Physical Protection: Questions involving DOE M 470.4-2 have arisen both the revised directives resulting from the streamlining initiative of August 2005 and the changes associated with elite force that were published in March 2006. Several of the questions of most general interest are provided below.

Q: What is a SF-700?

A: The first part of this two part form contains information on the responsible organization, container, type of lock, and names, addresses and telephone numbers of employees who are to be contacted if the container is found open and unattended. This portion is attached to the inside of the control drawer or vault door. The second part (comprised of Parts 2 and 2A) is a sealed combination record that is turned over to the designated person responsible for the central storage of the SF-700 forms. Parts 2 and 2A of each completed SF-700 must be classified and marked front and back with the highest classification level (and category, if RD or FRD) of information authorized for storage in the security container. These parts are to be stored in a different security container that only permits access to individuals who possess the same security clearance, any required formal access approval, and need to know for all of the information that may be protected by the enclosed combination.

Q: Why do I need to use SF-700?

A: Title 32, Code of Federal Regulations requires that the SF-700 be used in all situations that call for the use of a security container information form. Aside from being required by DOE policy, there is always a possibility with any combination lock that the combination could be lost or forgotten. If this ever happens you can easily recover the combination if you have a SF-700 on file. Having this combination record readily available may save you the cost of forcibly opening the container and having to spend money to protect the classified information while the container is being repaired.

Q: Must I install high security padlocks on gates providing access to public and property protection areas?

A: No, high security padlocks are not required; but, DOE M 470.4-2, provides security criteria for Level III security locks and keys that are required for use on gates in fences, cargo containers and storage areas for the protection of Government property.

Q: Where can I find information about the Levels of federally approved locks and keys?

A: Federal specifications, appropriate for high security locks and keys securing public and property protection areas, are available at the Department of Defense Lock Program Technical Support organization. They provide information to DOE on security hardware and are available by accessing their web site at https://portal.navfac.navy.mil/go/locks or by calling (800) 290-7607 or (805) 982-1212.

Q: Is there an inventory requirement for Level IV locks and keys?

A: No. There are no DOE requirements to inventory Level IV locks and keys. However, a locally developed procedure addressing the issue, turn-in, loss, compromise and control of Level IV locks and keys is a sound business practice.

Q: I know that there is a new badge being issued - when can I expect to receive my new badge and how long will my current DOE badge remain effective?

A: DOE and DOE contractor employees possessing a DOE badge will be contacted when the identity verification processing is completed. This will be followed by the turn-in of the current badge in exchange for the new DOE badge. The current DOE badge will remain active until the new badge is issued.

Q: What are the national drivers for the posting of trespassing signs at DOE facilities, installations, and real property as prescribed by DOE M 470.4-2?

A: Section 229 of the Atomic Energy Act of 1954 (42 U.S.C. 2278a) as implemented by 10 CFR 860-Trespassing on Department of Energy Property provides details for posting the regulations and penalties. Those DOE activities located on property under the charge and control of the General Services Administration, 41 CFR 101-20.3, Conduct on Federal Property, and 41 CFR 102- 81, Security, provide the guidance on the rules and regulations involving the property. Chapter XIV, Posting Notices, DOE M 470.4-2, describes the requirements for the Posting of property owned by or contracted to the United States for DOE.

Q: Does the DOE-approved combination lock on my vault door require modification to permit one-handed operation for egress in the event of an emergency?

A: No. If the lock meets the requirement for installation on vault and vault-type-room (VTR) doors, it does not require modification. The approved lock has a built-in safety release which must be engaged upon opening the lock. It automatically releases the latch when the door is opened. Thus, there is no modification required to the existing lock. Before someone is allowed to work in a vault, he/she should be instructed in the operating procedures, including the opening, closing, and alarm shunting/activating, the notification procedures when the alarm is shunted/activated upon arriving/departing the vault/VTR, and the response procedures for incidents.

Q: What's DOE policy concerning leaving a badge in a vehicle? Could I leave it in my car, that way, I won't forget and leave it at home because it will always be in my vehicle when I return to work.

A: Paragraph 3.e of Chapter XV, DOE M 470.4-2, requires each badge-holder to protect "the security badge against loss, theft, or misuse" and to report "a lost, stolen, or misused badge to the cognizant security authority within 24 hours of discovery." It is a poor security practice to leave a DOE badge in your vehicle. DOE badges should be protected the same as you would protect/secure cash, check book or credit card. Under isolated, unavoidable circumstances, leaving the badge in your locked vehicle, out of sight may be necessary, but any available means must be employed to eliminate unauthorized access to the badge (e.g. placed in a glove box, kept out of sight, car parked in an access-controlled area).

Q: While on official travel hotel personnel ask to make a copy of my DOE badge (in addition to my official orders) to verify my DOE status in order to receive the official government rate. Should I allow them to make a copy of my DOE badge?

A: No. Your DOE travel orders, your Government credit card, and when asked, showing your DOE badge, are sufficient to validate the individual's status as a person on official government travel. Title 18 U.S. Code, Section 701, prohibits the photography, engraving, printing or impression in the likeness of any such badge, identification card, or any colorable imitation. Violations of this Code may result in a fine or imprisonment or both.

Q: On December 3, 2007, the DOE Chief Health, Safety and Security Officer signed out a memorandum establishing policy panels to increase feedback from the implementers of DOE policy. How will the Physical Protection policy panel be organized?

A: At this point we are looking to use the organization structure previously utilized on physical protection quality panels but modified through the experience we have had in performing the zero based policy review and it's resultant re-write of DOE M 470.4-2. This may be modified further as we do not plan to have the number of individual policy panels as we did quality panels and we will not be able to have as many face to face meetings. We will attempt to leverage current technology, such as video conferencing, to have meaningful panels without the resource drain resulting from many face-to face meetings requiring large numbers of people to travel. As this is in the early "conceptual" stage future updates will be available upon request.

Q: What is the most significant change in the draft DOE M 470.4-2?

A: The most significant change is that the manual has been reorganized into what are being referred to as "tiers". The attempt is to have all the physical protection requirements that apply to everyone in DOE/NNSA appear in the first tier. Sites that do not have classified documents, classified matter or SNM would only have to apply relevant requirements in this tier, and would not need to delve deeper into the document. The next tier would include all those requirements that apply to sites that have classified matter and no more than CAT III SNM. These requirements as well as those for the first tier would be what security personnel at those sites would be required to implement. Finally the third tier would have requirements that apply only to CAT I and CAT II sites. These major facilities would be responsible for implementing all the DOE physical protection requirements.

Q: What are the most significant changes in DOE M 470.4-2 the requirements regarding physical protection?

A: The most significant changes are associated with the implementation of Homeland Security Presidential Directive 12 (HSPD-12). In 2005 President Bush signed out HSPD-12 requiring a common identification badge or credential for all government employees and contractors. A working group has developed DOE's implementation plan for HSPD-12 and the draft physical protection manual has been updated as these plans have been provided to HSS. As the technical specifications for the HSPD-12 badges have been made public, DOE will no longer have an OUO section of the physical protection manual where these specifications have been published in the past.

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