DOE O 5634.1A, Facility Approvals, Security Surveys, and Nuclear Materials Surveys

I 1 . 0I u.s. Department of Energy <) ORDER 00. j C Washington, D.C. I DOE 5634.1A I 2-3-88 SUBJECT: FACILITY APPROVALS, SECURITY SURVEYS, AND NUCLEAR MATERIALS SURVEYS j 1 1. PURPOSE. To establish the Department of Energy (DOE) requirements for granting facility approvals prior to permitting safeguards and security interests on the premises and the conduct of on-site security and/or nuclear material surveys of facilities with safeguards and security interests. I · 2. CANCELLATION. DOE 5630.7, CONTROL AND ACCOUNTABILITY OF NUCLEAR MATERIALS SURVEYS, of 7-8-81, and DOE 5634.1, SECURITY SURVEY AND FACILITY APPROVAL, of 5-2-83. 3. SCOPE. The provisions of this Order apply to all Departmental Elements and contractors performing work for the Department as provided by law and/or contract and implemented by the appropriate , contracting officer. ~ '·'··· 4. BACKGROUND. DOE shall assure that all facilities eligible to . ;0· ., receive, process, reproduce, store, transmit, or handle classified matter or special nuclear material (SNM) have been granted facility approval prior to permitting access to such matter or material. 5. POLICY. DOE special nuclear materials (SNM) and classified interests shall not be permitted on premises occupied by the DOE and/or its contractors, subcontractors, consultants, or other organizations performing work for the DOE until facility approval is granted. Activities involving the possession, use, and production of nuclear materials and classified matter shall be afforded appropriate levels of protection to prevent unacceptable adverse , impact to national security or the health and safety of the public. 6. CONCEPT OF OPERATIONS. DOEl s policy for approving facilities and conducting surveys to ensure satisfactory safeguards and security of DOE interests apply equally to all Departmental elements, contractors, subcontractors and consultants. However, this policy is implemented at a wide range of facilities, and site- and program­ specific characteristics must be considered to assure that Departmental safeguards and security interests are provided appropriate and cost-effective protection. In order to allow for DISTRIBUTION: INITIATED BY: All Departmental Elements Office of Safeouards and Security 2 o DOE 5634.1A 2-3-88 J effective implementation of Departmental policy on a site-specific or program-specific basis, an exception mechanism is provided that allow facility approval and survey programs to be tailored to address these specific requirements. The exception procedures are outlined in paragraph 6e. a. Information and requirements regarding cover operations are no longer provided in this Order. The nature of these sensitive classified interests require specialized instructions which shall be provided by DP-34 on an as needed basis. r b. Initial facility approval shall be based upon a determination that satisfactory safeguards and security can be afforded the DOE interests. Such determination shall be based upon initial and periodic on-site nuclear materials and/or security surveys conducted by DOE safeguards and security personnel, and upon written security and material control and accountability plans approved by the cognizant field organization or, in the case of Headquarters, by the Director of Safeguards and Security (DP­ 34).

c. The DOE will determine whether, and to what extent, any contractors performing or proposing to perform work which will involve access to classified information or significant quantities of SNM (as defined in 10 CFR 710), are foreign owned, controlled, or influenced. In addition, the DOE shall determine on a case-by-case basis whether any degree of foreign ownership, control, or influence might constitute a basis for the compromise of classified information, unauthorized access to or use of SNM, or other related adverse impact on the national security. To assist in these determinations DOE will use information provided by the contractor in accordance with Department of Energy Acquisition Regulation 952.204-73, "Foreign Ownership, Control, or Influence Over Contractor (Representation)." The contractor shall also execute a certificate which indicates that the information, provided in accordance with the DEAR clause identified above, is accurate, \ complete, and correct. d. On-site nuclear materials and/or security surveys shall be conducted initially and periodically thereafter, at intervals specified in this Order, to ensure satisfactory safeguards and security of DOE interests. Surveys of each site for which a Master Safeguards and Security Agreement has been written shall be conducted in such a manner as to be consistent with the Master Safeguards and Security Agreement requirements. e. Alternate means of providing adequate facility approvals and security and/or nuclear materials surveys may be proposed to meet a specific requirement of this Order. Exceptions to the Order, developed by the Heads of Field Elements, include the following: o o DOE 5634.1A 3 (and 4) 2-3-88 (1) Safeguards and security interests covered by the classified threat guidance issued by DP-1 and Headquarters program organizations. These exceptions should be submitted in writing to DP-34 for review and concurrence prior to implementation. Written records of such exception should be included in appropriate field organizations safeguards and security policy documents and MSSAs. (2) Safeguards and security interests not covered by the classified threat guidance issued by DP-1. These exceptions should be submitted to and approved by the Heads of Field Elements. Written records of such exceptions should be included in appropriate field organization safeguards and security policy documents. 7. REFERENCE. DOE 5630. Safeguards and Security Program for Department of Energy Operations, and other Facility Approval, Security Surveys and Nuclear Materials Surveys references cited in Attachment 1 of this Order. 8. DEFINITIONS. Facility Approval, Security Survey and Nuclear Materials Survey definitions are appended to this Order at Attachment 2. BY ORDER OF THE SECRETARY OF ENERGY: LAWRENCE F. DAVENPORT Assistant Secretary Management and Administration r.·····. i \..I I ~ o 0 J o o DOE 5634.1A Attachment 1 2-3-88 Page 1 REFERENC1S 1. DOE 5630.13, MASTER SAFEGUARDS AND SECURITY AGREEMENT, of 2-3-88, which provides guidance on the establishment of basic safeguards and security requirements. 2. DOE 5632 Series, PHYSICAL PROTECTION OF SECURITY INTERESTS ORDERS, which prescribe policies, objectives, responsibilities and authorities, requirements, and standards for the physical protection of DOE security interests. 3. DOE 5633.3, CONTROL AND ACCOUNTABILITY OF NUCLEAR MATERIALS, of 2-3-88, which prescribes responsibilities and authorities for control and accountability of DOE nuclear materials.

4. DOE 5670.1, MANAGEMENT AND CONTROL OF FOREIGN INTELLIGENCE, of 8-22-86, which establishes policy for the management of, and assigns responsibilities and authorities for, foreign intelligence activities of DOE. 5. ATOMIC ENERGY ACT of 1954, as amended, which describes requirements for the protection of classified information relating to atomic energy. 6. TITLE 10 CFR 710, "Criteria and Procedures for Determining Eligibility for Access to Classified Matter or Significant Quantities of Special Nuclear Material,tI of 1-1-82, which establishes criteria and procedures for determining eligibility for access to classified matter or significant quantities of SNM. 7. EXECUTIVE ORDER 10450, Security ReqUirements for Government Employment, of 4-27-53, which establishes criteria for investigating, and granting authorization for access to classified National Security Information. 8. EXECUTIVE ORDER 10865, Safeguarding Classified Information within Industry, of 2-24-60, which established criteria and procedures for the protection of classified National Security Information within industry. 9. EXECUTIVE ORDER 12356, National Security Information, of 4-6­ 82, which establishes government-wide policy for safeguarding classified National Security Information. 10. Department of Energy Acquisition Regulation (DEAR) 904.70, FOREIGN OWNERSHIP, CONTROL, OR INFLUENCE OVER CONTRACTORS, which prescribes DOE policies and procedures regarding foreign ownership, control, or influence over contractors. Attachment 1 DOE 5634.1A Page 2 2-3-8a 11. Department of Energy Acquisition Regulation (DEAR) 952.204-2, "Security Requirements," of 4-84, which outlines contract clause requirements for contractors and subcontractors whose performance involves, or is likely to involve, classified information. 12. DEAR 952.204-73, "Foreign Ownership, Control, or Influence over Contractor (Representation)," contract provision. 13. DEAR 952.204-74, of 4-84, "Foreign Ownership, Control, or r Influence over Contractor," contract clause. 14. DOE Safeguards and Security Standards and Criteria of 4-21-87, •which provide baseline guidance to Heads of Departmental Elements, Headquarters program managers, field office managers, and the managers of facilities for planning and developing protection operations for classified and sensitive matter and the protection of life and property. 15. DOE Espionage Threat Policy Statement of 3-30-87, which establishes baseline hostile intelligence threat guidance for DOE's sophisticated technologies and nuclear weapons research, production, and testing facilities. 16. DOE GENERIC THREAT GUIDANCE, of 1-31-83, which establishes baseline threat guidance for DOE nuclear programs and facilities. 17. DOE PROCEDURAL GUIDE, "Security Standards for Sensitive Compartmented Information and Facilties," of 1986, which establishes policy, procedures and responsibilities for establishing and maintaining the security integrity of Sensitive Compartmented Information Facilities. 18. Title 10 CFR 50, Domestic Licensing of productli?n an~ Uti lfi zatld·on . Facilities, of 3-3-75, which provides for the lcenslng 0 pro uct lon and utilization facilities. 19. Title 10 CFR 1016, Safeguarding of Restricted uate,.ot ~-flU-tltj, .WhtiCdh establishes criteria and procedures for the protectlon 0 res rlC e data. http:uate,.ot o o DOE S634.1A Attachment 2 2-3-88 Page 1 c DEFINITIONS

1. Access Permit. A permit, issued by the DOE, authorizing access by the named permittee to Restricted Data applicable to the civilian uses of atomic energy. 2. Accountability. That part of the safeguards and security program which encompasses the measurement and inventory verification systems and records and reports to account for, nuclear materials. 3. Classified Interest. Classified information or material possessed by DOE, a DOE contractor, or any other facility• under DOE jurisdiction. This may include SNM owned by DOE. 4. Facility. An educational institution, manufacturing plant, laboratory, office, building (or complex of buildings contiguously located on the same site) protected as one unit and used by the Department or its contractors for the performance of work under the jurisdiction of the Department. 5. Facility Approval. A determination that a facility is eligible to receive, produce, use, or store classified matter, SNM, or other DOE property. This approval determination is limited to a safeguards and security perspective only. 6. Facility Data and Approval Record. A standard DOE form which is used to register a security facility on the Master Facility Register and to record approvals, changes, and deletions of security facilities and interests, the dates of surveys, and Headquarters review and analysis of survey reports. 7. Facility Register. An index of security facilities under the administrative or survey responsibility of a field organization. 8. Field Organization. DOE Operations Offices, Energy Technology Centers, Federal Energy Regulatory Commission Regional Offices, and Power Administrations. o o Attachment 2 DOE 5634.1A Page 2 2- 3-88 9. Finding. A separate and distinct situation in a surveyed organization that exists in violation of directives. "Finding" situations shall be either brought into compliance with DOE Orders, or granted an approval based on an exception, or accepted program departure. Each "findingll shall be referenced to a specific directive and assigned a unique identification number used in conjunction with a specific corrective action proposed and implemented by the field organization or contractor. 10. Foreign Ownership, Control, or Influence. a. Foreign ownership, control, or influence exists when a DOE contractor performing classified work has an institutional or personal relationship with any of the following foreign interests, which are defined as: (1) Foreign government or foreign government agency; (2) Any form of business enterprise organized under the laws of any country other than the United States or its possession; or (3) Any form of business enterprise organized or incorporated under the laws of the U.S., or a State or other jurisdiction of the U.S., which is owned, controlled, or influenced by a foreign government, agency, firm, corporation, or person who is not a citizen or U.S. national. b. A contractor is considered to be under foreign ownership, control, or influence when the degree of interest as defined above is such that a reasonable basis exists for concluding that compromise of classified information or significant quantity of special nuclear material, as defined in 10 CFR 710, may result. 11. Graded Safeguards. A system designed to provide varying degrees of physical protection, accountability, and material control to different types, quantities, physical forms, and chemical and isotopic compositions of nuclear materials consistent with the risks associated with malevolent acts and varying levels of attractiveness and convenience to potential adversaries.

12. Heads of Headquarters Elements. This term refers to the Office of the Secretary, Secretarial Officers and DOE Staff Operations. J , .. o o DOE 5634.1A Attachment 2 ~~M Page 3 13. Malevolent Act. An illegal action, or an action that is committed with the intent of causing wrongful harm. 14. Master Facility Register. Central record index maintained by DP-34 of all security facilities under the administrative jurisdiction of Departmental Elements. 15. Nuclear Materials. All materials so designated by the , Secretary. Presently, these materials are: depleted uranium, enriched uranium, plutonium-242, americium-241, americium-243, curium, berkelium, californium, plutonium 239-241, lithium-6, uranium-233, normal uranium, neptunium-237, plutonium-238, • deuterium, tritium, and thorium. 16. Nuclear Materials Accounting. The part of the safeguards program applied to nuclear materials and their associated records to: (a) Maintain knowledge of the quantities of nuclear materials; c (b) Verify the existence of nuclear materials through physical inventories; (c) Promptly detect malevolent acts involving nuclear material; (d) Help investigate and resolve apparent losses of nuclear materials. 17. Nuclear Materials Control. The part of the safeguards program applied to nuclear material and personnel and equipment handling nuclear material to: (a) Govern and maintain vigilance over nuclear material activities; (b) promptly verify the existence of nuclear material; (c) Promptly detect malevolent acts involving nuclear material; (d) Help investigate and resolve apparent losses of nuclear material. Nuclear materials control interfaces with the nuclear materials accounting and physical protection parts of the safeguards program. - IC o Attachment 2 DOE 5634.1A Page 4 2-3-88 J 18. Nuclear Materials Survey. A comprehensive examination and evaluation of the effectiveness of the control and accountability of nuclear materials at DOE facilities to meet a spectrum of threats. 19. Physical Protection (Physical Security). The application of methods for preventing malevolent acts against DOE safeguards and security interests. detecting such acts as they occur. and responding to such acts. Available methods include, for , example. couriers, guards. vaults, and alarm systems. They do not include such things as seals. in-line instruments, or area monitors of the recording type, as distinguished from alarms. 20. Property Protection Facility. A facility other than a security facility. 21. Responsible Organization. The DOE organization responsible for implementation and oversight of Safeguards and Security requirements at a DOE facility. including approval of security plans and resolution of deficiencies other than those which are specific to another DOE organization's security interests. If there is more than one DOE organization with security interests at a facility, the organization which is responsible for the programs involving the highest level of security interest is normally the responsible office. However, this responsibility may, by mutual agreement of the offices involved, be accepted by an office which does not have the highest level of security interest but a greater scope interest, as with a long term or traditional interest. When more than two offices have interests at the same facility and when there is no overriding or traditional interest the

organization assigned geographic responsibility in Attachment 111-1 of this Order should be assigned as the responsible organization. 22. Safeguards. A collective term that comprises those measures designed to guard against malevolent acts involving material such as source or special nuclear material. Safeguards includes providing timely or delayed indication of possible malevolent acts or credible assurance that the malevolent acts have not occurred. The measures may include, but are not limited to: (a) The maintenance and verification of records of receipt, shipments, and periodic inventories; (b) Physical protection; J j i o o DOE 5634.1A Attachment 2 2-3-88 Page 5c (c) Personnel security; (d) Inspection of nuclear facilities to provide that malevolent acts have not occurred; assurance (e) Physical methods to detect or measure materials; or loss of (f) Federal statues. 23. Safeguards and Security Interest. Any of the following that may require special protection: classified matter, SNM, and associated facilities; security shipments; critical facilities; secure communications centers; Sensitive Compartmented Information Facilities; processing centers, or other systems that include classified information or Departmental property. 24. Safeguards and Security Survey. The security survey and/or nuclear materials survey, as appropriate. The security survey and nuclear materials survey may be performed independently or as one integrated survey. Integrated safeguards and security survey refers to the combined security and nuclear material survey. 25. Security. Any and all measures taken to guard against theft, diversion, sabotage, and espionage. 26. Security, Physical. See Physical Protection. 27. Security Facility. Any facility which has been approved by DOE for generating, receiving, using, proceSSing, storing, reproducing, transmitting, destroying, or handling classified matter and/or SNM. 28. Security Interest. Any of the following which requires special protection: classified matter; special nuclear material; security shipments; secure communications centers; Sensitive Compartmented Information Facilities; automatic data processing centers; or other systems that include classified information or Departmental property. 29. Security Survey. On-site examination of the devices, equipment, personnel, and procedures employed at a facility to safeguard SNM, classified matter, and/or DOE property. I · , ! I !j C···"'· i I I 1 I I Attachment 2 DOE 5634.1A Page 6 2-3-88 30. Sensitive Compartmented Information. All classified information and materials bearing intelligence community special access controls formally limiting access and dissemination. This does not include Restricted Data, as defined in the Atomic Energy Act of 1954, as amended. 31. Sensitive Compartmented Information Facility. An accredited area, room, group of rooms, or installation where sensitive compartmented information may be stored, used, and/or electronically processed. 32. Significant System Alarm. Any facility safeguards and security capability that provides a communicable indication of a malevolent act involving radiological or industrial sabotage, espionage, or the theft or diversion of classified matter or nuclear materials which could be used to construct an improvised nuclear device, a nuclear device, or unauthorized detonation of a weapon or test device. 33. Significant Vulnerability. The loss of, or discovered way to

bypass, an essential safeguards and security system component or set of components for which there is no effective backup. 34. Suggestion. Information a field organization provides as guidance to a facility's management to identify potential program enhancements associated with survey observations. J 35. Surveying Organization. The DOE safeguards and security organization which has responsibility for conducting a security and/or nuclear materials survey of a DOE facility. 36. SNM. See Special Nuclear Material. 37. Source Material. Uranium, thorium, or any other material determined, pursuant to the proviSions of Section 61 of the Atomic Energy Act of 1954, as amended, to be source material; or ores containing one or more of the foregoing materials in such concentration as may be determined by regulation. 38. Special Nuclear Material. Plutonium, uranium enriched in the isotope 233 or in the isotope 235, and any other material which, pursuant to the provisions of Section 51 of the Atomic Energy Act of 1954, as amended, has been determined to be special nuclear material, but which does not include source material; or it also includes any material artificially enriched by any of the foregoing, not including source material. 39. Special Nuclear Material Facility. Any facility which has been approved by DOE to possess SNM. J o•DOE 5634.1A ; 2-3-88 TABLE OF CONTENTS CHAPTER I: RESPONSIBILITIES AND AUTHORITIES G 1. Director of Safeguards and Security •••••••••••••••••••••••• I-l 2. Heads of Headquarters Elements ••••••••••••••••••••••••••••• I-2 Heads of Field Elements ••••••.•••••••••••••.••••••••••••••• I-3 • 4. Director of Computer Services and Telecommunications 3. Management ••••••••••••••••••••••••••••••.•••••••••••••••• 1-6 5. Director of Procurement and Assistance Management •••••••••• I-6 CHAPTER II: FACILITY IMPORTANCE RATINGS AND APPROVALS 1. Facility Importance Ratings ••••••••••••••••••••••••••••••• ll-l a. Purpose .......•......................................• I1-1 b. Criteria•••••••••••••••••••••••••••••••••••••••••••••• 11-1 (1) Class "Au •••••••••••••••••••••••••••••••••••••••• II-l (2) Class "B" ••••••••••••.••••••••••••••••••••••••••• 11-2 (3) Class tlCt' •..••.•.•..••.••..••.•.•.•••••••.••...•• II-2 (4) Class "AP" ••••••••••••••••••••••••••••••••••••••• 11-2 (5) Class "PP" ••••••••••••••••••••••••••••••••••••••• 11-2 c. Facility Register ••••••••••••••••••••••••••••••••••••• 11-3 2. Facility Approval ••••••••••••••••••••••••••••••••••••••••• 11-3 a. Purpose ••••••••••••••••••••••••••••••••••••••••••••••• 11-3 b. Accepting Existing DOE Facility Approval •••••••••••••• II-4 c. Granting New Facility Approval •••••••••••••••••••••••• II-4 d. Verification•••••••••••••••••••••••••••••••••••••••••• 11-7 e. Terminating Facility Approval ••••••••••••••••••••••••• II-7 3. Facility Data and Approval Record ••••••••••••••••••••••••• II-8 a. Purpose ••••••••••••••••••••••••••••••••••••••••••••••• 11-8 b. Submission of the Facility Data and Approval Record ••• II-8 c. Attachment to the Facility Data and Approval Record ••• II-8 d. Nonsubmission of a Facility Data and Approval Record .............•...••••....•......••..••..•..••• I1-9 e. Distribution•.•••••••••••••••••••••••••••••••••••••••• 11-9 ATTACHMENT II-I DOE F 5600.2 Facility Data and Approval Record ••••••••••• II-ll CHAPTER III: GENERAL SURVEY REQUIREMENTS 1. Purpose •.•••..••••.••••••••.•••••.•••••••••••••.••••••••• 111-1

2. Types of Surveys ..•••.•.••••••••••••••••••.•••••••••••••• III-l a. Initial Survey••..••••••••••.•••••••.•••••••••••••••• III-l b. Periodic Survey•••••••••••••••••••••••••••••••••••••• III-l c. Special Survey•.•.••••.••••.••••••••••••••••••••••••• III-l d. Termination Survey••••••••••••••••••••••••••••••••••• Ill-l e. Shipment Survey •••••••••••••••••••••••••••••••••••••• III-l 3. Coverage••••••••••••••••••••••••••••••••••••••••••••••••• 111-1 a. Initial and Periodic Surveys ••••••••••••••••••••••••• III-l b. Special Surveys •••••••••••••••••••••••••••••••••••••• III-l ii o DOE 5634.1A 2-3-88 J c. Termination Surveys •••••••••••.••••.•••••••••.•••.••• III-2 d. Shipment Surveys .••••••.••••.••••••.•••••••••••.••••• III-2 4. Pre-Survey Planning and Scheduling•.••.•••••••••••••••••• III-2 5. Coordination of Nuclear Materials and Security Surveys ••• III-3 6. Survey Documentation and Reports ••••••••••••••••.•••••••• III-3 7. Distribution••••••.••.•.••••.••.•.••.•.•.••••.••••.•••.•. 111-4 ATTACHMENT 111-1 DOE F 5634.2 Safeguards and Security Survey Report •.••••• lII-5 CHAPTER IV: SECURITY SURVEYS 1. Purpose ................................................... IV-l 2. Geographical Responsibilities and Exemptions ••••••••••••• IV-l 3. Frequency ...•....•....•..•.•.......................•...... IV-l 4. Survey Report Content ••••••••••••••••••••••••••••••••••••• IV-2 5. Training and Qualifications •.••••••••••••••••••••••••••••• IV-3 6. Compliance Segment ...........•..•...•.••.....•...•..•..•.• IV-3 7. Performance Segment ............•.........•...........•.•.• IV-3 ATTACHMENT IV-l Geographical Areas for Surveys ••••••.••• IV-5 CHAPTER V: NUCLEAR MATERIALS SURVEYS 1. Purpose .................................................... V-l 2. Frequency ......................•.........•.................V-l 3. Survey Report Content ...•.••..••..••.•..•....•••.•...••••.. V-l 4. Training and Qualifications ••••••••.••••••••••••••••••••••• V-3 5. Camp1i ance Segment ..•......................................V-3 6. Performance Segment ........................................V-3 CHAPTER VI: SURVEY RATINGS AND FOLLOW-UP ACTIONS 1. Rating System.•......•..•......•..•........•..............VI-l d. Ratings ...............................................VI-l (1) Satisfactory .....•......•........................VI-l (2) Marginally Satisfactory ••••••••••••••••••••••••••VI-l (3) Unsatisfactory .....•.............................VI-1 2. Identified Protection Needs ••••••••••••••••••••••••••••••• VI-l 3. Use of the "Marginally Satisfactory" Rating ...............VI-l 4. Corrective Actions and Survey Ratings ••••••••••.••••••••••VI-2 5. Deficiencies in Documentation••••••••••••••••••••••••••.••VI-2 6. Compliance•••.•••••••••••••••••••.•••••••••••••••••••••••• VI-2 7. Performance...................•.........•.................VI-2 8. Survey Follow-up and Corrective Actions ••••••.•.•••••••••. VI-2 • J o o ODE 5634.1A I-I 2- 3-88 CHAPTER I RESPONSIBILITIES AND AUTHORITIES 1. THE DIRECTOR OF SAFEGUARDS AND SECURITY (DP-34) shall: a. Develop for review and approval by the Assistant Secretary for Defense Programs (DP-l), policies, standards, and procedures for DOE nuclear materials and security surveys and facility approvals • • b. Review and evaluate the degree of adherence by field elements to DOE policies and procedures relating to the content and conduct of surveys.

c. Review nuclear materials and security survey reports submitted by each field element. d. Advise cognizant Headquarters elements, DP-l, and the Office of Inspector General (IG-l), of any significant problems identified as a result of reviews of field element activities and nuclear materials and security survey reports, and recommend appropriate measures to correct noted deficiencies. e. Review and concur on exceptions to this Order, as appropriate, prior to implementation. f. Provide policy guidance to all Departmental Elements in the implementation of the survey and facility approval system. g. Oversee surveys for Headquarters-administered contracts; furnish the surveying organization complete information concerning Headquarters interests when survey coverage is requested; initiate necessary action to implement suggestions resulting from surveys of Headquarters facilities; and notify the surveying organization, when applicable, of such implementations. h. Conduct surveys of facilities for which Headquarters is the surveying organization and transmit copies of survey reports to responsible Heads of Field Elements and appropriate Headquarters program organizations. i. Assure that surveys examine the adequacy and effectiveness of the protective measures afforded all interests. j. Assure findings resulting from security and/or nuclear materials surveys are documented. k. Maintain the Master Facility Register, including the recording of: 0"''''', f o 1-2 DOE 5634.1A 2-3-88 J (I) Facility register changes in a timely and accurate manner; and (2) At a minimum, the facility's name, location, importance rating, classified mailing address, security officer's name, and the identificaton of responsible and surveying organizations. 1. Maintain a file of facilities either under Headquarters­ administered contracts or for which Headquarters is the surveying organization. m. Approve physical and technical security criteria for sensitive compartmented information facilities prior to initiation of new construction and ensure that appropriate surveys are performed prior to occupancy. n. Ensure that, as a prerequisite for the granting of a facility approval, each contractor has executed a certificate which includes a statement of the nature and degree of foreign ownership, control, or influence, or a statement that there is no foreign involvement. o. ~:~~~~a~~:~;m~;~~~r~~~~~d~~rb~e~~~~~r~!~~e~~~e~;s~~ and, in . ~ coordination with the Office of General Counsel (GC-l) and ~ Director of Procurement and Assistance Management (MA-4), determine whether the degree of foreign ownership, control, or influence may constitute a reasonable basis for compromise of classified information, unauthorized access to or use of special nuclear material, or other adverse impact on the national security. p. For facilities under Headquarters-administered contracts: (I) Grant facility approvals; (2) Approve security plans, when required; (3) Terminate facility approvals; (4) Prepare and distribute facility data and approval records; and (5) Ensure the conduct of initial and periodic surveys. 2. HEADS OF HEADQUARTERS ELEMENTS shall: a. For facilities under Headquarters-administered contracts, request DP-34 to: (I) Determine the adequacy of safeguards and security, J grant facility approvals; and o•DOE 5634.1A 1-3 2-3-88o

(2) Terminate the safeguards and security interests, upon completion of the classified work and removal of special nuclear material (SNM) or classified matter. b. For facilities of field elements under their programmatic or administrative jurisdiction, take action to ensure acceptable safeguards and security. Such action may include recommending that the Head of the Field Element curtail or suspend operations when such operations would result in an immediate and unacceptable risk to national c security or public health and safety. c. Recommend to Heads of Field Elements the curtailment or • suspension of operations when such operations would result in an immediate and unacceptable risk to national security or public health and safety. d. Ensure that contracting officers incorporate contract and solicitation provisions implementing the requirements of this Order in new or existing contracts which involve SNM or classified information. c e. Ensure that corrective actions required as a result of nuclear materials and/or security surveys of facilities under their administrative jurisdiction are implemented and that the Director, DP-34 and other responsible Heads of Field Elements, if appropriate, are promptly notified of the implementing action. f. Identify to the contracting officer those procurements which involve classified information and that require the security provisions of DEAR 952.204-2. 3. HEADS OF FIELD ELEMENTS shall: a. Establish written delegations of authorities and responsibilities for the administration of the facility approval and nuclear materials and security survey programs •• b. Ensure that nuclear materials and/or security surveys are conducted as specified in this Order and in accordance with safeguards and security interests under their administrative jurisdiction. Ensure prompt submission of survey reports to the Director, DP-34, responsible Heads of Field Elements, and the appropriate Headquarters elements and that such survey reports are properly classified. c. Ensure that procurement request originators (organizations initiating a requirement on DOE F 4200.33) notify contracting officers when acquisitions involve safeguards and security concerns. 1-4 DOE 5634.1A 2-3-88 d. Ensure that prior to the initiation of any action involving nuclear materials with a license-exempt (as defined in 10 CFR Part 50) contractor, appropriate contractual coverage is in place to permit the implementation of this Order with regard to the contractor's classified matter and/or nuclear materials activities. e. Develop procedures for the administration and conduct of nuclear materials and security surveys in accordance with this Order. f. Ensure that prior to an initial nuclear materials and/or security survey, the Manager of the Operations Office or Head of Headquarters Elements executes a security agreement that includes a statement of the degree of foreign ownership, control, or influence or a statement of no foreign involvement. When foreign ownership, control, or influence is established, notify DP-34 and forward the certification statement and all supporting foreign ownership, control, or influence information, including the review and rationale for acceptance or non acceptance for final adjudication. g. In coordination with GC-1 and DP-34, restrict or deny award of contract in cases where foreign ownership, control, or influence is such that:

(1) A reasonable basis exists for concluding that compromise of classified information, unauthorized access to or use of SNM, or other adverse impact on the national security may result; and (2) The foreign ownership, control, or influence cannot be satisfactorily avoided or mitigated. h. Provide sufficient resources for the survey programs to support professional, administrative, technical, and clerical staffing requirements, equipment and materials, logistics requirements, and training and development. i. Ensure that corrective action{s) is taken for findings disclosed during nuclear materials and security surveys and notify DP-34 and other responsible Heads of Field Elements of the action(s), as appropriate. j. Take such action, as may be appropriate, to ensure acceptable safeguards and security, including curtailment or suspension of operations when such operation would result in an immediate and unacceptable risk to national security or public health and safety. k. Ensure that contracting officers incorporate contract and solicitation provisions implementing the requirements of this Order in new or existing contracts which involve classified matter and/or nuclear material activities. o o DOE 5634.1A 2-3-88 1. m. n. G o. p. q. r. s. t. G 1-5 Ensure that surveys examine the adequacy and effectiveness of the protective measures afforded: (1) Secure communications centers; (2) Automatic data processing centers and remote interrogation points; and (3) Sensitive compartmented information facilities. Approve each new or updated facility security and nuclear materials control and accountability plan and submit copies to DP-34 for incorporation into the Master Facility Register. Also submit copies to the surveying organization if different from the responsible organization. Conduct surveys of selected security shipments for which they are responsible, take corrective actions resulting from these surveys, and submit copies of such reports to DP-34 for incorporation in the Master Facility Register. Grant facility approval for facilities under their administrative jurisdiction. Prepare and submit facility data approval records to DP-34, as required. Assign importance ratings to facilities based on criteria contained in this Order. Maintain a register of all security and nuclear materials facilities for which they are either the responsible or surveying organization including recording: (1) Facility register changes in a timely and accurate manner; and (2) At a minimum, the facility1s name, its importance rating, location and classified mailing address, and the security officer1s name. Wh~n site or program considerations make strict implementation of this Order not feasible, develop an alternate approach using the exception procedure cited in paragraph 6e; Develop detailed facility approval, suspension, and termination procedures to accommodate a need to retain possession of classified matter or nuclear materials at facilities under their jurisdiction. o 1-6 DOE 5634.1A 2-3-88 4. THE DIRECTOR OF COMPUTER SERVICES AND TELECOMMUNICATIONS MANAGEMENT (MA-25) shall conduct COMSEC audits and surveys and TEMPEST inspections of secure communications centers and crypto facilities.

5. DIRECTOR OF PROCUREMENT AND ASSISTANCE MANAGEMENT (MA-4), shall, in coordination with GC-l and DP-34, maintain solicitation and contract articles implementing this Order and procedures to protect DOE contractual arrangements from foreign ownership, control, or influence. where these could constitute a reasonable basis for concluding that the compromise of classified information, unauthorized access to or use of SNM, or other related adverse actions could impact on the national security. o o DOE 5634.1A 11-1 c 2- 3-88 CHAPTER II FACILITY IMPORTANCE RATINGS, APPROVALS, AND RECORDS 1. FACILITY IMPORTANCE RATINGS. a. Purpose. Importance ratings assigned to security interests provide a means of identifying the relative importance of such facilities and interests on facility registers and the Master Facility Register. The responsible DOE organization shall assure that all facilities eligible to receive, process, reproduce, store, transmit, destroy, or use SNM or classified matter (including SNM owned by DOE) have been granted facility approval prior to permitting classified matter or SNM on the premises. b. Criteria. Facility importance ratings are assigned using the following criteria: (1) Class IIA" facility importance ratings are assigned those facilities which are: C (a) Judged by Heads of Field Elements to be engaged in administrative activities considered to be essential to the direction and continuity of the overall DOE nuclear weapons program; (b) Engaged in research and development, manufacture, production, assembly, or storage of nuclear weapons or weapon assemblies; (c) Engaged in research and development, manufacture, production, assembly, or operation of military reactors; (d) Engaged in major research and development in uranium enrichment or operation of major uranium enrichment facilities; (e) Involved in research and development, manufacture or production, and assembly of non-nuclear weapon components, assemblies, and parts essential to the weapons or military reactors programs; (f) Receiving, handling, and storing Top Secret documents (exclusive of keying material for secure communications) over an extended period; or (g) Possessors of Category I quantities of SNM owned G by DOE. (2) Class 118" facility importance ratings are assigned to the following facilities: II-2 DOE 5634.1A 2-3-88 J (a) Possessing security interests other than the type categorized for Class "A" facilities and which handle and store Secret weapon data documents or Secret research and development reports; (b) Other than the type categorized for Class "A" facilities, in the uranium enrichment program; (c) Possessing Category II quantities of SNM owned by DOE; (d) DOE national laboratories with security interests other than the type categorized for Class "A" facilities; or (e) Emergency operations centers (except those unmanned, which are Class "CII facil ities). (3) Class "C" facil ity importance ratings are assigned to facilities which are: (a) Engaged in manufacturing, research and development, administrative or consultant activities, including machine and specialty shops, automatic data processing, printing and photographic work, and design engineering where the security interests are limited in scope; (b) Possessors of Categories III and IV quantities of SNM; (c) Established for classified bid negotiations or quotations;

(d) Authorized to retain classified matter (except SNM) other than that noted under paragraphs Ib(2)(a) and (2)(b) above, after completion or other aqreement; or (e) Federal records centers holding DOE security interests. (4) Class "AP" (Access Permit) facility importance ratings are assigned to those facilities at which restricted data is received, originated, or stored under an access permit. (5) Class IIpp ll (Property Protection) facility importance ratings are assigned to those facilities at which a special standard of protection must be applied when significant monetary value, DOE program continuity, national security considerations, or protection of the o o DOE 5634.1A 11-3 ~.. 2-3-88 ~ public health and safety constitutes an important DOE responsibility. Basic considerations include physical protection to prevent or deter acts of arson, civil disorders, riots, sabotage, terrorism, vandalism, and theft or destruction of DOE property and facilities. c. Facility Register. The responsible DOE field element and the surveying office, if not the same, shall maintain a facility register on those facilities as follows for which it has responsibility: (1) The facility register: (a) Accurately reflects facilities with Class A, B, C, property protection, and access permit facility importance ratings. (b) At a minimum, reflects the facility's name, its importance rating, location and classified mailing address, security officer's name, and identifies the responsible and surveying organizations. (c) Is controlled appropriate to its contents. (2) Changes shall be timely and properly coordinated with the responsible DOE organization, or surveying organization if different. (3) Responsible and surveying organizations shall confirm the accuracy of Master Facility Register maintained at Headquarters and that it reflects established facilities and security interests under their jurisdiction, via prompt submission of accurate facility data and approval records (DOE F 5600.2). A copy of the facility data and approval record is provided by Attachment II-I. 2. FACILITY APPROVAL. a. Purpose. To ensure that all facilities eligible to receive, process, reproduce, store, transmit, use, or destroy, SNM or classified matter, have been granted facility approval, based upon a validated satisfactory safeguards and security system, prior to permitting classified matter or classified and unclassified SNM on the premises. The requirements for establishing facility approvals are outlined below. o o 11-4 DOE 5634.1A 2-3-88 J b. Accepting Existing DOE Facility Approval. The organization seeking to establish a classified interest shall check the Master Facility Register to determine whether the location already has DOE facility approval. If already approved, the responsible organization may accept the existing DOE facility approval, provided: (1) The existing safeguards and security program at the facility accommodates the new DOE interest; and (2) The responsible organization determines that, on the basis of the latest survey report, the existing safeguards and security program is compatible with the level of the new interest. Additional requirements shall be established and completed prior to the initiation of the security interest when the existing safeguards and security program cannot meet the requirements of the added DOE interest. These additional requirements may include the conduct of vulnerability analyses and validation exercises and shall be documented

in approved security and/or Nuclear Material Control and Accountability plans. As appropriate, the existing MSSA, and security and material control and accountabiltiy plans shall be revised to reflect the new or added interest. J c. Granting New Facility Approval. (1) Approval of a new facility or interest at a DOE facility, it's contractors, subcontractors, consultants, or access permittees. The following conditions shall be in effect prior to approval: (a) When SNM is present, all facilities subject to facility approval shall have DOE approved site­ specific security and material control and accountabilty plans and an established Reporting Identification Symbol (RIS) for Nuclear Materials Management and Safeguards System reporting. (b) For SNM, approval is based upon an initial security survey and material control and accountabiltiy survey, both with a satisfactory composite rating. (c) For classified information, approval is based on an initial survey report, conducted by geographical survey office, with a satisfactory composite rating. (d) For those security interests covered under . .~ facility MSSAs which are to be protected in a ,.., graded fashion, the facility shall have completed a vulnerability analyses of the proposed security o o DOE 5634.1A 11-5 2-3-88 c interest. The facility shall have this analysis available for review during the survey. (e) The date of the nuclear materials and security survey and site-specific security/material control and accountability plan upon which the granting of facility approval is based shall not be more than 12 months prior to the granting of facility approval. (f) When the level of classified information is raised from Confidential to Secret or Top Secret, or the category of SNM holdings is raised from Category III to Category II or I, facility approval at the higher level shall be based upon a survey with a satisfactory composite rating. (g) In addition to the above requirements, facility approval for access permittees is based on a review of the access permittee's written statement of its procedures for the safeguarding of Restricted Data and for the security education of its employees consistent with the requirements of 10 CFR Part 1016, Safeguarding of Restricted Data. (h) Access authorizations shall be in place at the responsible DOE organization for persons included in a new interest. I ~ (i) Adequate classification guidance pertaining to the new security interest will be available to assure protection of the interest. I (2) Accepting an existing U.S. Government agency facility approval for work at one of it's contractors when a I ! « DOE facility approval does not exist. I ! (a) Work remains under the programmatic cognizance of DOE, however, security survey and oversight isi . ceded to the other U.S. Government agency. Whenever practicable, a DOE security facilityI approval shall be established. However, accepting another U.S. Government agency facility approval for work under DOE cognizance may be considered when:I 1 The interest is short term or of minor J t significance to the Department; J 2 A security facility approval by anotherIO~" agency already exists; ,j I o II-6 DOE 5634.1A 2-3-88 J3 It is not economically prudent for the responsible or another field organization to complete the facility approval and survey requirements; and 4 T,le interest does not involve SNM or access to restricted data.

(b) Facility approval is based upon an existing U.S. Government agency facility clearance at the Confidential or Secret classification level and provided that: 1 The U.S. Government agency facility clearance encompasses the DOE classified interest and the last surveyor inspection report is noted as Satisfactory in those areas which could affect the DOE interest. 2 The U.S. Government agency cognizant security office furnishes to the responsible DOE security office copies of its periodic inspection reports or periodic memoranda covering the DOE classified interest, citing that a satisfactory survey was conducted. 3 The U.S. Government agency cognizant security office agrees that it will not cancel the facility clearance without prior notification to the DOE security office requesting security support. 4 All employees granted access to DOE classified information have, as a minimum, U.S. Government security clearances based on a National Agency check. 5 Requirements identified in paragraph 2c(2)(a)1 through 2c(2)(a)~ above are documented in a letter or memorandum of agreement between the DOE responsible security office and the U.S. Government cognizant security office prior to the establishment of a security interest. (c) If the foregOing provisions cannot be met or when SNM or DOE Top Secret, or Secret, or Confidential Restricted Data is involved, facility approval is based upon the provisions df paragraph 2c(1), page I1-4. (d) When an existing U.S. Government agency cleared J facility also has a DOE facility approval, the . latter is used, when practicable, instead of the . other U.S. Government agency facility clearances. o o DOE 5634.IA 11-7 2-3-88 c d. Verification. Verification of capability of other U.S. Government agencies and their contractors to protect classified information for reference or use in work not under DOE cognizance is as follows: (1) Approval to transmit classified information shall be based upon a written assurance from the Government agency that DOE classified matter in its possession or in the possession of its contractors, subcontractors, or consultants will be afforded physical protection and safeguards in accordance with Executive Order 10865, IISafeguarding Classified Information Within Industry,lI as amended, Executive Order 12356, "National Security Information," and its implementing Information Security Oversight Office directive; and that the mandatory personnel clearance requirements of the Atomic Energy Act of 1954, as amended, pertaining to access to restricted data, be met. (2) When an agreement between DOE and another Government agency specifically limits the dissemination of certain categories of DOE classified information within that agency e.g., restricted data, the responsible DOE organization shall request the agency, on execution of the agreement, to furnish a statement of its procedures to ensure such limitation. e. Terminating Facility Approval. (1) When a facility has completed its activities involving SNM or classified matter, the responsible organization assures destruction or return of matter or material returned to DOE custody through a termination survey or by correspondence that includes the following: I ., I (a) Security termination statements; (b) Written certification of nonpossession of • classified matter or SNM; (c) Cancellation of personnel clearances or access authorizations which are no longer needed;

(d) Discontinuance of physical security and material control and accountabiltiy measures; and (e) Preparation of a DOE F 5600.2, Attachment II-I, cancelling facility approval. c (2) A certificate of possession and periodic surveys are required if the facility is authorized to retain classified matter after termination of a contract or agreement. The responsible DOE organization shall: 11-8 DOE 5634.1A 2-3-88 (a) Maintain appropriate documentation to support receipts of destruction or certificates of nonpossess;on. (b) Establish guidelines for terminating facility approval and coordinating termination activities with appropriate contracting, program, security, and safeguards organizations. 3. FACILITY DATA AND APPROVAL RECORD. a. Purpose. To register pertinent facility information on the Master Facility Register which must be in agreement. Prompt submission of Facility Data and Approval Records and accuracy of reported information are essential to the continued integrity of the system. b. Submission of the Facility Data and Approval Record. A Facility Data and Approval Record, DOE F 5600.2, is submitted to DP-34 by the responsible organization when: (1) Granting initial facility approval; (2) Accepting existing facility approval for an additional .' .~ interest; ~ (3) There is a Significant change in a registered facility or interest within a facility (e.g., a change in name, address, facility importance rating, responsible organization, classified mailing address, contract or purchase order number, classification, Restricted Data authorization, or nature or scope of work); (4) Facility approval for a registered facility or interest is terminated; (5) Interests are surveyed for DOE by DOD or other Government agencies; or (6) When SNM is to be placed in the facility. c. Attachment to the Facility Data and Approval Records. When sUbmitting facility data and approval records, attach a copy of the following: (1) Initial survey reports to the facility data and approval record granting facility approval; (2) Report of survey in memorandum form and pertinent correspondence, when applicable, to the facility data and approval record granting facility approval; and • • DOE 5634.lA 11-9 (and 11-10) 2-3-88 o (3) Termination survey report, if conducted, to the Facility Data and Approval Record terminating facility approval. d. Nonsubm;ssion of a Facility Data and Approval Record. Nonsubmission of an Facility Data and Approval Record increases the risk that an interest will not be encompassed by the normal safeguards and security administration expected at a cleared facility and may be missed during the normal oversight provided by a periodic or termination survey. However, after appropriate consideration, a Facility Data and Approval Record need not be submitted for the following: (1) An organization holding a contract with a facility executes a purchase order or contract amendment for additional work or material similar to that registered under the contract, unless such purchase order or amendment requires substantial changes in existing security or nuclear material control and accountability programs. (2) An invitation to bid tendered by a field organization is consonant with the interest(s) previously registered by that organization.o e. Distribution. The organization preparing the Facility Data

and Approval Record shall forward the original and two copies to DP-34 which will make appropriate distribution to other Departmental Elements having a safeguards and security interest. o o DOE F 6600:2 DOE 5634.1A Attachment 11-1 (Formerly DP-80) 2-3-88 Page 11-11 (and 11-12) 111-81) U.S. DEPARTMENT OF ENERGY fACILITY DATA AND .APPROVAL RECORD NO. CM-66-99 1. FACI LlTY NAME AND ADDRESS CITY STATE ZIP CODE T. A. James and Associates, Inc. 8330 S. Jefferson Rd. Any town Illinois 60699 2. CLASSIFIED MAILING ADDRESS 3. TYPE FACILITY T. A. James and Associates 4. REASON FOR APPROVAL CHANGEP.O. Box 2278 IKJ Add FacilitY 0 Change Mailing Address Any town , Illinios 60699-2278 o Add Interest 0 Change Shipping Address o Delete FacilitY 0 Change Facility LocationUSS REGISTERED OR CERTIFIED }ffiIL ONLY o Delete Interest 0 Change FacilitY Interest o Other (describe): 0 Change Survey Office o Change Responsible Office 6. IMPORTANCE RATING Other OA o B mC OPP o AP 0 5. CLASSIFIED SHIPPING ADDRESS DNA 7. SECUR ITY OF F I CER (name and telephone number) Valentino F. Antonio 10. CONTRACT P.O. or A.P. NO(s): Various Contracts 11. OTHER SECURITY INTERESTS: o Computer o Secure Comm. Systems o Cover o Other _____________ 8. OFFICES INVOLVED Responsible Field Office CH 12. HIGHEST CLASSIFICATION OF Documents Material SINSI DNA 13. SNM CATEGORY: DNA 10 110 1110 14. BRIEF DESCRIPTION OF SECURITY INTEREST T. A. James and Associates TAJA is an engineering firm specializing in the design and evaluation of high security protection systems. TAJA is performing work for CH relating to safeguards and security systems at Northeast·- :;ational Laboratory and Midwest National Laboratory. ji ' 15. BASIS FOR FACILITY APPROVAL: ! Periodic security survey conducted by CH. 16. DISTR IBUTION (Item to be filled in by Division of Security. Haedquarters) c 17. PREPARED B DATE John Doe 4,1988Safeg'uard 18. APPROVED By.~rield) Thomas W. Ha January 4, 1988Security Branch, SSD 19. RECORDED (Division of Sscurity. H8IIdqusrters) DATE THIS REPORT AMENDS, SUPERSEDES OR DELETES FDAR NO. CH-88-992/'l5/86 o o DOE 5634. IA 111-1 2-3-88 CHAPTER III GENERAL SURVEY REQUIREMENTS 1. PURPOSE. To provide the basis for evaluating the adequacy and effectiveness of safeguards and security programs and the protection afforded DOE safeguards and security interests. 2. TYPES OF SURVEYS. a. Initial Survey. An on-site examination of a facility prior to granting facility approval. b. Periodic Survey. An on-site examination of a facility conducted at scheduled intervals. c. Special Survey. An on-site examination of a facility conducted for a specific purpose. d. Termination Survey. An on-site examination of a facility conducted when the safeguards and security interests are removed from a facility or the contractor is changed for a facility, or to assure proper disposition of nuclear material and close out of records. o e. Shipment Survey. An examination of protection afforded security interests during shipment. 3. COVERAGE. a. Initial and periodic surveys cover the protection afforded DOE safeguards and security interests within a facility, including an evaluation of the adequacy and effectiveness of material control and accountability (MC&A) and security programs and a thorough examination of policies and procedures to ensure compliance/performance with appropriate safeguards and security directives and agreements. All facilities are subject to the compliance and performance segments of surveys, as described in Chapters IV and V.

b. Special surveys evaluate the following: (1) Existing protection for additional activities; (2) Need for changes in material control and accountability and security procedures and measures due to changing conditions; and (3) New material control and accountabilty and security measures taken as a result of findings identified under a previous survey(s). • • I II-2 DOE 5634.1A 2-3-88 c. Termination surveys evaluate actions taken to ensure termination of safeguards and security interests, execution of an appropriate security termination statement, and submission of a certificate of possession or nonpossession, as appropriate. Termination of facility approvals for Class "A" facilities, facilities possessing classified material, and/or SNM, require an on-site termination survey. For other facilities, termination may be by survey or correspondence. d. Shipment surveys provide a basis for evaluating the adequacy of protection afforded DOE classified matter or SNM during shipment. Shipments which move between sites by rail, truck, air, or ship are subject to survey based on an approved security plan unless the shipment is made via a commercial carrier(s) licensed by the Nuclear Regulatory Commission (NRC). Movements of SNM between security areas at the same site shall be surveyed during the security survey of the site protection system. Each type of security shipment shall be surveyed initially and at least once every 12 months thereafter by the organization having administrative jurisdiction over the shipment. Shipment survey reports shall provide sufficient detail to enable a proper evaluation of the report and its findings. 4. PRE-SURVEY PLANNING AND SCHEDULING. Certain activities should be accomplished prior to the conduct of a security or nuclear materials survey. These are normally done by the surveying organization, the responsible organization (if different from the surveying), the facility being surveyed, and DP-34. The following activities are necessary: a. Determine the extent of, and establish procedures for reviewing, exceptions and other program departures. b. Review files for relevant information, issues, and topics to include in the survey. Such files include those pertaining to: previous surveys, security and MC&A plans, exceptions, and correspondence. c. Define the scope of the survey by identifying the program areas to be inspected, the methodology, and the resources to be used. The scope should allow for review of areas of concern that may arise during the survey process. d. Coordinate all planned survey activities in advance with parties involved in advance and establish communications channels. Such coordination should specifically include advance planning and agreed participation in a pre-survey briefing. e. Schedule the survey to allow prioritization of and changes .'~ to survey coverage of facilities. ~ ~ i I 1;; ~ o o DOE 5634.1A 111-3j 2- 3-88 Ie 5. COORDINATION OF NUCLEAR MATERIALS AND SECURITY SURVEYS. a. Security and nuclear materials surveys may be conducted simultaneously or separately. When performed separately, the I surveying organization shall prepare an agreement outlining the I : responsibility of each survey that include the following: i I i (1) Assessing system performance against applicable threats; I (2) Evaluating different components of the safeguards and security system; andI

I (3) Rating items on Headquarters-approved survey report forms. (See Attachment 111-1.)I . b. When nuclear materials and security surveys are conducted separately at Class "A" and "8" facilities, they should be performed within a 2 month period. 6. SURVEY DOCUMENTATION AND REPORTS. c a. The survey report shall describe the state of the safeguards and security program. The report shall reflect the ratings on Headquarters-approved survey report forms as well as the performance ratings based upon exercises, where appropriate. As locally determined, work papers shall support the contents of the survey report. b. The narrative portion of the survey report shall outline strengths and weaknesses, correlate the results from the compliance and performance (where required), survey segments, and discuss both compliance and performance ratings. The report shall explain in detail the factors responsible for the assignment of a less than Satisfactory rating. c. Findings shall be identified and correlated with items on the survey report forms approved by DP-34. The terms "findings" and "suggestions" may be used in the survey report. The term "finding" shall be used to refer to deficiencies, or concerns reached during the survey. The term "suggestion" may be used to refer to non-mandatory potential program enhancements for observations cited in the survey report. d. Survey results shall be validated by discussion, observations, or exercises during the survey process to ensure accuracy. e. As determined locally, survey work papers pertaining to findings not fully documented in the survey report should be retained, as a minimum, until the next survey is completed. o 111-4 DOE 5634.1A 2-3-88 f. Survey observations of conditions in facility operations or systems which may adversely impact the health and safety of employees and/or the public shall be reported expeditiously to the facility's management and the responsible organization's environmental, safety, and health organization for follow-up action. g. Survey reports for Class "PP" facilities and terminations may be in memoranda form. h. Findings shall be documented and monitored until resolved. Quarterly reporting on unresolved findings shall be made by the responsible organization to DP-34. The first quarterly report shall be issued not later than 90 days after receiving written corrective action information from the surveyed facility. 7. DISTRIBUTION. a. Within 60 working days after the completion of the survey, the surveying organization(s) shall forward one copy of each survey report to the responsible organization, two copies to DP-34, copies to appropriate Headquarters elements, and one copy to the surveyed organization, as determined locally. b. Heads of Field Elements or DP-34 (for Headquarters), may make ;~ internal distribution of survey reports, as appropriate. ~ J 3 copies copy 1 copy 1 copy o • o DOE 5634.1A Attachment 111-1 2- 3-88 I II- 5 DOE Form 56342 (148. (~1.0"'1 U. S. DEPARTMENT OF ENERGY SAFEGUARDS AND SECURITY SURVEY REPORT Responsible Field Office: Other Offlce(s) with Interests­ SAl'i SNR Distribution Date: December 10, 1987 1 copy 1 copy 1 c n • Facility Name, Reporting Identihcation Symbol (RIS), and Address Bates Midtown Division (CES) 909 Prince Avenue Hidtown, OH 45201 Facility Security Officer: Ronald Limrnins TelephoneNumber (804) 312-5566 Contract. Pllrchase Order, InQuiry or Access Permil Number

Various DOE contracts and Purchase Orders FaCility Importance Rating (check one): o Class A [l Class 8 0 Class C 0 Property Protection 0 Other Interests o Computer o Access Permit Date of Survey: November 11-14, 1987 riI Yes 0 No Date of Previous Su r vel': November 4-8, 1986 Highest Classification of Documents S/RD Materials S/RD Work: S/RD DescnptlOn of Interest(s): For active security interests, see Exhibit tiD" of this report. Classlhed Mailing Address: Bates Midtown Division ATTN: Document Custodian 909 Prince Avenue Midto'Nn, OH 45201 USE REGISTERED CR CER!I lED Claaaifted Shipping Address: Bates Midtown Division ATTH; Document Custodian FOR: Ovid Foster Midtown, OH 45201 Facility MetA Manager: Ovid Foster Telephone Number: (804) 312-5567 Foreign Ownership, ContrOl or Influence Certificate Submitted I Ci Yes 0 No Other DNAo Other Composite Facility Rating­ I ex Setisfactory o Marginal o Unsatisfactory IPre\l1ous Rallng­ "0 SAT I clear Matenal: o Category I o Category N ex Category II DONA I !o Category III I r ~ f I t I ! Surveying Office: CH G I (See Rever!le Side of Form) I I ~ o Attachment 11I-1 II 1-6 PROGRAM PLANNING AND MANAGEMENT Planning Process Organization and Management Safeguards and Security Plans Reporting and Notification Resolution of Findings Rating PROTEC1l0N PROGRAM OPERAnONS Physical Security Systems Property Protection . Protective Force System Performance Tests Rating MATERIAL CONTROL AND ACCOUNTABIUTY Program Management Materials Accounting Material Control Administrative Controls System Performance Tests Rating COMPUTER SECURITY Computer Security Management and Planning Protection of Information Assets Physical Protection of Computing Resource Assets Continuity and Reliability of Critical Operations TEMPEST Program Rating OPSEC OPSEC Program Structure Vulnerability Assessment Rating PERSONNEL SECURITY Personnel Clearance Program Selective Reinvestigation Program Security Education Program Visitor Control Rating FACILITY SURVEY AND APPROVAL Facility Register Facility Approval Process Security Surveys MC&A Surveys Rating Rate Each Item: S - Satisfactory M - Marginal DOE 5634.1A 2-3-88 5 -5­ -5­ -5­ -5­ ~ --L­ ~ _5_ _5_ _5_ 5 -5­ -5­ U - Unsatisfactory DNA - Does Not Apply J c o o DOE 5634.1A IV-l o 2-3-88 CHAPTER IV SECURITY SURVEYS 1. PURPOSE. To assure that facilities maintain effective safeguards and security programs by requiring surveys which provide monitoring and evaluation. 2. EXEMPTIONS. (Attachment IV-l outlines geographic responsibilities for security surveys). Each field organization and DP-34 shall conduct surveys of the facilities within its assigned geographic area, except in cases when a responsible organization may elect to perform this function itself. In the latter case, the responsible • organization shall coordinate its decision with the organization having geographic responsibility. a. The Pittsburgh Naval Reactors Office, Schnectady Naval Reactors Office, and the Strategic Petroleum Reserve Project Management Office are exempt from conducting security surveys for other field organizations within their immediate geographic areas. However, this exemption is not all inclusive since travel restrictions based on budget restraints may dictate that field organizations request these organizations to conduct the surveys for them. In such cases, mutually acceptable agreements are encouraged.

b. When the volume of survey work assigned by geographical areas exceeds the ability of the surveying field organization to absorb the work, and the problem cannot be resolved between affected field offices, DP-34 shall be notified. The affected surveying field organization shall provide DP-34 with a current list of facilities/interests within its assigned geographical area, survey delay times, survey schedules, staffing status, and other pertinent information. If the proposed delays are not satisfactory, DP-34 will coordinate a resolution with affected field office and program offices, recommending temporary reassignment of surveys, personnel or resources to the Heads of Departmental Elements. , 3. FREQUENCY. Security surveys are conducted with the following schedule: a. Class nAil and "BII facil ities shall be surveyed at least once every 12 months. b. Class "C U and Class "AP" facil ities shall be surveyed at least once every 18 months, except for those facilities containing security interests listed in paragraph 3c, page IV-2. c. Secure communication centers, classified automatic data processing centers, remote interrogation points, sensitive compartmented information facilities, and selected security shipments shall be surveyed at least once every 12 months. IV-2 DOE 5634.1A 2-3-88 d. Property Protection (Class "PP II ) facilities shall be surveyed at least once every 24 months, except those facilities containing security interests listed in subparagraph 3c above. e. Those safeguards and security interests documented in a facility Master Safeguards and Security Agreement as requiring protection against industrial or radiological sabotage shall be surveyed at least once every 12 months. 4. SURVEY REPORT CONTENT. Initial and periodic security survey reports consist of a narrative section reflecting both the compliance and performance segments of the survey and a completed survey report form as supplied by DP-34. A copy of an approved survey report form is shown as Attachment 111-1. Locally developed survey forms may be used to supplement the approved survey report form. a. A report on the results of a survey of a security interest should include such items as: (1) A statement of the survey scope and period of coverage. (2) A statement regarding the facilityls function and scope of operations related to security interests. (3) An assessment of management (if appropriate) relative to .'~ security, program planning and review, and security control ~ exercised by the facility. (4) Corrective actions on findings, including status of prior, unresolved findings. (5) Discussion of major points which had, or might have, a significant effect on security controls at the facility. b. A periodic survey report need not contain a complete narrative description of each component and element of the security program unless significant changes have occurred or 5 years have elapsed since the last description. The phrases "no change" or lias previously reported II may be used. However, the new report shall identify the survey report which provides the latest description of the unchanged item. When a complete report is warranted, paragraph 4a above applies. c. Special and termination survey reports may be written in memoranda form.

d. Within 60 working days after completion of the survey, the surveying organization shall forward one copy of each survey report to the responsible organization, one copy to DP-34, copies to Headquarters elements as directed, and one copy to the surveyed organization as determined locally. When the special survey is the basis for granting facility approval for a new or expanded security interest or for continUing facility approval for an existing interest, and time is of the essence, the surveying organization shall: o DOE 5634.1A •IV-3 (and I-¥-4) 2-3-88 (1) Advise the responsible organization by telephone or teletype of the results of the survey; (2) Confirm this action by memorandum; and/or (3) Submit a formal survey report, as appropriate. e. The surveying organization is not required to send a copy of a survey report to a responsible organization when the only security interest at the facility involves an individual interest (e.g., consultant, responsible reviewer, or a person with a personal service contract). In this case, the surveying organization should advise the responsible organization by memorandum that the interest has been included in the survey report, the date of survey, composite survey rating, and findings, if applicable. f. The surveying organization shall forward copies of each termination survey report, including the certificate of nonpossession/possession, to the responsible organization, DP­ 34, and other Headquarters elements, as appropriate. g. The surveying organization shall forward one copy of the portions of the survey report regarding secure communications centers or crypto facilities to the Director of Computer Services and Telecommunications Management (MA-25). 5. TRAINING AND QUALIFICATIONS. Team personnel for security surveys shall possess qualifications and training sufficient to accomplish effective and thorough surveys. 6. COMPLIANCE SEGMENT. The compliance segment of the security survey shall address how well the facility meets requirements contained in DOE directives and the applicable facility Security Plan and/or Master Safegaurds and Security Agreement. The results shall be entered on an approved security survey report form. 7. PERFORMANCE SEGMENT. Surveys of facilities shall include a performance evaluation to assess the capability of the safeguards and security system to meet performance objectives. The performance evaluation shall determine system performance against scenarios for applicable threats/targets. C 0 J J J o o o • c 1 DOE 5634.1A 2-3-88 Field or Headquarters Organizations Albuquerque Chicago Idaho Nevada Oak Ridge Richland San Francisco Savannah River Office of Safeguards and Security, Headquarters Attachment IV-l IV-5 (and IV-6) Geographic Responsibilities for Surveys Survey Area Arizona, Colorado, Kansas, New Mexico, Oklahoma, Texas, Jackson County in Missouri Connecticut, IllinOis, Indiana, Iowa, Maine, Massachuesetts, Michigan, Minnesota, Nebraska, New Hampshire, New Jersey, New York, North Dakota, Ohio, Pennsylvania, Rhode Island, South Dakota, Vermont, Wisconsin Idaho, Montana, Utah, Wyoming Hawaii, Nevada, Johnston Atoll, Aleutian Islands Arkansas, Kentucky, Louisiana, Mississippi, Puerto Rico, Tennessee, West Virginia, Missouri (except Jackson County), Virgin Islands Oregon, Washington, Alaska (except Aleutian Islands) California Alabama, Florida, Georgia, North Carolina, Canal Zone, South Carolina

Delaware, District of Columbia, Maryland, Virginia, DOE offices in foreign countries o J o o DOE 5634.1A ~~M V-1 CHAPTER V NUCLEAR MATERIALS SURVEYS 1. PURPOSE. To assure that facilities are maintaining effective safeguards and security programs. This Order requires and describes the conduct of surveys which provide such monitoring and evaluation. 2. FREQUENCY. a. Nuclear materials surveys of each license-exempt (as defined in 10 CFR Part 50) contractor and Government operated facility shall be performed annually for Category I, II, and III materials, and biennially for Category IV nuclear materials, unless: (1) The total value of the nuclear materials inventory at any time does not exceed $150,000 and the value of nuclear material receipts for any 12-month period is less that $500,000; (2) The total inventory consists entirely of source material, less than 10 tons of heavy water, less than 350 grams of SNM, or any combination of these; or (3) Exception approval is obtained from the Operations Office Manager or Director of Safeguards and Security (DP-34). b. Surveys of contractor facilities meeting the criteria in paragraphs 2a(1) and 2a(2), above, shall be conducted at the discretion of the Operations Office Manager. Definitions of Categories I, II, III and IV are contained in DOE 5633.3. 3. SURVEY REPORT CONTENT. Initial and periodic nuclear materials survey reports consist of a narrative section reflecting the results of both the compliance and performance segments of the survey. For those facilities holding Category II and larger quantities of SNM, an approved survey report form as provided by Attachment 111-1.) Locally developed survey forms may be used to supplement the approved survey report form. a. A report on the results of a survey of nuclear materials control and accountability should include such items as: (1) A statement of the survey scope and period of coverage. o (2) A statement regarding the facility·s function and scope of operations related to nuclear materials. (3) An assessment of the effectiveness of management (if appropriate) relative to nuclear material control and o V-2 DOE 5634.1A 2-3-88 accountability (MC&A) program planning and review. and the safeguards control exercised by the facility. (4) Corrective actions on findings. including status of prior. unresolved findings. (5) Discussion of major points which had. or might have. a significant effect on inventory procedures and safeguards control at the facility. b. The nuclear materials survey report shall include results from: (1) Assessing the ability of the safeguards system to detect and respond to theft and/or diversion of nuclear materials. (2) Reviewing and evaluating: (a) Practices and procedures for the inventory of nuclear materials and the records system reconciliation; (b) Measurements and statistical programs. system; (c) Site's nuclear materials accounting information . .~ system; ~ (d) Nuclear material control practices and procedures; (e) Internal control system;and (f) Program planning and procedures. (3) Reviewing the training and qualification records of material balance area custodians. material handlers. and accountability clerks responsibile for nuclear material data generation and/or transmission. (4) Reviewing the facility's vulnerability assessment program and material control and accountability internal control system.

c. In addition to the requirements in paragraph 3a and 3b. page V-I above. during periodic nuclear material surveys. DOE personnel shall, as appropriate for the type and quantity of nuclear material in the inventory: (1) Ascertain facility compliance with written procedures and objectives of DOE directives on control and accountabilit of nuclear materials and the Material Control and Accountability plan; o o DOE 5634.1A V-3 2-3-88 (2) Review and evaluate the cause, magnitude, reasonableness, and disposition of accidental losses, normal operational losses/measured discards, approved write-offs, inventory differences, and shipper­ receiver differences; (3) Audit the nuclear material records and reports to verify the accuracy of the facility's material status reports and subsidiary records; and {4} Observe inventory procedures and practices and control the independent tests of the inventory to confirm the facility's statement of the quantity of material on hand. Operations offices may develop and use statistically based sampling plans o • appropriate for their site-specific needs to establish that stated nuclear material quantities are accurate. Inventory testing shall be based on a graded safeguards concept, and documentation shall be maintained to support the survey inventory testing criteria, sampling plans, test results, and conclusions. For those populations that do not conform to conventional weighing and sampling methods (or Non-Destructive Assay analyses), confirmation of the contained nuclear materials shall be consistent with accepted estimation techniques, whether independently performed or observed by survey personnel. Inventory exemptions for highly radioactive materials are contained in DOE 5633.3, CONTROL AND ACCOUNTABILITY OF NUCLEAR MATERIALS. d. A periodic survey report need not contain a complete narrative description of each procedure and element of the Material Control and Accountability program unless significant changes have occurred or 5 years have elapsed since the last description. The phrases "no change" or lias previously reported" may be used. However, the new report shall identify the survey report which provides the latest description of the unchanged item. e. Within 60working-days after completion of the survey, the surveying organization shall forward one copy of each survey report to DP-34, copies to Headquarters elements as directed, and one copy to the surveyed organization as determined locally. When a special nuclear materials survey is a part of the basis for granting facility approval for a new or expanded safeguards and security interest involving SNM, or for continuing facility approval for an existing interest where SNM is present, and time is of the essence, the surveying organization shall comply with the requirements of Chapter IV, paragraphs 4d(1},(2) and (3), page IV-3. 4. TRAINING AND QUALIFICATIONS. Team personnel for nuclear materials surveys shall possess qualifications and training sufficient to accomplish effective and thorough surveys. o 5. COMPLIANCE SEGMENT. The compliance segment of the nuclear materials survey shall address how well the facility meets requirements contained in DOE directives and the applicable facility Material Control and Accountability plan and/or MSSA. Results shall be entered on an approved nuclear materials survey report form. o V-4 DOE 5634.1A 2-3-88 J 6. PERFORMANCE SEGMENT. Surveys of facilities shall include a performance

evaluation to assess the capability of the safeguards and security system to meet performance objectives. The performance evaluation shall determine system performance against scenarios for applicable threats/targets. o Q DOE 5634.1A VI-1 2-3-88 CHAPTER VI SURVEY RATINGS AND FOLLOW-UP ACTIONS 1. RATING SYSTEM. Permissible composite nuclear materials or security survey ratings are SATISFACTORY, MARGINALLY SATISFACTORY, and UNSATISFACTORY. The following composite survey rating shall reflect a balance of performance and compliance results as determined by the surveying organization. a. Satisfactory. The safeguards and security element being evaluated meets identified protection needs or provides plausible assurance that those protection needs will be met .. should they arise • b. Marginally Satisfactory. The safeguards and security element being evaluated only partially meets identified protection needs or provides questionable assurance that those protection needs will be met should they arise. c. Unsatisfactory. The safeguards and security element being evaluated does not meet identified protection needs or does not provide adequate assurance that those protection needs will be met should they arise. 2. IDENTIFIED PROTECTION NEEDS. Identified protection needs are those defined by DOE Orders as modified by approved MSSAs, facility safeguards and security plans, approved safeguards and security upgrades, and documented and approved exceptions to DOE requirements. These modifiers specify site-specific considerations and tailor the safeguards and security program to the local mission and operating environment. They shall be comprehensive and supportable relative to threat and safegaards and security interests (i.e., targets). 3. USE OF THE "MARGINALLY SATISFACTORY" RATING. A facility shall not be assigned a survey rating of Marginally Satisfactory for consecutive survey periods unless the following conditions apply: a. The previous survey which resulted in a composite survey rating of Marginally Satisfactory identified different deficiencies and reasons for the rating. c b. Thp. deficiencies and reasons which were the basis for the previous Marginally Satisfactory composite survey rating were related to the completion of a major line-item construction project. In that case, acceptable interim measures must have been implemented and physically verified pending completion of the construction. These interim measures shall be documented in the survey report. 4. USE OF UNSATISFACTORY RATING. If either of the conditions cited in paragraphs 3a or 3b above are not met, an Unsatisfactory rating shall be assigned. o VI-2 DOE 5634.1A 2-3-88 J 5. CORRECTIVE ACTIONS AND SURVEY RATINGS. A composite nuclear materials and/or security survey rating which must be based on conditions existing when the rating was assigned. shall be stated in the survey report, ratings shall not be based upon future corrective actions. If corrective actions have been taken in the interval between the performance of the on-site survey and the aSSignment of the composite survey rating, the final rating should reflect these actions. 6. DEFICIENCIES IN DOCUMENTATION. A facility·s failure to comply with procedural documentation requirements, of and by itself, shall not normally be the basis for a reduction in a composite rating. Ratings of less than Satisfactory in any area shall be based on verified weaknesses in the safeguards and security system or deficiencies in performance in an operational area.

7. COMPLIANCE. The compliance segment rating of a facility reflects the judgments of the surveying organization as to the assurance with which the facility·s safeguards and security system protects the DOE interests located at that facility as measured against related DOE directives, see page V-3, paragraph 5. 8. PERFORMANCE. The rating for the set of exercises, system studies, and technical evaluations, constituting the Jperformance segment of the survey, shall be based on an evaluation of the degree to which the elements of the safeguards or security system meet protection objectives. 9. SURVEY FOLLOW-UP AND CORRECTIVE ACTIONS. a. When a nuclear materials and/or security survey report contains findings, the surveyed organization shall submit a response identifying corrective action(s) for each finding to the responsible and surveying organizations not later than 30 days after receiving the survey report. b. When a survey report indicates a composite rating of Satisfactory and contains findings requiring corrective action, the responsible organization shall provide to DP­ 34, appropriate Headquarters elements, and the surveying organization (if appropriate), a quarterly status report of corrective actions. Notification shall be by memorandum and shall include the identification of the facility, a description of the deficiency, and a description of corrective actions taken to date or planned (with associated milestone dates). c. When a survey report has a composite rating of Marginally Satisfactory, the responsible organization shall notify the J" Director DP-34, the surveying organization (if appropriate), and the applicable field and Headquarters program office(s) within 15 working days after completion a Q DOE 5634.1A VI-3 2-3-88 of the survey of interim corrective actions taken, or to be taken, to correct identified risks or vulnerabilities. If interim corrective actions are instituted, the surveying organization shall physically verify them for adequacy. If the surveying organization differs from the responsible organization, the surveying organization shall promptly notify the responsible organization of the rating. The responsible organization shall then take appropriate corrective and notification actions outlined above or authorize the surveying organization to take those actions. If the surveying organization is unable to contact the responsible organization and a serious threat exists or is imminent, the surveying organization shall take action to protect the safeguards and security interest(s) until the responsible organization is notified. Subsequent action shall be taken on the basis of agreement between the two organizations. d. When a survey report has a composite rating of Unsatisfactory, and the rating is indicative of a significant vulnerability such as unacceptable risk in the area of SNM theft, radiological or industrial sabotage or espionage, the Operations Office Manager shall immediately or as soon as possible, but not later than within 24 hours: (1) Take action to shut down/suspend operation of the facility or activity, pending remedial action; or (2) Provide the rationale for continuing this critical operation to the Assistant Secretary for Defense Programs (DP-l), Director, DP-34, Head~ of the Headquarters Elements; as directed, the Head of the responsible organization, responsible office, and the applicable field and Headquarters program office(s) and identify those immediate interim corrective actions being undertaken to mitigate identified risks or vulnerabilities.

For all other Unsatisfactory ratings, the Operations Office Manager of the responsible organization shall notify the Secretary, DP-l, Director, DP-34, and Heads of Headquarters Elements, as directed, applicable program and field office(s), and the responsible office within 15 working days of interim corrective actions taken, or to be taken, to correct identified risks or vulnerabilities. e. When either a Marginally Satisfactory or Unsatisfactory !composite rating is assigned, the responsible office shall provide to DP-34 and the applicable field and Headquarters program office(s) quarterly status reports on completed or I planned corrective actions (with associated milestone I fdates) until all have been completed. When the responsible organization determines that the composite survey rating should be upgraded to Satisfactory, the surveying VI-4 DOE 5634.1A 2-3-88 organization shall physically verify the completion and adequacy of corrective actions for those deficiencies which contributed to the Marginally Satisfactory or Unsatisfactory composite rating. The responsible organization shall then notify the Director DP-34 and the Head(s) of applicable Headquarters Element(s) that the rating should be upgraded. f. A finding associated with a significant vulnerability shall not be considered closed until associated corrective action has been completed and the Director DP-34 and Heads of Headquarters Elements are notified. A commitment by the facility to institute corrective action does not constitute completion of that corrective action. J J DOE 5634.1A.pdf DOE 5634.1Axtra