ML23080A085
| ML23080A085 | |
| Person / Time | |
|---|---|
| Issue date: | 03/30/2023 |
| From: | Timothy Pulliam NRC/ADM/DFS |
| To: | Gross W Nuclear Energy Institute |
| References | |
| ADM-23-00002 | |
| Download: ML23080A085 (1) | |
Text
March 30, 2023 Mr. William R. Gross, Director Incident Preparedness Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004
SUBJECT:
SECURITY CONTAINERS FOR STORING SAFEGUARDS INFORMATION
Dear Mr. Gross:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), we are responding to the Nuclear Energy Institutes letter dated February 9, 2023, seeking confirmation from the NRC that continued use of certain General Services Administration (GSA) approved security containers manufactured from 1954 through 1989 (Black GSA Approval labels) will continue to remain acceptable for meeting agency requirements for the protection of Safeguards Information (SGI) after GSA rescinds its approval for storage of classified information starting in October 2024.
In a GSA memorandum dated January 27, 2021, government agencies and industry were notified of a phase-out plan for GSA security containers and vault doors bearing a black GSA label. The memorandum describes a 4-year phase-out plan starting in October 2024 and applies to all GSA-approved class 1, 2, 3, and 4 cabinets beginning with the oldest containers.
The reasons stated in the GSA memorandum for rescinding the approval of black label containers are directly related to the age of the mechanical systems, some of which will be 70 years old in 2024. The memorandum points out that the older designs use mechanical combination locks and either lack a lockbox or used cast iron instead of steel, which is inferior to the current design specifications. The limited availability of replacement parts was also stated as a reason for rescinding the approval for the storage of classified information.
The NRC has firsthand experience with failed locking mechanisms, drawers, and locks on GSA black label containers. Years before the GSA memorandum, the NRC conducted an internal inventory of the containers in our control and possession and was able to substantially reduce the number of black label containers by consolidating and/or reducing classified holdings.
Additionally, for the remaining black label containers, the NRC upgraded the mechanical locks with GSA-approved KABA MAS X-09 and X-10 high security electromechanical locks, and had each container inspected and repaired by a GSA certified locksmith to extend the service life of these containers. Since our containers are used to store classified information, we now plan to replace the remaining inventory of black label containers after further reducing our holdings of such information and our need for containers.
The NRC views the age of the black label containers as a substantial risk for malfunction, which could result in the loss of the containers availability and/or the availability of its contents.
W. Gross 2 However, the NRC does not assess that there is a greater risk of compromise (i.e., theft) of the contents of such containers. In the judgement of the NRC, black label containers will continue to meet the requirements for protection of SGI outlined in Title 10 of the Code of Federal Regulations (10 CFR) § 73.22(c), Protection while in use or storage, and 10 CFR § 73.22(g),
Processing of Safeguards Information on electronic systems beyond the GSA published end of serves dates.
Although the continued use of GSA black label containers for the storage of SGI has been assessed to meet requirements, users of these containers should consider reducing their SGI holdings to reduce the need to use black label containers and should have all remaining containers inspected and repaired by a GSA certified locksmith. If you have any questions, please contact Denis Brady at 301-415-5768 or by via e-mail at Denis.Brady@nrc.gov.
Sincerely, Signed by Pulliam, Timothy on 03/30/23 Timothy I. Pulliam, Director Division of Facilities and Security cc: NRC Document Control Desk
W. Gross 3
SUBJECT:
SECURITY CONTAINERS FOR STORING SAFEGUARDS INFORMATION DATED: MARCH 30, 2023 DISTRIBUTION:
PUBLIC SAtack, OIP DBrady, ADM BKing, ADM DParsons, NSIR RidsAdmMailCenter Resource ADAMS Accession No.: ML23080A085 *e-concurrence OFFICE ADM/DFS/SMOB/BC* ADM/DFS/D*
NAME DBrady TPulliam DATE 3/29/2023 3/30/2023