High Risk Property Management at Sandia National Laboratories

High Risk Property Management at Sandia National Laboratories Gary D. Swanson, CPPM Duke City Chapter Background High risk is the term the Department of Energy's (DOE's) property management system applies to personal property or material that represents a high risk if transferred or disposed of carelessly. Less than careful handling has the potential to assist nuclear proliferation, damage national security or, at the very least, to seriously embarrass DOE. The Department first developed guidelines for managing the disposal of high risk property in 1994 after two unhappy experiences involving the sale of excess equipment. In one case a company persuaded DOE that instead of destroying surplus nuclear weapon parts at DOE s Pantex plant it should turn swords into plowshares and let the company mount the parts on wall plaques to be sold as peace dividends. But others at both Pantex and DOE Headquarters questioned the wisdom of putting nuclear weapon parts on public view where nuclear proliferants could study them. After much argument, the peace dividend scheme was allowed to die. The second experience was the Idaho National Engineering Laboratory s (INEL's) sale of surplus components of a nuclear fuel reprocessing plant to a Pocatello used car dealer. Instead of selling the components for scrap, as INEL had expected but not required, the used car dealer offered them worldwide as a plutonium reprocessing facility. When the U.S. Government learned of this, various agencies told the car dealer he would need an export license to ship the plant abroad, and would not get one. He complained that INEL had not mentioned any restriction on what he could do with his purchase. After weeks of stalemate, the car dealer took his story to the Wall Street Journal and CBS s prime time television show "Eye to Eye with Connie Chung. In the ensuing furor, DOE wound up paying the car dealer many times what the parts had cost him in return for his agreement to sell the parts for scrap. He did, and by the terms of the agreement, he kept the proceeds. So was born the concept of high risk property. Regulatory Requirements Realizing that in an era of downsizing and dismantlement tighter control over disposal of excess property was vital, DOE developed and published the DOE Interim Guidelines on Export Control and nproliferation on vember 3, 1994. This document provided the first guidance on the management of export controlled, proliferation sensitive personal property. Although it addressed property that is now defined as high risk, the initial version did not use the term high risk property in it. Revision 2, published on July 6, 1995, used the term high risk personal property and included guidance on the management of hazardous and radioactive property, export controlled information (ECI), and unclassified nuclear information (UCNI). The DOE established a requirement for all operating elements and contractors to define and implement a high risk property management system in which personal property identified as meeting the high risk definition would be managed throughout its life cycle, from cradle to grave. This requirement was published in DOE Personal Property Letter, 970-3, March 25, 1996. Personal property letters were established by the DOE as a mechanism for disseminating changes in personal property management policy until the changes could be NPMA Property Professional Volume 7 Number 3 1

incorporated by rule-making into the DOE Property Management Regulations (DOE- PMR). In February 1997, the interim guidelines were published as the DOE Guidelines on Export Control and nproliferation and, on February 3, 1998, a revised DOE Personal Property Letter, 970-3 was published. The changes in both documents resulted from the efforts of a DOE-wide Working Group established to review applicable high risk property management guidance and procedures. Procedures were streamlined and clarified in both documents as a result of their work. The DOE Personal Property Letter, 970-3 was superseded when the DOE-PMR was revised, effective May 20, 1998, including management of high risk personal property in Subpart 1.53. In DOE- PMR Section 109-1.100-51, "Definition and acronyms," the definition for high risk property continues to include such items as hazardous and radioactive property, export controlled information (ECI), and Category Components, subassemblies, piece parts or equipment/material used in the research, design, development, testing, or production of nuclear or other weapons of mass destruction. Military equipment (especially items on the Department of State Munitions List, 22 CFR Part 121). Commercial, off the shelf, items with modifications made for military, chemical, biological, nuclear fuel cycle, or nuclear weapons use (NSG Dual-Use List). Designed or especially prepared for use in the nuclear fuel cycle (NSG Trigger List) unclassified nuclear information (UCNI). However, the scope of Subpart 109-1.53, "Management of High Risk Personal Property" says the subpart provides guidance for categories of high risk personal property of especially designed or prepared property, export controlled property, nuclear weapons or weapon-like components, and proliferation sensitive property. It further states the other categories of high risk personal property are controlled by other life cycle management programs and procedures managed by other DOE elements. The remainder of this article will focus on the management of high risk personal property in accordance with the DOE-PMR. Categories of High Risk Property/Material with Examples The following table shows the various categories of high risk property or material and provides examples in each category. Examples Bomb casings, missile body sections, nose cones; MC numbered parts from nuclear weapons; nuclear weapons test equipment; or specialized tubes (krytrons or sprytrons). Firearms or ammunition; guided missiles, rockets, torpedoes, or bombs; protective personnel equipment (armored vests); fire control or optical, guidance & control equipment; or high speed cameras. Lasers, mass spectrometers, high voltage power supplies; or electronic streak and framing cameras (meeting specifications shown in the NSG Dual-Use List). Source and special fissionable material; reactors and equipment therefor; and equipment for reprocessing of irradiated fuel elements, separation of isotopes of uranium, or gas centrifuge or gaseous diffusion enrichment. NPMA Property Professional Volume 7 Number 3 2

Sandia National Laboratories' System In the Sandia National Laboratories' (SNL's) Enhanced Property Management System (EPMS), Property Coordinators (PC's) are required to identify high risk property when submitting a property or material pickup request. When the pickup request is printed, it clearly shows the property or material has been identified as being in the high risk category. Since a copy of the pickup request accompanies the property/material to the Reapplication facility, it lets the Reapplication Team stock keepers know the item(s) must be handled as high risk property. PC's are also required to complete a "Reapplication Identification Form for High Risk Property/Material" and send it to the SNL High Risk Property Control Representative (HRPCR). The form is available as a template in the Corporate Forms section of SNL's internal web and is shown in Figure 1 at the end of the article. The HRPCR reviews the property identified on a pickup request as being high risk after its receipt at the Reapplication facility. He also reviews items identified as potentially being high risk by stock keepers to determine if they should be categorized as high risk. The HRPCR completes monthly reviews of all property items for high risk prior to the items being screened for donations by the responsible New Mexico agency. In addition, he screens all property items at the SNL contractor auction warehouse for high risk prior to conduct of the monthly auction. SNL has identified two high risk property holding areas at the Reapplication facility for holding high risk or potentially high risk property items. Items identified as high risk on pickup requests and as potential high risk by stock keepers are stored in them until the HRPCR reviews them to determine if they are high risk items. The two areas are located at the far West end of the Reapplication facility where access is limited. When the HRPCR has determined that an item should be categorized as high risk, he enters information about it in the High Risk Property Control Log. The log is prenumbered with High Risk Property Control (HRPC) Numbers and a pre-printed label with the HRPC Number on it is placed on the property item. The HRPC Number is also written on the item with an indelible marker in case the label comes off or is bleached out by the weather. Additional information in the log includes the Pickup Control Number (assigned by EPMS); property number/description and quantity (material); location (high risk holding area); high risk determination (//Pending), by whom and date; disposition determination (Destroy/Release), by whom and date; and destroyed, by whom and date. The log provides an audit trail for identifying and tracking high risk property items until they are destroyed. A copy of the log is shown in Figure 2 at the end of the article. The DOE-PMR includes a presumption of destruction for NSG Trigger List and nuclear weapons related items. This means the items must be made useless for their intended purpose and sold for scrap or destroyed. An exception may be requested from DOE HQ if another valid user is identified for an item. Military Munitions List items must be disposed of in accordance with the Department of Defense (DOD) Demilitarization and Trade Security Controls Manual (DOD 4160.21-M-1). NSG Dual-Use List items may be transferred or sold but an export restriction notice must be included in the transfer or sale documentation. Guidance to help the SNL staff make high risk property determinations is provided in a number of different ways. EPMS Pickup NPMA Property Professional Volume 7 Number 3 3

Request Screens provide access to a high risk help screen; the "Reapplication Identification Form for High Risk Property/Material" and a High Risk Property Home Page are available on the SNL internal web. Biography: Gary Swanson (CPPM) is the Vice President of the NPMA Duke City Chapter and a Property Administrator at Sandia National Laboratories (SNL), a Department of Energy Designated Contractor. He is responsible for the High Risk Property Management and Control Program at SNL. Gary would like to acknowledge the cooperation and support of Zan Hollander, Office of nproliferation and National Security (NN-43), DOE Headquarters, for reviewing and providing a draft rewrite of the Background section of the article, and Judith Langenhorst, Office of Contract and Resource Management (HR-53), DOE Headquarters, for reviewing the article and providing comments on the Regulatory Requirements section. NPMA Property Professional Volume 7 Number 3 4

SF 6951-HRF # (10-98) Supersedes (12-97) issue Reapplication Identification Form for High Risk Property/Material Use this form to determine if property or material being transferred to the Property Management and Reapplication Department (10267) is High Risk by answering the four questions below. If the answer to all questions is, the property or material is not High Risk and this form is not required. If the answer to any question is, complete this form, have it signed by the department manager, and send it in distribution to Gary Swanson, High Risk Property Control Representative, MS1118, or by fax to 844-1152. High Risk property or material will not be formally accepted in EPMS by reapplication until a form is received. Pickup Request Control # Qty (Material) Property # Model # Serial # Description Is the property/material: 1) a nuclear weapons component, subassembly, or piece part? (Equipment or material used in the research, design, development, testing, or production of nuclear weapons.) 2) military equipment? (Any equipment funded by, modified, designed, or developed for use by the military, including, but not limited to, any part of: firearms, artillery projectiles, ammunition, missiles, rockets, torpedoes, bombs, mines, explosives, warships, tanks, vehicles, aircraft, training equipment, protective personnel equipment, electronics, guidance and control equipment, cryptographic systems, communications equipment, toxicological agents, radiological equipment, telemetry, spacecraft, nuclear weapons design and/or test equipment, or submersibles.) 3) commercial, off the shelf, with modifications made for military, chemical, biological, nuclear fuel cycle, or nuclear weapon use? (Any equipment modified for design development, test, production, use, transportation, or storage.) 4) designed or prepared especially for use in the nuclear fuel cycle? (materials: source and special fissionable material, heavy water, or nuclear grade graphite; equipment: reactors and components; irradiated fuel processing; uranium isotope separation; heavy water/deuterium processing; or uranium conversion) Check or For more information on categorizing property/material, call Gary Swanson, High Risk Property Control Representative (10267), at 844-4932. Requester: Department Manager: Printed Name Department Phone Date Signature Soc. Sec.. Phone For our information, has the property/material already been made useless for its originally intended purpose? Figure 1

HIGH RISK PROPERTY CONTROL LOG Organization 10267-1 INPUT HR PICKUP HIGH RISK PROPERTY./ LOCATION DATE FORM (Y/N) CONTRO L. PROPERTY CONTR.. HIGH RISK DETERMINATION DISPOSITION DETERMINATION DESTROYED DESCRIPTION & QTY (Material) (Y/N/P) 1 BY WHOM DATE (D/R) 2 BY WHOM DATE BY WHOM DATE HRPC-001 HRPC-002 HRPC-003 HRPC-004 HRPC-005 HRPC-006 HRPC-007 HRPC-008 HRPC-009 HRPC-010 1 Y = ; N = ; P = Pending 2 D = Destroy; R = Release 10/14/98 Figure 2