my current DOE badge remain effective?

A: DOE and DOE contractor employees possessing a DOE badge will be contacted when the identity verification processing is completed. This will be followed by the turn-in of the current badge in exchange for the new DOE badge. The current DOE badge will remain active until the new badge is issued.

Q: What are the national drivers for the posting of trespassing signs at DOE facilities, installations, and real property as prescribed by DOE M 470.4-2?

A: Section 229 of the Atomic Energy Act of 1954 (42 U.S.C. 2278a) as implemented by 10 CFR 860-Trespassing on Department of Energy Property provides details for posting the regulations and penalties. Those DOE activities located on property under the charge and control of the General Services Administration, 41 CFR 101-20.3, Conduct on Federal Property, and 41 CFR 102- 81, Security, provide the guidance on the rules and regulations involving the property. Chapter XIV, Posting Notices, DOE M 470.4-2, describes the requirements for the Posting of property owned by or contracted to the United States for DOE.

Q: Does the DOE-approved combination lock on my vault door require modification to permit one-handed operation for egress in the event of an emergency?

A: No. If the lock meets the requirement for installation on vault and vault-type-room (VTR) doors, it does not require modification. The approved lock has a built-in safety release which must be engaged upon opening the lock. It automatically releases the latch when the door is opened. Thus, there is no modification required to the existing lock. Before someone is allowed to work in a vault, he/she should be instructed in the operating procedures, including the opening, closing, and alarm shunting/activating, the notification procedures when the alarm is shunted/activated upon arriving/departing the vault/VTR, and the response procedures for incidents.

Q: What's DOE policy concerning leaving a badge in a vehicle? Could I leave it in my car, so I don't forget and leave it at home because it will always be in my vehicle when I return to work.

A: Paragraph 3.e of Chapter XV, DOE M 470.4-2, requires each badge-holder to protect "the security badge against loss, theft, or misuse" and to report "a lost, stolen, or misused badge to the cognizant security authority within 24 hours of discovery." It is a poor security practice to leave a DOE badge in your vehicle. DOE badges should be protected the same as you would protect/secure cash, check book or credit card. Under isolated, unavoidable circumstances, leaving the badge in your locked vehicle, out of sight may be necessary, but any available means must be employed to eliminate unauthorized access to the badge (e.g. placed in a glove box, kept out of sight, car parked in an access-controlled area).

Q: While on official travel, hotel personnel ask to make a copy of my DOE badge (in addition to my official orders) to verify my DOE status in order to receive the official government rate. Should I allow them to make a copy of my DOE badge?

A: No. Your DOE travel orders, your Government credit card, and when asked, showing your DOE badge, are sufficient to validate the individual's status as a person on official government travel. Title 18 U.S. Code, Section 701, prohibits the photography, engraving, printing, or impression in the likeness of any such badge, identification card, or any colorable imitation. Violations of this Code may result in a fine or imprisonment or both.

Q: On December 3, 2007, the DOE Chief Health, Safety and Security Officer signed out a memorandum establishing policy panels to increase feedback from the implementers of DOE policy. How will the Physical Protection policy panel be organized?

A: At this point, we are looking to use the organization structure previously utilized on physical protection quality panels but modified through the experience we have had in performing the zero-based policy review and it's resultant re-write of DOE M 470.4-2. This may be modified further as we do not plan to have the number of individual policy panels as we did quality panels and we will not be able to have as many face-to-face meetings. We will attempt to leverage current technology, such as video conferencing, to have meaningful panels without the resource drain resulting from many face-to face meetings requiring large numbers of people to travel. As this is in the early "conceptual" stage future updates will be available upon request.

Q: What is the most significant change in the draft DOE M 470.4-2?

A: The most significant change is that the manual has been reorganized into what are being referred to as "tiers". The attempt is to have all the physical protection requirements that apply to everyone in DOE/NNSA appear in the first tier. Sites that do not have classified documents, classified matter, or SNM would only have to apply relevant requirements in this tier, and would not need to delve deeper into the document. The next tier would include all those requirements that apply to sites that have classified matter and no more than CAT III SNM. These requirements, as well as those for the first tier, would be what security personnel at those sites would be required to implement. Finally the third tier would have requirements that apply only to CAT I and CAT II sites. These major facilities would be responsible for implementing all the DOE physical protection requirements.

Q: What are the most significant changes in DOE M 470.4-2 the requirements regarding physical protection?

A: The most significant changes are associated with the implementation of Homeland Security Presidential Directive 12 (HSPD-12). In 2005, President Bush signed out HSPD-12 requiring a common identification badge or credential for all government employees and contractors. A working group has developed DOE's implementation plan for HSPD-12 and the draft physical protection manual has been updated as these plans have been provided to HSS. As the technical specifications for the HSPD-12 badges have been made public, DOE will no longer have an OUO section of the physical protection manual where these specifications have been published in the past.

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Protective Force

Q: DOE Directives allow for reduced frequency of inventory and maintenance checks for stored firearms. What is meant by the term "stored firearms"?

A: To qualify as "stored firearms," the weapons cannot be designated as available to support "contingency operations;" e.g., M-4s that could be issued for an emergency response would need to be inspected semiannually. They could not be defined as "stored firearms". In other words, "stored firearms" cannot be part of the active inventory available for duty, training, qualifications, or contingency response operations.

Q: Federalization of the Department's protective force is an option which has been discussed for many years. What is the official DOE position on this option?

A: Since 2004, several studies have been conducted by the DOE and the National Nuclear Security Administration (NNSA) regarding this issue. After jointly reviewing the results of the studies, on January 19, 2009, the Administrator, National Nuclear Security Administration, and the Chief, Health, Safety and Security Officer issued a joint memorandum stating that, "…federalizing the protective force is no longer a viable option that should be pursued" in the current environment. This decision, however, was not meant to foreclose further action to improve the situation of protective force members. On the contrary-the leadership of the Department is committed to exploring every feasible protective force career option and is further committed to developing both near- and long-term actions on behalf of the protective forces. There is a need to consider every aspect of the issue while giving due consideration to previously proposed actions. This will require the collective insight of the senior technical staff of the Department's security community.

Q: How does DOE determine what modifications should be authorized for its weapon systems (both duty weapons and those modified for electronic simulation system use) and how is that information promulgated?

A: When a site identifies a new weapon modification, a package outlining the change is developed and provided to the Office of Security Policy and the National Training Center. After review and discussion with subject matter experts, e.g., at the Armorer's Policy Panel, if the modification is approved, it is added to the Firearms Modification List posted on the HSS website in the Protective Force Supplemental document section at http://www.hss.energy.gov/SecPolicy/pfs/FML.pdf. Additionally, the Firearms Modification List is reviewed annually at the policy panel held in conjunction with annual armorer training.

Q: During a review of the new Contractor Protective Force Manual (DOE M 470.4-3A) it was noted in Attachment 1, Chapter II, paragraph 7.a.(3) that instructors must have the ability to develop course objectives, lesson plans, training aids, and student evaluations. Does this mean that instructors need a course in curriculum development in addition to Basic Instructor Training in order to fulfill the "ability to develop" requirement?

A: No. The intent is that instructors should understand the basic principles and techniques involved in curriculum development, which enables them not only to assist in that process, but also to be able to conduct effective reviews of lesson plans--all designed to make them more proficient in delivery. National Training Center's Curriculum Development (CD) course would be an excellent professional development vehicle, but it is by no means required that instructors attain that skill level. Obviously, if an instructor functions also as a curriculum developer then the formal CD course would be advisable.

Q: Given the publication of DOE M 470.4-3A, Contractor Protective Force, why hasn't the old DOE M 470.4-3, Chg.1, Protective Force, been canceled?

A: The old protective force manual addresses both contractor and Federal protective force requirements. The associated Contractor Requirement Document was canceled by the issuance of DOE M 470.4-3A. However, until the publication of Draft DOE M 470.4-8, Federal Protective Force, the old directive must remain in force.

Q: Department of Energy (DOE) protective force (PF) operations have been satisfactory and stable for years. Why is the change to an “elite force” or Tactical Response Force necessary?

A: As the events of 9/11 and subsequent events worldwide have shown, the adversary that we have consistently projected since 1983 is not likely to be the adversary we now expect to face. Today, we can anticipate facing an adversary with more resources and enhanced capabilities, and who routinely plans to use suicidal tactics as a portion of their overall tactical plan. In the past, we were able to demonstrate an adequate level of site defense by using a large number of PF personnel in dispersed positions to overwhelm the adversary upon detection. Even a small increase in projected adversary numbers makes this tactic unfeasible, both tactically and from a resource standpoint.

Q: What policy directives were changed to affect the Secretary’s vision of an elite PF for the DOE?

A: Page change revisions to implement the elite PF initiative were made to the three most applicable manuals to ensure an integrated, systems approach to implementation of Tactical Response Forces at Category I/rollup and Threat Level 2 facilities (facilities where a denial strategy is applicable):

• DOE M 470.4-1 Chg1, Safeguards and Security Program Planning and Management, now contains the new DOE Tactical Doctrine and other requirements for protection program planning.
  
  
• DOE M 470.4-2 Chg1, Physical Protection, addresses physical security enhancements and more reliance on technology to augment PFs.
  
  
• DOE M 470.4-3 Chg1, Protective Force, focuses on changes to PF structure, organization, deployment, training, supervision, equipment, performance testing, and tactical exercises. A career progression plan and new Rules of Engagement for the application of deadly force have been included within this manual.
  
  

Q: What is the Tactical Response Force concept of employment?

A: The tactical response force concept, combined with the integrated use of security technology and a well designed barrier plan, provides a solution that is less manpower intensive and, at the same time, is less sensitive to the number of adversaries encountered. It recognizes that there traditionally have been PF duties and posts that are primarily intended to support routine operations and, because of location or other considerations, are of secondary tactical value during an attack on a special nuclear material (SNM) location. The tactical response force concept redirects highly trained and tactically skilled PFs toward their primary mission. Similarly, the defense of an SNM location involves three equally important functions: early detection and assessment capabilities to enable early interdiction as far away from the target as possible; establishment of a formidable protective perimeter around the target before the adversary arrives; and deployment of highly mobile, heavily armed forces who assess early alarms, engage adversaries sufficiently to evaluate their main assault, and maneuver decisively against them when the assault team is fixed by fire from the defensive perimeter. Mobility and firepower for the maneuver forces are provided primarily by lightly armored vehicles with weapons providing high rates of fire, and secondarily by dismounted forces with lighter, high rate of fire weapons such as the squad automatic weapon. In general, mobile units will be covered by overwatch elements with long range weapons on vehicles or within the static defensive perimeter.

Q: What are the primary duties of the Tactical Response Force?

A: Application of the Tactical Response Force principles is dependent upon site-specific defense strategies, but tends to lead naturally to three categories of armed combatant: 1) armed personnel who are primarily assigned to routine duties but who assume key blocking positions upon attack; 2) armed personnel near target locations who assume prepared defensive positions upon attack; and 3) mobile forces who carry the fight to the adversary. The first two of these categories will generally not be required to move long distances under tactical conditions and are categorized as Special Police Officers (SPO)-I in the revised policy. Members of the mobile force whose primary duty is to fight using the capabilities and armament of the vehicle could also be designated as SPO-I. Mobile force members whose primary mission is to maneuver on and attack adversary forces on foot should be designated as SPO-II and therefore subject to more rigorous physical fitness standards. Members of either the static or mobile force who are designated as special response team members with responsibility for reentering areas defended by an adversary or other special response team duties, such as hostage rescue and pursuit, should be designated as SPO-III, with the accompanying training and physical fitness requirements.

Q: Is every site required to have a Tactical Response Force?

A: No. A Tactical Response Force is required only at sites where the PF is responsible for the security of Category I quantities of SNM; credible rollup of SNM to a Category I quantity; and those facilities that meet or exceed the Threat Level 2 criteria specified in DOE O 470.3A, Design Basis Threat Policy, for chemical, radiological, or biological thresholds. (At this time, none have been communicated)

Q: Who determines which categories of SPOs are needed at a site and in what numbers?

A: DOE line management ultimately is responsible for the determination of numbers and categories of PF personnel needed to provide the level of security required by their site. This determination is based on mission, vulnerability analyses, protection strategy, and response plans.

Q: Are all DOE PF personnel required to complete a one-mile run as part of their physical fitness qualifications?

A: No. DOE M 470.4-3 Chg1, Protective Force, requires that those personnel designated as SPO-II or SPO-III must meet the Offensive Combative Standard (OCS) specified in Title 10, CFR, Part 1046, “Physical Protection of Security Interests.” Those designated as SPO-I are required only to meet the Defensive Combative Standard (DCS). The most significant difference between the OCS and DCS is a 1-mile run in 8 minutes 30 seconds for OCS versus the half-mile run in 4 minutes 40 seconds for DCS. Unarmed security officers have no physical fitness standard.

Q: What is the difference between offensive and defensive posts?

A: In general, offensive posts are those manned by individuals who take the fight to adversaries and who meet the OCS fitness requirement. These are members of the active defense, or maneuver element, and would deploy from a vehicle or post with expectations of moving greater than 50 yards from that vehicle or post. Defensive posts are situated such that the adversaries must come to them and are staffed by personnel who meet the DCS fitness requirements. As part of the static or fixed defense, they may deploy from a vehicle or post with expectations of moving less than 50 yards from that vehicle or post. The cited distances associated with deployment are intended as general guidelines and are dependent upon the most tactically advantageous maneuver options available from the post or patrol at the time of deployment. They distinguish relatively short distances that could be negotiated by less physically-capable SPOs, as opposed to longer distances that might require more stamina. Line management is responsible for determining the likelihood of extended deployment zones for each assigned post.

Q: Why is there no longer a “grandfather clause” for the OCS so that PF personnel with age, illness, or injury issues can keep their jobs as SPO-IIs?

A: With the publication of DOE M 473.2-2, Protective Force Program Manual, on 6-30-00, the fitness requirement for SPO-IIs was established at the OCS as described in Title 10 CFR 1046, “Physical Protection of Security Interests.” A “grandfather clause” was inserted that allowed incumbent SPO-II personnel to remain at the DCS. When DOE M 470.4-3, Protective Force, was published on 8-26-05, the grandfather clause was not included, because the original intent of the CFR was spelled out in more detail, noting that the fitness standard for an individual depended on assignment. DOE sites were to designate posts as either offensive or defensive in nature, with the intent that less physically demanding defensive posts could be staffed by those who could not meet the OCS.

Q: How do the new designations of SPO-I, II, and III relate to the old ones, especially with regard to physical fitness standards?

A: Previously, few sites used the SPO-I designation, but those who were so designated were required to meet the DCS contained in Title 10 CFR. The SPO-II designation was applied to more highly-trained PF personnel who, depending on duty assignment, might be required to meet either the DCS or the OCS specified in 10 CFR 1046. SPO-IIIs were even more highly trained, including certain specialized training, and required to meet the OCS. The revised categories and physical fitness standards are shown in the table below.

Previous Directives		Current Directives
Position Designation	Physical Fitness Standard	Position Designation	Physical Fitness Standard
SO	None	SO	None
SPO-I	Defensive Combative Standard	SPO-1	Defensive Combative Standard
SPO-II (Defensive)	Defensive Combative Standard
SPO-II (Offensive)	Offensive Combative Standard	SPO-1I	Offensive Combative Standard
SPO-III	Offensive Combative Standard	SPO-1II	Offensive Combative Standard

Q: How are the older and more senior PF personnel supposed to be able to qualify as SPO-IIs?

A: The ability to qualify as a SPO-II at the OCS is not so much a function of age, seniority, or gender as it is of physical conditioning resulting from a disciplined individual wellness and fitness program. Injuries or illness can produce exceptions, of course. The Secretary’s elite force initiative resulted in a Tactical Doctrine and a Career Progression Plan that combine to provide DOE sites the opportunity to develop protection plans that include the establishment of both offensive and defensive posts. Personnel who can meet the OCS may be categorized as SPO-IIs or -IIIs and assigned to the offensive posts, while those who can qualify only at the DCS may be categorized as SPO-Is and assigned to defensive posts. This policy changes mainly the title, or categorization, of PF personnel. Those persons who previously worked SPO-II defensive posts may continue to be eligible to work those posts and remain valued and essential members of the PF; the new policy simply redesignates them as SPO-Is.

Q: Does DOE policy dictate which categories of PF personnel, and in what numbers, are to be assigned to a site?

A: No. DOE policy provides sites/facilities the latitude, based on mission, vulnerability analyses, protection strategy, and response plans, to decide how many SPOs are needed in each category. Those decisions are made in conjunction with respective Headquarters Program Offices.

Q: If circumstances warrant the designation of most or all PF personnel as SPO-IIs, thereby requiring the OCS, must all qualify at that standard immediately?

A: If management is committed to designating all or most of their PF personnel as SPO-IIs, then those so designated will be required to meet the OCS. Even at that, management will have the latitude to establish compliance milestones in their implementation plans to allow phasein of the OCS. Paragraph 8 of the introductory section of DOE M 470.4-3, Chg. 1, states: "Requirements that cannot be implemented within 6 months of the effective date of this Manual or within existing resources must be documented by the cognizant security authority and submitted to the relevant program officers…" That provision allows the sites time to prepare PF personnel who will be assigned to offensive posts to attain the ability to complete the OCS.

Q: Why do the DOE physical fitness standards not allow for age and gender variations?

A: DOE policy does not discriminate based on age or gender with regard to the performance of assigned duties. All SPOs within specific categories, regardless of age or gender, must be able to perform the essential tasks of their assigned positions, whether offensive or defensive. This concept has been accepted within the DOE since the mid-1980s.

Q: Why doesn’t the DOE adopt an approach to fitness standards such as that used by the military?

A: The military, although similar in some respects, is structured differently. With some exceptions, older, more senior individuals and females are generally more remote from direct engagement with the enemy than younger males. The vast infrastructure of the military demands that more experienced personnel advance into less tactically-oriented, and thus less physically demanding, roles; therefore, their fitness standards adjust accordingly. DOE PF organizations are not structured to accommodate large numbers of personnel whose primary duties do not revolve around tactical defense of a nuclear site. Any modifications to the current standards will comply with rulemaking requirements, to include addressing all public comments.

Q: Are the mile and half-mile run standards legitimate tests of a person’s fitness to perform DOE PF duties?

A: The present standards were derived from a correlation between observed performance of a series of tactical scenarios and the selected evaluative criteria. The DOE Office of Security Policy is evaluating a revised standard that will be equally demanding, but will consist of tasks more closely resembling current PF duty requirements.

Q: Must the assignment of automatic weapons, particularly, crew-served firearms, be limited to PF personnel who have qualified at the OCS?

A: No. DOE policy does not limit the employment of automatic weapons to sites or posts designated as offensive. In fact, DOE Tactical Doctrine encourages the placement of crew-served automatic weapons in defensive emplacements protecting sensitive targets.

Q: Did the elite force policy revisions change the requirement for possession of a “Q” clearance to be assigned an automatic weapon?

A: No. The issue of the requirement to have a “Q” clearance to be armed with an automatic weapon was not affected by the elite force policy revisions. Title 10 Code of Federal Regulations (CFR) 1046.14 conveys two stipulations: "SPOs possessing less than "Q" access authorization shall not be assigned to offensive positions or (emphasis added) duties where fully automatic firearms are required." "Offensive positions" and "duties where fully automatic firearms are required" are not synonymous. It makes no difference whether an automatic weapon is deployed in a defensive or an offensive position; the SPO to which the weapon is assigned must have a "Q" clearance according to the CFR.

Q: What has been done to clarify the circumstances under which deadly force may be applied at the site level?

A: The March 2006 policy revisions included, for the first time, guidelines for rules of engagement (ROE) that require the development of site- and post-specific ROE incorporating the concept of “hostile intent.” Such ROE must consider the type of materials being protected, site geography, building construction, PF strength and capability, adversary task times, adversary characteristics as described in the current DOE Design Basis Threat, and consequences of asset loss. The ROE must clearly state under what conditions the circumstances of hostile intent have been met for each post in order for deadly force to be applied. The posting of perimeter signage that states, “Halt, Deadly Force is Authorized Beyond This Point” is authorized. Completed ROE must be submitted to the DOE cognizant security authority for review and approval. The National Nuclear Security Administration requires that site ROE be reviewed by the local DOE Chief Counsel. Upon approval, examples of likely scenarios where the use of deadly force may and may not be authorized must be included in General and Post Orders.

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Information Security

Q: Why was the timing for CMPC refresher training removed from the Information Security Manual?

A: The timing element was removed to provide CMPC POCs with sufficient latitude to manage and implement their program. The Manual requires each site/facility to establish its own CMPC Program with a CMPC Point-of-Contact (POC). There is a national requirement for individuals to have an initial security briefing and/or training when they receive a clearance or access authorization. There is also a national requirement for an annual security refresher briefing based on that initial security briefing/training. In addition, individuals who work with classified information on a routine basis are required to receive detailed CMPC briefing/training as it applies to his or her duties prior to their taking on those tasks.

Since the CMPC POC is knowledgeable about the activities and missions at his or her site/facility, the POC is responsible for determining when CMPC briefing/training should be provided based on his or her knowledge of the national requirements, the information provided at the initial security briefing/training, the activities of individuals at his or her site/facility, and whether the specific skills are perishable or not. They are also responsible for disseminating new information as policies or other factors change. Depending on the information that needs to be promulgated, the CMPC POC may choose to add that information to the annual security refresher briefing or they may choose individually developed briefing/training based on the specific topical areas within CMPC.

Q: Why was the one-hour rule not included in DOE M 470.4-4A?

A: The one-hour provision was removed as a result of the comment and resolution period within the RevCom process for DOE M 470.4-4A. DOE and National policy requires that classified matter be protected from unauthorized access and for it to be provided appropriate storage when not in use or under the control of an authorized individual. Anything that does not meet those requirements would require a deviation. Additionally, one of the objectives in revising the information security manual was to reduce or eliminate "how-to" direction for local program implementation and the one-hour rule was a how-to. Local procedures to implement classified matter storage and in-use requirements must be documented as part of your CMPC program plan and included in your local site/facility security plan.

Q: There was a change in the length of time a Top Secret working paper could remain a working paper, decreasing from 180 days to 30 days. Does the 180 days still apply for Confidential and Secret working papers?

A: Yes, each Confidential and Secret working paper must be marked as a final document no later than 180 days after creation. Only Top Secret working papers must be brought into final marking condition within 30 days. Also, once something is determined to possibly be Top Secret, it becomes accountable, even if it is still a working paper.

Q: I have a piece of Accountable Classified Removable Electronic Media (ACREM) that has been degaussed and is awaiting physical destruction, so do I still have to inventory it as accountable matter?

A: Yes, unless it is verified that the item no longer contains any of the information that required it to be accountable and no such information is recoverable from the item, it must still be considered accountable and subject to inventory requirements. DOE M 470.4-4A states, "Inventories must consist of a physical comparison of each item against the current inventory listing. Discrepancies must be resolved, if possible using the previously reconciled inventory and receipts, transfers and destruction records. Each item listed in an accountability record must be verified visually."

However, since 32 C.F.R. Parts 2001 and 2004, and the National Industrial Security Program Operating Manual (NISPOM) do not specify the "physical" and "visual" aspects of inventories, it may be acceptable to develop an acceptable substitute to DOE's requirements, provided:

• The media remain adequately protected;

• The current and previous individual assigned control/possession of the media at any given time are documented and this information remains available throughout record retention periods;

• The media remain accessible for inspection; and

• Inventories and resolution of discrepancies are used to validate the location and status of the media.

For example, if multiple appropriately degaussed media are inventoried and placed into a container that is sealed with an adequate tamper indicating device, and the sealed container is stored in a security area cleared for open storage of the highest level/category of the media, with the container being configured and located such that there is high assurance the media have not been accessed since being placed, it may be acceptable to base the subsequent inventory of the media on verification of the sealed container rather than by access to the individual media. Approval of this type of deviation must also consider the potential to access the information on the media, including presence and recoverability of information and all applied protection measures. Destruction requirements remain applicable for all accountable matter.

Q: What role do HSS and/or the Office of Security Policy have in the DOE OPSEC Program?

A: Our goal is to provide OPSEC managers and practitioners in DOE with policy direction, interpretation of its requirements, and other assistance as requested. This policy focus will enable the DOE Program Offices to concentrate on their various operational implementation responsibilities.

Q: What is Controlled Unclassified Information (CUI) and does it apply in DOE?

A: Controlled Unclassified Information (CUI) refers to unclassified information that does not meet the standards for National Security Classification under Executive Order 12958, as amended, but is:

• Pertinent to the national interests of the United States or to the important interests of entities outside the Federal Government, or

• Under law or policy requires protection from unauthorized disclosure, special handling safeguards, or prescribed limits on exchange or dissemination.

On May 9, 2008, President Bush issued a memorandum mandating the use of the term "Controlled Unclassified Information" within the Information Sharing Environment (ISE) and mandating Government-wide policies for the identification and safeguarding of CUI within the ISE. Policies for CUI are being developed by the CUI Office within the National Archives and Records Administration with the assistance of a CUI Council. The Office of Classification (HS-90) is the DOE representative to the CUI Council and is the lead for CUI policy in DOE. Because CUI policies under the May 2008 memorandum are under interagency development, no action should be taken by DOE employees until CUI requirements are finalized and promulgated. Employees should continue to follow Unclassified Controlled Nuclear Information and Official Use Only directives.

Additional information regarding CUI may be found on http://www.archives.gov/cui

Q: Is the Department of Energy Authorized to create Special Access Programs (SAPs)?

A: Executive Order 12958, Classified National Security Information Act, as amended, (March 28, 2003) states, "Unless otherwise authorized by the President, the Secretary of Energy, or the principal deputy, may create a special access program."

Q: When are Special Access Programs established?

A: Special Access Programs are established only when the program is required by statute or upon a specific finding that:

(1) the vulnerability of, or threat to, specific information is exceptional; and
(2) the normal criteria for determining eligibility for access applicable to information classified at the same level are not deemed sufficient to protect the information from unauthorized disclosure.

Q: Are there Special Access Program limitations?

A: Special access programs are limited to programs in which the number of persons who have access is reasonably small and commensurate with the objective of providing enhanced protection for the information involved.

Q: Why were many of the national requirements removed from the new DOE M 470.4-4A, Information Security?

A: Secretary Bodman's memo of September 10, 2007 required: "Departmental directives shall not duplicate or be inconsistent with applicable laws or regulations. To the extent possible, directives also should be written so that they are consistent with or incorporate widely accepted national standards." Requirements were removed to comply with this Secretarial initiative.

Q: How do I know which laws and regulations are applicable?

A: DOE M 470.4-7, Safeguards and Security Program References, lists applicable references for the DOE 470-Series Security Manuals. In addition, applicable references for DOE M 470.4-4A, Information Security, have been added to that Manual and its Contractor Requirements Document for easy reference. Further, the Office of Security Policy is developing a web application to maintain a current list of these references, provide a limited search feature, and give a current web-based link to these national level policies/references. The Office of Health, Safety and Security (HSS) plans to place this application on its web site in 2009.

Q: Why should I have a new or updated document reviewed by a classifier if it only contains information that was marked as Unclassified, even though the information was extracted or copied from a classified document?

A: The review provides a protection for the author as well as for the information. Whenever information is taken from a classified document to be placed into another document it obviously came from a classified subject area. If you are not an expert in the subject area, you may not realize that adding that particular unclassified information with other unclassified information may result in a compilation - which is where pieces of information, which are unclassified when separate, become classified when joined together. For example, a date and location may not be classified when included by themselves. However, if you add a third fact, such as a planned meeting topic to the mix, it may become classified.

Q: Why does the Department establish and require specifically-defined protection of Accountable Classified Removable Electronic Media (ACREM) when other U.S. Government agencies do not?

A: Based on several past incidents at the Department, and the potential for losing large quantities of classified information regarding nuclear weapons via one or a small number of electronic media, the Deputy Secretary of Energy established additional requirements for protecting and accounting for classified electronic media that contain the most sensitive information for which DOE is responsible.

Q: The Information Security manual states, "ACREM may be reproduced when any of the data that resides on a piece of ACREM is to be copied onto a piece of media that has already been placed into the formal accountability system, provided there are no other limitations. Permission is required from the DOE cognizant security authority before copying any of the data that resides on a piece of ACREM onto a piece of media that has not already been placed into the formal accountability system." This appears to be unnecessary and does not increase security or accountability for these assets; why am I required to place such media into accountability before copying any information onto it?

A: CREM is an acronym for Classified Removable Electronic Media, and ACREM is Accountable CREM. This particular requirement applies to certain cases that were identified subsequent to CREM/ACREM requirements being established at the direction of the Deputy Secretary of Energy. Generally, ACREM is copied onto other ACREM. If, for example, unclassified information is copied from ACREM to non-ACREM, this requires DOE CSA authority, approval and accountability. However, to clarify the intent of this requirement, proposed Manual 470.4-4A, Information Security, contains the following replacement for this paragraph.

"When any of the data that reside on a piece of ACREM (source media, in this case) is moved to, or reproduced on, another piece of media, the receiving media immediately becomes (or remains) accountable because it must be assumed to contain that which made the source media accountable, until proven otherwise and approved by the DOE CSA."

Q: Why do I have to have Classified Matter Protection and Control (CMPC) training if I don't have responsibility for a safe or repository?

A: Training is required by various National directives, such as the National Industrial Security Program Operating Manual, and 32 CFR Parts 2001 and 2004, Classified National Security Information Directive No. 1, the latter which states in part:

• General. Each department or agency shall establish and maintain a formal security education and training program which provides for initial and refresher training, and termination briefings. This subpart establishes security education and training standards for original classification authorities, declassification authorities, security managers, classification management officers, security specialists, and all other personnel whose duties significantly involve the creation or handling of classified information. These standards are not intended to be all-inclusive. The official responsible for the security education and training program may expand or modify the coverage provided in this part according to the agency's program and policy needs.



• Elements of initial coverage. All cleared agency personnel shall receive initial training on basic security policies, principles, practices, and criminal, civil, and administrative penalties. Such training must be provided in conjunction with the granting of a security clearance, and prior to granting access to classified information. The following areas should be considered for inclusion in initial briefings.
• Roles and responsibilities,
• Elements of classifying and declassifying information,
• Elements of safeguarding.
• Specialized security education and training. Original classification authorities, authorized classification authorities, individuals specifically designated as responsible for derivative classification, classification management officers, security managers, security specialists, and all other personnel whose duties significantly involve the creation or handling of classified information should receive more detailed training. This training should be provided before or concurrent with the date the employee assumes any of the positions listed above, but in any event no later than six months from that date.

Q: Why was non-standard storage removed from the Information Security Manual?

A: By definition, non-standard storage (NSS) differs from normal storage conditions and ability to meet typical requirements. Given this divergence from the norm and the wide dissimilarities from one instance of NSS conditions to the next, policy was previously changed such that NSS was intended to be treated as a deviation rather than an ordinary process. However, the current information security manual (DOE M 470.4-4A) contains sections on 1) Non-conforming Storage: to address classified matter that cannot be protected by the established standards and requirements due to its size, nature, operational necessity, or other factors; and 2) Permanent Burial: to address permanent placement of classified matter.

Q: Regarding the reproduction section of the Information Security manual, why not just recognize that all accountable CREM will be placed into accountability?

A: The associated requirement was written as a result of extensive discussions with individuals from various sites and programs regarding their local implementations. There were occasions when it was asserted that it was possible to copy some of the data from a piece of ACREM onto separate media in such a way as for that new media to not contain information that requires it to be placed into accountability and that it would not need to be marked at the accreditation level of the system where the source ACREM resided. The expanded language in the Reproduction section is, in part, responsive to this scenario.

So, if someone creates a new piece of ACREM, he or she must place it into accountability before writing any information to it that would make the media accountable or placing it into an information system which is accredited for S/RD or higher. No CSA action is required in these cases. However, to EXTRACT a file (say an unclassified document or appendix) from a piece of ACREM - to media that will not be designated as ACREM, the process for doing so, and ensuring that ACREM is not inadvertently created, requires Classification Officer and Designated Approving Authority involvement and CSA approval.

To clarify the intent of this topic, proposed Manual 470.4-4A, Information Security, contains the following: "When any of the data that reside on a piece of ACREM (source media, in this case) is moved to, or reproduced on, another piece of media, the receiving media immediately becomes (or remains) accountable because it must be assumed to contain that which made the source media accountable, until proven otherwise and approved by the DOE CSA."

Q: Does classified matter that is going to be destroyed have to be protected (but not stored) and controlled until it is finally destroyed?

A: Yes, classified matter must be protected and controlled until it is finally destroyed. For classified matter to be protected and controlled, it must either be "in use" (constantly attended by, or under the control of, a person possessing the proper security clearance and need-to-know) or securely stored in an approved secure storage repository (i.e. vault, safe or vault-type room).

Q: I am the ACREM Custodian, do I have to destroy my ACREM or can I delegate it to someone?

A: As ACREM Custodian, you would not have to destroy your ACREM personally unless it is required by local procedures. However, an individual who is authorized access to the ACREM must accompany the matter to the destruction site and witness the destruction to include inspecting the residue. To remove the ACREM from accountability, a copy of the destruction certificate certifying the ACREM was destroyed would have to be presented to you as the ACREM Custodian. The certificate must include the name of the individual who validated the destruction.

Q: What is the NISPOM and how does it apply to DOE?

A: The National Industrial Security Program Operating Manual (NISPOM) is the implementing directive for the National Industrial Security Program (NISP), which was established by Executive Order 12829, to achieve common standards for protecting classified information that is held by contractors, licensees, and grantees of the Federal Government. National security requires that this information be safeguarded equivalent to its protection within the executive branch. The NISP is applicable to all executive branch departments and agencies. Under the Atomic Energy Act of 1954, as amended (AEA), DOE is responsible for controlling the protection, classification, dissemination and declassification of Restricted Data and Formerly Restricted Data. Concurrently, under the NISPOM, the Secretary of Energy retains authority over the information classified under the provisions of the Atomic Energy Act of 1954, as amended. Moreover, the security cognizance over the Department remains with the Department of Energy. Thus, DOE retains responsibility for security administration regarding classified activities and contracts under its purview.

Q: Why must I remove my DOE/Site parking pass/DOE Badge from open view when I leave DOE property?

A: Your parking pass and badge reveal information about you. There are several reasons to remove parking passes from open view (and similarly protecting badges). These include considerations of personal safety as well as personal and organizational security. From a safety perspective, a parking pass hanging from a rear-view mirror can obstruct a driver's vision. Additionally, the parking pass or badge provides information about you that may be useful to a stranger who intends you harm, or to an adversary or competitor of your organization or the Federal Government. Significant concerns include turning you and/or your car and its contents into a target of opportunity (breaking into your vehicle to steal the pass; or creating a counterfeit pass or badge based on visual access to yours). Such release of relatively small amounts of information (e.g. parking passes, individuals who possess them and how they are used) may be combined with other public or unprotected information to permit an aggressor to defeat access control processes, disrupt missions/operations, or otherwise compromise important activities.

Q: What is the difference between the terms Electronic Storage Media (ESM) and Classified Removable Electronic Media (CREM), as used in DOE M 470.4-4, Information Security?

A: Electronic storage media (ESM) refers to all electronic storage media. It does not have to be classified or removable, whereas CREM must be both classified and removable. Additionally, the term ACREM is used for accountable classified removable electronic media. Given these definitions, ACREM is a subset of CREM and CREM is a subset of ESM.

Q: When may I consider classified electronic storage media (ESM) to be unclassified?

A: Generally, DOE M 470.4-4A, Information Security, does not permit classified ESM to be removed from accountability, downgraded, or declassified if the ESM provides any potential access to information that made/makes it accountable or classified at a specific level and/or category. The basic performance requirement is that no classified information is present or recoverable before any of these actions are permissible. The DOE Office of the Chief Information Officer promulgates policy indicating approved methods for accomplishing the sanitization, clearing, and destruction of electronic media for use in determining the proper classification and accountability status of ESM.

Q: On December 3, 2007, the DOE Chief Health, Safety and Security Officer signed out a memorandum establishing policy panels to increase feedback from the implementers of DOE policy. How will the Information Security policy panel be organized?

A: The Information Security Policy Panel (ISPP) is divided into three separate Policy Panels: Classified Matter Protection and Control (CMPC), Operations Security (OPSEC), and Technical Surveillance Countermeasures (TSCM). The policy panels are organized to provide expert opinion to the Office of Security Policy on policy implementation issues, legal, and technology factors that affect information security policy and other relevant topics as they are identified. Temporary or permanent subcommittees may be formed as needed to provide specific input to issues raised, and participants or topics may span across more than one of the ISPP sub-elements as needed. HSS will attempt to leverage technology to conduct meaningful panels without the financial and administrative burden posed by many face-to-face meetings. Meetings may consist of teleconferences, videoconferences, and in-person events.

Q: Does the Information Security manual apply to anything besides paper documents?

A: Yes, the Information Security manual applies to all classified information, in all forms. These forms include, but are not limited to paper, electronic, parts, waste, and auditory (for example, spoken information). Although this manual provides requirements for all classified information, there are other DOE directives that provide additional requirements for certain forms of classified information. Two prime examples are requirements for protecting classified special nuclear material (SNM), which are found in DOE M 470.4-2, Physical Protection and DOE M 470.4-6, Nuclear Material Control and Accountability, and cyber security requirements (for classified information in electronic form), that are promulgated by the DOE Office of the Chief Information Officer (OCIO).

For information in electronic format, the Information Security manual provides general requirements for protecting classified information that apply, and provides requirements for protecting the physical aspects of classified (cyber) information. Please note that the following examples do not include all relevant requirements as they are just provided here for illustration.

Examples of General Requirements:

• Classified information and matter that is generated, received, transmitted, used, stored, reproduced, or destroyed must be protected and controlled.
• Controls must be established to prevent, deter, and detect unauthorized access to classified matter.
• Classified information may be disclosed only to individuals who have appropriate access authorization for the level and category of the information involved, all required formal access approval(s), and a legitimate need-to-know.

Examples of Physical Aspect Requirements:

• All classified information systems media must be marked with the accreditation level of the information system unless an appropriate classification review has been conducted. All classified electronic storage media (ESM) must have the overall classification level and category (if RD or FRD) visible on the front and back.
• Classified Removable Electronic Media (CREM) that contain Sigma 1, 2, 14, or 15; a combination of nuclear weapons design/test data; or Top Secret or Special Access Program (SAP) matter must be separated from and not commingled with other classified information/media.
• Vaults or VTRs that are used to store ACREM must be configured to provide limited access to ACREM by only the ACREM custodian(s) or alternate ACREM custodian(s).

Q: Does the Information Security manual address verbal discussion of classified information?

A: Yes, the Information Security manual addresses the auditory form of classified information in Section A, Paragraph 2, which states, in part:

• Classified information and matter that is generated, received, transmitted, used, stored, reproduced, or destroyed must be protected and controlled.
• Buildings and rooms containing classified matter must be provided the security measures necessary to deter unauthorized persons from gaining access to classified matter; specifically, security measures that prevent unauthorized visual and/or aural access.
• Classified information may be disclosed only to individuals who have appropriate access authorization for the level and category of the information involved, all required formal access approval(s), and a legitimate need-to-know.

Q: What is an "Ad Hoc Working Group" as used in the Information Security Manual?

A: An Ad Hoc Working Group (AHWG), in the context of the manual, is a formally defined (documented by or in accordance with line management) group of individuals participating in a specific activity, project, or group of activities in which all members have been determined to have the appropriate access authorization, any required formal access approvals, and need-to-know. The AHWG must have the ability to limit access to on-line activities to only those members of the AHWG and use that ability when transmitting classified information which is not marked as a final document. Limiting access to on-line information is essentially a cyber security issue. Questions regarding requirements and guidance for such access limitations should be directed to the DOE Office of the Chief Information Officer.

This terminology was developed primarily to allow a defined group of individuals the ability to work together on draft documents without requiring any individual document to be marked as a final document just because control of the document changed from one person to another in the same working group. Each AHWG is required to be formally defined to increase the assurance that all marking and other requirements are met and that individuals are accountable for classified matter entrusted to them.

Q: What were the major changes for the Information Security manual when DOE M 470.4-4 Change 1 was published?

A: The manual was changed to reflect input from various field/program activities and updates to CMPC requirements. These changes were designed to allow more efficient application and management of program resources and to provide increased flexibility in implementation of departmental security requirements, bounded by required performance levels. Changes include:

• Requirements for protection, handling, and accountability of Classified Removable Electronic Media (CREM) were changed to eliminate unnecessary resource burdens while maintaining protection and accountability by:
  • modifying the number of allowable custodians/alternate custodians based on site specific procedures, operational need, and associated risk;
  • providing for appropriate temporary storage of ACREM when necessary;
  • modifying required inventory frequency, depending on risk and other site-specific factors,
• The current Confidential Foreign Government Information-Modified Handling Authorized (C/FGI-MOD) coversheet was replaced with an updated version.
• Marking requirements for automated information system hard copy output were clarified.
• A new intelligence dissemination marking, Releasable by Information Disclosure Official (RELIDO), was added.
• Office names were changed to conform with DOE organizational changes (e.g. Office of Security to Office of Health, Safety and Security).

Q: The Operations Security section of the Information Security manual refers to Critical Program Information (CPI). Is this just a form of Official Use Only information?

A: Critical Information is not a subset of OUO or FOUO. Qualifying for either marking is not a prerequisite for information to be Critical in this context. CPI has its basis in National Security Decision Directive (NSDD) 298, National Operations Security Program. This information includes specific facts about friendly intentions, capabilities, and activities vitally needed by adversaries for them to plan and act effectively and guarantee failure or unacceptable consequences for friendly mission accomplishment. Further, this information may be OUO, UCNI and/or classified and still meet the CPI threshold.

Q: If a document is received from another agency (e.g., DOD) and the classification markings do not meet current requirements, is the receiving organization required to re-mark the document? (Implicit in the question is that the document has been properly classified, just the marking is in question).

A: As long as the classification level and category is correctly marked on the document, DOE is not required to re-mark other agency documents. If it is necessary to completely and correctly mark a document from another agency, the other agency should be contacted regarding the marking, or the document should be returned to that agency for correct markings. There may be cases where the corrections are minor or the other agency has a waiver from the requirement in question. Contacting the sender would be necessary to determine whether or not they had a waiver or how to make the appropriate corrections to the document.

Q: Where on NSI-only documents should we put the new "Derivative Declassifier Review Required Prior to Declassification" stamp?

A: According to the Office of Classification, there is no requirement for the exact placement of the marking. However, for clarity, it is suggested that it be placed on the first page of the document near the classification stamp that has the "Declassify On" line. That way it serves as a reminder that it is not automatically declassified as it may seem to indicate. The marking should be legible and should stand out apart from both the classifier stamp and any other text.

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Nuclear Material Control and Accountability

Q: Can material from two Reporting Identification Symbols (RISs) be used and stored in the same Material Balance Area (MBA)?

A: Yes, you can have materials associated with multiple RISs (location and/or programmatic RISs) in a single MBA.

Q: What are L-RIS and P-RIS?

A: Location Reporting Identification Symbols (L-RIS) can be assigned to represent an entire site such using AWA to represent Pantex, a particular facility at a single site such as the KAMS area at SRS, or for multiple facilities operated by the same contractor at the same site (e.g., Hanford used to have a different L-RIS for the PNNL, Fuel Fabrication operations, Reactor operations, and Chemical Separations reflecting different operating contractors). These L-RISs are assigned at the discretion of the field office with oversight responsibilities for the facilities and materials.

Programmatic Reporting Identification Symbols (P-RIS) are also assigned at the discretion of the field office (usually coordinated with the headquarters program office) based on the funding responsibility for the projects used in reporting the materials assigned to those projects.

Q: Do L-RIS and P-RISs have to be the same?

A: Location Reporting Identification Symbols (L-RIS) and Programmatic Reporting Identification Symbols (P-RIS) for a particular project can be the same but do not have to be the same. P-RISs are associated with projects rather than locations and are established at the same time the project number is established in the NMMSS. For example if PNNL were doing work on tritium research and development in support of Defense Programs programmatic activities at Los Alamos. Any tritium physically located at PNNL would have a PNNL L-RIS of HYA and a PNNL project number but the PNNL project number might have a LANL P-RIS of AUA indicating the tritium located at PNNL is in support of the LANL activities.

Q: How is P-RIS used in NMMSS?

A: The Programmatic Reporting Identification Symbols (P-RIS) is used to sort and total material in programmatic project reports (e.g., P-111's). Therefore, NMMSS reports are able to be produced, based on programmatic responsibility for materials across the entire DOE complex.

Q: Who uses P-RIS information?

A: HQ program offices and materials managers are the typical users of the Programmatic Reporting Identification Symbols (P-RIS) information based reports. NMMSS operations also use this information to respond to requests from site representatives about what materials they have at their site that "belong" to other sites.

Q: How is the P-RIS information collected?

A: Programmatic Reporting Identification Symbols (P-RIS) Information is entered/updated during an annual data call to the field offices, which is done for updating the project numbers, and/or when a new project number is established within the NMMSS.

Q: What are Technical Standards?

A: Technical Standards are developed and adopted by voluntary consensus standards bodies as a means to carry out policy objectives or activities as determined by the agencies and departments.

Q: Why are we making a technical standard for MC&A?

A: This technical standard on Nuclear Material Control and Accountability (MC&A) is being developed to provide site facilities with an accepted means of meeting the performance objectives and metrics specified in the policy requirements for MC&A.

Q: What is the purpose of an MC&A plan?

A: MC&A plans can serve as a planning document for the facility to use in carrying out its MC&A program and budgeting for its operations. Additionally, MC&A plans have several purposes:

Q: Who approves MC&A plans?

A: DOE M 470.4-6 requires that a specific DOE cognizant security authority (which could be the site security director, site manager, or MC&A program manager depending on formal delegation) be designated as the DOE approving authority for MC&A plans, activities, and documents - including the MC&A plan, but does not specify who the approving authority should be. Program and site offices decide at what level of their organization MC&A approval authorities should reside based upon their resources and management structure. More generally, DOE O 470.4A designates the Departmental Under Secretaries as the overall cognizant security authorities for their organizations, and allows them to delegate those authorities to lower level DOE/NNSA officials. The delegations of authority are required to be in writing, and should be addressed in documents describing program functions, responsibilities, and authorities.

Q: What are Reporting Identification Symbols (RISs) and how are they used?

A: RISs are three or four letter codes assigned to DOE offices and contractors that possess nuclear materials, as well as NRC office and licensees that possess these materials. RISs for DOE offices and contractors are assigned by the Office of Information Management, HS-1.22. RISs for NRC offices and Licensees are assigned by the NRC Office of Nuclear Material Safety and Security. They are used for reporting nuclear materials inventories and transactions to the NMMSS. All DOE offices and contractors possessing reportable quantities of nuclear materials are required to have an RIS. They are also required to have a nuclear materials representative (NMR) for the RIS; the NMR is responsible for submitting site/facility data to NMMSS.

There is a rough correspondence between DOE sites and RISs, but the correspondence is not exact for several reasons:

• Different RISs are required for each DOE contractor possessing nuclear materials, and sites can have more than one contractor that possesses materials.
• Different RISs are used for waste areas than for processing and storage areas on the same site.
• Materials under the International Atomic Energy Agency (IAEA) are reported to NMMSS using a different RIS from other site RISs.
• Many DOE site offices have their own RIS separate from contractor RISs. For these reasons, most major DOE sites have more than one RIS.
• Additionally, some offsite materials may be included in the DOE office's or contractor's RIS.

Q: What nuclear materials does DOE M 470.4-6 address?

A: These nuclear materials include: Americium-241, americium-243, berkelium, californium-252, curium, deuterium, depleted uranium, normal uranium, enriched uranium, uranium-233, enriched lithium, plutonium, neptunium-237, thorium, and tritium.

DOE M 470.4-6 focuses on plutonium, enriched uranium, uranium-233, separated americium, and separated neptunium-237, because of their proliferation potential, but requires MC&A programs for all these materials.

Plutonium, enriched uranium, and uranium-233 are defined or designated as special nuclear material (SNM) by the Atomic Energy Act of 1954 and have long been considered material of concern for nuclear proliferation. More recently the International Atomic Energy Agency recommended that separated americium and separated neptunium-237 be treated the same as SNM for safeguards purposes, and DOE has adopted this recommendation into its regulations.

Q: What are the MC&A requirements for non-SNM?

A: Requirements for tritium, separated americium, and separated neptunium are based on those for SNM. Requirements and graded safeguards thresholds for separated neptunium-237 and separated americium are identical to those for U-235. Tritium is treated as either Category III or IV SNM depending on its form, quantity, and isotopic purity.

MC&A requirements for non-SNM materials other than tritium, separated neptunium-237, and separated americium are largely at the discretion of the DOE cognizant security authority responsible for MC&A. The only specific requirements are that

Q: Are DOE-owned nuclear materials at NRC licensee facilities reported to NMMSS under DOE requirements or NRC requirements?

A: They are reported using DOE requirements. This is based on an agreement between DOE and NRC and is reflected in NRC regulatory documents NUREG/BR-0006, Instructions for Completing Nuclear Material Transaction Reports, and NUREG/BR-0007, Instructions for the Preparation and Distribution of Material Status Reports. Additionally, the requirement to report pursuant to DOE instructions is usually reflected in contract and lease agreements for use of DOE-owned materials by NRC licensees.

Q: What does the term "credible roll-up" mean with regard to MC&A?

A: Roll-up is the accumulation to a higher safeguards category of special nuclear material (SNM) from lower category locations. Roll-up is credible if the materials can be accumulated and removed from the site prior to interruption and defeat by site personnel, including protective forces.

Q: I'm confused by tritium "reportable quantity" vs. "reporting unit." Table I-2 of Section A of DOE M 470.4-6, Chg 1, lists the "reportable quantity" for tritium as 1 gram, but Table XV-1 of Section B of same manual lists the "reporting unit" for tritium as 1/100 of a gram. Why are these two quantities different?

A: Reporting unit and reportable quantity are different concepts. Reporting unit is the mass unit that facility/site nuclear material accounting systems use for recording and reporting inventories and transactions. Reportable quantity is the minimum amount of a material that a facility must have to be subject to requirements of DOE M 470.4-6 for that material. Except for tritium, the reporting units and reportable quantity for nuclear materials are same. Historically, a hundredth of a gram was both the reporting unit and the reportable quantity for tritium. In 2003, the reportable quantity of tritium was changed to a gram in order to exempt facilities with less than that amount (primarily research facilities) from the MC&A requirements for tritium. The reporting unit was being maintained at 1/100 of a gram at the request of our larger tritium facilities and to maintain compatibility with historical MC&A record-keeping systems. Facilities with more than a gram of tritium are still required to report transactions of 1/100 of gram or more.