DOE-STD-1217-2016, Safeguards and Security Survey and Self-Assessment Planning, Conduct, and Reporting
Functional areas: Safeguards and Security, Self-Assessments
This document provides the Department of Energy (DOE) with a standard methodology for adapting the Department’s requirements for Safeguards and Security (S&S) surveys and self-assessments to organization-specific needs in a coherent, consistent, and repeatable fashion.
Superseded By:
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Section 1
NOT MEASUREMENT
SENSITIVE
DOE-STD-1217-2016
February 2016
DOE STANDARD
SAFEGUARDS AND SECURITY SURVEY
AND SELF-ASSESSMENT PLANNING,
CONDUCT, AND REPORTING
U.S. Department of Energy
Washington, D.C. 20585
AREA SANS
DISTRIBUTION STATEMENT A. Approved for public release; distribution is unlimited.
DOE-STD-1217-2016
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This Page Intentionally Left Blank
DOE-STD-1217-2016
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TABLE OF CONTENTS
FOREWORD........................................................................................................................... vi
1. SCOPE .......................................................................................................................... 1
2. PURPOSE ..................................................................................................................... 1
3. APPLICABILITY ......................................................................................................... 1
4. REFERENCES ............................................................................................................. 1
5. ACRONYMS AND DEFINITIONS ............................................................................ 2
6. DUTIES, RESPONSIBILITIES AND TRAINING ..................................................... 2
a. Survey Team Leader ............................................................................................... 3
b. Survey Topical Lead ............................................................................................... 3
c. Survey Team Members ........................................................................................... 3
d. Self-Assessment Team Leads and Members .......................................................... 4
7. SURVEY AND SELF-ASSESSMENT OVERVIEW..................................................4
8. SURVEY AND SELF-ASSESSMENT PLANNING .................................................. 6
a. Cyclical Planning for Surveys and Self-Assessments ............................................ 6
b. Planning a Facility Survey or Self-Assessment ...................................................... 6
9. SURVEY AND SELF-ASSESSMENT CONDUCT ................................................... 8
a. In-Briefing............................................................................................................... 8
b. Maintaining Communication .................................................................................. 9
c. Data Collection ....................................................................................................... 9
d. Performance Tests ................................................................................................... 10
e. Data Validation ....................................................................................................... 12
f. Data Analysis .......................................................................................................... 12
g. Ratings .................................................................................................................... 13
h. Exit Briefing............................................................................................................ 15
10. REPORT PREPARATION .......................................................................................... 15
11. CORRECTIVE ACTION PROGRAM........................................................................ 17
DOE-STD-1217-2016
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Section 2
APPENDIX A: SURVEY AND SELF-ASSESSMENT TOOLKIT
1.0 Introduction ............................................................................................................ 19
2.0 Planning Tools ....................................................................................................... 20
2.1 Sample In-briefing ........................................................................................... 21
2.2 Sample Survey Plan Format............................................................................. 24
2.3 Documents for Possible Review ...................................................................... 26
2.4 Sample Notification Memos ............................................................................ 31
2.4.1 Notification and Data Call ..................................................................... 31
2.4.2 Safeguards and Security Periodic Survey ............................................. 32
2.4.3 Initial Safeguards and Security Survey ................................................. 35
2.5 Sample Accommodation Request .................................................................... 40
3.0 Conduct Tools ........................................................................................................ 41
3.1 Sample Survey Worksheet ............................................................................... 42
3.2 Instructions for Completing the Sample Survey Worksheet ............................ 43
3.3 Sample Performance Test Safety Plan ............................................................. 46
3.4 Sample Performance Test Plan ........................................................................ 51
4.0 Topical Area Tools ................................................................................................ 54
A. Program Management Operations .................................................................... 55
A.1 Protection Program Management .............................................................. 57
A.2 S&S Planning and Procedures .................................................................. 59
A.3 Management Controls ............................................................................... 61
A.4 Program-Wide Support ............................................................................. 63
B. Protective Force ................................................................................................. 66
B.1 Management .............................................................................................. 67
B.2 Training ..................................................................................................... 68
B.3 Duties ........................................................................................................ 69
B.4 Facilities and Equipment ........................................................................... 70
C. Physical Security ............................................................................................... 71
C.1 Access Controls ......................................................................................... 72
C.2 Intrusion Detection and Assessment Systems ........................................... 74
C.3 Barriers and Delay Mechanisms ............................................................... 76
C.4 Testing and Maintenance .......................................................................... 77
C.5 Communications........................................................................................ 78
Section 3
D. Information Protection ...................................................................................... 79
D.1 Basic Requirements ................................................................................... 80
D.2 Technical Surveillance Countermeasures ................................................. 81
D.3 Operations Security ................................................................................... 83
D.4 Classification Guidance ............................................................................ 84
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D.5 Classified Matter Protection and Control.................................................. 85
E. Personnel Security ............................................................................................. 87
E.1 Access Authorizations ............................................................................... 89
E.2 Human Reliability Program ....................................................................... 91
E.3 Control of Classified Visits ....................................................................... 92
E.4 Safeguards and Security Awareness .......................................................... 94
F. Foreign Visits and Assignments ........................................................................ 96
F.1 Sponsor Program Management and Administration .................................. 97
F.2 Counterintelligence Requirements ............................................................. 98
F.3 Export Controls/Technology Transfer Requirements ................................ 99
F.4 Security Requirements ............................................................................... 100
F.5 Approvals and Reporting ........................................................................... 101
G. Material Control and Accountability ................................................................ 102
G.1 Program Management ............................................................................... 104
G.2 Material Accountability ............................................................................ 105
G.3 Materials Control ...................................................................................... 107
G.4 Measurement ............................................................................................. 109
G.5 Physical Inventory..................................................................................... 110
5.0 Post Survey Tools .................................................................................................. 111
5.1 Sample Initial/Periodic Survey Report Format ................................................ 112
5.2 Sample Termination Survey Report................................................................. 115
5.3 Sample Slides for Exit Briefing ....................................................................... 117
5.4 Sample Report Transmittal Memorandum....................................................... 119
5.5 DOE Survey/Inspection Report Form .............................................................. 120
CONCLUDING MATERIAL ............................................................................................ 121
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FOREWORD
This Department of Energy Technical Standard is for use by all Departmental elements.
Beneficial comments (recommendations, additions, and deletions) and any pertinent data that
may improve this document should be emailed to mary.gallion@hq.doe.gov or mailed to:
Section 4
U.S. Department of Energy
Office of Health, Safety, and Security
Office of Security Policy, GTN/AU-51
1000 Independence Ave., SW
Washington, D.C. 20585-1290
Department of Energy Technical Standards do not establish requirements. However, all or part
of the provisions in this Technical Standard can become requirements under the following
circumstances:
They are explicitly stated to be requirements in a Department of Energy requirements
document (e.g., a purchase requisition).
The organization makes a commitment to meet a standard in a contract, implementation
plan, or program plan.
This Technical Standard is incorporated into a contract.
Throughout this standard, the word “shall” is used to denote an action that is to be performed if
the objectives of this standard are to be met, and the word “should” is used to denote an action
that is expected to be performed unless a technically equivalent action is substituted. Goals or
intended functionality are indicated by “shall,” or “should.” However, it is not appropriate to
consider that “should” statements would automatically be converted to “shall” statements, as this
action would violate the consensus process used to approve this standard.
This Technical Standard was prepared following requirements for due process, consensus, and
approval as required by the U.S. Department of Energy Standards Program. Consensus is
established when substantial agreement has been reached by all members of the writing team and
the Technical Standard has been approved through the Department of Energy directives approval
process (REVCOM). Substantial agreement means much more than a simple majority, but not
necessarily unanimity. Consensus requires that all views and objections be considered, and that
a concerted effort be made toward their resolution.
DOE-STD-1217-2016
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SAFEGUARDS AND SECURITY SURVEY AND SELF-
ASSESSMENT PLANNING, CONDUCT, AND REPORTING
1. SCOPE. This document provides the Department of Energy (DOE) with a standard
methodology for adapting the Department’s requirements for Safeguards and Security
(S&S) surveys and self-assessments to organization-specific needs in a coherent,
consistent, and repeatable fashion. It describes a consistent and acceptable approach to
planning, conducting, and reporting the results for S&S surveys and self-assessments.
2. PURPOSE. The purpose of this Technical Standard is to provide Federal and contractor
personnel who have S&S oversight responsibilities with an accepted, compliance and
performance based process to conduct the S&S surveys and self-assessments prescribed
in DOE O 470.4B.
3. APPLICABILITY. This Technical Standard is intended for use by Federal and
contractor S&S organizations conducting either S&S surveys or S&S self-assessments.
4. REFERENCES.
a. DOE Policy 470.1A, Safeguards and Security Program, December 29, 2010.
b. DOE Order 470.3B, Graded Security Protection (GSP) Policy, August 12, 2008.
c. DOE Order 470.4B Administrative Change 1, Safeguards and Security Program, July
21, 2011.
d. DOE Guide 414.1-1C, Management and Independent Assessments Guide, March 27,
2014.
e. DOE Order 226.1B, Implementation of Department of Energy Oversight Policy,
April 25, 2011.
f. DOE Order 413.3B, Program and Project Management for the Acquisition of Capital
Assets, November 29, 2010.
g. DOE Order 142.3A, Unclassified Foreign Visits and Assignments Program, October
14, 2010.
h. DOE Order 452.8, Control of Nuclear Weapon Data, July 21, 2011.
Section 5
i. DOE Order 470.6, Technical Security Program, September 2, 2015.
j. DOE Order 471.3, Administrative Change 1, Identifying and Protecting Official Use
Only Information, April 9, 2003.
k. DOE Manual 471.3-1, Administrative Change 1, Identifying and Protecting Official
Use Only Information, April 9. 2003.
DOE-STD-1217-2016
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l. DOE Order 471.5, Special Access Programs, March 9, 2011.
m. DOE Order 471.6, Administrative Change 2, Information Security, Ju 29, 2011.
n. DOE Order 472.2, Change 2, Personnel Security, July 21, 2011.
o. DOE Order 473.3, Protection Program Operations, June 29, 2011.
p. DOE Order 475.1, Counterintelligence Program, December 10, 2004.
q. DOE Order 475.2B, Identifying Classified Information , October 3, 2014.
r. DOE Order 580.1A, Administrative Change 1, DOE Personal Property Management
Program, March 30, 2012.
s. Title 32 Code of Federal Regulations, Part 2001—Classified National Security
Information.
t. Title 32 Code of Federal Regulations Part 2004 – National Industrial Security
Program Directive Number 1.
u. Title 10, Code of Federal Regulations Part 824, Procedural Rules for the Assessment
of Civil Penalties for Classified Information Security Violations.
Some external sources of useful reference materials include:
http://energy.gov/cio/downloads/doe-f-4708 (Current version of Survey Form)
http://www.efcog.org/guides/ (EFCOG Self-assessment Tool Kit)
5. ACRONYMS AND DEFINITIONS. Definitions and acronyms commonly used in the
Safeguards and Security Program can be found in the Environment, Health, Safety and
Security Policy Information Resource located at https://pir.doe.gov/. Definitions that
have unique meanings in this Technical Standard include:
a. Observation. An item for management attention noted in a survey or self-assessment
report that identifies a potential deficiency if not addressed or a possibility for
program enhancement that should be further studied before implementation.
b. Opportunity for Improvement. A term used by some oversight activities to identify
an item for management attention noted in a survey or self-assessment that identifies
a possibility for program enhancement that should be further studied before
implementation.
c. Suggestion. A term used by some oversight activities to identify an item for
management attention noted in a survey or self-assessment that identifies a possibility
for program enhancement that should be further studied before implementation.
6. DUTIES, RESPONSIBILITIES, AND TRAINING
DOE-STD-1217-2016
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a. Survey Team Leader
For a survey of a facility with an importance rating of “A” or “B,” the survey team
lead shall be a Federal employee appointed by line management of the DOE
cognizant security office. For other facilities, the survey team lead may be a
contractor acting under the supervision of a Federal employee designated by line
management of the DOE cognizant security office. The survey team lead is
responsible for the successful completion of the survey. This person must have a
comprehensive understanding of safeguards and security (S&S) programs, have
previous survey experience (preferably as a topic lead or survey team lead), and be
especially capable of integrating topical area results into a comprehensive assessment
of facility security. It is highly desirable that the survey team lead has completed
training courses offered by the National Training Center on survey conduct and
management.
Section 6
The survey team lead is responsible for managing the efforts of the survey team and
for keeping the participants informed of all matters affecting the team and/or the
facility during the survey. The survey team lead is responsible for team planning and
logistics, coordination of team activities, focusing the activities of the team, ensuring
that deliverables are prepared and provided according to the schedule, promoting
integration among topic teams, and acting as a team spokesperson during meetings
and briefings. In particular, the team lead needs to ensure that all pertinent elements
of the S&S program are reviewed, that analysis is particularly focused upon the most
critical elements, and that any concerns or deficiencies identified are fully supported
by documented and validated data.
b. Survey Topical Lead
A topical lead for each topic to be surveyed should either be appointed by the same
authority appointing the survey team lead or, alternately, be designated by the survey
team lead. For surveys of facilities with an importance rating of “A” or “B”, the
topical lead should be a Federal employee. The topical lead shall be an expert in his
or her assigned topic. In some cases, it may be necessary to select a contractor as
topic lead because of his or her outstanding technical qualifications, with the
understanding that a contractor cannot supervise the work of Federal employees. The
topical leads work closely with the survey team lead to complete pre-planning, to
ensure that each topic team collects the data required for preparation of the survey
report, and to ensure that written and verbal deliverables assigned to the topical teams
are of high quality and are delivered according to the schedule. Each topical lead
conducts, with the assistance of the topical team, a topical analysis of results, and
recommends topical and sub-topical ratings to the survey team leader. It is highly
desirable that topical leads have completed the training courses offered by the NTC
on survey conduct and management.
c. Survey Team Members
DOE-STD-1217-2016
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Selection of survey team members should be coordinated among the survey team
leader, topical leads, and the organizations for which the individuals work. Team
members should be selected for technical competence, professionalism, and maturity,
with particular emphasis on interpersonal skills that will allow them to interact with
facility personnel to collect and analyze data without creating an unnecessary burden
on operations or controversy with facility personnel. Team members should have
previous experience and demonstrated expertise in the topical or sub-topical area to
which they are assigned, unless they are specifically selected for the purpose of
training and/or furthering their professional development. Team members selected
for training or professional development should perform under the direct supervision
of an individual with previous experience and demonstrated expertise in the topical or
sub-topical area. Unless they are specifically selected for training or professional
development, it is highly desirable that survey team members have completed training
courses offered by the National Training Center on survey conduct and management.
d. Self-assessment Team Leads and Members
Self-assessment team leaders, topical leads, and team members should be chosen
using the same criteria as listed above for survey team leaders, topical leads, and team
members. However, as self-assessments are a contractor activity, it is not necessary
to have Federal employees as survey and topical team leaders.
Section 7
7. SURVEY AND SELF-ASSESSMENT OVERVIEW
Without an adequate S&S survey program, line managers cannot effectively manage the
S&S programs for which they are responsible. Surveys compare planned S&S program
performance to the actual achievement. The survey report presents accumulated data and
provides an analysis of S&S program effectiveness for the areas surveyed/assessed at the
surveyed location. The survey activity provides two vital components to the Federal
management of an S&S program – measurement of the degree to which actual
implementation matches planned implementation, and feedback indicating actions needed
to make program implementation match program planning and/or needed changes to
program planning and implementation to better achieve mission objectives. Management
support and commitment to the S&S survey program are critical to ensuring the time and
resources required to produce a useful survey product are available.
To provide the best possible information for management consideration, the S&S survey
needs to include a significant sample of the elements of the local S&S mission and the
resulting report needs to contain a logical and thorough presentation of the survey results,
accompanied by a complete and logical analysis of those results that leads to conclusions
regarding the status of program implementation, reflected in the ratings awarded, and
identification of needed actions. These conclusions regarding the status, accompanied by
measurements and analysis supporting the conclusions, inform not only local Federal
management, but also line management at higher levels about the current status of the
S&S program at the surveyed site or facility.
DOE-STD-1217-2016
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S&S programs have traditionally been considered to be logically divided into topical
areas and, within each topical area, sub-elements known as sub-topics. While this
organizational structure might be considered to be somewhat arbitrary, it forms a useful
way to organize data collection and to report the results of a survey or self-assessment.
This division into topics and sub-topics is reflected in the DOE Form 470.8,
Survey/Inspection Report Form (see Appendix A, Section 5.5), and this topical and sub-
topical structure will be used in discussion of the survey and self-assessment process to
follow. In addition to providing a structural reference for this technical standard, the
form is often used to provide a means of summarizing the results of a comprehensive
survey or self-assessment and is the appropriate data entry form for entering survey and
self-assessment data into the Safeguards and Security Information Management System
(SSIMS).
Self-assessments provide the same management information to local contractor managers
on a more frequent basis than the survey or at a time between surveys. The need for
documentation of self-assessment activities leading to a periodic comprehensive report is
no less than for surveys. The benefits of these self-assessments are several:
Local managers receive notification of program weaknesses on a more timely basis,
thereby allowing them to address and correct the issues sooner than might be possible
using only an external review;
Local S&S personnel are encouraged to be self-critical, allowing them to be more
proactive in providing adequate security to local assets; and,
Employees who have security duties but are not security professionals are provided a
more comprehensive view of the security program.
Section 8
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8. SURVEY AND SELF-ASSESSMENT PLANNING
Survey and self-assessment planning consists of two components – cyclic program
planning and planning for a survey of a particular facility or a particular self-assessment.
Effective planning requires the planner to fully understand the assets at each facility to be
reviewed during a planning period, the operations and characteristics of each facility, the
safeguards and security directives that apply at each facility, and the past performance of
each facility on previous surveys, facility self-assessments, and recent external reviews.
a. Cyclic Planning for Surveys and Self-Assessments
Comprehensive planning is key to the success of a survey or self-assessment
program. Review activities may be scheduled around a one-time evaluation, ongoing
observations during the reporting interval, or a combination of the two. Each activity
conducting surveys or self-assessments should establish a planning cycle that best
allows the allocation of resources and assures that surveys or self-assessments are
scheduled to meet the requirements of DOE O 470.4B. A survey or self-assessment
plan shall be prepared for the selected planning cycle to reflect the approach used for
data collection and report preparation, a schedule of planned surveys or self-
assessments during the planning period, and an initial assessment of personnel and
other resources required to complete the planned activities. Personnel requirements,
both the number of personnel and their skills, will be a function of the particular
facilities scheduled for that planning period. Planning shall include an identification
of the information needed to conduct a comprehensive evaluation at each facility,
including the identification of topics and sub-topics required. If information is to be
collected over an extended period, for example by observing particular operations
during the time period, the plan will need to consider whether the information
collected remains completely reliable or is somewhat degraded by the passage of time
between the observation and final report preparation. Planning should identify
sampling or verification methods that ensure perishable information gathered early in
a survey or self-assessment planning period remains valid at the time the report is
completed.
b. Planning a Facility Survey or Self-Assessment.
Survey and comprehensive self-assessment planning involves gathering and
analyzing large amounts of information from many sources, making decisions based
on the analysis, and preparing survey activities based on the decisions. Because there
is only a limited amount of time available onsite to collect the data necessary to
characterize the status of the programs being surveyed, planning should focus on
determining what program elements to review and how best to survey those elements
to help ensure the most effective use of that time. In particular, the plan shall identify
program elements that will be fully or partially evaluated based upon sampling
activities during a survey cycle (such as the results of surveillances or shadowing).
For those elements the plan shall specify the additional data necessary to assess the
applicability and accuracy of data obtained from periodic sampling during the final
DOE-STD-1217-2016
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phase of survey conduct. Planning activities also include identifying personnel and
other support requirements for all phases of the survey.
(1) Pre-planning.
Section 9
Pre-planning includes determining the scope and objectives of the review.
Information such as the facility importance rating, S&S interests, and security
contract requirements provide the basis for the scope and objectives of the
assessment, but other factors such as previous performance, recent site operational
changes, and new missions are also important in establishing the scope of the
review. The team leader develops an initial schedule and considers whether a
preliminary visit is needed. Throughout the planning process, the team leader is
responsible for obtaining any necessary management approvals of decisions and
actions.
(2) Preliminary Coordination.
Before data collection begins, the team leader’s responsibilities should include:
Coordinating the proposed schedule with the facility and other responsible
parties;
Identifying basic information needed in the data collection, such as a site or
facility security plan, assessment/ inspection reports, approved deviations
(including equivalencies/exemptions for DOE policy and deviations from
national policy), and contract data;
Sending the notification letter or other agreed upon notification;
Team member selection and coordination with members’ management;
If a data call is deemed necessary to support a team planning meeting,
determining the documents needed, preparing a list, and requesting the listed
documents from their respective sources.
Conducting a team planning meeting;
Establishing a schedule and topic assignments;
Gathering facility data (e.g., location, S&S interests, queries of SSIMS, EFOCI,
and other data bases to obtain information regarding the facility clearance,
importance rating, key positions, assets, current S&S plans, and active
deviations);
Establishing protocols, including a schedule for team meetings, a procedure for
communicating schedule changes or additional support requirements, a process
for managing classification concerns and issues, a determination of the validation
DOE-STD-1217-2016
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process to be used, a consolidated document call, a report outline reflecting the
desired format for the report, and a compilation of logistical information (travel
dates, hotel arrangements, rental cars, site access, in-briefing time/location);
Providing the format for plans, reports, findings, process improvements, and
corrective actions;
Providing official notification; and,
Preparing an overall plan for the survey or self-assessment.
The level of pre-planning required for a survey or self-assessment that includes
ongoing data collection such as surveillances or shadowing of key activities will be
even more stringent, since specific measures for validation of such data will need to
be identified, and methods for inclusion of these data sets into the analysis leading to
topical area ratings and facility ratings will need to be specified.
9. SURVEY AND SELF-ASSESSMENT CONDUCT
Valid sampling and accurate evaluation should be the focus of all survey and self-
assessment activities during the conduct of the review. This focus should be apparent
during all phases of the review activity so that, as far as possible, the review is a joint
exercise between reviewer and reviewed to identify and correct program issues, with the
goal of improving the local S&S program. Methodologies typically used to measure
performance include, but are not limited to, document review, testing, observation,
interviews, data collection, and data analysis and validation.
Section 10
a. In-Briefing.
A formal in-briefing has traditionally been the initial on-site activity of the type of
review that one might call a “snapshot in time,” during which all data is collected in a
relatively brief interval – one day to a few weeks depending on the complexity of the
site. More recently, comprehensive survey and self-assessment reports have often
been based, partially or completely, upon data collected over an extended period,
perhaps as long as a year. Even in the case of the more extended data collection effort,
an in-briefing at the beginning of the review period should be conducted to assist in
establishing and maintaining effective communication with the site. A carefully
prepared in-briefing can ensure a positive start for the assessment, create a good first
impression, and provide an opportunity to reduce the stress and tension associated with
the survey or self-assessment. Items to be covered during the facility in-briefing
should include (but are not limited to):
Survey or self-assessment scope and objectives;
Survey or self-assessment approach and methodology (with respect to data-
collection methods), including whether all data will be collected during one site
DOE-STD-1217-2016
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visit, whether the final report will be based on a set of observations conducted
throughout the assessment cycle, or some combination of these approaches;
For surveys, the level of reliance on the contractor assurance system and how data
derived from the contractor assurance system will be verified by the survey team
and included in the analysis of survey data;
General introductions of team members; and,
Schedule of survey or self-assessment activities.
b. Maintaining Communication
The team leader and topical leads should plan on meeting frequently during the course
of the survey or self-assessment. The frequency of the meetings will be partially
dictated by the assessment approach – snapshot or extended – but are vital to ensure
that the team leader and topical leads understand the status of data collection toward
meeting the selected lines of inquiry, understand information that is of interest in their
respective topics that has been identified by other teams, and maintain an awareness of
emerging areas of concern.
The team also should emphasize communication with the assessed site. Again, the
frequency of planned communications with site points of contact and site management
will depend on the pace of data collection. However, it is vital to effective
communication with the site, and therefore to the success of the assessment, that the
points of contact and site management remain informed concerning the progress of
data collection and have early notice of potential issues, particularly as they relate to
rolling or shadow assessments if these techniques are a portion of the survey or self-
assessment procedure.
c. Data Collection
All members of the survey or self-assessment team work to collect data. Members of
one topical area often collect data that supports other topical areas and should share
such data with other interested topical area teams. For example, data collected about
physical security systems could also be useful to the analysis of protective force and
nuclear material control, as they are each elements of the overall protection design.
Data collection efforts as well as analysis efforts must always remain focused on the
effectiveness of the entire S&S program in providing appropriate security for national
security assets.
Section 11
The selected lines of inquiry always guide data collection. Within a line of inquiry,
data collection can be prioritized to allow schedule adjustments if complications or
unforeseen events do not permit completion of all planned activities. If this occurs,
the team can concentrate on gathering the data deemed most critical. High-priority
data-collection activities should be scheduled early in the process to ensure that they
DOE-STD-1217-2016
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are accomplished. When a full line of inquiry is endangered by data collection issues,
the team leader will decide the best course of action.
All working papers and data-collection records, notes, checklists, and other
documentation accumulated during data collection should be retained as backup
documentation to the final report. Ensure that all items are either reviewed by an
Authorized Derivative Classifier and appropriately marked and protected, or are
protected and marked at a level and category specified by the team lead until review
by an Authorized Derivative Classifier can be performed. Working papers are used to
support the validity of findings and as a source of information for future reviews.
These papers also can be used for assessing the progress of the review, especially if an
extended data collection methodology is employed. Working papers are maintained at
least until the completion of the following survey or self-assessment. If deemed useful
for extended tracking and trending of issues, they may be retained for longer periods.
Data collection methods and techniques are chosen based upon their utility in
addressing the selected lines of inquiry. Each method and technique has an associated
purpose and cost (both to the team and the facility). It is important to know when and
where to use each method. For example, running an expensive force-on-force (FOF)
performance test would not be cost-effective if the data were available through an
interview, observation, or limited scope performance test (LSPT). An essential step
that should be accomplished in the planning phase is to associate data collection
methods with each line of inquiry chosen.
The results of previous Federal and contractor reviews, including facility description,
security interests examined, and findings and suggestions, shall be considered as a
valuable data source. The corrective action plans and resolution of the previous
findings also are indicative of the quality of the program and level of management
support the program receives. In particular, the review of past findings can reveal
significant indicators of the effectiveness of S&S program management. Concerns
about open or repeat findings or the inability to establish and implement effective
corrective action plans in a particular topical area should be discussed with the entire
team. The determination of whether similar concerns exist in other topical areas will
give those performing the program management evaluation important indicators as to
whether the issues extend beyond the topical area in which they were first identified.
It is always desirable to minimize impacts to the facility. For example, procedures,
such as special nuclear material (SNM) transfers, security alarm preventive
maintenance checks, or portal monitor checks, should, whenever possible, be observed
during regularly scheduled times rather than at the team’s request for a special
demonstration. However, the need for data to inform the analysis of a line of inquiry
is primary. For example, if an operation such as a nuclear material inventory is not
scheduled during the survey or assessment and observing the operation is critical to
evaluating system operations, then initiating an inventory through a performance test
is appropriate.
Section 12
DOE-STD-1217-2016
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d. Performance Tests
Performance testing is a key data collection technique deserving special mention.
While compliance with specific directive requirements is one of the primary interests of
a review team, the actual performance of processes, personnel, and systems in
providing protection to national security assets should be measured to provide an
appropriate level of assurance that assets are adequately protected. Performance tests
are typically onsite exercises of the personnel, equipment, and/or procedures of selected
portions of S&S systems to determine system effectiveness. Performance tests are not
limited to the systems protecting special nuclear material or classified matter; they can
be conducted to assess any portion of the facility security design. In all cases, they
should focus on the elements of a topic or sub-topic that are essential to the
effectiveness of that topic or sub-topic. Performance tests will not necessarily reflect
the overall state of security at a facility because the observed result of a performance
test usually reflects only on the security element tested, not the full protection system.
Further, the outcome of a single performance test can reflect temporary or unusual
conditions existing at the time of the test. Therefore, while the results of a single
performance test are valid data, performance test data should be placed in context with
other findings, observations, and conclusions.
Performance tests shall be designed to provide objective data to assist the team in
determining whether:
Personnel know and follow procedures;
Procedures are effective;
Plans and procedures accurately describe operations conduct;
The processes described in procedures produce the expected product;
Personnel know how to operate equipment;
Personnel and equipment interact effectively;
Equipment is functional, operational and effective;
Equipment has adequate sensitivity; and/or,
Equipment meets design objectives.
If the facility has a program for conducting performance tests, the team should
consider requesting that the facility conduct one of its performance tests rather than, or
in addition to, one designed by the team. Observing the facility conduct a
performance test provides information concerning the facility's own assessment
program as well as providing the needed data about the protection element being
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tested. An additional source of performance data is the routine documentation
maintained in the course of implementing an S&S program. Performance data
reflected in facility documentation such as inventory records, files, classified
documents, reports, and access logs are useful in assessing the effectiveness of control
processes.
e. Data Validation
An essential component of data collection is data validation. When any data is
collected, it is imperative that the data collector determine whether site personnel
observing the same event perceive the same outcome as the data collector. If they do
not, it is essential to understand why not and to inform the site observer why the data
collector has a different perception. It is also essential to share this perception because
of the limited sample set that is collected during a review. If site personnel understand
that the data collector perceives the result of an observation differently than they do, it
provides them an opportunity to supply additional data that provides a fuller context to
the data collector’s view of the result.
Section 13
Similarly, it is important for the team to share perceptions with site management on a
periodic basis. Site management should be informed when the assessment team is
moving toward a conclusion in a particular area, whether that conclusion is positive or
negative. Again, site management might be able to offer additional information that
would modify the team’s view of the situation.
When final conclusions are reached in the survey or self-assessment report, they shall
be based upon a set of facts agreed to by both the review team and the site. However,
the analysis of those facts, and the subsequent assessment of site protection
effectiveness, is always the sole prerogative of the review team.
f. Data Analysis
After all data is collected and verified to be current and accurate, it should be compiled
and analyzed to determine the effectiveness of protection by overall facility, by topical
area, and/or by sub-topical area, as appropriate. The facts established during the data
collection and validated by the site and the team’s analysis of those facts form the
basis for observations and findings in the final report. Even when no findings or
observations are made, the presentation of validated data and the logical interpretation
of that data is a valuable contribution to management understanding of site status and
should never be neglected in the final report. Key facts and the team analysis of them
should be documented in the report immediately before an observation or finding is
made and additional supporting information, if any, should be contained in the
retained working papers. The logical path from facts to the finding or observation
needs to be clear in the final report, even if some detail is omitted. Findings and
observations shall be clearly identifiable in the final report and shall be highlighted
during the close out briefing. It is often helpful to repeat all findings and observations
from all topical areas in a single appendix or attachment to the report. Tracking and
trending of results is enhanced by the assignment of a unique tracking number to a
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finding or observation, especially findings, to assist in tracking and reporting on
actions taken in response. For findings in particular, since they must be entered into
the SSIMS database, a tracking number is needed that conforms to the SSIMS finding
format. An example would be 13-NOV-01-HQ-0123-SSIS-PM-001, where 13-NOV-
01 is the date of the survey, HQ is the cognizant security office, 0123 is the facility
code for the surveyed facility, SSIS is the type of survey (see DOE O 470.4B,
Appendix A, Section 2, paragraph 3), PM is the topical area in which the finding is
made, and 001 is a sequential number of the finding within the topical area.
Section 14
The terms finding, observation, suggestion, opportunity for improvement, and others
are used in surveys and self-assessment reports to indicate issues that require
management attention. The term finding is defined in DOE policy and is always used
to identify any validated program deficiency (a failure to meet a performance or
compliance requirement derived either from internal or external directives or the
approved site/facility security plan.) The term observation is used to identify areas
where the review team perceives a need for particular management attention, even if
DOE requirements and security plan performance elements have been met.
Observations also may be used to identify potential areas for program enhancement.
In some cases, survey and self-assessment programs have used the terms suggestion or
opportunity for improvement. These are similar in intent to an observation, but are
used to clearly separate potentially positive results from potentially negative ones.
Usually this distinction is made when management believes both findings and
observations are indicators that program improvements are needed whereas a
suggestion or an opportunity for improvement indicates that the review team has
identified a potential program improvement which local security management might
consider. Findings, observations, suggestions, opportunities for improvement, or any
other conclusion reached during data analysis shall be based upon validated data
collected during the various activities comprising the review.
g. Ratings
Upon completion of survey or self-assessment data collection, a recommended rating
for each sub-topical and topical area reviewed shall be determined, usually by the
topical team members. When considering a topical rating, the topical team should
consider the results from each sub-topical area and the relative contribution of each
sub-topical area to the success of the overall topic within the local context. The logic
and determinations supporting the recommended ratings should be included in the
draft survey or self-assessment report to support the topical rating proposed to the
team leader.
The team leader, in consultation with topic leads and team members, shall determine
the composite facility rating and the topical and sub-topical ratings, based upon the
results of the survey or self-assessment. The team leader shall ensure that the basis for
the rating determinations is explained in the survey or self-assessment report. A
composite facility rating shall be based upon the topical and sub-topical ratings and an
analysis of the relative importance of each topical and sub-topical area in the overall
protection design of the site/facility. As with each of the topical and sub-topical
DOE-STD-1217-2016
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ratings, the logic and considerations leading to the award of the composite facility
rating should be explicitly addressed in the survey report.
The ratings listed below are used for all surveys (except termination), reviews, and
self-assessments. Does Not Apply (DNA) and Not Rated (NR) shall also be used in
lieu of a rating when appropriate.
Satisfactory. The element being evaluated meets protection objectives or
provides reasonable assurance that protection objectives are being met.
Marginal. The element being evaluated partially meets protection objectives or
provides questionable assurance that protection objectives are being met.
Section 15
Unsatisfactory. The element being evaluated does not meet protection objectives
or does not provide adequate assurance that protection objectives are being met.
A topic or sub-topic should be rated Satisfactory if all aspects of the topic or sub-topic
are found to be as depicted in the approved security plan, including any approved
equivalences or exemptions, and observed performance is sufficient to provide
assurance that the topical or sub-topical elements are providing the level of protection
assumed in the approved site/facility security plan. In particular, any security element
within the topic or sub-topic that is identified as an essential element shall demonstrate
performance at least equal to that required to support overall security effectiveness, as
documented in the approved security plan. A topic or subtopic should also be rated
Satisfactory if, for any measure not met, documented and approved compensatory
measures are in place to provide comparable protection and action is either under way
to return the security elements comprising the topic or sub-topic to full capability or an
approved plan to restore the security elements is being satisfactorily pursued. In some
instances, a topic or subtopic might be rated Satisfactory when some component
element fails to meet an applicable measure but, in the judgment of the topical area
experts and the survey team leader, the impact of that shortfall does not erode the
contribution of the topic or sub-topic to the effectiveness of S&S under the approved
security plan. The logic underlying such a decision shall be included in the survey
report. Notwithstanding the Satisfactory rating, however, the component should be
brought to full effectiveness as soon as possible in all cases.
Noncompliance with one or more requirements of the approved security plan shall
result in a rating of Marginal or Unsatisfactory for a survey or self-assessment topic
or sub-topical area when the observed shortcoming(s) reduces the assurance that the
S&S program, as depicted in the approved security plan, represents the actual S&S
practices at the site or facility. If performance testing indicates that a significant
question regarding adequate protection exists, even when the site/facility is in full
compliance with the approved security plans, a topic should be rated no higher than
Marginal.
Assignment of one or more subtopic ratings of Marginal or Unsatisfactory shall lead
the topical area team to carefully analyze the seriousness and multiplicity of findings
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in a sub-topical area against the definitions for Marginal or Unsatisfactory before
assigning a rating to a topic. If less-than-satisfactory sub-topical ratings exist within a
topical area rated Satisfactory, the survey or self-assessment report shall explain why
the impact of these sub-topical ratings do not justify a reduced topical rating.
A topic or subtopic shall be rated Unsatisfactory if limited compliance with the
approved security plan and/or performance testing results indicate that the topical or
sub-topical contributions to the approved security plan fall short of the performance
required to protect security assets. Performance should consider the adequacy of any
compensatory measures in place when the rating is determined, since adequate
compensatory measures supported by a plan to restore the planned functionality can
result in a satisfactory rating. However, an unsatisfactory rating shall also be awarded
if no plan exists for restoring security element function and removing current
compensatory measures, even if the compensatory measures provide a temporary
mitigation of the security concern.
Section 16
After ratings have been assigned to all sub-topics and topics, a rating shall be assigned
to the site/facility. While the same three ratings are available – Satisfactory, Marginal,
and Unsatisfactory – the context is somewhat different. The site/facility rating shall be
based upon an integrated view of the entire security program, taking into consideration
the topical ratings. The site/facility rating is the team leader’s certification to the
appointing official regarding the security status of the site/facility. A Satisfactory
rating indicates that the site/facility is operating in accordance with the approved
security plans and that the demonstrated S&S performance is at least equal to that
required to adequately protect all site/facility security assets. A Marginal rating
indicates that action is needed to advance the site/facility toward compliance with the
approved security plans and/or to fully achieve the performance anticipated when the
security plans were approved. An Unsatisfactory rating conveys the team’s judgment
that immediate management attention is needed to ensure continued protection of one
or more of the national security assets located at the site/facility or to ensure that
adequate progress will be maintained toward achieving a satisfactory status.
h. Exit Briefing
At the conclusion of the survey or self-assessment, an exit briefing should be
conducted with management officials of the organization reviewed. The briefing
should include at least a summary of the following areas:
Program strengths and weaknesses, including all findings and observations;
Corrective action reporting requirements for all open findings, regardless of
source; and,
Sub-topical, topical and facility ratings.
The team leader should prepare an agenda for the exit briefing. Because of the
potential for confrontation during the briefing, it is generally best for the team leader
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to provide the briefing and, if necessary, to ask the topical leads to assist with technical
details. Agreements and commitments made during the conduct of the survey should
be summarized during the exit briefing. This provides an opportunity to identify
potential misconceptions before they are presented formally to management outside
the surveyed facility. Agreements and commitments should be documented in writing
as soon as possible.
10. REPORT PREPARATION
As soon as possible after the survey or self-assessment is completed, a formal report of
the results shall be finalized. The individual team members and topic and subtopic leads
should ensure that a complete, concise, and accurate final report of the results is compiled
in a timely manner. The report preparation shall be overseen by the team leader, who has
ultimate responsibility for its completion and accuracy.
Reports and all working papers and other retained material shall be evaluated and
reviewed by an Authorized Derivative Classifier before publication of the final report.
Before this review, the working drafts shall be protected and marked as working papers
classified at a level determined by the team leader to be the highest likely classification of
the final report, including paragraph markings as appropriate. Required protection and
control shall be provided for classified or sensitive information. Even if the overall
report is determined to be Restricted Data (thereby eliminating the requirement for
paragraph marking), each finding shall be marked with its classification level and
category to ensure that the information will continue to be protected appropriately when
the finding is extracted from the report.
Section 17
Team meetings should be held as necessary to facilitate the finalization of the survey
report and evaluate lessons learned from the review. During these meetings the following
actions should be undertaken as necessary:
Review draft report or report section(s);
Review lessons learned;
Identify trends that might indicate areas of interest for the next review;
Identify helpful information sources and resources to consider in the next review;
Review and summarize agreements and commitments made during the conduct of
the review and the exit briefing;
Determine final report content, especially for areas of contention;
Document any unique organizational structures/functions or item of potential use
to those planning the next review; and,
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Prepare for briefings on the review results to DOE and contractor management, as
appropriate.
The survey report should consider all available data in its analysis. Depending upon the
survey methods used, this may include data that reflect:
documented observations of activities at the surveyed facility;
full and limited scope performance tests;
documented data collection conducted during the survey period;
the results of any documented Federal shadowing of contractor self-assessments;
targeted data collection conducted to satisfy remaining data requirements late in
the survey period (particularly as required to verify accuracy of information
acquired during rolling assessments, contractor shadow activities, or derived from
contractor reports);
any other documented, objective data that the survey team determines is pertinent.
The resulting report provides measurement results, an analysis of those results, including
ratings, and specific identification of areas needing improvement, in the form of findings,
observations, and/or suggestions to management.
The appointing authority responsible for the conduct of the survey or self-assessment
should require that a review board be established to review the draft report and make
recommendations to the team leader to improve the report. Such a board can
significantly improve the final product by verifying that there is a clear, logical
presentation of results. Questions regarding what assets were present at the facility, what
data collection methods were used, what facts were discovered using those methods, what
facts were considered and with what relative weight to arrive at findings and ratings, and
what factors support the overall facility rating should all be clearly addressed in the
report. Use of a review board can ensure that all these questions are adequately
addressed and logically presented in the final report.
After the report has been completed, SSIMS data entries have been made, and the report
has been distributed, the team leader should document and file lessons learned. These
lessons learned should identify what processes were effective, observations of team
dynamics, and specific recommendations for the next review. The team leader should
include lessons learned as reported by topical leads and their teams. These lessons
learned should be provided to the appointing authority for information and evaluation to
improve the survey process.
11. CORRECTIVE ACTION PROGRAM
DOE-STD-1217-2016
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Section 18
A survey or self-assessment activity only fulfills a portion of its objective if it lacks a
robust corrective action program. Therefore, DOE directives require that corrective
actions are taken for findings, that finding status is tracked to completion, and that
accumulated findings from a given site/facility and from all sites/facilities surveyed or
self-assessed by a review activity should be subjected to trending analysis to determine
whether they collectively indicate a broader weakness in the S&S program that is not
fully addressed by the corrective actions taken in response to the individual findings.
A corrective action program shall include, as a minimum:
Causal analysis appropriate to the complexity of the issue identified (the rigor of
causal analysis should not be based upon the perceived consequence of protection
element failure – sometimes very serious issues have readily apparent root causes
and sometimes important lessons can be learned from issues that have little
immediate protection impact – but on the difficulty in identifying the root causes);
Identification and implementation of compensatory measures required to maintain
required performance levels while corrective actions are in progress;
Identification and implementation of priorities for completion of corrective
actions if all cannot be pursued simultaneously (priorities might be based on
availability of resources, costs of associated compensatory measures, and many
other factors);
Identification and implementation of necessary validation testing when corrective
actions are complete and before compensatory measures are removed; and,
A means of tracking and trending causal factors to allow identification of possible
systemic management issues that are only discernible when viewing the results of
multiple reviews. It should be noted that tracking in SSIMS is required for survey
findings.
To maximize the value of surveys and self-assessments, it may also be desirable to go
beyond the basic requirements applicable to findings and corrective actions. For
example, observations do not specifically require action on the part of the site
management, but the careful consideration of observations can lead to improvements in
S&S program effectiveness and/or efficiency. Other considerations noted in the survey
or self-assessment report or even in supporting working papers may be useful as well,
even if the team did not believe they should be highlighted as a finding or an observation
at the time of the final report. An examination of these additional factors in conjunction
with the findings may contribute to the development of more effective corrective actions
or lead to more in-depth improvements which will strengthen and enhance the overall
security posture at the site.
DOE-STD-1217-2016
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APPENDIX A.
SAFEGUARDS AND SECURITY
SURVEY AND SELF-ASSESSMENT
TOOLKIT
1.0 INTRODUCTION
This Toolkit was created to augment the Safeguards and Security (S&S) Survey and Self-Assessment
Technical Standard by providing a variety of samples and tools that may be used to complement the
overall survey/self-assessment process. The Toolkit is not meant to be all-inclusive, but rather to provide
a starting point that can be expanded and built upon.
Section 19
The Toolkit is divided into three sections: Planning, Conduct, and Post-Survey Activities. The Planning
section provides tools associated with survey notification, planning, and in-briefings. The Conduct
section is broken down into topical areas and their respective subtopical areas. Each topical area contains
information, such as areas to be considered in the survey, sample interview questions, etc., that may assist
the surveyor in conducting the survey. The Post-Survey Activities section includes sample survey
formats, exit briefing slides, transmittal memos, sample corrective action plans, and DOE F 470.8,
Survey/Inspection Report.
DOE-STD-1217-2016
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2.0 PLANNING TOOLS
This section addresses the logistics and notifications associated with conducting a survey or self-
assessment and provides sample documents for survey notification, planning and in-briefings. The
following specific areas are addressed:
2.1 Sample In-Briefing
2.2 Sample Survey Plan Format
2.3 Documents For Possible Review
2.4 Sample Notification Memos
2.5 Sample Accommodation Request
DOE-STD-1217-2016
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2.1 Sample In-Briefing (Customize for specific survey objectives, activities, etc.)
DOE-STD-1217-2016
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DOE-STD-1217-2016
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DOE-STD-1217-2016
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2.2 Sample Survey Plan Format
1. Title of survey
2. Location of facility
3. Purpose of survey
4. Survey dates
5. General facility information /description
a. Facility data
b. Work/activities performed
c. Operating organization (contractor)
d. S&S interests
e. Strategic Partnership Projects or other security activities
6. Scope of survey
a. Period of review, including extended observation or data collection if applicable
b. Objectives
c. Topical areas to be included/excluded and justification for each
d. Topical areas with findings from previous surveys, inspections reports, audits and appraisals (e.g.
Government Accountability Office [GAO]/ Inspector General [IG])
e. Special areas/items of interest/concern
7. Survey planning and preparation
a. Performance tests (associated safety plans)
b. Survey guide information
c. Pre-survey information
8. Survey conduct—approach and methodology
a. Documents to be reviewed
b. Performance tests
c. Individuals to be interviewed
d. Sampling activities, including extended observation, shadowing or surveillance if applicable
9. Schedule of activities
a. Survey schedule
b. In-briefing information
c. Coordinating instructions
d. Exit briefing
e. Schedule for report development
10. Team composition/assignments
a. Team members
b. Assignments/responsibilities
c. Contractor support
d. Points-of-contact at the facility
DOE-STD-1217-2016
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11. Authority/governing documents
a. Directives
b. References (unclassified/classified)
12. Survey report format
13. Administration, support, and logistics
a. Work facilities
b. Transportation
c. Computer support
d. Administrative support
e. Classification support
f. Training requirements
14. Appendices
a. Performance tests (including Safety Plans)
b. Survey guides
c. Forms
DOE-STD-1217-2016
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2.3 Documents for Possible Review
The following is a list of documentation that may be considered for review during survey conduct.
Whether or not to include these documents as part of the data call or to review during the Conduct phase
will be determined based on the focus of each topical area, as outlined in the survey plan. The list is not
comprehensive; other documents may be available which should also be considered
Section 20
Program Management Operations
Organization charts depicting the Safeguards and Security (S&S) management structure
and S&S functional structure
Documents depicting responsibilities and authorities of S&S management, including all
delegations of authority and designations of Officially Designated Federal Security
Authority (ODFSA) and Officially Designated Security Authority (ODSA)
Position descriptions for S&S management
Program Office and local instructions for the implementation of S&S programs
Supplemental documents and guidance for implementing S&S programs
Facility/site security plan (SP) and any referenced or supplemental plans and
documentation
Emergency management and security condition (SECON) plans
Survey reports, inspection reports, Government Accountability Office and Inspector
General audit/appraisal reports, self-assessment reports
Staff raining records
Contract(s), including Statement of Work
List of all subcontractors and consultants conducting work for the contractor
List of U.S. Department of Energy (DOE) directives and security clauses that have been
incorporated into applicable contracts
Approved and pending equivalencies/exemptions to DOE directives and any deviations to
national drivers (e.g., Code of Federal Regulations)
Copy of the facility registration
Applicable Memoranda of Understanding (MOU)/Agreement (MOA)
Completed Foreign Ownership, Control or Influence (FOCI) questionnaire (SF 328)
Key Management Personnel (KMP) list
Dates of all applicable FOCI determinations and copies of any mitigation agreements
A copy of the contractor's records of all contracts and subcontracts involving access
authorizations
Vulnerability Assessment (VA) reports
Risk assessment reports
Contingency plans
Survey and self-assessment program procedures
Issues management plans and procedures
Corrective action plans and status updates for all open deficiencies
Finding/deficiency corrective action validation and closing procedures
Incidents of Security Concern procedure, including initial notification and inquiry reports
Contract Security Classification Specification (CSCS) forms
Facility Data and Approval Record (FDAR) forms
Copy of the approved Performance Assurance Program Plan
List of essential elements documented in the Performance Assurance program and the
testing schedule for each
Documentation of the integrated contractor assurance system
DOE-STD-1217-2016
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Protective Force (PF)
Organization and function charts
PF general, special and post orders
PF shift schedules and post assignments
PF standard equipment issuance (Security Police Officer [SPO] I, II, III, and Special
Response Team [SRT])
PF weapons and ammunition inventories
Weapons maintenance logs
MOU with local law enforcement agencies and documentation of exercises conducted
with those agencies
Integration of crisis management personnel into procedures
PF training records which include:
A list of PF personnel who are subject to weapons qualification within 90 days of the
start date of the survey
A list of PF personnel who are medically certified to participate in the physical
fitness program
All documentation of PF exercises conducted since the last S&S survey
Instructor certification
Job analysis
Section 21
Job task analyses
Security Emergency Response Plan (SERP)
Security Incident Response Plan (SIRP)
Facility Evacuation Response Plans
Security Contingency Response Plans
Target folders
Schedule for performance testing (results of recent tests)
Compensatory measures currently in place (including pertinent documentation)
Procedures (administrative, training, non-response-related operational requirements)
Access/badge control
Information containing, at a minimum, policies/procedures for issuing, replacing, and
recovering passes/badges
Inventories (since last S&S survey) of passes/badges made, issued, lost, recovered,
returned, and destroyed
Shipment security plans
Shipment procedures
In-transit emergency plan
Shipment emergency response plan
Physical Protection
Organization and function charts
Lock and key records and procedures
Automated access control system records and procedures (including biometric access
input as well as access credential issuances (e.g., keycards, tokens)
Barrier maintenance procedures/records
Property control procedures
Access control procedures
Local performance testing plans and procedures
Physical security system description(s) and location(s)
Intrusion detection system (IDS) maintenance and testing records and procedures
IDS Analysis and Evaluation Report
DOE-STD-1217-2016
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Unscheduled alarm reports
Central Alarm Station (CAS)/Secondary Alarm Station (SAS) procedures (interface
description)
Emergency response for CAS/SAS recovery
Emergency power systems (uninterruptible power supply system)
Compensatory procedures for equipment outages
Security container documentation and maintenance records
Automated systems description and procedures
Manual
Procedures
Controls
Calibration and testing procedures and records (e.g., X-ray, metal detectors, IDS)
Inspection procedures
Limited Scope Performance Test (LSPT) results
Information Security
Organization and function charts
Training records
Technical surveillance countermeasure (TSCM) survey reports
Site inventory of accredited systems, showing property tag number, the accrediting
authority, and most recent accreditation date for each
Formal assignments of TSCM personnel
TSCM activity support memoranda (if applicable)
Local TSCM implementation guidance
TSCMO service schedules, files, and corrective action reports
TSCM team equipment maintenance and calibration files
TSCM team training and certification records
Operations Security (OPSEC) Plan
OPSEC procedures
OPSEC program files
Local threat statement
Critical Program Information
Counter-Imagery Program Plan (if applicable)
Number of derivative classifiers and declassifiers
Appointment letters (e.g., Inquiry Officer, custodians)
Training records, reports, and lesson plans
Classification guidance
Classified Matter Protection and Control (CMPC) procedures
Control station procedures
List of classified holdings, including documents, electronic media, and matter
Number of Special Access Programs (SAPs)
Personnel Security
Local procedures for terminations, leave of absences, reinstating clearances, clearance
processing, exit briefing process
Contractor access authorization requests
Sample initial, comprehensive, refresher, and termination briefing materials
Previous findings and corrective action plans
Reciprocal access authorization documentation
Awareness tools (posters, newsletters)
Section 22
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Security infraction and violation records
Requests for visit or access approval (notification and approval of incoming and outgoing
classified visits records and records of cleared non-DOE personnel granted access to RD)
Written delegation of senior Federal official authorized to make determinations on access
to Restricted Data by non-DOE personnel in connection with a classified visit
Visitor control logs
Local visitor control procedures
Central Personnel Clearance Index (CPCI) list of individuals overdue for reinvestigation
Drug testing/handling procedures
Drug testing records
Human Reliability Program (HRP) participants
HRP criteria/plans/procedures
Random test procedures
List of individuals on leaves of absence and the associated procedures for tracking
List of inactive classified contracts
List of personnel with access authorizations and the associated contract(s)
List of clearances terminated during the survey period
List of all access authorizations held by the contractor, including all contractors and
subcontractors that have cleared employees conducting work at the facility. This list can
come from the DOE CPCI of access authorizations held by the contractor. The CPCI and
contractor lists, including the current KMP list, should be compared for discrepancies.
Foreign Visits and Assignments
List of foreign visitors from sensitive countries during the survey period
Specific security plans for foreign visitors from sensitive countries
Escort procedures
Local procedures for requesting, processing, and approving visits and assignments
List of foreign visitors or assignees, including hosts, during survey period
Incident reports involving foreign nationals
Requests for foreign national visits
Indices checks
Documentation authorizing approval for specific categories of visits and assignments
Sensitive country listings
Equivalencies/exemptions pertinent to visits and assignments
Personnel assignment agreements
Nuclear Material Control and Accountability (MC&A)
MC&A plans and procedures
Training records, reports, and lesson plans
Performance tests
Categorization process documentation
Incident reporting process and procedures
Emergency response plans and facility procedures
Database descriptions
Material Balance Area (MBA) account structure
Material transfer records
Internal control procedures
Nuclear Material Management and Safeguards System (NMMSS) reports
Shipper/receiver difference procedures and records
Material control indicator program
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Inventory difference program
Materials containment documentation
Facility procedures
Material access program
Authorization access lists
Search procedures
Material surveillance procedures
Portal monitor records and procedures
Daily administrative check program and procedures
Tamper indicating device program
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2.4 Sample Notification Memos
2.4.1 Notification and Data Call
DATE:
TO:
FROM:
SUBJECT: Notification and Data Call Request - Safeguards and Security (S&S) Survey of XYZ
Facility
This memorandum is to formally notify you that a representative of the [Surveying Organization] will
conduct a S&S survey of the XYZ facility and its satellite offices during the period [DateDate], in
accordance with the requirements of DOE O XXX, [Title], [Appendix, Section, Chapter, etc.]. The
topical areas to be evaluated include:
Section 23
- Program Management Operations
- Protective Force
- Physical Security
- Information Protection
- Personnel Security
- Foreign Visits and Assignments
- Nuclear Materials Control and Accountability.
A list of personnel participating in the survey is reflected in Attachment 1. The Survey Team Leader is
John Doe. This survey involves a review and evaluation of the S&S program as implemented by the
XYZ facility.
System performance tests will be conducted during this survey in several topical areas. Attachment 2
contains the data call. Please ensure the data call items are available for the survey team’s review no later
than [Date]. Items can be sent electronically to the Survey Team Leader or in hardcopy form to Room
XXX, Building XXX. The in-briefing will be held on [Day, Date], in Room XXX, Building XXX. The
exit briefings are scheduled for [Day, Date], in [place] at time(s) to be announced at a later date.
If you or your staff have any questions or require additional information, please contact John Doe on
[phone number] or by pager [pager number].
2 Attachments
DOE-STD-1217-2016
32
2.4.2 Safeguards and Security Periodic Survey
DATE:
TO:
FROM:
SUBJECT: Safeguards and Security Periodic Survey (SSPS)
The [Surveying Organization] will conduct an SSPS of the [Organization to be Surveyed] during the
period of [DateDate]. This will be a comprehensive survey and will be conducted in accordance with
[Appendix, Section, Chapter, etc.] of DOE O XXX,[Title]. The survey will examine the performance of
safeguards and security programs to ensure that S&S measures employed by the facility are adequate for
the protection of security assets and interests and will encompass all topical areas on DOE F 470.8,
Survey/Inspection Report Form.
To aid in the planning process, you are requested to provide the documentation listed in the Attachment.
These documents are to be provided to [Survey Team Leader] not later than close of business [Day,
Date]. In addition, please provide points of contact information for each topical area, including
pagers/cellphone and phone numbers. The names of [Surveying Organization]’s Survey Team Leader
and Topical Area Leads will be forwarded to your organization under separate cover.
Survey activities will begin with an in-briefing at [Time, Date], in [Place]. Points of contact representing
your organization in each topical area should plan to attend.
If you have any questions or require additional information, please contact [Survey Team Leader] on
[phone number].
Attachment
DOE-STD-1217-2016
33
[Sample Attachment - Documentation Request]
Attachment 1
All documentation provided should include the past 12 months unless otherwise noted.
Program Management Operations
1. Organization chart(s) or listings with brief description of organizations functions and
responsibilities
2. Current site security plan with all referenced or supplemental plans
3. Recent self-assessment report(s)
4. Copy of findings/corrective action plan tracking procedures
5. Current status of all open and closed findings/corrective action plans since the last survey
(including Office of Independent Enterprise Assessments, Government Accountability Office and
Inspector General)
6. List of and current status of all approved policy equivalencies and exemptions and any approved
deviations from national policy (e.g., Code of Federal Regulations)
7. List of all subcontractors performing work (name of company, contract number, names of
individuals with access authorizations)
Section 24
8. Copies of all CSCS and FDAR forms related to the facility clearance
Protective Force
1. Facility security plans
2. Emergency security operation procedures
3. Security emergency response plan
4. Memoranda of Agreement/Understanding (e.g., with local law enforcement)
Physical Protection
1. Security systems test procedures
2. Security systems maintenance procedures
3. Lock and key records and procedures
4. Access control procedures
5. Unscheduled alarm reports for the past three months
Information Security
1. List of locations where classified matter is stored and the name and telephone number of the
responsible custodian
2. List of locations where classified matter is used/processed
3. List of total number of classified materials and documents in accountability, including level and
category
4. Operations Security (OPSEC) plans
5. All training materials to support the OPSEC program (have available on request)
6. All documents that support OPSEC briefings for contractor personnel (have available on request)
7. All other internal program procedures that support OPSEC
8. List of derivative classifiers
Personnel Security
1. List of all assigned (cleared) employees/subcontractors who have traveled to sensitive countries
(official and unofficial)
2. List of all visits and assignments of foreign nationals
DOE-STD-1217-2016
34
3. List of all subcontractors
4. List of uncleared visitors
5. List of outgoing classified visits
6. List of all incoming classified visitors
7. List of Human Reliability Program participants
8. List of terminated clearances (including name, date termination statement signed, date clearance
terminated, Central Personnel Clearance Index [CPCI] number)
Foreign Visits and Assignments
1. List of visits
2. List of foreign national (FN) visitors from sensitive countries
3. Specific security plans for FNs visiting from sensitive countries
4. Escort procedures
5. Local procedures for requesting, processing, and approving visits and assignments
Nuclear Material Control and Accountability (MC&A)
1. Categorization process documentation
2. Material Balance Area account structure
3. Inventory difference program plans
4. MC&A plan/procedures (may be part of site security plan or separate document[s])
DOE-STD-1217-2016
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2.4.3 Initial Safeguards and Security Survey
Date:
To:
From:
Subject: Safeguards and Security (S&S) Survey of XYZ Company
This memorandum confirms informal arrangements between [Surveying Office] and [Organization to be
Surveyed] Safeguards and Security Organization personnel that established [DateDate] as the dates for
the [Surveying Office] S&S survey of the [Organization to be Surveyed] facility. The survey is
conducted in accordance with Title 48 Code of Federal Regulations Subpart 952.204.73(c) and the
requirements of DOE O XXX, [Title], [Appendix, Section, Chapter, etc].
An informal and brief preliminary meeting is requested for [Date, Time] with S&S management and
selected survey personnel. The survey process will be discussed during this meeting.
Enclosure 1 is a pre-survey questionnaire/data call that identifies the preliminary information required in
the topics to be surveyed. Please provide this information to [Surveying Office] by [Date]. This material
will be distributed to team members for review and familiarization prior to the survey. Enclosure 2
identifies the accommodations requested for the team’s use during the survey.
Section 25
If there are any questions regarding survey activities, please contact [Survey Team Leader] on [phone
number]. Your assistance is appreciated.
Enclosures
DOE-STD-1217-2016
36
[Sample Enclosure - Pre-survey Questionnaire/ Data Call]
Enclosure 1
The survey team needs the following to be delivered to Room XXX no later than [Date] for the XYZ
facility and satellite office buildings:
A. PROGRAM MANAGEMENT OPERATIONS
1. A list reflecting security staffing since [month, year]. This list should include name of
person, date of hire/termination, job title, and security functions (responsibilities)
2. Copies of all memoranda of understanding and management agreements relating to
safeguards and security (S&S) programs
3. A copy of all internal operations procedures/practices, with index
4. Copies of the most recent S&S risk assessments, including documentation reflecting risk
determination methodology
5. A list of all security training courses that have been approved as part of the training approval
plan process
6. A list that reflects the training courses taken by personnel responsible for security functions.
Include name, title of course, number of hours, and date of completion
7. Copies of any procedures or other guidance pertaining to the identification and development
of S&S training
8. A list of all facilities (copies of Facility Data and Approval Records are acceptable) where the
XXX DOE Office is identified as the Designated Responsible Office.
9. A list of all classified activities (including the contract), classification level and category of
the activity, identification by office and/or Cognizant Security Office, identification by
contract number, purchase order number, task statement, or proposal number (including
classified Strategic Partnership Projects) (Note: Copies of the Contract Security
Classification Specification (CSCS) form may be used in lieu of a listing.)
10. List of all terminated and completed contracts since [month, year]. This listing should
identify the company/vendor, address/location, Contracting Officer name, organization,
office location, and telephone number (Note: Copies of terminated CSCS forms may be used
in lieu of a listing.)
11. List of pending Foreign Ownership, Control, or Influence (FOCI) determinations
12. List of FOCI determinations completed since [month, year]
13. List of FOCI approved companies, including the FOCI determination date, mitigation types if
any, and date of the latest FOCI update
14. A copy of any desktop procedures or other formal XYZ-originated guidance documentation
used for the development of the facility/site security plan and other security-related planning
documents
15. A list that reflects all S&S plans (e.g., response, emergency, and contingency plans) including
title, date, and approval vehicle. Also list any draft plans and plans pending approval
16. Copies of all XYZ-generated guidance or direction (hardcopy or electronic) provided for the
conduct of self-assessments and other internal evaluations
17. List of all open findings
18. List of open findings pending validation
19. Copy of Incidents of Security Concern program procedures
20. A list of all security incidents, including computer security incidents, occurring since [month,
year]. This list should identify the date of the incident, the date of the inquiry report, and the
nature of the incident
21. Copies of award fee data (Award Fee Plan, performance criteria)
DOE-STD-1217-2016
Section 26
37
B. PROTECTIVE FORCE (PF)
1. Copies of all security emergency plans (response, facility evacuation). If this information is
not available from this office, please provide the name, organization, office location, and
telephone number of the responsible person
2. Copies of all post and general orders, as well as implementing instructions for various
program activities (e.g., key control, alarm testing and maintenance, training program
development). If this is not applicable to the area being surveyed check here N/A ___. If this
is applicable, but the records are not available from this organization, please identify the
name, organization, office location, and telephone number of the responsible person
3. Copies of all Memoranda of Understanding (MOUs)/Memoranda of Agreement (MOAs) with
local law enforcement agencies (LLEAs) or other organizations/agencies relating to security
programs at the XYZ facility and satellite office buildings. If this is not applicable to the area
being surveyed, check here N/A ___
4. List of all Protective Force personnel, identified by rank, and supervisors. Also provide a
separate listing including PF management name, rank (if applicable), and responsibility (e.g.,
Lt. John Smith, Supervisor, IMF Instructor, Firearms Instructor)
5. A list of training documentation including, but not limited to, Job Task Analyses, lesson
plans, core topics, individual records, physical fitness maintenance. Samples of each should
be available for review during the survey
6. Copy of any DOE approval of the PF job analysis
7. Copy of the last (and immediately preceding) annual review of the PF job analysis.
8. Copy of the most recent approved Training Plan
9. If available, an approved Training Approval Program Assessment Report
10. A list of permanent and temporary security posts including post number and hours staffed
11. If existing, a copy of all duty checklists used by the PF during routine and/or emergency
operations (e.g., vehicle inspection checklist, incident reports, field interview reports, pre-
duty inspection checklists, equipment checklists, Central Alarm Station logs and radio
checks, weapons issue, weapons maintenance, weapons cleaning, emergency call-out)
12. Copy of plans documenting the physical configuration of security posts
13. Copy of traffic/parking procedures (safety or security PF interface/enforcement)
14. Copy of general and specific patrol orders that define patrol intervals and routes for classified
repositories, vaults, and vault-type rooms
15. Weapons inventory list, including serial number and storage location.
16. Quality Assurance program documentation
17. Communications equipment inventory list, including quantity, make, model, and auxiliary
equipment, as well as interface capabilities with LLEA
18. Auxiliary equipment inventory list including quantity, make, model of assigned equipment
(e.g., gas masks, protective vests)
19. Copy with pictures (if possible) of patrol and other vehicles used under the contract by the
PF. A list including vehicle make, model, vehicle identification number, mileage, condition,
unit number, license number, equipment (emergency and standard), owner (company, DOE,
or leased from XYZ agency), maintenance agreement, and identification of location of
maintenance records (a sample of maintenance records would be helpful)
C. PHYSICAL PROTECTION
1. Copy of key control and property pass procedures
2. Copy of documentation that reflects the total value of capital and sensitive/equipment items
Section 27
(include precious metals as applicable)
3. Listing of all controlled substances and locations, including copies of Drug Enforcement
DOE-STD-1217-2016
38
Agency certificates
4. Listing that identifies all security alarm transmission and monitoring systems, including type,
model, manufacturer, and purpose for each (i.e., describe the DOE assets being protected)
5. List of all alarm points identified by system application (e.g., Argus, Litton) and location that
provides protection for classified matter and property
6. Copy of the approved alarm test plan and a copy of the DOE approval correspondence
7. Copy of the procedures for making changes to alarm transmission/monitoring systems
databases or software
8. Copies of reports since [month, year] of unscheduled alarm activations
9. Copy of false alarm rate and nuisance alarm rate since [month, year]
10. Copies of maintenance procedures and test results since [month, year]
11. Copies of IDS Analysis and Evaluation report since [month, year]
D. INFORMATION SECURITY
1. A list of all current XYZ original and derivative classifiers
2. A list of reviewing officials, including name, title, organization, office location, and
telephone number
3. A list of all classification guides, including title and date
4. A list of all XYZ shipping/mailroom logs pertaining to the transmission of classified matter
since [month, year]
5. A list of all areas authorized for processing and storage of classified information/matter,
including the classification level authorized and functions performed in each area
6. List of all classified document control stations, including the custodian names, organization,
location, and telephone extension.
7. Copy of Classified Matter Protection and Control procedures (marking, destruction)
8. List of all classified material accountability records
9. Copy of DOE-approved Technical Surveillance Countermeasures (TSCM) Plan
10. Copy of the TSCM officers appointment memoranda
11. Copy of the site-wide procedures for the control and use of potential TSCM equipment
12. Copy of the procedures controlling TSCM equipment, the DOE approval for purchasing and
controlling TSCM equipment, and an inventory listing, if appropriate
13. Copy of Operations Security (OPSEC) Plan
14. Copy of OPSEC assessment and review reports conducted since [month, year]
15. List of contractors (on- and off-site) under the OPSEC program
16. Copy of OPSEC working group meeting minutes for meetings conducted since [month, year]
E. PERSONNEL SECURITY
1. A list of all cleared personnel whose access authorization has been terminated since [month,
year] (Note: This list should include the date of termination, name of person, and
organization for which the individual worked.)
2. A list of names of all consultants/vendors issued security clearances that conduct business
with XYZ
3. A list of all individuals by name and clearance number terminated for cause
4. A list of individuals by name and clearance number who have had clearances
canceled/terminated prior to completion of the background investigation
5. A list by name and clearance number of all foreign nationals who are/were clearance
applicants or incumbents. Include in the listing the country of origin and level of clearance
6. A list by name and clearance number of all dual citizens processed for access authorization
(clearance) since [month, year]
DOE-STD-1217-2016
39
Section 28
7. A list of individuals on leave-of-absence or extended leave. This list should include name,
clearance number, reason for leave, date leave commenced, expected date of return to duty,
and/or date of termination
8. Have available each report submitted for derogatory information since [month, year]
9. Copy of attendance records for initial, comprehensive, and termination briefings for all
contractor employees since [month, year]
10. Copies of most current security education briefing/lesson plans for initial, comprehensive,
refresher, and termination briefings since [month, year]
11. Copy of the compliance verification numbers associated with the most recent refresher
briefing
12. Documentation describing the badging system and operating procedures for classified visits.
Provide examples of all badge types in use
13. Copy of the procedures for administering incoming and outgoing classified visits
14. Copies of incoming visit requests since [month, year]
15. Classified visitor logs since [month, year]
16. Copies or log of classified visitor badge requests since [month, year]
17. A listing of the number and dates of each positive substance abuse test report
18. A copy of drug test policy
19. A list of all personnel, by name and clearance number, enrolled in the Human Reliability
Program (HRP) or other performance assurance program
20. List of all individuals, by name and clearance number, removed from the HRP since [month,
year]
21. Justifications for HRP positions and date of last review
22. Procedures for Personal Identify Verification process
G. FOREIGN VISITS AND ASSIGNMENTS
1. Lists of all host reports submitted since [month, year] including date submitted
2. Local procedures for requesting, processing, and approving visits and assignments
3. List of foreign visitors or assignees, including names of hosts, for survey period
4. Incident reports involving foreign nationals
5. Requests for foreign national visits
6. Indices checks
7. Documentation authorizing approval for specific categories of visits and assignments
8. Sensitive country listings
H. NUCLEAR MATERIALS CONTROL AND ACCOUNTABILITY (MC&A)
1. MC&A Plan
2. Performance test data
3. Categorization documentation
4. Internal control procedures
5. Inventory difference program
6. Shipper/receiver difference procedures and records
DOE-STD-1217-2016
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2.5 Sample Accommodation Request
The following items will need to be made available to the survey team for the duration of the survey
period:
Two conference rooms or a two-office suite with tables and seating for 15 to 20 people
Four desktop computers running Microsoft® Windows® [current operating system],
loaded with Microsoft Word [current version] and two Hewlett-Packard LaserJet printers
Telephones with outside lines and official site phone books or listings
White board and associated supplies
U.S. General Services Administration-approved security container (with appropriate
markings and required forms)
Office supplies (staplers, scissors, tape, disks, etc.)
Copies of XYZ procedures and policy manuals related to survey topics, security plans,
Vulnerability Assessments, and applicable DOE directives.
DOE-STD-1217-2016
41
3.0 CONDUCT TOOLS
This section contains tools that have been developed and field-tested by survey and self-assessment
teams. They are provided as examples only; other tools may be developed and used as necessary.
Section 29
3.1 Sample Survey Worksheet
3.2 Instructions for Completing the Sample Survey Worksheet
3.3 Sample Performance Test Safety Plan
3.4 Sample Performance Test Plan
DOE-STD-1217-2016
42
3.1 Sample Survey Worksheet
CLASSIFICATION
WORKSHEET
ORIGINATION DATE:
RESPONSIBLE AGENCY:
FINDING NUMBER:
CONCERN: COMPLIANCE PERFORMANCE BOTH
TOPICAL AREA: SUBTOPICAL AREA:
FINDING DESCRIPTION:
FINDING SYNOPSIS:
IMPACT if not corrected:
DOE DIRECTIVE:
OTHER (Plan or Procedure Citation):
ORIGINATOR’S NAME/PHONE:
POINT-OF-CONTACT NAME/PHONE:
POINT-OF-CONTACT SIGNATURE:
CLASSIFICATION
DOE-STD-1217-2016
43
3.2 Instructions for Completing the Sample Survey Worksheet
ORIGINATION DATE: Date form completed.
RESPONSIBLE AGENCY: Agency responsible for implementing corrective actions.
FINDING NUMBER: Each finding identified in the survey report should have a unique
identification number assigned, which should be used throughout the reporting and tracking
process. The following number system provides consistency with the Safeguards and Security
Information Management System (SSIMS). A number in this format should be system-generated
upon entry of the finding into SSIMS.
Example of a finding number:
04OCT15-HQ-12345-SSPS-PF.1-001-5789
| | | | | | |
1 2 3 4 5 6 7
1: the date of the survey/inspection (year/month/day)
2: the office responsible for correcting the finding
3: the facility code of the facility surveyed/inspected
4: the type of survey (e.g., Safeguards and Security Initial Survey, Office of Enterprise
Assessments, Inspector Government Accountability Office)
5: the subtopical area code
6: the sequential number of an individual finding within the topical area
7: the facility code of another facility if a finding was issued to it during the survey
The acronyms used to identify the new topical areas for findings are as follows:
PMS Program Management Support
PF Protective Force
PSS Physical Protection
IP Information Security
PSP Personnel Security Program
FVA Foreign Visits and Assignments
NMCAA Nuclear Materials Control and Accountability
CODE TYPES OF SURVEY DOCUMENTS
EPR Excluded Parent Review
GAO Government Accountability Office Reports
IG Inspector General Reports
NPR Non-possessing Review
EA Office of Security Assessment inspections/reviews
SA Self-Assessments
SPEC Special Surveys
SSIS Safeguards and Security Initial Surveys
DOE-STD-1217-2016
44
SSPS Safeguards and Security Periodic Surveys
SSTS Termination Surveys
TSCM TSCM Reports
FINDING DESCRIPTION: The finding description should be used to provide a clear
understanding of what was observed or discovered. It is not adequate to reiterate the requirement.
The description should clearly identify the pertinent facts, circumstances, and observations
surrounding the finding or leading to the finding.
Findings should be clear and focused on the root cause of the observed protection shortfall, rather
than merely stating the occurrence of a protection element failure or weakness. A finding should be
written in such a manner that it is actionable by the responsible agency, i.e., that action can be taken
that will close the finding and the action will correct the observed deficiency. A well-worded
finding is one that is readily closeable when the cause or source is corrected and impossible to close
without correcting the cause or source.
Section 30
Necessary and pertinent information should be presented regarding the finding in order to clearly
identify what was found, how the information was collected, and any other background
information. The discussions should attempt to correlate the data collected and focus on the root
cause of the deficiency. The nature of the data (e.g., observations, interviews, tests) should be
described, as well as any quantifying data that will put the results in perspective.
For example:
A review was conducted of all current classified contracts at XYZ. This list was
compared to a current badge listing, dated 3-1-15, which showed employees, by company,
who currently hold a DOE access authorization. This comparison revealed that
individuals holding access authorizations are employed by organizations that do not have
Foreign Ownership, Control, or Influence (FOCI) determinations on file.
Based on the FOCI report provided by XYZ personnel, dated 3-1-15, and the employee
list by contractor, dated 3-1-15; TCY Company currently holds 7 “Q” clearances and
Smith Manufacturing currently holds five “Q” clearances. Neither organization has a
FOCI determination on file.
FINDING SYNOPSIS: Each finding should be concisely described in a synopsis format. The
SSIMS allows a maximum of 2,000 alpha/numeric characters and spaces. Each finding is to have a
separate, stand-alone classification level and category. A separate field is provided for the finding
classification level and category. The symbols “S” for Secret, “C” for Confidential, “U” for
Unclassified, “OUO” for Official Use Only, and “UCNI” for Unclassified Controlled Nuclear
Information shall be used for the classification level.
For example:
Not all organizations employing cleared staff members have an approved FOCI determination.
IMPACT STATEMENT: Clearly identify the impact of the deficiency.
DOE DIRECTIVE: Each finding is to have alpha/numeric references to the DOE directive(s), or
other documents that identify the requirement(s) not being met in the finding. This reference
DOE-STD-1217-2016
45
should be written as DOE O XXX.XX, followed by the specific identification numbers and/or
letters [e.g., DOE O 470.4B, admin chg., 1, Appendix A, Section 2, paragraph 6.(b)].
OTHER: Identify alternative sources stating the requirement (e.g., section of the Code of Federal
Regulations, specific local procedures, site security plan).
ORIGINATOR’S NAME/PHONE: Print your name and telephone number.
POINT-OF-CONTACT NAME/PHONE: Print the name and phone of the POC witnessing the
activity.
POINT-OF-CONTACT SIGNATURE: Obtain the POC’s signature.
DOE-STD-1217-2016
46
3.3 Sample Performance Test Safety Plan
PERFORMANCE TEST SAFETY PLAN
I, ________________________, acknowledge receipt of the attached safety plan. I understand it is my
responsibility to become familiar and comply with the contents of this safety plan.
Acknowledgment of the receipt of this safety plan is a requirement to participate in or observe this
exercise. This page must be signed and returned no later than _________________.
Name _____________________
Signature ___________________
Position ____________________
Date _______________________
Detection of Contraband and Prohibited Items
(Type of Performance Test)
Ongoing 365 Days per Year; 24 Hours per Day
(Performance Test Date and Time)
Detection of Contraband and Prohibited Items, John Doe
(Safety Plan Name and Person Preparing)
Section 31
ALL LIMITED SCOPE PERFORMANCE TESTS (LSPT’S) WILL BE CONDUCTED IN
CONFORMANCE WITH THIS SAFETY PLAN AND ONLY AFTER SPECIFIC APPROVAL
TO CONDUCT THE LSPT’S HAS BEEN GRANTED BY A RESPONSIBLE U.S.
DEPARTMENT OF ENERGY OFFICIAL. PERSONNEL SERVING AS CONTROLLERS WILL
BE FULLY QUALIFIED IN ALL ASPECTS OF THE LSPT.
Scenario:
The ongoing LSPTs are conducted to test the ability of Protective Force (PF) personnel to detect and
prevent contraband and prohibited items from being introduced into Limited Areas, Exclusion Areas,
Protected Areas, and Material Access Areas. LSPTs will be conducted on X-ray machines, metal
detectors, and hand and vehicle searches. Security and non-security personnel will try to enter and exit
the above-mentioned areas with contraband and prohibited items. Using personnel with whom PF
personnel are unfamiliar will ensure credible and realistic test results. The person attempting to introduce
the contraband or prohibited item will use only contraband test items that have been approved by the
DOE cognizant security office. Once the entry is initiated, the person attempting the entry will only
proceed after being cleared to do so by the security officer conducting the search. The persons attempting
the entry will wear clothing that would make the concealment of any weapons on their person virtually
impossible, and they will keep their hands open and in plain view at all times. The persons attempting to
enter or exit any of the aforementioned areas will strictly follow all instructions given by the DOE
controller and obey all instructions given by PF personnel. The DOE controller will announce the LSPT
DOE-STD-1217-2016
47
to PF personnel once the contraband or prohibited item has been detected/undetected by the PF. The sole
purpose of the LSPTs is to evaluate the ability of the PF to detect contraband and prohibited items prior
to their release into the aforementioned areas. The LSPTs are not designed to test what actions the PF
undertakes once they detect or fail to detect the contraband or prohibited item.
IN THE EVENT OF AN ACTUAL SECURITY ALARM OR SECURITY INCIDENT, THE
CONTROLLER WILL IMMEDIATELY ANNOUNCE AND CONCLUDE THE LSPT, TAKE
POSSESSION OF THE TEST ITEM/CONTAINER, AND FOLLOW ALL INSTRUCTIONS
ISSUED BY PF PERSONNEL.
Requirements:
1. DOE Controller
2. Person to carry contraband or prohibited item into the area
3. Contraband and prohibited item(s)
4. Support items, such as lunch boxes, purses, notebooks, gym bags, vehicles.
PF Response:
_____ Yes _____ No
If a no-notice PF response is desired, check the following measures being taken to ensure safety during
the response.
____ Drill announcements will be made on all PF networks immediately after PF response is initiated,
and periodically thereafter.
X Controller is located in the PF Central Alarm Station (CAS).
____ The PF is informed that an exercise will take place and that they are to follow the safety and health
requirements contained in this plan and in the site procedures. This instruction will be provided by
site representatives briefing the PF prior to the shift during which the performance test will take
place.
X Controllers are located at the exercise location.
If PF response is not desired, check those measures being taken to preclude response.
____ Prior notification of CAS.
____ Prior notification of PF.
____ Presence of non-playing PF personnel briefed on the scenario at the performance test location.
Section 32
X Controller located in the CAS. A second controller will be located in the CAS with a final
approved copy of this LSPT Safety Plan and LSPT Safety Briefing. This controller will be
able to provide positive identification of the onsite controller and any support personnel
participating in the LSPT. The onsite controller will ensure that the CAS controller is
physically located in the CAS prior to departure for the area in which the LSPT will be
conducted.
DOE-STD-1217-2016
48
X Controller located in the immediate vicinity (within sight and hearing of the PF and support
personnel) of the LSPT.
List other specific safety measures below:
1. All personnel attempting to gain entrance into one of the identified areas will be briefed on the
LSPT objectives and how they should conduct themselves during the LSPT.
2. All contraband or prohibited items will be photographed prior to the initiation of the LSPT.
3. All personnel attempting to gain entry or exit with contraband items will be photographed prior to
the initiation of the LSPT.
4. All personnel attempting to gain entry or exit with contraband or prohibited items will be
instructed to keep their hands in plain view, not to make any sudden moves, and comply with all
instructions given by PF personnel.
5. Only epoxy–encased, DOE cognizant security office-approved test weapons will be used in
LSPTs requiring weapons.
6. All support personnel attempting to gain entrance or exit with contraband or prohibited items will
be briefed and required to read and sign the attached rules of exercise.
Performance Test Boundaries:
X Applicable
The immediate area of the security post where the LSPT is being conducted.
X Not applicable
If applicable, describe the performance tests boundaries and the restrictions on performance test
participant movements in detail:
Off-Limit Areas:
____ Applicable
X Not applicable
If applicable, describe the off-limit areas and how they will be designated:
Safety Equipment:
____ Controller Radios
____ PF Radios
____ Orange Vests
____ “Glow Sticks”
____ First Aid Kit
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____ Other required safety equipment:
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Specific Safety Hazards Not Covered Elsewhere:
____ Applicable
X Not applicable
These LSPTs are being conducted with armed PF personnel. As with all such exercises, the
remote possibility exists that weapons may be drawn if the exercise plan is not adhered to, or if
PF personnel are not properly trained. However, because of the constraints placed upon the
exercise controllers by this plan and the level of preparation of the DOE participants, the level of
risk is actually below that experienced during normal day-to-day operations.
Radiation Safety Provisions:
____ Applicable
X Not applicable
If yes, check those applicable to this LSPT:
____ Personnel participating in the LSPT have been briefed concerning radiation safety
requirements for the area with which the LSPT will be conducted.
____ Personnel will be continuously escorted while in the radiation areas in which the LSPT
will be conducted.
List any other specific radiation safety provisions for this LSPT:
Personnel Assignments (list below):
The names of the DOE controller and the person carrying the contraband or prohibited items will be filled
in prior to conducting the LSPT.
Protective Force Appendix Required:
____ Yes
X No
DOE Safety Review:
Section 33
List any pertinent safety procedures concerning this LSPT that are not addressed in this plan.
Normally, the PF will not be notified in advance of the specifics of the LSPT being conducted. The shift
captain will be notified upon termination of the LSPT.
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APPROVALS:
_________________________________________ Date _________________
Director, Safety and Health Organization
DOE Cognizant Security Office
_________________________________________ Date _________________
Contractor Safety and Health Representative
_________________________________________ Date _________________
Director, Security Organization
DOE Cognizant Security Office
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3.4 Sample Performance Test Plan
PERFORMANCE TEST PLAN
TEST OBJECTIVE
This performance test is designed to
1. Test individual employee response to finding an unattended Secret Restricted Data (SRD) document
2. Verify compliance with the notification process to Classified Document Control Office (CDCO)
3. Verify PF compliance with the procedure for responding to this incident.
SCENARIO DESCRIPTION
A simulated SRD document will be left unattended in an area accessed by “L”-cleared employees. This
document will be marked as a formal SRD document. Personnel recovering and responding to the
simulated classified document shall have no indication that the contents of the document are actually
unclassified.
TEST METHODOLOGY AND EVALUATION CRITERIA
1. A simulated SRD document consisting of approximately five pages of unclassified text and drawings
shall be placed on the table next to a copy machine located in Building xxx, Room zzz. The
document shall be placed in the designated location at approximately 7:30 am.
2. Upon notification of the unattended “classified” document, the CDCO will verify that the individual
finding the document completed the following actions:
a) Xxxx
b) Xxxx
c) Xxxx
The Document Control Center shall also verify that the PF completed the following actions:
a) Xxx
b) Xxx
c) Xxx
Pass/Fail Criteria
In order to successfully complete the performance test, the following must occur:
Classified Document Control Office is notified within three hours of placement.
Individual locating the unattended document adheres to all protection and notification requirements.
PF officer responding to the incident adheres to all protection and notification requirements.
TEST CONTROLS
The following controls will be adhered to during conduct of this performance test.
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Only survey team members involved with the conduct and evaluation of this performance test will be
made aware of all information surrounding the conduct of the test.
There are no additional safety requirements for this performance test. All current facility safety
requirements will be adhered to during this performance test.
This will be a no-notice exercise; therefore, the surveyed organization will not be given any
information regarding the conduct of this performance test prior to the test.
The simulated SRD document used during this exercise will consist of an unclassified document
marked at the SRD level with all appropriate markings and covers. There will be no indications to a
casual observer that the document is not classified.
RESOURCE REQUIREMENTS
The following resources are needed to conduct this performance test.
Simulated SRD document
Identified location to place the document
Three survey team members to be assigned the following:
Section 34
a) Monitor the document
b) Monitor the PF response
c) Monitor the CDCO
TEST COORDINATION REQUIREMENTS
No coordination requirements are necessary since this is a no-notice exercise. Survey team members
monitoring the various aspects of the performance test will identify themselves to participants only when
it becomes necessary.
OPERATIONAL IMPACT(S) OF TESTING PROGRAM
Since this performance test is being conducted during normal duty hours, there will be no need for
additional funds for overtime payments, and there is no expectation of a loss of productive time for
personnel who will be participating in the exercise.
COMPENSATORY MEASURES
There are no compensatory measures required for the conduct of this exercise.
COORDINATION AND APPROVAL PROCESS
The following steps and documentation will be followed in the conduct of this exercise.
This test plan will be approved by the survey team leader prior to the conduct of the performance test.
Approval of this test plan will be documented by the Survey Team Leader’s signature and date on this
test plan.
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A participant log containing name, job title, organization, telephone number, and date will be
completed by all participants of this exercise.
A data collection form containing the date, performance test type, name of evaluator, and
chronological description of actions observed will be completed by all survey team members
participating in the evaluation of this performance test.
REFERENCES
The following references will be used in the conduct and evaluation of this performance test.
DOE O XXX.X, Information Security
Information Security Standard Operating Procedure #
PF Standard Operating Procedure #
PF Post Order #
SURVEY TEAM LEADER:
DATE:
(Signature of Approval)
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4.0 TOPICAL AREA TOOLS
This section contains items that can be used to assist team members in conducting surveys and self-
assessments by providing a series of guidelines, including:
(1) subtopical areas,
(2) areas of consideration
(3) sample documents list,
(4) sample interview candidates,
(5) suggested interview questions.
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A. PROGRAM MANAGEMENT OPERATIONS
Subtopical Areas to Program Management Operations
A.1 PROTECTION PROGRAM MANAGEMENT
Program Management and Administration
Resources and Budgeting
Personnel Development and Training
A.2 SAFEGUARDS AND SECURITY (S&S) PLANNING AND PROCEDURES
A.3 MANAGEMENT CONTROL
Surveys and Self-Assessment Programs
Performance Assurance Program
Resolution of Findings
Incident Reporting and Management
A.4 PROGRAM-WIDE SUPPORT
Facility Approval and Registration of Activities
Foreign Ownership, Control, or Influence (FOCI)
Security Management in Contracting
Areas of Consideration
The topical area team should research answers to the following types of questions during the
course of document reviews. Answers to questions such as these may help to focus and
streamline survey activities.
Is the organization adequately staffed to accomplish its mission?
Are there any vacant positions? If so, how long have they been vacant?
Do personnel perform the duties stated in their job descriptions?
Are job descriptions current and reviewed periodically?
Are personnel adequately trained to perform their assigned duties?
Is there a formal training program in place?
Are training programs based on the results of job task analysis?
Has funding been allocated for training?
Who maintains the organizations training records?
Has there been an analysis of the job skills needed to fulfill each assigned
Section 35
responsibility? Has this been documented in individual job descriptions?
Is succession planning considered when training staff?
Has management established an effective and efficient organization structure?
Is the organization structure documented in writing?
Are there indications of frequent change in the organizational structure?
Have responsibilities been explicitly assigned to individuals?
Are lines of communication, accountability, and authority clear?
Is there a formal, coordinated effort regarding the development, approval, and updates
associated with facility/site security plans?
Do security plans reflect security operations actually occurring at a facility?
Is there a process in place to ensure S&S plans are reviewed and updated in a timely
manner when changes to operating conditions occur?
Is expertise available to provide a meaningful review of security plans and procedures?
Are security plans supported by sufficient analysis to establish that protection
requirements will be met?
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Is documentation available for vulnerability assessments (VAs) and/or other tests and
analysis used to establish the requirements for specific security measures and
equipment?
Are there any equivalencies or exemptions from DOE requirements in place at the
facility? Are there any deviations from national requirements?
What methodologies are used for site VAs?
Are these methodologies adequate to evaluate the site’s vulnerabilities in light of the
operational environment?
How is the contractor performing and what criteria are used to evaluate performance?
Who has input into the award fee process?
How is the criteria “weighted” and by whom?
Are there areas requiring improvement? If so, what are they?
What were the ratings given during past surveys and self-assessments?
Is there a trend?
Have all areas been reviewed?
Is there a corrective action tracking system in place? If so, does it cover the entire site/facility?
Does this tracking system for findings include all periodic surveys, self-assessments,
Technical Surveillance Countermeasures (TSCM) services, and DOE review findings?
Are the milestones for completing the corrective actions reviewed on a recurring basis?
What types of cause analyses are completed on corrective action plans?
Is staff trained to conduct root cause analyses? If so, who provides training?
Are there any inquiries currently open?
Have any staff members conducted inquiries into incidents of S&S concern? Were
these individuals appointed in writing?
Have any inquiries established any possible crimes or fraud, waste, and abuse?
Have there been any formal inquiry reports developed?
Was it determined that any damage assessments were required?
If a damage assessment(s) was conducted, who appointed the damage assessment
team(s) and approved the damage assessment report(s)?
How many incidents of S&S concern have occurred since the last survey?
Of those incidents, how many were known compromises and how many were potential
compromises?
Have all applicable security requirements been incorporated into the contract?
What is the process for incorporating new directives into the site contract?
How are new directives incorporated into daily implementation for site-related DOE
organizations?
Has the incorporation of any directives been unduly delayed?
Are all equivalencies and exemptions correctly characterized?
Section 36
Are there any Strategic Partnership Projects being performed at the facility?
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A.1 PROTECTION PROGRAM MANAGEMENT
Subtopical Areas to Protection Program Management
Program Management and Administration
Resources and Budgeting
Personnel Development and Training
Sample Document List:
Document review in this area is key to understanding how the S&S organization functions. The
following types of documents should be carefully reviewed and validated:
Organization diagrams depicting the management structure
Functions, Responsibilities and Authorities Manual, Safeguards and Security
Management Plan, delegations of authority, and/or other documents depicting assigned
roles, responsibilities, and authorities
Position descriptions for S&S management positions
Operating instructions for the implementation of S&S programs
Supplemental documents and plans implementing S&S programs
Training records for personnel with S&S responsibilities
Contract documentation (which directives are applicable to the organization being
surveyed)
Budget documentation
Training plans and procedures
Overall training process and training record system (is there one program?)
Certification records for specialized jobs (material control and accountability [MC&A]
measurements, armorers, locksmiths, etc.)
Documentation of VAs and related tools used in preparation of the facility/site security
plan, i.e., ASSESS/ATLAS, JCATS, etc.
Copies of active equivalencies and exemptions
Survey and self-assessment reports for the last two years
The existence of other documents, which further delineate the management of the S&S program,
may be derived from the review of these initial documents.
Documents should be used as the basis for determining whether management supports the S&S
program in a manner that demonstrates both compliance with the requirements and a commitment
to performance that assures the adequate protection of national security assets.
Sample Interview Candidates:
Interview candidates may include:
DOE Operations/Field/Area Office Manager
DOE Assistant Manager or Director responsible for S&S
Individual DOE S&S Operational Program Managers
DOE and contractor management assigned responsibility for developing and
implementing this element of the S&S program
Contracts and Procurement Department management
Budget and/or Finance Department management
Human Resources Department management
Security managers assigned responsibility for developing and implementing the S&S
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programs
Property management
Emergency management
Training management
Contractor Program Managers/Coordinators responsible for S&S training activities
(including protective force)
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
Have resources been prioritized based on impact to mission? Have budgets been
allocated in accordance with this prioritization?
Has management established an effective and efficient organizational structure?
Is a system in place to ensure integration is occurring at the necessary levels to establish
and maintain an effective overall S&S program?
How have performance measures been communicated?
Does the program lack visibility or support at any level?
Is the organization aligned to ensure proper communication and integration? Does this
Section 37
alignment minimize fragmentation of the program?
Are staffing levels adequate to support the organization structure and to fulfill functional
requirements?
Have responsibilities been explicitly assigned to individuals?
Are all the positions filled? If not, how long have they been open?
Are personnel qualified and trained for their positions?
Are major tasks and skill requirements documented in individual job descriptions?
Are personnel qualified to perform their oversight responsibilities?
Is there a formal training program in place? Do all training programs meet established
standards?
Has a formal training process been developed to ensure all personnel who need the
training receive the training?
Are training methodologies and courses standardized and tailored to specific duties and
responsibilities?
Are training programs based on the results of job task analysis?
Has funding been allocated for training, equipment, and supplies?
Who maintains the organizations training records?
Is performance-based testing used?
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A.2 SAFEGUARDS AND SECURITY PLANNING AND PROCEDURES
Subtopical Areas to Safeguards and Security (S&S) Planning and Procedures
None
Sample Document List:
The following are representative of the documents that should be reviewed:
Facility/Site Security Plan and, where several facilities have been consolidated into a site,
any subordinate facility plans which have not been consolidated into or replaced by the
site security plan
Approved or pending equivalencies and exemptions with supporting documentation
Safeguards and Security Information Management System (SSIMS) reports
Emergency plans
Contingency plans
Local procedures
Material Control and Accountability plans
S&S training plan
Survey and inspection reports
Update projects and current compensatory measures
Data from evidence files
Current compensatory measures
The survey team should be thoroughly familiar with the purpose of each document reviewed.
The requirement for the document should be compared with the finished product, and an
assessment made of the adequacy of the document in complying with the requirement.
Sample Interview Candidates:
Interview candidates may include:
DOE Operations/Field/Area Office Manager
DOE Assistant Manager or Director responsible for S&S
DOE Division Director(s) responsible for S&S-related activities and plans
Individual DOE S&S Program Managers
Contractor Senior Management with line responsibility for S&S activities and plans
Contractor S&S Director
Contractor Program Managers responsible for S&S SP/Vulnerability Assessment (VA)
data
Personnel responsible for developing the various S&S plans
Protective Force managers
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
How does the facility determine the contents of the security plan?
Is there a local procedure for developing the facility/site security plan?
What is the protection strategy used at this facility?
Is the Graded Security Protection Policy (GSP) used for addressing threats? If not, is this
approved in writing? What basis is used if the GSP is not applicable?
What equivalencies/exemptions are in place? When were they approved and by whom?
Have they been entered in SSIMS and documented in the facility/site security plan?
How do equivalencies/exemptions impact protection strategy?
Are any S&S plans currently being updated? If so, why?
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What process is used for reviewing, approving, and/or updating major S&S plans? Is this
process documented?
Is expertise available to provide a meaningful review of S&S plans and procedures?
How is integration of major S&S plans ensured?
Who is responsible for maintaining the analytical data and details of assessment activities
supporting the security plan?
Are VA documents and validation results from performance tests reviewed during the
update process or are data obtained from new sources?
How are changes in policy and/or procedures communicated to those with implementing
responsibilities?
How has management effectively established program direction?
What is the process used for procedure development/update/approvals?
How are inspection/survey results used by management to evaluate the effectiveness and
viability of S&S plans?
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A.3 MANAGEMENT CONTROL
Subtopical Areas to Management Control
Surveys and Self-Assessment Programs
Performance Assurance Program
Resolution of Findings
Incident Reporting and Management
Sample Document List:
Documentation to be reviewed may include the following:
Survey and self-assessment program plans and schedules
Incidents of Security Concern (IOSC) plans and implementing procedures
Survey and self-assessment reports
Corrective action plans and tracking systems (information derived from)
Site specific survey/self-assessment guides and procedures
IOSC inquiry reports and status reports
IOSC trending and analysis
IOSC corrective action plan packages
Inquiry Official appointment letters
Damage assessments
Vulnerability Assessment (VA) test data
List of open/closed finding for past three to five years (review for recurring findings)
Copy of the approved Performance Assurance Program Plan
List of essential elements documented in the Performance Assurance Program and the
testing schedule for each
Performance assurance test procedures
Performance assurance test reports and subsequent correction actions
Sample Interview Candidates:
Interview candidates may include:
DOE management
Safeguards and Security (S&S) Division Directors, if appropriate
DOE Division Director(s)
Individual DOE S&S Program Managers
Contractor S&S Director
Contractor Program Managers
Personnel responsible for VA testing and security plan development
Protective Force Managers
IOSC Inquiry Officials
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
Are survey and self-assessment programs in place to determine the effectiveness of the
S&S program? Are procedures applicable to the programs documented in the facility/site
security plan?
When was the last self-assessment conducted? Did it include all applicable topical and
subtopical elements? Was a formal report prepared and submitted?
Are corrective actions identified in surveys and self-assessments implemented in a timely
and effective manner?
What ratings were given in previous surveys/self-assessments?
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Have recent survey or self-assessment activities resulted in any repeat findings?
What is the status of open findings? What is the status of the associated corrective action
plans?
What method of cause analysis is used? What training has staff received?
Are the results of surveys and self-assessments factored into performance measures or
Section 39
award fees?
For self-assessments, is there a system in place for tracking findings and corrective
actions? If so, does it cover the entire site/facility?
Are survey findings entered in SSIMS?
Are the milestones for completing the corrective actions reviewed on a recurring basis?
Have staff members conducted inquiries into incidents of security concern? Were these
individuals appointed in writing?
What kind of trending and analysis is performed on IOSCs? How are the results
disseminated to management & staff?
What kind of IOSC awareness is provided?
Are incidents involving individuals applying for or holding a security clearance reported
to the appropriate personnel security office?
How are corrective action plans coordinated with management?
Have any inquiries established any possible crimes or fraud, waste, and abuse?
Are there inquiries currently open?
Have there been any formal inquiry reports developed?
Was it determined that any damage assessments were required?
If a damage assessment(s) was conducted, who appointed the damage assessment team(s)
and approved the damage assessment report(s)?
Have any incidents of security concern occurred since the last survey? If so, how many?
Were the incidents appropriately categorized and reported?
Were the appropriate notifications made for each incident?
Does the facility IOSC program plan specify Management Interest (MI) incidents and
identify them by category?
Does the facility maintain a central record of all inquiries into incidents of security
concern and damage assessments? If not, in what manner are those records being
maintained that facilitates their retrieval and use within the facility (e.g., for tracking and
oversight purposes)?
How long are records maintained?
What training do staff receive prior to conducting inquiries?
Is there a formal process for implementing a performance assurance program?
How often is testing conducted? Are both operability tests and effectiveness tests
included?
Who reviews and approves the Performance Assurance Program Plan? Does the plan
identify the essential elements relevant to the site and describe how they were
determined?
Who determines what tests will be conducted and the criteria for evaluation? What is the
basis for this determination?
How are the results of tests documented and analyzed? Are issues requiring corrective
action documented and tracked until resolved?
Are appropriate compensatory measures taken immediately when unsatisfactory test
results indicate that national security or health and safety are jeopardized?
Are performance assurance plans reviewed and updated appropriately?
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A.4 PROGRAM-WIDE SUPPORT
Subtopical Areas to Program-Wide Support
Facility Approval and Registration of Activities
Foreign Ownership, Control, or Influence (FOCI)
Security Management in Contracting
Sample Document List:
Documentation to be reviewed may include the following:
Current contract(s) including statement of work, DOE directives incorporated into the
contract (including those pending), and security clauses
List of all subcontractors and consultants conducting work for the contractor being
surveyed (list of all contractors/subcontractors registered)
Approved facility/site security plan (SP)
Facility data sheets
Copy of current award fee criteria and award fee documentation (including performance
Section 40
measurement data) for the last two years
Most recent FOCI determination, including copies of any applicable FOCI mitigation
instruments and National Interest Determinations (NID)
Approved Contract Security Classification Specification (CSCS) F 470.1
Signed Facility Data and Approval Record (FDAR) F 470.2
Equivalencies/exemptions to DOE directives (pending and approved)
Master facility registration, in the Safeguards and Security Information Management
System, and local facility registration listings (if used)
Previous survey and inspection reports and self-assessments
List of cleared personnel, including access authorization number and date of latest
background investigation, by contract (including all contractors that have cleared
employees conducting work at the facility). This list can come from the DOE Central
Personnel Clearance Index (CPCI) of access authorizations held by the contractor. The
CPCI and contractor lists, including the list of current key management personnel (KMP),
should be compared for discrepancies.
Internal procedures (facility clearance, FOCI)
Applicable Memoranda of Understanding/Agreement (e.g., MOA documenting
responsibilities of DOE and a cognizant other government agency (OGA) for reciprocity
of a specific FCL)
Most recent SF 328, Certificate Pertaining to Foreign Interests
Most recent list of KMP
A list of all employees of the company possessing or in the process of obtaining DOE
access authorizations who are Representatives of Foreign Interests (RFIs)
A list identifying any Strategic Partnership Projects (formerly called Work for Others)
conducting work at the facility
A copy of the contractor's records of all contracts and subcontracts involving access
authorizations
A copy of the contractor's procedures for reporting events that have an impact on the
status of the facility clearance, and copies of reports filed since the last survey or self-
assessment.
Company visitors log
Loan or credit agreements (if applicable) to determine if any power has been granted the
lender. For each identified loan or credit agreement, obtain the names, country location,
and participation amount of each of the lenders involved, as well as the aggregate amount
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of the loan or credit agreement.
Board of Director's meetings minutes to determine if any actions taken by the Board
resulted, or will result, in changes that should be reported to DOE
Copies of all Schedules 13D and 13G submitted to the Securities and Exchange
Commission (SEC), if publicly traded
Annual report and/or financial statement of the company
Shareholders’ agreements to determine if amount of stock is sufficient to elect
representation to the Board or an agreement exists whereby the shareholder(s) is
permitted representation on the Board, currently or at a future date
Proxy statements (Notice of Annual Meeting of Stockholders) to determine (1) current
beneficial owners of 5% or more of the company's securities; (2) changes to the
company's directors; and (3) changes in location of its principal executive offices, state of
incorporation, or the company's business, management, proposed mergers
Annual report and SEC Form 10-K Report to determine (1) changes in revenue/income
derived from foreign interests; (2) loan or credit agreements entered into with foreign
lenders or in which foreign lenders are participants; and (3) joint ventures/contracts with
foreign interests
Section 41
Internal Revenue Service Form 5471, Information Return of U.S. Persons with Respect to
Certain Foreign Corporations to determine whether all foreign holdings were reported
Articles of Incorporation and By-Laws or Partnership Agreement to determine if any
changes have been made to the company's/partnership's business, management.
NOTE: The following reflects which of the above-mentioned documents apply to the different
types of business entities:
- Sole proprietor, divisions of a legal entity, or self-employed consultant –
none of the above documents would apply, except negative covenants in
loan or credit agreements
- Publicly traded – all of the above documents
- Privately owned – under normal circumstances, none of the documents
would be required. However, if the company has issued bonds or
debentures, it is required to file a Form 10-K Report with the SEC.
Sample Interview Candidates:
Interview candidates may include the following:
DOE Safeguards and Security (S&S) Division Director, if appropriate
DOE and Contractor Contracts and Procurement Managers
DOE S&S Program Managers
Contractor S&S Director
Contractor S&S Program Managers
Facility Security Officer (FSO)
Facility Procurement and Contracting Officer – Point-of-contact for records of all
contracts and subcontracts
Corporate Secretary – Point-of-contact for the organization's owners; any changes that
may have occurred in the company's business, management, or ownership of
subsidiary/parent (i.e., the creation of an intermediate parent); and information on
whether the company has acquired ownership in foreign corporations
Chief Financial Officer or Treasurer – Point-of-contact for information on
revenue/income derived from foreign interests, and loan or credit agreements entered into
with foreign lenders
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Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
Have all applicable DOE directives been incorporated into contracts as appropriate? Are
there any pending incorporation?
Have all applicable security clauses been incorporated into contracts as appropriate?
What is the process for ensuring contracting officers are made aware of security
considerations?
How are contracting officers informed of the security requirements to be included in a
contract?
Who has input into the award fee process?
How are the award criteria 'weighted' and by whom?
Are facility clearance and FOCI procedures documented in the facility/site security plan?
Are facility clearances granted prior to allowing DOE S&S interests on the premises of
the facility? Have all the DEAR requirements for approval of a facility clearance [48
CFR 952.204-73(c)] been met?
Have the contractor and subcontractors been given favorable FOCI determinations? Are
any of them under FOCI mitigation?
Does the facility have an approved security plan?
Is the FSO’s access authorization equivalent with the facility clearance?
Has an FDAR been completed and approved?
Has a CSCS form been completed for all activities?
Has a FOCI determination been made on all contractors and subcontractors that require
access authorizations?
Do the contractor and subcontractor provide notifications of any changes that may affect
the FOCI determination?
Do the key management personnel have appropriate access authorizations? If not, have
Section 42
appropriate exclusion actions been taken?
Have there been any changes in information reportable under any question on the SF
328? If so, were the changes reported as required?
Has there been a change in a previously reported foreign ownership threshold or factor
that was previously favorably adjudicated?
Have there been any changes in ownership or control, including stock transfers that affect
control of the company?
Did the location of the company’s principal executive offices change?
Have the Articles of Incorporation and By-Laws or Partnership Agreement changed?
Have anticipated changes and other reportable changes (e.g., changes to KMP
information) been identified and reported as required?
Have Strategic Partnership Projects (Work for Others) been registered in SSIMS?
Has information concerning classification and protection information been exchanged for
all Strategic Partnership Projects between the DOE activity and the requesting agency?
Are the exchanges documented?
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B. PROTECTIVE FORCE
Subtopical Areas to Protective Force
B.1 MANAGEMENT
B.2 TRAINING
B.3 DUTIES
B.4 FACILITIES AND EQUIPMENT
Areas of Consideration
The topical area team should research answers to the following types of questions during the
course of document reviews. Answers to questions such as these may help to focus and
streamline survey activities.
How are all aspects of the protection program adequately integrated to ensure effective
protection?
How does the overall protection system operate to accomplish its routine and emergency
tasks?
What protection strategy is used?
Does documentation accurately reflect current conditions and configurations of the facility?
Does the facility/site security plan accurately describe security operations at the location?
Does the security plan accurately reflect current site assets and security interests and
describe how the protection program is managed?
Are equivalencies/exemptions in place at the facility? Are they approved and entered in
SSIMS? Have they been incorporated into site procedures?
What are the assets of the site/facility?
Where are they located?
What is the importance level?
Are all assets identified in the facility/site security plan?
Are the assets readily identifiable by the PF?
Is there an approved acceptance and validation testing program in place that encompasses
security-related components and subsystems?
How is it implemented?
Are compensatory measures implemented immediately when any part of the critical
system is out of service?
How are Security Police Officers notified in case of system failure?
Are protection strategies for the protection of special nuclear material (where applicable) and
vital equipment adequately addressed in site planning documents?
Has a performance assurance program been fully implemented at the facility?
Are recapture, recovery, and pursuit strategies documented?
Are programs designed to mitigate the consequences of radiological/toxicological
sabotage in place?
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B.1 MANAGEMENT
Subtopical Areas to Management
None
Sample Document List:
Documentation to be reviewed may include:
Facility/Site Security Plan (SP)
Approved or pending equivalencies and exemptions
Staffing plans
Budget documents
Overtime allocations
Vulnerability Assessment (VA) data
Human Reliability Program (HRP) criteria and list of staff assigned to HRP positions
Response plans
Recent findings and associated corrective action plans
General, Post, and Special orders
Section 43
Sample Interview Candidates:
Interview candidates may include the following:
Protective Force (PF) Manager
DOE Safeguards and Security (S&S) Director
PF Training Coordinator
Individuals responsible for the VA data
Special Response Team Lead
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
How much of the staffing budget is allocated to overtime?
How does interface/integration with other S&S organizations occur?
Is the data contained in the security plan/VA an accurate reflection of site operations?
What could be changed that would improve the overall protection strategy?
How could technology be used to improve the security posture?
What is the current PF strength? Armed and unarmed?
What memoranda of understanding/agreement are currently in place? Are others in
process?
What is the supervision ratio? Is it adequate?
What is the process for selection of supervisors? What qualifications are necessary?
What is the process for developing, updated, and maintaining procedures?
How are changes in procedures communicated?
How many PF personnel are in the HRP?
What are the criteria for participation in HRP?
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B.2 TRAINING
Subtopical Areas to Training
None
Sample Document List:
Documentation to be reviewed may include:
Annual Protective Force (PF) Training Plan
Staffing plans
Job Task Analyses (JTAs)
Overtime allocations
Training records (including a list of PF personnel who are subject to weapons
qualification within 90 days of the start date of the survey and a list of PF personnel who
are medically certified to participate in the physical fitness program
Training materials (rosters, curriculum, tests)
Site-specific risk analysis for lesson plans
List of PF instructors and their certifications
List of Special Response Team instructors and their certifications
List of firearm instructors and their certifications
List of standard equipment issuance
General, Post and Special orders
Description of training records system in use
Recent findings and associated corrective action plans (including documented root cause)
relevant to this topic
Sample Interview Candidates:
Interview candidates may include:
PF Manager
DOE Safeguards and Security Director
PF Training Coordinator
Individuals responsible for Vulnerability Assessment data
Instructors
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
How many personnel have failed to pass fitness qualifications during the survey period?
How many personnel have failed their firearms qualifications during the survey period?
What type of remedial training is required for failing?
How many instructors have been certified through the National Training Center?
What types of training facilities are used?
Have JTAs been completed for all identified positions? Have all essential components
been included?
What are the strengths and weaknesses of the training program?
Are JTAs site-specific?
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B.3 DUTIES
Subtopical Areas to Duties
None
Sample Document List:
Section 44
Documentation to be reviewed may include the following:
Facility/Site Security Plan (SP)
Approved Job Task Analyses
Staffing plans
Overtime allocations
List of standard equipment issued
Protective Force schedules and post assignments
Memoranda of understanding/agreement affecting duties/response
General, Post, and Special orders
Shipment security plans and procedures
Emergency response plans
List of critical targets
Special Response Team (SRT) rosters
Security Incident Response Plan
Recent findings and associated corrective action plans relevant to this topic
Security lock and key control procedures
Sample Interview Candidates:
Interview candidates may include the following:
PF Manager
DOE Safeguards and Security (S&S) Director
PF Training Coordinator
Individuals responsible for Vulnerability Assessment data
PF Operations Manager
SRT personnel
Security Officers, Security Police Officers
Facility's designated responders (as described in the Emergency Response Plan)
Emergency Operations Center (EOC) personnel responsible for response and recovery
Warehouse personnel (shipment preparations)
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
How are compensatory measures determined? Relayed to PF?
What are the critical targets associated with this facility? How are they recognized?
How are communication channels determined to be effective (both internal to the PF
organization and external to its counterparts)?
What role does the EOC play during shipments?
When was the last Force-on-Force exercise conducted?
How are changes in operations (e.g., material movements, compensatory measures,
increase threat levels) communicated?
How are changes to policies and procedures transmitted? Who is responsible for
ensuring Post Orders are approved and current?
How are security locks and keys controlled within the PF?
What are the critical targets at this facility? What training is provided relative to the
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identification of critical targets? Who has received this training and what are the criteria?
B.4 FACILITIES AND EQUIPMENT
Subtopical Areas to Facilities and Equipment
None
Sample Document List:
Documentation to be reviewed may include the following:
Facility/Site Security Plan (SP)
Equivalencies and exemptions
Staffing plans
Budget documents
Overtime allocations
List of standard equipment issued and instructions for use
Protective Force (PF) schedules and post assignments
Memoranda of understanding/agreement affecting duties/response
General, Post and, Special orders
PF weapons and ammunition inventories
Equipment maintenance logs (including weapons)
Recent findings and associated corrective action plans relevant to this topic
Security Incident Response Plan
Sample Interview Candidates:
Interview candidates may include the following:
PF Manager
DOE Safeguards and Security Director
PF Training Coordinator
Individuals responsible for Vulnerability Assessment data
PF Operations Manager
Special Response Team (SRT) personnel
Armorers
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
What are the critical targets associated with this facility? How are they recognized?
Where are they located?
Are communication channels effective (both internal to the PF organization and external
Section 45
to its counterparts)?
Is the PF equipped to meet its mission?
Are training facilities adequate?
Are modifications in equipment or facilities anticipated? If so, when and why?
Has there been a change in mission that would affect the appropriateness of equipment
used in the protection strategy at this facility?
Are the vehicles used at this facility suitable and reliable to meet the mission?
Have any issues associated with maintenance or functioning of equipment been
identified? If so, has corrective action been taken?
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C. PHYSICAL SECURITY
Subtopical Areas to Physical Security
C.1 ACCESS CONTROLS
C.2 INTRUSION DETECTION AND ASSESSMENT SYSTEMS
C.3 BARRIERS AND DELAY MECHANISMS
C.4 TESTING AND MAINTENANCE
C.5 COMMUNICATIONS
Areas of Consideration
The topical area team should research answers to the following types of questions during the
course of document reviews. Answers to questions such as these may help to focus and
streamline survey activities.
How are aspects of the protection program integrated to ensure effective protection?
How does the overall protection system operate to accomplish its routine and emergency
tasks?
What protection strategy is used?
Does documentation accurately reflect current conditions and configurations of the facility?
Does the facility/site security plan (SP) accurately describe operations at this facility?
Does the facility/site security plan accurately reflect current site assets and security interests?
Does the SP accurately describe current site physical protection elements and systems?
Are equivalencies/exemptions in place at the facility? Are they supported by appropriate
VA or risk assessment? Have they been appropriately approved, entered in SSIMS, and
incorporated into the affected security plans?
Does the site have an approved, current Response Plan for security emergencies?
Does the site have an approved, current Compensatory Measures document?
What are the assets of the site/facility?
Where are assets located?
What is the impact of theft and/or diversion?
Are all assets identified in the facility/site security plan?
Is an approved verification and validation testing program in place that encompasses security-
related components and subsystems?
How is it implemented?
Are there documented procedures?
Are compensatory measures implemented immediately when any part of the critical
system is out of service?
How are repairs initiated when a system element fails?
Is the response to alarms and/or system failures documented?
Are protection strategies for the physical protection of special nuclear material, classified matter,
and vital equipment adequately addressed in site planning documents?
How are the Graded Security Protection (GSP) Policy, local threat guidance, and
Vulnerability Assessment used in protection and control planning?
Are recapture, recovery, and pursuit strategies documented?
How are programs designed to mitigate the consequences of radiological/toxicological
sabotage?
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Are there agreements with local agencies in place for assistance and/or notification ?
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C.1 ACCESS CONTROLS
Subtopical Areas to Access Controls
None
Sample Document List:
Documentation to be reviewed may include:
Lock and key records and procedures including storage, lock and key issuing, and
custodian responsibilities
Automated access control system records and procedures (including biometric access
Section 46
input as well as access credentials, issuance of keycards, tokens, etc.), System
Administrator responsibilities, and performance testing and maintenance
Property control and removal procedures, records, and issuance criteria
Contraband searches during entry or exit
Access control procedures, access lists/logs, and personnel training
Visitor logs
Performance testing plans and procedures, records of past performance tests
Documents identifying security areas and S&S interests
Termination/transfer procedures and notifications
Building plans and protection area diagrams
Comparison of Human Reliability Program (HRP) data with access control data
Badge control procedures and automated system descriptions
Date of last badge inventory and results (including issued, lost, recovered, destroyed)
Sample Interview Candidates:
Interview candidates may include the following:
Security staff and management assigned responsibility for developing and implementing
the Physical Security program
Receptionist/employee controlling access to facility
Access Control personnel
Personnel assigned to monitor portals
Personnel performing inspections of vehicles and hand-carried items
Personnel responsible for key control and automated access control systems
Locksmiths
Property Management personnel
Maintenance personnel
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
What types of access control systems are used at the facility (e.g., receptionists, badge
readers)?
How are various functions notified of terminations and transfers?
What policies are in place to ensure timely termination of access through retrieval of keys
and access credentials upon termination or transfer?
Have building lock-up procedures been established?
How are records secured, maintained, and retrieved?
Who performance-tests the systems, and how are the records kept?
What happens in the event of an unsuccessful test or system failure?
Are there well defined search system policies and calibration specifications for personnel
and vehicle searches?
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Is there a documented process for ensuring access is terminated as appropriate (e.g., HRP
status changes, clearances terminated, employees terminated)?
How is the site badging system equipment secured after hours?
Have auxiliary power sources been provided to all critical systems? What are the testing
and maintenance procedures for ensuring auxiliary power is available?
What type of temporary badge system is used at the facility?
What types of records are maintained relative to badging?
Are unused badges protected to prevent unauthorized use, theft, or loss?
Do the site procedures address badge recovery after an employee’s termination?
Are lost badges being handled according to appropriate procedures?
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C.2 INTRUSION DETECTION AND ASSESSMENT SYSTEMS
Subtopical Areas to Intrusion Detection and Assessment Systems
None
Sample Document List:
Documentation to be reviewed may include the following:
Facility/site security plan
Physical security system description(s) and location(s)
Maintenance and testing records and procedures
Alarm reports, including false and nuisance alarms
Calibration and testing procedures and records
Central Alarm Stations (CAS)/Secondary Alarm Station (SAS) procedures
Emergency response for CAS/SAS recovery
Emergency power systems (uninterruptible power supply system) certification and
Section 47
maintenance logs
Compensatory procedures for equipment outages
Limited scope performance test results
IDS Analysis and Evaluation Report
During the course of document reviews, the survey team should try to validate that (1) physical
security systems logs are maintained, (2) system tests are being performance-tested and
documented as required, (3) system maintenance is being performed and documented as required,
and (4) procedures are comprehensive.
Sample Interview Candidates:
Interview candidates may include the following:
Safeguards and Security staff responsible for security systems
Security Police Officers and Security Officers
Engineers (involved with security systems)
Alarms maintenance/installation and testing personnel
CAS/SAS management
CAS/SAS operators
Protective Force Managers
Emergency management planners
User personnel responsible for walk-testing or other performance testing of alarm
systems
Maintenance personnel
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
Are approved equivalencies/exemptions in place or pending? Have approved
equivalencies/exemptions been entered in SSIMS and documented in the facility/site
security plan? Have they been incorporated in site procedures?
Are any line-item construction projects associated with physical security systems? If so,
when were they last reviewed and who conducted the review?
Is there a documented Testing and Maintenance Plan?
How well is the physical security system program functioning?
Is equipment calibrated according to documented specifications?
Are response times consistent with those documented in security plans and Vulnerability
Assessment?
What areas of the system could be improved, and what steps have been taken toward the
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improvements?
Does the site have policies and procedures for the installation, alignment and calibration
of intrusion detectors?
Are there appropriate anti-tampering devices on primary and backup power sources for
intrusion detection equipment?
Are there a minimum of false or nuisance alarms that can be verified by documentation?
Do the site systems have power backups, tamper protection devices, etc.?
What strengths did the IDS analysis and evaluation identify? What weaknesses were
identified? What was the cause and what corrective actions have been implemented?
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C.3 BARRIERS AND DELAY MECHANISMS
Subtopical Areas to Barriers and Delay Mechanisms
None
Sample Document List:
Documentation to be reviewed may include the following:
Facility/Site security plan and Vulnerability Assessment (VA) data
Performance assurance test plans, procedures, and results
Post Orders
Critical target lists and locations
Physical security system description(s) and location(s)
Maintenance and testing records and procedures
Alarm reports
Calibration and testing procedures and records
Central Alarm Station (CAS)/Secondary Alarm Station (SAS) procedures
Emergency power systems (uninterruptible power supply system)
Compensatory procedures for equipment outages
Lock and key control procedures and inventory results
Sample Interview Candidates:
Interview candidates may include the following:
Safeguards and Security staff responsible for security systems
Security Police Officers and Security Officers
Engineers (involved with security systems)
Alarms maintenance/installation and testing personnel
CAS/SAS Management/Operators
VA staff
Emergency management planners
Lock and Key Administrator
Section 48
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
Are approved equivalencies/exemptions in place or pending?
Are any line-item construction projects associated with physical barriers? If so, when
were they last reviewed and who conducted the review?
Is there a documented Testing and Maintenance Plan for barrier systems?
How well are automated barrier systems functioning?
Is equipment calibrated according to documented specifications?
Are response times consistent with those documented in security plans and VAs?
What areas of the system could be improved, and what steps have been taken toward the
improvements?
What technologies could be deployed at this facility to enhance the overall protection?
How often are key inventories conducted? How are discrepancies resolved and what are
the reporting requirements?
Are the barriers at the site commensurate with the risk?
Are the barriers designed to provide for adequate delay time to allow for appropriate
response?
Are the barriers at SNM areas, vaults, and MAA perimeters sufficient to ensure SNM
cannot be removed?
Do the security containers meet all required DOE and other standards?
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C.4 TESTING AND MAINTENANCE
Subtopical Areas to Testing and Maintenance
None
Sample Document List:
Documentation to be reviewed may include the following:
Performance assurance test plans, procedures and results
Post Orders
Physical security system description(s) and location(s)
Maintenance and testing records and procedures
False Alarm Rate (FAR)/Nuisance Alarm Rate (NAR)
Calibration procedures and records
Central Alarm Station (CAS)/Secondary Alarm Station (SAS) procedures
Emergency power systems (uninterruptible power supply system)
Compensatory procedures for equipment outages
Inspection procedures
Sample Interview Candidates:
Interview candidates may include the following:
Safeguards and Security staff responsible for security systems
Security Police Officers and Security Officers
Engineers (involved with security systems)
Alarms maintenance/installation and testing personnel
CAS/SAS Management
CAS/SAS Operators
Other personnel responsible for monitoring/clearing alarm indications
Protective Force Managers
Emergency management planners
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
What is the process for implementing compensatory measures if a system fails?
Is any trend analysis of maintenance requests being conducted for security
equipment/systems?
How is information coordinated between the organization responsible for testing and
maintenance and the user organization?
Is any testing and maintenance of security systems completed by vendors? If so, what
mechanisms are in place to ensure appropriate access authorizations are held if required?
Who performs the periodic testing (technicians, custodians, or security personnel)?
How are the records maintained and/or retrieved?
Is the testing proceduralized, and how are personnel trained to the procedures?
Are maintenance personnel qualified by the equipment vendor to perform repairs?
What is required to put the system back in service after maintenance and/or repair?
Does the site have a training and qualification requirement for security technicians?
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C.5 COMMUNICATIONS
Section 49
Subtopical Areas to Testing Communications
None
Sample Document List:
Documentation to be reviewed may include the following:
Performance tests of communication equipment
Protective Force (PF) Post Orders
PF General Orders
Facility/site security plan and any Vulnerability Assessments
Description of communication equipment, its location and test documentation
Types of communication equipment issued to PF
Shipment procedures
Sample Interview Candidates:
Interview candidates may include the following:
PF Members
Safeguards and security staff responsible for communication systems
Alarms maintenance/installation and testing personnel
Central Alarm Station (CAS)/Central Alarm Station (SAS) personnel
Special Response Team members
Emergency management planners
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
How many channels are used on the PF radio system, and is this adequate?
Do the PF channels have priority?
Can non-PF radios eavesdrop on PF channels?
How are PF radios issued/controlled?
When was the last time your communication systems were upgraded and why?
Are PF radios equipped with an encryption capability?
Are there radio duress alarms, and how often are they tested?
Are alternate means of communication available, and what are they?
Is there an anti-jamming capability, and/or jamming detection?
Can a single radio be identified and disabled by the CAS/SAS operator?
How are the repeater towers protected?
What compensatory actions are taken when radio communication is unavailable?
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D. INFORMATION PROTECTION
Subtopical Areas to Information Protection
D.1 BASIC REQUIREMENTS
D.2 TECHNICAL SURVEILLANCE COUNTERMEASURES (TSCM)
D.3 OPERATIONS SECURITY (OPSEC)
D.4 CLASSIFICATION GUIDANCE
D.5 CLASSIFIED MATTER PROTECTION AND CONTROL (CMPC)
Control of Classified Matter
Special Access Programs and Intelligence Information
Areas of Consideration
The topical area team should research answers to the following types of questions during the
course of document reviews. Answers to questions such as these may help to focus and
streamline survey activities.
Is there a formal, coordinated effort regarding the implementation and management of the CMPC
program?
Have procedures been developed and approved for all aspects of the CMPC program,
(i.e., generation, transmission, reproduction, dissemination, destruction)?
Have control stations been established and are employees properly trained for their
duties?
Do the facility/site Security Plan and other planning documents adequately address
CMPC?
Has adequate training been provided to custodians and key personnel?
How is classification guidance disseminated?
Does the facility have Derivative Classifiers (DCs) appointed in writing?
Have DCs received required training?
Is current classification guidance on hand for each of the facility’s classified projects?
Does the facility have Special Access Programs (SAPs)?
Have the SAPs been properly registered in accordance with the applicable DOE policy?
Do all persons having access to SAPs have proper clearance and briefings?
Are there specific security plans and operating procedures associated with SAPs?
How are DOE-HQ guidance and directives distributed?
Are affected documents updated in a timely manner as guidance/direction is received?
Section 50
What ratings were given for CMPC topics during past surveys and self-assessments?
Is there a trend?
Have all elements been reviewed?
What is the status of open findings and corrective actions?
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D.1 BASIC REQUIREMENTS
Subtopical Areas to Basic Requirements
None
Sample Document List:
The following documents should be requested and reviewed during the survey:
Training records for personnel with information security responsibilities
Information security procedures
Classification guidance
Local site-specific implementation procedures
Facility/site security plan
Controlled Unclassified Information procedures
Sample Interview Candidates:
Interviews candidates may include the following:
Classification Officer
Classified Matter Protection and Control (CMPC) Custodians and Control Station
Operators
CMPC Program Manager
S&S Director
Users of classified matter and Controlled Unclassified Information
Cyber Security management and staff
Operation Security Program Manager
Technical Surveillance Countermeasures Operations Manager
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
How is information security guidance disseminated to the facility personnel?
What kind of training is provided to generators, users, control station operators?
Is approved classification guidance disseminated and available to users for each of the
facilities’ classified projects?
How is guidance (policy/procedure/requirements/changes) disseminated to the
field/users?
How are information system requirements funneled into security education and
awareness?
How is information security integrated to overarching S&S planning documents and
other topical area plans?
Do facility/site Security Plan and related documents adequately address the information
security program?
How is Controlled Unclassified Information stored, marked, generated, and reviewed at
this facility?
Are initial and annual classification awareness briefings conducted as required?
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D.2 TECHNICAL SURVEILLANCE COUNTERMEASURES
Subtopical Areas to Technical Surveillance Countermeasures (TSCM)
None
Sample Document List:
The following documents should be reviewed:
Formal assignments of TSCM Operations Managers (TSCMOMs) and TSCM Officers
(TSCMOs)
TSCM activity support memoranda (if applicable)
Local TSCM operations plan
TSCM service case files including inspections, surveys, advice and assistance, and
preconstruction services
Current annual TSCM schedule
List of facilities that meet the minimum technical and physical security requirements
TSCMO service files and corrective action reports
TSCM team training and annual eligibility for TSCM Technician certification or re-
certification records
Local TSCM awareness education program
Local security procedures, safety concerns, facility layout, site operation, and badge
procedures
Equivalencies/exemptions to DOE directives the facility may have pending and/or
approved
Sample Interview Candidates:
The following individuals may be interviewed as appropriate:
DOE TSCMOM
Local Sensitive Compartmented Information Facility Special Security Officer (if
applicable)
Contractor TSCMO(s)
Managers and technicians working with the TSCM program
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
Are local TSCM capabilities available and sufficient to detect, deter, and/or nullify
Section 51
technical penetrations and hazardous conditions? If not, is a signed memorandum of
understanding (MOU) to provide for appropriate TSCM support with another DOE site
approved and coordinated through TSCM management?
What kind of training has been provided to the TSCM team members?
What reporting procedures of a TSCM penetration or hazard are in place? Are these
procedures included in the site TSCM awareness briefing?
Is there a TSCM awareness program?
Is there a list of all facilities that meet TSCM service criteria?
What procedures are followed to request TSCM services or report TSCM concerns?
Are TSCM assets effectively utilized to conduct TSCM services in areas that discuss,
process, and/or produce classified information?
Is an annual schedule of TSCM activities in writing and approved? Is the schedule
completed before the beginning of each new fiscal year?
Are complete and up-to-date TSCM reference documents and memoranda, including
DOE TSCM Manual and classified TSCM Annex, available?
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Is there an annual re-certification eligibility of TSCM personnel sent to TSCM program
management?
Are an appropriate number of contractor TSCMOs assigned to provide for effective
management and coordination of local TSCM services?
Have TSCMOs attended any training concerning TSCM services and activities?
Does TSCM Technician training include safety, administrative, and specialized technical
course (e.g., telephony, Operations Security, counterintelligence, information systems)?
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D.3 OPERATIONS SECURITY
Subtopical Areas to Operations Security (OPSEC)
None
Sample Document List:
Specific OPSEC program documentation to be reviewed may include:
Local OPSEC Plan
Local OPSEC Awareness program files
OPSEC reviews (of sensitive activities and facilities)
Local Threat Statement
Local Critical Information (CI) list
Indicators list or other documentation reflecting current assets, threats, operations, and
other relevant factors
Counter-Imagery Program Plan (if applicable)
Results of Internet Website assessments
Sample Interview Candidates:
Interview candidates may include the following:
OPSEC point-of-contact
Counterintelligence Program Manager
OPSEC Working Group Chairperson
Director/Manager of Safeguards and Security (S&S)
Program/Project Manager of selected sensitive activities
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
What OPSEC training has been provided to the OPSEC point-of-contact?
Is an OPSEC program implemented to cover each program office, site, and facility to
ensure the protection of classified and controlled unclassified information?
Has a point-of-contact been established with overall OPSEC responsibilities for each site,
facility, and program office?
Does the OPSEC point-of-contact participate in the development of local implementation
training and/or briefings tailored to the duties of the individual employees?
Are OPSEC assessments being conducted at facilities having Category I special nuclear
material (or credible rollup of Category II to a Category I quantity), Top Secret, or
Special Access Program information within their boundaries?
How are OPSEC concerns being disseminated to the staff of the facility?
Have CPI and Indicator lists been developed? Are they current?
Are assessments of websites conducted? How are they done? Has a process been
Section 52
established to conduct these assessments?
Is there a review process for looking at website information prior to posting/making
public? Who conducts the review and have criteria been established?
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D.4 CLASSIFICATION GUIDANCE
Subtopical Areas to Classification Guidance
None
Sample Document List:
The following documents should be requested and reviewed during the survey:
Number of Derivative Classifiers (DCs) and Derivative Declassifiers (DDs)
Appointment letters
Training records and materials
Procedures
Classification guidance
Reviews/Inspections/Appraisals by other organizations
Sample Interview Candidates:
Meetings should be scheduled and interviews conducted with the following personnel:
Classification Officer
DCs and DDs
Users of classified matter
Classified Matter Protection and Control points of contact and custodians
Unclassified Controlled Nuclear Information (UCNI) Reviewing Officials
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
Have DCs been formally appointed and trained?
How is classification guidance issued to other DCs?
How is DC training provided and at what frequency?
How do site personnel know where to go to get information reviewed for classification?
Are reviews being conducted in a timely manner?
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D.5 CLASSIFIED MATTER PROTECTION AND CONTROL
Subtopical Areas to Classified Matter Protection and Control (CMPC)
Control of Classified Matter
Special Access Programs and Intelligence Information
Sample Document List:
Documentation to be reviewed may include the following:
CMPC procedures
Control station procedures
Training/briefing records and materials
List of repositories (by custodian/organization, location, accountable/unaccountable)
Facility/site Security Plan and any subordinate plans applicable to CMPC
Recent self-assessments, survey reports, security appraisals and inspections
Incidents of Security Concern (IOSC) involving CMPC
List of equipment used to reproduce and destroy classified matter with locations and
associated approvals
Accountable matter inventory list(s)
Special Access Program (SAP) security plans
Results of accountable annual inventories
Corrective action plan packages for recent findings
Sample Interview Candidates:
Interviews may be conducted with the following individuals:
CMPC point-of-contact
Control Station Operators
Custodians or authorized users
Reproduction staff
Classified communications center staff
Safeguards and Security (S&S) Director
IOSC Program Manager
SAP Manager/Sensitive Compartmented Information Facility Manager
Cyber security management and staff
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
How are site-specific implementation instructions disseminated to facility staff?
What kind of training is provided to Control Station Operators, custodians, and
authorized users of classified information? How often?
Does the facility have any special or unique equipment to generate classified documents?
What kind of training and procedures are available for this equipment?
What procedures are used to enforce limiting access, need-to-know, and handling
classified documents outside storage locations?
What is the process for receipts not returned within the suspense period? How are
Section 53
follow-up actions documented?
How are fax transmissions documented for verbal receipts?
What are the hand carry procedures? How are staff identified and approved for hand
carry? What kind of contingency plans are in place?
How is information from other government agencies handled?
What are the emergency procedures pertaining to CMPC?
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What procedures are available for intra-site messengers or post office couriers to ensure
they constantly attend and control classified matter?
What check-out procedures are used for staff who have transferred, terminated
employment, or are otherwise unavailable for employment to ensure that they have
surrendered all classified material in their possession?
What is the notification process for suspensions/revocations of access authorizations?
When was the last inventory conducted of accountable matter? What were the results?
Is classified email a common practice at this facility?
Are e-mails containing classified information marked in accordance with national
requirements?
How are classified document facilities managed (is there overnight storage, how is
classified waste handled)?
How is security managed for SAPs at this facility?
How is need-to-know for SAPs determined?
How are intelligence-related efforts coordinated with the Office of Intelligence?
Has an individual been designated as being responsible for procurements involving field
intelligence elements and/or Sensitive Compartmented Information?
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E. PERSONNEL SECURITY
Subtopical Areas
E.1 ACCESS AUTHORIZATIONS
E.2 HUMAN RELIABILITY PROGRAM (HRP)
E.3 CONTROL OF CLASSIFIED VISITS
E.4 SAFEGUARDS AND SECURITY AWARENESS
Areas of Consideration
The topical area team should research answers to the following types of questions during the
course of document reviews. Answers to questions such as these may help to focus and
streamline survey activities.
Is there a formal, coordinated effort regarding the implementation and management of the
Personnel Security program?
Have procedures been developed and approved for all aspects of the program?
Are processes completed in a timely and efficient manner?
Do the facility/site security plan and other planning documents include Personnel
Security elements such as HRP?
Has adequate training been provided to key personnel?
Has the HRP been formally documented? Have roles and authorities been defined?
Are the appropriate people cleared for the mission of the facility?
Is proper justification required for all access authorizations? Is the approval appropriate?
How often are re-justifications required?
Are regular reviews conducted of access authorizations for subcontractors/consultants?
Are employees knowledgeable of their safeguards and security (S&S) responsibilities?
Are meaningful briefings/training provided to staff in accordance with national
requirements and DOE directives?
Are attendance records kept?
Are evaluations or other records used to ensure the information provided as part of S&S
awareness is meaningful, adequate, and understood by staff?
Does the security awareness program undertake use other supplementary awareness
activities? If so, what are they? How are they distributed and what populations do they
reach? Are they effective?
Have individuals (both DOE Federal employees and contractor employees) been
designated in writing as authorized representatives for purposes of accepting the SF 312,
Classified Information Non-Disclosure Agreement?
Section 54
Is there an effective classified visits program in place?
Do the site security plan and local procedures address all types of classified visits (DOE
employees, other cleared U.S. citizens, non-U.S. citizens?
Who is the designated Federal official responsible for approving and documenting
cleared U.S. citizens for access to RD/SNM during classified visits? Are clearances of
visitors appropriately verified? What records of these visits are kept?
Are continuing classified visits approved for no more than one year at a time?
Are the identities of visitors, their level and type of clearance, and need to know
established?
For visit by foreign nationals, do procedures ensure that the following are established and
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verified: identity of the visitor, assurance that the classified information to be shared is
covered by an existing treaty or agreement, security assurances from the appropriate
foreign embassy, and approval by the appropriate DOE Federal official for the sharing of
the specific information to be disclosed?
Are knowledgeable hosts assigned for classified visits by non-U.S. citizens? What
training do the hosts receive? Do the hosts ensure that the foreign national does not
receive access to classified information before approval is received from the appropriate
DOE Federal Official? How do the hosts ensure that the foreign national is precluded
from access to classified information outside the scope of the governing treaty or
international agreement?
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E.1 ACCESS AUTHORIZATIONS
Subtopical Areas to Access Authorizations
None
Sample Document List
Documentation to be reviewed may include the following:
Access authorization/clearance requests to determine if justifications are adequate and
include appropriate contract references
Personnel security files:
Has proof of U.S. citizenship been validated using acceptable evidence?
Have the appropriate preprocessing checks been completed?
When access authorizations/clearances are granted based on reciprocity, are the
required procedures for verifying the existing clearance followed and appropriately
documented?
Have the appropriate forms been completed and submitted?
Do procedures ensure that individuals are not permitted to access classified
information/matter or special nuclear material (SNM) until the DOE has granted,
reinstated, shared, or transferred an active clearance/access authorization?
Are the files current and do they include all records required by the applicable DOE
directive?
Local procedures
Contractor access authorization requests (justifications)
Nondisclosure Agreement (SF 312) forms
Training records, to include adjudicator training at sites where adjudicators are located
Central Personnel Clearance Index records
List of clearances terminated during the review period
Case analysis sheets
List of reinvestigations that are due or past due
List of individuals on administrative leave
List of individuals on leave of absence during the period
List of classified contracts and the access authorizations associated with them
Sample Interview Candidates:
Interview candidates may include the following:
Personnel Security Specialists, Personnel Security Assistants and other operations
personnel
Supervisors and cleared employees
Badging personnel
Personnel with clearances
Human Reliability Program Adjudicator
Sample Interview Questions:
Section 55
Suggested questions to be asked during the interview process may include the following:
Is the need for an access authorization/clearance determined prior to processing? What
constitutes valid need?
What constitutes the type of access authorization/clearance to be processed and how is
this determined (i.e., are the category and level of classified information/matter or
category of SNM for each level requested defined)?
What are the criteria for processing interim access authorizations?
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What procedures are in place to ensure foreign nationals who have been granted access
authorizations are not granted access to classified matter such as Top Secret or NATO- or
Intelligence-related information or to SNM?
What procedures are in place to ensure that clearances/access authorizations are
terminated for individuals who terminate employment or transfer to a position not
requiring an access authorization?
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E.2 HUMAN RELIABILITY PROGRAM
Subtopical Areas to Human Reliability Program (HRP)
None
Sample Document Lists:
Documentation to be reviewed may include the following:
Implementation schedule
Training records/materials
Drug testing/handling procedures
Drug testing records
Random test procedures
Site implementation plans and procedures
Review procedures against requirements established in 10 CFR Part 712
Are HRP positions designated in accordance with the appropriate criteria (and are
criteria defined)?
Do procedures include annual submission of required forms?
Do procedures include appropriate reviews (i.e., supervisory review, medical
assessment, management evaluation, and DOE personnel security)?
Do procedures address reporting requirements?
Do procedures address temporary reassignments and/or removals based on issues
identified through the HRP process? Appeals process?
Review the initial and annual refresher HRP instruction and education program
Do lesson plans include appropriate information for all types of positions (i.e.,
supervisors and managers, employees, HRP medical personnel, and for those with
nuclear explosive responsibilities)?
Review files to ascertain if appropriate records are maintained and properly protected
Sample Interview Candidates:
Interview candidates may include the following:
Facility Managers, Supervisors, and cleared personnel
Participants in the HRP
Supervisors
HRP Coordinator
Medical personnel
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
Has the program been reviewed and approved by DOE?
Is there a drug testing program for HRP positions? Have procedures been developed and
implemented which provide for random drug testing of staff in HRP-designated
positions?
What is the rate of random drug testing?
Does the site have an HRP Implementation Plan?
Do individuals in or applying for an HRP position undergo a security review and
clearance determination prior to being assigned an HRP position?
What training is provided for individuals in and/or administering the HRP program?
Do all employees have a “Q” access authorization prior to assuming the duties of an HRP
position?
Has a formal process been established for HRP?
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E.3 CONTROL OF CLASSIFIED VISITS
Subtopical Areas to Control of Classified Visits
None
Sample Document List:
Section 56
Documentation to be reviewed may include the following:
Written delegation of authority for senior Federal official to make determinations
allowing individuals cleared by another agency to have RD access in connection with
classified visits
Procedures applicable to the classified visits program as documented in the facility/site
security plan
Classified visit reports, control logs, and other classified visit files, including tracking of
access granted in connection with a classified visit to individuals cleared by another
agency
Documentation establishing responsibility for operational approval of classified visits
Documentation of programmatic approval received for access to specified facilities, data,
or technology
Designation of individuals to serve as hosts for classified visits by non-U.S. citizens
Sample Interview Candidates:
The following people should be considered for interviews:
Employees responsible for processing and controlling classified visits
Individuals responsible for processing, controlling, and approving visits of uncleared U.S.
citizens
Staff who routinely host visitors or tours
Senior Federal official delegated authority to make determinations of RD access for
individuals cleared by another agency
Sample Interview Questions:
Suggested questions to be asked during the interview process may include the following:
What is the local policy regarding escort-to-visitor ratios?
Are visitor logs used at Protected Areas? Material Access Areas? Exclusion Areas?
Have procedures been developed and implemented for classified visits by DOE
employees, contractors, and subcontractors? For employees and contractors of other
Government agencies, including DoD, NRC, and NASA employees? For non-U.S.
citizens?
Are specific procedures developed for individuals from other government agencies who
wish to access classified information for which they do not hold the appropriate
clearance?
Who approves requests for classified visits?
When are briefings provided to individuals cleared for access to RD solely in connection
with the classified visit? What acknowledgement do these individuals sign?
What are the responsibilities of an escort?
From what office are classified visit requests sent and received?
How is information concerning