DEVIATIONS FROM DEPARTMENT OF ENERGY DIRECTIVES TO ACCOMMODATE UNIQUE CIRCUMSTANCES

The Department of Energy (DOE) establishes safeguards and security policy to delineate requirements for the protection of national security assets, including classified information, special nuclear material, and unique physical resources. Assets within the Department are located in many different configurations in many different environments. Developing a common set of specific requirements that are necessary and sufficient for establishing the required levels of protection across these many situations is a daunting task. In addition, the nature of the DOE mission, encompassing as it does scientific and engineering research, work related to the nuclear weapons stockpile, and the cleanup and removal of legacy facilities, creates situations from time to time that were not envisioned at the time a particular requirement was established. Therefore, there are situations in which the specific, literal requirement is either impossible to implement or the impact on operations is so severe that other means of establishing appropriate security protections are necessary. This paper will discuss the DOE system for reviewing and approving specific responses to these unique situations in which adherence to published policy is not practical while either preserving equivalent protection or explicitly accepting the resulting risk beyond the level of risk accepted in the directive requirements. Examples of the expected methodologies and approaches will be included.