12/11/2003 01/20/2004 12/05/2004
Grants and records in WDACS authorization to access Sigma 1 NWD. <17> Grants and records in WDACS authorization to access Sigma 1 NWD. g(1) Designate from each access to Sigma 1 NWD. (5) Coordinate access of Sigma 1 NWD. (7) Ensure that documents in their custody containing Sigma 1 NWD. i(1) Designate from each field element access to Sigma 1 NWD. (2) Ensure that the data in access to Sigma 1 NWD. The Order needs to clearly state that it does not cover Sigma 14 and 15 which is covered by DOE Manual 452.4-1. The requirement to protect Computer Systems that contain NWD the same as for other media may be an impact to Computer Systems at SNL/NM. For example, the IMS/CMS databases on the SCN contain NWD; the draft order would require that all users be certified for NWD; that is not the case now. It may be difficult to partition the NWD in these databases to control access. Sigma 20 will probably be better handled in the same Manual (or similar manual) that covers Sigma 14 and 15 since it parallels requirements for Sigma 14 and 15. Sigma 20 Site Coordinators and Sigma Authorizing Officials have overlap in responsibilities. Also, this appears to be a major resource impact to SNL/NM. Many of the responsibilities under Manager, Classified and Controlled Information Division, NNSA Service, are better suited under Assistant Deputy Administrator for Military Applications and Stockpile Operations since they are more intimately involved with NWD and therefore should control access to NWD. Delegate Ashley McConnell for Sandia National Laboratories To avoid significantly hampering efficient and economical performance: RECOMMENDATION Change, through out the Order and Manual, the required Sigma authorization from any Sigma category to Sigma 1 category and Sigmas 1, 3, 3V, 4, 11, 12 and 13 to Sigma 1. RATIONALE The long-standing requirements of Q clearance and Need To Know provide proven, adequate security for Sigmas 3, 3V, 4 11, 12, and 13. In contrast, the drafted requirement would impose a significant addition in measures and recordkeeping to be performed with a doubtful improvement in security. EXAMPLES: DOE O 471X 4e(1) Authorization for personnel to access Sigma 1 category will be granted 4e(2) Authorization for DOE or NNSA personnel to access Sigma 1 category, 5f(3) Grants or denies waivers or deviation requests from the requirements of this Order, the CRD, or DOE M 471 X-Y, relating to Sigma 1 material (15) Using WDACS, provides authorization for the transfer of Sigma 1 NWD (16) Grants, and records in WDACS, authorization to access Sigma 1 NWD (17) Grants, and records in WDACS, authorization to access Sigma 1 NWD g(1) Designate from each access to Sigma 1 NWD (5) Coordinate access of Sigma 1 NWD (7) Ensure that documents in their custody containing Sigma 1 NWD i (1) Designate from each field element access to Sigma 1 NWD (2) Ensure that the data in access to Sigma 1 NWD. (Sandia/Martinez - SME/Blackburn) Comment: Overall comment - neither the order or manual provide guidance on how to request the listed Sigma access, justification for access, or any records retention requirements as these are official record files. (SME: Sandia/Bechnell) Comment: Sigma 11 needs to be reworded to reflect the program desires. I would hope that the type of information protected includes issues such as implosion mesh zoning and handling; as well as possibly details of High Energy Density Physics Experiments that relate to Stockpile Stewardship. Some "minor" items would cause extreme problems for the weapon community. Approval at the Federal level prior to access at the contractor level would be a non-starter. This requirement calls into question the status of a "Q" clearance at laboratories. We should understand that access to information requires a clearance and need-to-know. An established Sigma system is a process for handling need-to-know determinations in a process consistent throughout the complex. The SIGMA system should not be the need-to-know determination that must be originally made in the hiring process by all managers with NWD information in their program. That is to say that Managers hire someone having the appropriate clearance to work with NWD are making a need-to-know determination. Whatever additional layers of Sigma approval DOE/NNSA feels the need to add, would best be added into the hiring process, if at all On site, the access by Q-cleared personnel to NWD should be a completely local determination and ad hoc. That is to say the fact that Employee ABC needs access to an on-site meeting for general Nuclear Weapon Data (currently Sigma 1-10) should be local determination with local controls regardless of what the system has electronically. Formal Sigma assignments for basic weapon data should only come about when the supervisor wants to approve authority to receive program documents, or the individual needs to travel to anther site. Sigmas 11, 12, 13, 14, 15, 16, and 20 are the exceptions that require additional controls internally, although 11, and 16 do not even fit there if sigma 11 is defined properly as a subset of sigma 1, and 16 only applies to documents as envisioned in recent meetings on the subject. The order continues with a schism in the NWD aggregate. The NWD Order must address all the Sigmas. Since there will be at least two manuals that address sigma handling, the Order should indicate which manuals to go to for each Sigma grouping that is desired. I would group the Sigmas as 1-10 & 16 for general first and second generation weapons data, Sigma 11: Inertial Confinement Fusion (ICF), Sigma 12-13: Nuclear Directed Energy (NDEW), Sigma 20: Improvised Nuclear Devices (IND) and Sigma 14-15 Use Control (UC). I realize the names used here are simplifications. I would strongly suggest that the Sigma 20 be removed except for a small portion that says who manages/controls it under the provisions of the order, and a separate Manual be issued. Sigma 14/15 should also state up front who has overall management and control policy responsibility and address the reference to the manual (M 452.4-1) covering those Sigmas. If 12 and 13 were to be reactivated as a program, I would also recommend their breakout as well. The organization having control for 12 and 13 management should be identified. One of our program representatives would suggest modification of O471.X and M471.X to (1) reference DOE M452.4-1 up front (the draft order currently does not), (2) add the Sigma 14/15 Coordinator roles to the appropriate sections, and (3) at least put a placeholder in to refer to the controls in DOE M452.4-1 for Sigma 14/15 materials. I agree with her (it states more clearly what I said in the previous paragraph). Implementation of this order could result in a number of snafus, not unlike the implementation of M 452.4-1. Some of the issues are probably minor. For example, all new cover sheets will be needed, since the terminology is different than that which currently exists (see manual section 4.b.2). However, will we need to pull all existing cover sheets and do a 100% update/replacement? The manual leaves no provision for leaving the old ones in place, or allowing comparable language. SIGMA 11 - The Definition here should recognize that the information is essentially Sigma 1. If we do not eliminate this Sigma it should have approximate parity in handling (if not outright equivalence) with Sigma1 SIGMA 20 - Several issues pop up immediately. Recovering old "out and about" IND documents. Remarking and coversheets No in use policy. WDACS input prior to access and use ... creates an undue administrative burden on those responsible for maintaining records of programmatic determinations. Encryption on classified systems rather than password access seems to be overly restrictive with no tangible benefit. The "segregation" requirements need to be better defined (see section 6). It would appear that a and b require locked storage even within vaults/VTRs, while c merely requires a repository. And, does separation (especially for c) mean separate hanging file, separate drawer, or separate safe? Similarly, for computers, will segregation be required in terms only of access to systems (section 8), or will separate media/drives/etc. be required? One of the largest issues in implementation will be the requirement in 2.a to re-mark existing documents. This will be a massive, time-consuming effort. It will be compounded by the vague definition of "inactive". For example, will "inactive" material need to be stored away from actively accessed material? Or, can I keep my old documents in my safe "as-is" as long as I swear I haven't touched them (except as allowed in the manual)? Personally, I think the "inactive" strategy will also lead to the same issues that came up when we were asked to implement Sigma 14/15. If inactive documents are pulled up (perhaps by a current custodian without sigma 20), will they know to re-mark these documents correctly, and know that they need to immediately give them up? In LLNL's security refresher briefing, it states that a "Q" clearance is required for SRD and for SFRD. Individuals with a DOE "L" are not permitted SRD. Note: this is the result of a lack of clarity as to whether SRD non-weapon data could be accessed by an "L" cleared person, if the requirement is that they do not access weapon data at all. Here they can only see CRD (Can it be weapon data? actually it can be but rarely is.) and SFRD that contain no weapons data (without DOE approval). However, the table in Appendix A shows "L" cleared personnel are eligible for Sigmas 1 - 13. Have the rules changed, or is LLNL being more restrictive? I think that this table is not correct. (Livermore/Cyganowski - SME/Damoulos)]]> Major comment criteria: to avoid significantly hampering efficient and economical performance:
RECOMMENDED CHANGE: throughout the Order and Manual, the required Sigma authorization from 'any Sigma category' to 'Sigma 1 category and 'Sigmas 1, 3, 3V, 4, 11, 12 and 13' to 'Sigma 1.'
RATIONALE: The long-standing requirements of Q clearance and Need to Know provide proven, adequate security for Sigmas 3, 3V, 4, 11, 12 and 13. In contrast, the drafted requirement would impose a significant addition in measures and recordkeeping to be performed with a doubtful improvement in security.

EXAMPLES: Order 471.X 4e(1) Authorization for personnel to access Sigma 1 category will be granted.
4e(2) Authorization for DOE or NNSA personnel to access Sigma 1 category.
5f(3) Grants or denies waivers or deviation requests from the requirements of this Order, the CRD, or Masnual 471.X-Y, relating to Sigma 1 material.
(15) Using WDACS provides authorization to access Sigma 1 NWD. <16> Grants and records in WDACS authorization to access Sigma 1 NWD. <17> Grants and records in WDACS authorization to access Sigma 1 NWD.
g(1) Designate from each access to Sigma 1 NWD.
(5) Coordinate access of Sigma 1 NWD.
(7) Ensure that documents in their custody containing Sigma 1 NWD.
i(1) Designate from each field element access to Sigma 1 NWD.
(2) Ensure that the data in access to Sigma 1 NWD.

The Order needs to clearly state that it does not cover Sigma 14 and 15 which is covered by DOE Manual 452.4-1.
The requirement to protect Computer Systems that contain NWD the same as for other media may be an impact to Computer Systems at SNL/NM. For example, the IMS/CMS databases on the SCN contain NWD; the draft order would require that all users be certified for NWD; that is not the case now. It may be difficult to partition the NWD in these databases to control access.
Sigma 20 will probably be better handled in the same Manual (or similar manual) that covers Sigma 14 and 15 since it parallels requirements for Sigma 14 and 15.
Sigma 20 Site Coordinators and Sigma Authorizing Officials have overlap in responsibilities. Also, this appears to be a major resource impact to SNL/NM.
Many of the responsibilities under Manager, Classified and Controlled Information Division, NNSA Service, are better suited under Assistant Deputy Administrator for Military Applications and Stockpile Operations since they are more intimately involved with NWD and therefore should control access to NWD.]]> Major comment criteria: to avoid significantly hampering efficient and economical performance:
RECOMMENDED CHANGE: throughout the Order and Manual, the required Sigma authorization from 'any Sigma category' to 'Sigma 1 category and 'Sigmas 1, 3, 3V, 4, 11, 12 and 13' to 'Sigma 1.'
RATIONALE: The long-standing requirements of Q clearance and Need to Know provide proven, adequate security for Sigmas 3, 3V, 4, 11, 12 and 13. In contrast, the drafted requirement would impose a significant addition in measures and recordkeeping to be performed with a doubtful improvement in security.

EXAMPLES: Order 471.X 4e(1) Authorization for personnel to access Sigma 1 category will be granted.
4e(2) Authorization for DOE or NNSA personnel to access Sigma 1 category.
5f(3) Grants or denies waivers or deviation requests from the requirements of this Order, the CRD, or Masnual 471.X-Y, relating to Sigma 1 material.
(15) Using WDACS provides authorization to access Sigma 1 NWD. <16> Grants and records in WDACS authorization to access Sigma 1 NWD. <17> Grants and records in WDACS authorization to access Sigma 1 NWD.
g(1) Designate from each access to Sigma 1 NWD.
(5) Coordinate access of Sigma 1 NWD.
(7) Ensure that documents in their custody containing Sigma 1 NWD.
i(1) Designate from each field element access to Sigma 1 NWD.
(2) Ensure that the data in access to Sigma 1 NWD.

The Order needs to clearly state that it does not cover Sigma 14 and 15 which is covered by DOE Manual 452.4-1.
The requirement to protect Computer Systems that contain NWD the same as for other media may be an impact to Computer Systems at SNL/NM. For example, the IMS/CMS databases on the SCN contain NWD; the draft order would require that all users be certified for NWD; that is not the case now. It may be difficult to partition the NWD in these databases to control access.
Sigma 20 will probably be better handled in the same Manual (or similar manual) that covers Sigma 14 and 15 since it parallels requirements for Sigma 14 and 15.
Sigma 20 Site Coordinators and Sigma Authorizing Officials have overlap in responsibilities. Also, this appears to be a major resource impact to SNL/NM.
Many of the responsibilities under Manager, Classified and Controlled Information Division, NNSA Service, are better suited under Assistant Deputy Administrator for Military Applications and Stockpile Operations since they are more intimately involved with NWD and therefore should control access to NWD. Delegate Ashley McConnell for Sandia National Laboratories To avoid significantly hampering efficient and economical performance: RECOMMENDATION Change, through out the Order and Manual, the required Sigma authorization from “any Sigma category” to Sigma 1 category and “Sigmas 1, 3, 3V, 4, 11, 12 and 13” to “Sigma 1.” RATIONALE The long-standing requirements of Q clearance and Need To Know provide proven, adequate security for Sigmas 3, 3V, 4 11, 12, and 13. In contrast, the drafted requirement would impose a significant addition in measures and recordkeeping to be performed with a doubtful improvement in security. EXAMPLES: DOE O 471X 4e(1) Authorization for personnel to access Sigma 1 category will be granted … 4e(2) Authorization for DOE or NNSA personnel to access Sigma 1 category, … 5f(3) Grants or denies waivers or deviation requests from the requirements of this Order, the CRD, or DOE M 471 X-Y, relating to Sigma 1 material … (15) Using WDACS, provides authorization for the transfer of Sigma 1 NWD … (16) Grants, and records in WDACS, authorization to access Sigma 1 NWD … (17) Grants, and records in WDACS, authorization to access Sigma 1 NWD … g(1) Designate from each … access to Sigma 1 NWD … (5) Coordinate access … of Sigma 1 NWD … (7) Ensure that documents in their custody containing Sigma 1 NWD i(1) Designate from each field element … access to Sigma 1 NWD … (2) Ensure that the data in … access to Sigma 1 NWD …]]>