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NNSA approves ACREM policy changes

National Nuclear Security Administration Director Linton Brooks recently approved four of the five changes Los Alamos had requested in order to “normalize” accountable classified removable electronic media (ACREM) operations at the Lab. The Laboratory requested the changes to the current requirements because security specialists identified issues that hindered effective implementation of the classified media library model at the Laboratory.

In a mid-January letter, the Security and Safeguards (S) Division Leader Jack Killeen asked for the following changes:

• To change the limit of two classified library custodians for each classified media library. Killeen asked that each library be allowed to determine the appropriate number of custodians to ensure efficient and secure operations. Because some libraries serve many customers and have numerous transactions per day, the limit of two classified library custodians strains the ability to meet programmatic needs and may fail to provide the intended redundancy.
• To change the requirement that checked-out ACREM items must be returned to the library by the end of the workday. Killeen asked for ACREM to be allowed to be stored outside the CML if it was in an approved General Services Administration container and that the situation constituted a clearly defined operational need. Killeen’s rationale explained that sometimes this would be necessary in order to conduct programmatic missions that may extend beyond normal working hours.
• To change the requirement of locking containers storing ACREM when not immediately in use. The Los Alamos request letter asked for the change to allow containers to remain unlocked when a custodian directly supervises them and secure the container if the CLC is not present. The January letter to Brooks stated that the requirement to secure the file cabinets or safes between transactions is overly restrictive and impedes the operations of busy CMLs making transactions in each instance intolerably long.
• To repeal the prohibition on reproducing ACREM or provide a better definition of the word “reproduction.” The request letter states that this requirement contradicts the operational requirement to create backups of vital data and the simultaneous work by geographically separated teams or workers.
• To change the Los Alamos-specific requirement of conducting an inventory on a daily basis. Killeen requests that the change include that all ACREM that has been checked out and returned during a business day be inventoried daily by a “transaction to holdings” comparison and that all ACREM within a container that has been accessed during a business week will be inventoried weekly. The letter also requested that inventories be waived if the container has not been accessed since the previous inventory. The reason, explained in the letter, was that daily inventories would be dominated by rechecking thousands of undisturbed ACREM, requiring significant time and effort that may force CMLs to close early in order to conduct such inventories.

“We have made considerable progress in implementing an effective accountability system and the control measures inherent in the centralized library approach go a long way in erasing the weaknesses of past approaches to ACREM accountability,” Killeen said in the January letter.

In Brooks’ Feb. 14 letter to the Lab, through the Los Alamos Site Office, Brooks approved the revised procedures with some caveats and one disapproval.

Request number one was approved with the caveat that the Laboratory must ensure that media libraries that have more than two custodians must have no more than is absolutely necessary to perform operations.

Brooks did not approve request number two: the request to allow ACREM outside the centrally approved storage setting, stating that he may be willing to revisit the issue if the Laboratory can prove a sustained performance in controlling and accounting for ACREM.

The third change request was approved without any caveats. For the fourth issue, Brooks promised additional guidance of what constitutes reproduction of ACREM. And the fifth request was approved if a positive verification, such as a seal or lock audit feature, is used to ensure that the container has not been accessed since the last inventory.

“We are working to achieve proper balance between tight control of ACREM and ease of operational use,” Killeen said. “These approvals help considerably. We expect another inspection of our ACREM system at the end of March, and we hope to demonstrate at that time that our system is tight enough to enable NNSA to support the one request they were not prepared to approve at this time.”

--Kathy DeLucas

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