ML23123A329

SGI Training ML13108A326

ML23123A329
Person / Time
Issue date:	06/06/2023
From:	Office of Nuclear Material Safety and Safeguards
To:
Shared Package
ML23123A240	List: ML23123A329 ML23123A332
References
Download: ML23123A329 (1)

Text

Safeguards Information (SGI)

Awareness Training U.S. Nuclear Regulatory Commission

Atomic Energy Act Describes Safeguards Information (SGI) as a special category of sensitive unclassified information authorized by Section 147 of the Atomic Energy Act, of 1954, as amended. SGI must be protected from unauthorized disclosure.

Definition SGI is information that is not National Security Information or Restricted Data. Its information that specifically identifies a NRC licensees detailed:

1) Security measures for the physical protection of source, byproduct, or special nuclear material, or

2) Security measures for the physical protection and location of certain plant equipment vital to the safety of NRC licensed facilities See 10 CFR 73.2

NRC Requirements The criteria for designating special nuclear material and power reactor information as SGI, restricting access to it, and the protections for SGI are codified in Section 73.22 of Title 10 of the Code of Federal Regulations (10 CFR 73.22)

Who is covered by the Atomic Energy Act?

Any person, whether or not a licensee of the NRC, who produces, receives, or acquires SGI is subject to the requirements (and sanctions) of the Atomic Energy Act of 1954, as amended See 10 CFR 73.21

Penalties for Unauthorized Disclosure Inadequate protection of SGI, including inadvertent release or unauthorized disclosure, can result in civil and/or criminal penalties (The Atomic Energy Act)

See the Atomic Energy Act of 1954, as amended, Section 147

Penalties for Unauthorized Disclosure Furthermore, willful violation of any regulation or order governing SGI is a felony subject to criminal penalties in the form of fines or imprisonment, or both See the Atomic Energy Act of 1954, as amended, Section 147

Conditions for Access Access to SGI requires both a need-to-know and a determination that the proposed recipient is trustworthy and reliable. This is normally accomplished through a FBI fingerprint criminal history records check and a background check.

Background check examines

- Employment History

- Education

- Personal References See 10 CFR 73.22(b)

Background Check Exemptions Fingerprinting, and the identification and criminal history records checks required by Section 149 of the Atomic Energy Act of 1954, as amended, and other elements of background checks are not required for the following individuals prior to granting access to SGI as defined in 10 CFR 73.2:

- Tribal officials or the Tribal officials designated representative and Tribal law enforcement personnel Note: Despite exemption from the fingerprint and background check requirement, a need-to-know determination must be made prior to granting access to SGI See 10 CFR 73.59(l)

Need-to-Know A determination by a person having responsibility for protecting SGI (typically the person possessing the SGI) that a proposed recipients access is necessary for the performance of official, contractual, or licensee duties of employment See 10 CFR 73.22(b)

Tribal Official Expected Interactions with SGI Take receipt Review/Use Storage Reproduce Share/Transmit Destroy See 10 CFR 71.97 and 73.37

Protection Requirements While in Use Under the control of an authorized individual Requirement is satisfied if the SGI is attended by an authorized individual even though the information is, in fact, not constantly being used (SGI Cover Sheet or other method to shield the text should be used)

See 10 CFR 73.22(c)

Protection Requirements While in Storage Stored in an approved security storage container Within a protected or controlled access area:

- a steel filing cabinet equipped with a steel locking bar and a 3-position, changeable combination, General Services Administration (GSA) approved padlock Outside of a protected or controlled access area:

- A Security filing cabinet that bears a Test Certification Label on the side of the locking drawer, or interior place, and is marked GSA Approved Security Container Knowledge of lock combinations or access to keys protecting SGI should be limited to a minimum number of authorized personnel with a "need-to-know" Access to lock combinations or keys should be strictly controlled to prevent unauthorized disclosure of information See 10 CFR 73.22(c)

Transportation of SGI Documents Outside of facility When transported outside an authorized place of use or storage

- Enclosed in two sealed envelopes or wrappers Inner envelope or wrapper contains the name and address of the intended recipient, marked both sides, top and bottom with the words "Safeguards Information" See 10 CFR 73.22(f)

Transportation of SGI Documents Outer envelope or wrapper addressed to the intended recipient, address of the sender, not contain any markings or indication that the envelope or wrapper contains SGI Transported by commercial delivery company providing nation-wide overnight service with computer tracking features, US first class, registered, express, or certified mail, or by any individual authorized access Within a facility Transported using a single opaque envelope or wrapper See 10 CFR 73.22(f)

Preparation and Marking of Documents Marked "Safeguards Information" in a conspicuous manner on the top and bottom of each page to indicate the presence of protected information First page of SGI Document also contains

- (i) the name, title, and organization of the individual authorized to make a SGI determination, and who determined the document contains SGI;

- (ii) the date the document was originated or the SGI determination made;

- (iii) an indication that unauthorized disclosure is subject to civil and criminal sanctions See 10 CFR 73.22(d)

Preparation and Marking of Documents (continued)

Transmittal letters or memoranda which do not contain SGI are marked to indicate that attachments or enclosures contain SGI but that the transmittal document does not (e.g., "When separated from SGI enclosure(s), this document is decontrolled)

Each item of correspondence should clearly indicate which portions contain SGI and which portions do not; however, portion marking is only required for correspondence to and from the NRC See 10 CFR 73

Removal from SGI Category Removed from SGI category (decontrolled) only after a determination is made that the information no longer meets the SGI criteria Authority to determine if a document/information can be removed from SGI category is exercised by the NRC, with the NRC approval, or in consultation with the individual (or organization) making original SGI determination

- Indicate name and organization of individual removing document from SGI category and date of removal

- Reasonable effort should be made to notify other persons who have the document in their possession, that the document has been downgraded See 10 CFR 73.22(h)

Reproduction of Documents Containing SGI Reproduced to the minimum extent necessary, consistent with a need-to-know without permission of the originator Reproduction equipment must be evaluated to ensure that unauthorized persons cannot access the SGI through retained memory or network connectivity See 10 CFR 73.22(e)

Destruction of Matter Containing SGI Destroyed by means approved for classified information or by tearing into small pieces, burning, shredding or any other method that precludes reconstruction by means available to the public at large (piece sizes no wider than one quarter (1/4) inch composed of several pages or documents and thoroughly mixed would be considered completely destroyed)

See 10 CFR 73.22(i)

Use of Electronic Systems Processed or produced on a stand-alone computer system.

Stand-alone means a computer or computer system with which access is limited to individuals that are approved for access to SGI. The stand-alone computer may not be connected to a network that is accessible to individuals that are not approved for access to SGI Removable media containing SGI must be labeled "Safeguards Information" and stored in approved security storage container See 10 CFR 73.22(d) and 73.22(g)

Use of Electronic Systems If SGI is produced on a typewriter, the ribbon must be removed and stored in the same manner as other SGI (i.e.

marked and placed in an approved storage container)

SGI files may be transmitted over a network if the file is encrypted

- Encryption must take place on a stand-alone computer

- Encryption standard: (Federal Information Processing Standards (FIPS) 140-2 or later.)

See 10 CFR 73.22(f)

Telecommunications Infrequent or non-repetitive telephone conversations regarding a physical security plan or program are permitted provided discussion is general in nature Individuals should use care when discussing SGI at meetings or in the presence of others to ensure that SGI is not inadvertently released or compromised SGI may only be transmitted over secure electronic devices that employ encryption approved by the NRC See 10 CFR 73.22(f)

No Comment Policy Occasionally, sensitive information appears in the public domain without authorization Your response to questions raised about the accuracy, SGI designation, and/or technical merit of such information should be no comment

Questions?

Forward questions regarding SGI and its protection requirements to:

U.S. NRC Office of Nuclear Security and Incident Reponse Division of Security Operations Information Security Branch (301) 415-2278 or (301) 415-2214 Q