High Risk Personal Property

1
High Risk Personal Property

• 2002 Export Control Coordinators Annual Meeting
• June 5, 2002
• Faye Zimmerman
• Personal Property Management Division
• Office of Procurement and Assistance Management
• Headquarters, Department of Energy
• faye.zimmerman_at_hq.doe.gov
  202-586-4887

2
High Risk Personal Property

• Current High Risk (HR) Guidance
• Department of Energy Property Management
  Regulations (DOE-PMRs)
• DOE 109-1.100.51
• DOE 109-1.53
• DOE 109-1.42
• DOE 109-1.43
• DOE 109-1.45
• Personal Property Letter (PPL) 970-3, Revision 1
• Executive Order 13148

3
High Risk Personal Property

• Changes to High Risk Guidance
• PPL 970-3, Revision 2
• Personal Property Management Guide
• End-Use Certificate

4
High Risk Personal Property

• A Little History
• Prior to 1994 No Guidance
• August 1994 The Idaho Incident
• September 1998 The Sandia Incident
• Other Incidents

5
High Risk Personal Property

• Subsequent Policy Formulations
• Draft PPL 970-3, Revision 2
• Personal Property Management Guide

6
High Risk Personal PropertyChanges to High Risk
Procedures

• CURRENT
• HR Procedures apply to four of the ten HR
  categories

• PROPOSED
• Fifth category to be added

7
High Risk Personal PropertyChanges to High Risk
Procedures

• CURRENT
• Categories subject to provisions of PPL
• Export Controlled Property
• Especially Designed or Prepared Property
• Proliferation-Sensitive Property
• Nuclear Weapon/ Weapon-Like Components

• PROPOSED
• New Category
• Information Technology Equipment (IT) (formally
  ADPE)

8
High Risk Personal PropertyChanges to High Risk
Procedures

• CURRENT
• Guidance on specific handling of ADPE (IT) not
  addressed

• PROPOSED
• IT requires HR controls when it meets any one or
  more of these conditions
• Processed classified information, unclassified
  controlled nuclear information, or export
  controlled information
• Cannot be certified as sanitized
• Categorized as a high performance computer

9
High Risk Personal PropertyChanges to High Risk
Procedures

• CURRENT
• No formal certification form is currently
  referenced

• PROPOSED
• End-Use Certificate required when HR property is
  sold or transferred to any end-user other than a
  Department or Agency of the Federal Government

10
High Risk Personal PropertyEffects of September
11, 2001

• In particular, no regulations have been put into
  place with regard to the 9/11 tragedies
• Security heightened at DOE sites
• Property disposal awareness has been raised
• End-Use Certificate