AAAAAAAAAAAAAAAAA 

 

U.S. Department of Energy 

Office of Inspector General 

Office of Inspections and Special Inquiries 

Inspection Report 

Removal of Categories I and II Special 

Nuclear Material from Sandia National 

Laboratories-New Mexico 

DOE/IG-0833 January 2010 

 
Department of Energy 

Washington, DC 20585 

January 15, 2010 

MEMORANDUM FOR THE SECRETARY 

FROM: Gregory H. Friedman 

 Inspector General 

SUBJECT: INFORMATION: Inspection Report on “Removal of Categories I 

and II Special Nuclear Material from Sandia National LaboratoriesNew Mexico” 

BACKGROUND

The Department of Energy's (DOE’s) Sandia National Laboratories-New Mexico 

(Sandia) develops science-based technologies in support of national security in areas such 

as nuclear weapons, nonproliferation, military technologies, and homeland security. 

Sandia's primary mission is ensuring that the U.S. nuclear arsenal is safe, secure, and 

reliable and can fully support the Nation's deterrence policy. Part of this mission includes 

systems engineering of nuclear weapons; research, design, and development of nonnuclear components; manufacturing of non-nuclear weapons components; the provision 

of safety, security, and reliability assessments of stockpile weapons; and the conduct of 

high-explosives research and development and environmental testing. Sandia 

Corporation, a subsidiary of Lockheed Martin Corporation, operates Sandia for the 

National Nuclear Security Administration (NNSA). 

On May 7, 2004, the Secretary announced that the Department would evaluate missions 

at DOE sites to consolidate Special Nuclear Material (SNM) in the most secure 

environments possible. The Administrator of the NNSA said that this effort was a key 

part of an overall plan to transform the nuclear weapons complex into a smaller, safer, 

more secure, and more efficient national security enterprise. In February 2008, Sandia 

was the first site to report it had reduced its on-site inventory of nuclear material below 

"Categories I and II" levels, which require the highest level of security to protect material 

such as plutonium and highly enriched uranium. 

The Office of Inspector General initiated an inspection to determine if Sandia made 

appropriate adjustments to its security posture in response to the removal of the 

Categories I and II SNM. 

RESULTS OF INSPECTION

We found that Sandia adjusted its security posture in response to the removal of 

Categories I and II SNM. For example, security posts were closed; unneeded protective 
2 

force weapons and equipment were excessed from the site; and, Sandia's Site Safeguards 

and Security Plan was modified. 

We also found that some highly enriched uranium in a complex material configuration 

was not removed from Sandia. This material was designated as Category III material 

using a methodology for assessing the attractiveness of complex materials that was not 

specifically addressed in any current DOE directive. Although DOE and NNSA officials 

believed that this designation was appropriate, the methodology used to support this 

designation had not, as of the time of our review, been incorporated into the DOE 

directives system. Historically, the Department has considered the categorization of 

SNM to be an important national security and public policy issue. Consequently, we 

believe that expedited action should be taken to formalize this methodology in the DOE 

directives system and that it be disseminated throughout the Department of Energy 

complex. 

MANAGEMENT REACTION

In comments to a draft of this report, the Office of Health, Safety, and Security (HSS) 

concurred with the report recommendation and identified corrective actions that have 

been and will be taken to address the recommendation. 

We consider HSS’ comments generally responsive to our report recommendation. 

However, HSS raised certain issues regarding the distinction between the publication of a 

“guide” and the promulgation of “policy.” While we recognize the point that HSS was 

making and understand the need to consider the practical impact of these kinds of 

distinctions, we believe the position that we have taken is appropriate. This matter is 

discussed more fully in the attached report. 

In comments to a draft of this report, NNSA generally agreed with the report and 

recommendation. We consider NNSA’s comments generally responsive to our report 

recommendation. 

Management’s comments are provided in their entirety in Appendix B of the report. 

Attachment 

cc: Deputy Secretary 

 Administrator, National Nuclear Security Administration 

 Chief Health, Safety and Security Officer, Office of Health, Safety and Security Office 

 Chief of Staff 

 Manager, Sandia Site Office 

 Director, Office of Internal Review (CF-1.2) 
REMOVAL OF CATEGORIES I AND II SPECIAL NUCLEAR 

MATERIAL FROM SANDIA NATIONAL LABORATORIES-NEW 

MEXICO

TABLE OF 

CONTENTS 

OVERVIEW

Introduction and Objectives 1 

Summary 1 

DETAILS OF FINDINGS 

Background 3 

Categorization of SNM 3 

RECOMMENDATION 5 

MANAGEMENT COMMENTS 6 

INSPECTOR COMMENTS 6 

APPENDICES

A. Scope and Methodology 7 

 B. Management Comments 8 
Overview

 

Page 1 Removal of Categories I and II Special 

Nuclear Material from Sandia National 

Laboratories-New Mexico 

INTRODUCTION AND The Department of Energy's (DOE’s) Sandia National 

OBJECTIVES Laboratories-New Mexico (Sandia) develops science-based 

technologies in support of national security in areas such as nuclear 

weapons, nonproliferation, military technologies, and homeland 

security. Sandia's primary mission is ensuring that the U.S. 

nuclear arsenal is safe, secure, and reliable and can fully support 

the Nation's deterrence policy. Part of this mission includes 

systems engineering of nuclear weapons; research, design, and 

development of non-nuclear components; manufacturing of nonnuclear weapons components; the provision of safety, security, and 

reliability assessments of stockpile weapons; and the conduct of 

high-explosives research and development and environmental 

testing. Sandia Corporation, a subsidiary of Lockheed Martin 

Corporation, operates Sandia for the National Nuclear Security 

Administration (NNSA). 

On May 7, 2004, the Secretary announced that the Department 

would evaluate missions at DOE sites to consolidate Special 

Nuclear Material (SNM) in the most secure environments possible. 

The Administrator of the NNSA said that this effort was a key part 

of an overall plan to transform the nuclear weapons complex into a 

smaller, safer, more secure, and more efficient national security 

enterprise. In February 2008, Sandia was the first site to report it 

had reduced its on-site inventory of nuclear material below 

"Categories I and II" levels, which require the highest level of 

security to protect material such as plutonium and highly enriched 

uranium. 

The Office of Inspector General initiated an inspection to 

determine if Sandia made appropriate adjustments to its security 

posture in response to the removal of the Categories I and II SNM. 

SUMMARY We found that Sandia adjusted its security posture in response to 

 the removal of Categories I and II SNM. For example, security 

posts were closed; unneeded protective force weapons and 

equipment were excessed from the site; and, Sandia's Site 

Safeguards and Security Plan was modified. 

We also found that some highly enriched uranium in a complex 

material configuration was not removed from Sandia. This 

material was designated as Category III material using a 

methodology for assessing the attractiveness of complex materials
 

Page 2 Summary 

that was not specifically addressed in any current DOE directive. 

Although DOE and NNSA officials believed that this designation 

was appropriate, the methodology used to support this designation 

had not, as of the time of our review, been incorporated into the 

DOE directives system. Historically, the Department has 

considered the categorization of SNM to be an important national 

security and public policy issue. Consequently, we believe that 

expedited action should be taken to formalize this methodology in 

the DOE directives system and that it be disseminated throughout 

the Department of Energy complex. 
Details of Findings 

 

Page 3 Details of Findings 

BACKGROUND DOE follows a graded safeguards program for nuclear material. 

Under this concept, a safeguards program must provide the greatest 

relative amount of control and accountability for the types and 

quantities of SNM that can be most effectively used in a nuclear 

explosive device. SNM is designated by "Attractiveness Levels" 

and "Categories." The Attractiveness Levels, which are designated 

A through E, address the chemical and physical form of the 

material (weapons, pure products, high-grade material, low-grade 

material, and all other material). The Categories, which are 

designated I through IV, are based on the Attractiveness Level and 

the amount and type of nuclear material (i.e., Pu, U-233, U-235, 

Np-237, and Am-241/243). 

Since 1994, the DOE policy applicable to the designation of SNM 

for safeguards purposes has been promulgated through DOE 

orders, manuals, and guides. For the purposes of determining 

SNM Attractiveness Levels and Categories, DOE's current policy 

is found under DOE Order 470.4A, "Safeguards and Security 

Program," and the associated Manual, DOE M 470.4-6, Change 1, 

dated August 26, 2005. Under this Manual, the "Graded 

Safeguards" table provides specific information on the chemical 

and physical form of SNM, as well as the amount and type of 

SNM, for use in determining SNM Attractiveness Levels and 

Categories. This Manual cancelled a DOE guide which had 

addressed the use of another methodology, "weight percent 

criteria," for determining SNM Attractiveness Levels and 

Categories. The "weight percent criteria," when it was part of the 

DOE directives system, had allowed DOE to consider the percent 

by weight of SNM in addition to the chemical/physical form and 

the amount/type of SNM found in the "Graded Safeguards" table. 

However, current DOE directives do not specifically address this 

methodology for use in determining SNM Attractiveness Levels 

and Categories. 

CATEGORIZATION OF We found that Sandia adjusted its security posture in response to 

SNM the removal of Categories I and II SNM. For example, security 

posts were closed; unneeded protective force weapons and 

equipment were excessed from the site; and, Sandia's Site 

Safeguards and Security Plan was modified. 

We also found that some highly enriched uranium in a complex 

material configuration was not removed from Sandia. This 

material was designated as Category III material using a 
 

Page 4 Details of Findings 

methodology for assessing the attractiveness of complex materials 

that was not specifically addressed in any current DOE directive.

Annular Core Research Sandia maintains an Annular Core Research Reactor (ACRR). 

Reactor Fuel The reactor fuel is uranium, enriched to 35 percent U-235 with 

21.5 weight-percent U02 and 78.5 weight-percent BeO. In a May 

16, 2006, e-mail to Office of the Associate Administrator for 

Defense Nuclear Security (NA-70), the Sandia Site Office (Site 

Office) stated that there was confusion with regard to the 

Attractiveness Level for the nuclear material in the ACRR. The 

Site Office stated that the current order/manual did not make any 

reference to "weight percent criteria" in determining Attractiveness 

Levels and the current manual could not stand on its own as a 

source for determining Attractiveness Levels. The Site Office 

requested policy clarification and guidance that could be used to 

direct Sandia in determining the Attractiveness Levels for the 

ACRR. 

In an e-mail dated May 17, 2006, an official from NA-70 told the 

Site Office that they could use the "weight percent criteria" in 

determining Attractiveness Levels. This official stated that "This 

is not a new issue - as soon as they deleted all references to the 

Guide to take care of the 20-50% isotopic enrichment issue in the 

Safeguards Table (which conflicted with the Guide), they 

essentially threw out the baby with the bath water as the entire 

Guide then became defunct." This official stated that the Office of 

Health, Safety and Security (HS-70) was working on policy 

revisions, but policy revisions would take significant time. 

In a June 16, 2006, Site Office memorandum, the Site Office 

acknowledged that the August 26, 2005, publication of DOE M 

470.4-6 removed all references to the Guide which contained the 

“weight percent criteria.” The Site Office stated that, “Most 

recently, this resulted in the categorization of the Annular Core 

Research Reactor (ACRR) as a Category IC SNM target.” This 

categorization was based on the "Graded Safeguards" table in DOE 

M 470.4-6, Change 1, and a March 23, 2005, NA-70 policy 

memorandum stating that uranium metal and oxides enriched to 

greater that 20 percent in the U-235 isotope should be considered 

material of Attractiveness Level B and C, respectively. The Site 

Office memorandum went on to state that NA-70 had since 

determined that the ACRR material was Attractiveness Level "D" 

versus "C," resulting in the ACRR being designated as a Category 

IIID target.
 

Page 5 Recommendation 

Policy Revisions The designation of the ACRR fuel as a Category IIID target 

Needed was based on the use of the “weight percent criteria.” However, 

DOE O 251.1C, Departmental Directives Program, Section 4d(6), 

Unofficial Guidance, states that “Existing requirements that cross 

organizational lines and apply to contractors but were not 

developed and promulgated through the formal directives process 

are to be considered invalid unless/until they have been reviewed 

and adopted through that process.” 

The Deputy Director, Office of Security Policy, Office of Health, 

Safety and Security (HS-70), told us that the guide containing the 

“weight percent criteria” was cancelled because certain aspects of 

the guide were no longer consistent with Departmental policy. 

However, this official said that the cancellation of the guide was 

unrelated to the use of weight percent in determining material 

attractiveness. This official stated that the use of weight percent 

remained a common and acceptable technical technique in the 

Material Control and Accountability community that would soon 

become an even more important technique if proposed revisions to 

the use of the Graded Safeguards Table were published. Further, 

this official stated that a working group was formed in 2008 to 

revise the manual based on current security considerations and that 

the revised policy was expected to make even greater use of weight 

percent. 

In comments to a draft of this report, the Chief Health, Safety and 

Security Officer confirmed that the “weight percent criteria” is an 

authorized methodology for determining the category and 

attractiveness level of SNM. However, as of the date of our review 

and despite the passage of considerable time, the use of the 

"weight percent criteria" methodology still had not been 

formalized in the DOE directives system, which is the mechanism 

by which Departmental policy/requirements are captured and 

disseminated. Consequently, we believe that expedited action 

should be taken to formalize this methodology in the DOE 

directives system so that the designation of the ACRR fuel as 

Category IIID is on a firm, recognizable policy foundation, 

consistent with U. S. national nuclear requirements. 

RECOMMENDATION We recommend that the Chief Health, Safety and Security Officer, 

Office of Health, Safety and Security, ensures that action is taken 

to formalize the use of the “weight percent criteria” in the DOE 

directives system and that revised guidance be disseminated 

throughout the Department of Energy complex. 
 

Page 6 Management and Inspector 

 Comments 

MANAGEMENT In comments on a draft of this report, the Office of Health, 

COMMENTS Safety, and Security (HSS) concurred with the report 

recommendation. Management identified corrective actions that 

have been and will be taken to address our recommendation. 

In comments on a draft of this report, NNSA generally agreed with 

the report and recommendation. 

Management’s comments are included in their entirety at 

Appendix B. 

INSPECTOR We consider HSS comments generally responsive to our report

COMMENTS recommendation. However, HSS stated that the report seemed to 

view publication of a guide as establishing requirements, noting 

that a guide is explicitly not policy. We would like to note that 

published manuals “supplement other directives, laws, regulations, 

or other requirements by providing more instructions or details on 

how the provisions of those directives or laws must be carried out 

throughout DOE.” The Guide associated with the previous Manual 

had provided preferred, non-mandatory supplemental information 

about the acceptable methods to meet requirements. When the 

Manual cancelled the Guide, the acceptable methods which 

included “weight percent criteria” were also cancelled. 

We consider NNSA’s comments generally responsive to our report 

recommendation. 
Appendix A 

 

SCOPE AND We conducted the majority of the fieldwork for this inspection 

METHODOLOGY between February and March 2009. Our review included 

interviews with Sandia Site Office officials, NNSA and DOE 

Headquarters representatives, and Sandia National Laboratory 

personnel. We reviewed and evaluated DOE and NNSA policies, 

the Site Safeguards and Security Plan, and related security 

documentation. We also toured Sandia’s Technical Area V. 

Pursuant to the “Government Performance and Results Act of 

1993,” we reviewed Sandia’s performance measurement processes 

as they relate to the removal of SNM from Sandia. 

This inspection was conducted in accordance with the "Quality 

Standards for Inspections" issued by the President's Council on 

Integrity and Efficiency, currently known as the Council of the 

Inspectors General on Integrity and Efficiency (CIGIE). 

. 

Page 7 Scope and Methodology 
Appendix B 

 

Page 8 Management Comments 
Appendix B 

 

Page 9 Management Comments 
Appendix B 

 

Page 10 Management Comments 
IG Report No. DOE/IG-0833 

CUSTOMER RESPONSE FORM 

The Office of Inspector General has a continuing interest in improving the usefulness of its 

products. We wish to make our reports as responsive as possible to our customers’ requirements, 

and, therefore, ask that you consider sharing your thoughts with us. On the back of this form, 

you may suggest improvements to enhance the effectiveness of future reports. Please include 

answers to the following questions if they are applicable to you: 

1. What additional background information about the selection, scheduling, scope, or 

procedures of the inspection would have been helpful to the reader in understanding this 

report? 

2. What additional information related to findings and recommendations could have been 

included in the report to assist management in implementing corrective actions? 

3. What format, stylistic, or organizational changes might have made this report’s overall 

message clearer to the reader? 

4. What additional actions could the Office of Inspector General have taken on the issues 

discussed in this report which would have been helpful? 

5. Please include your name and telephone number so that we may contact you should we have 

any questions about your comments. 

Name Date 

Telephone Organization 

When you have completed this form, you may telefax it to the Office of Inspector General at 

(202) 586-0948, or you may mail it to: 

Office of Inspector General (IG-1) 

Department of Energy 

Washington, DC 20585 

ATTN: Customer Relations 

If you wish to discuss this report or your comments with a staff member of the Office of 

Inspector General, please contact Ms. Felicia Jones at (202) 253-2162.
This page intentionally left blank. 
The Office of Inspector General wants to make the distribution of its reports as customer friendly 

and cost effective as possible. Therefore, this report will be available electronically through the 

Internet at the following address: 

U.S. Department of Energy Office of Inspector General Home Page 

http://www.ig.energy.gov

Your comments would be appreciated and can be provided on the Customer Response Form 

attached to the report.