Transcript Slide 1

Approval Sheets
2
Export Controlled
Information
3
MODULE #80183
R E V. F 0
FSS-4121
ISMS
4
 The Integrated Safety Management
System (ISMS) is a systematic,
common sense approach to working
safely. The objective of ISMS is to
integrate working safely into
management and work practices at all
levels, addressing all types of work
and all types of hazards to ensure
safety for the workers, the public, and
the environment. ISMS integrates
working safely into planning and
execution of work.
Purpose
5
 This procedure establishes guidelines, security
measures, and practices for the handling and control
of “export controlled information” (ECI), in all forms
[such as documents, data, and matter (equipment,
tools, etc.)].
Scope
6

This procedure applies to all DOE contractors at PORTS (including subcontractors) who handle
ECI (in any form — including information, material, equipment, etc.).

This procedure applies to ECI that is also company proprietary.

This procedure applies to ECI that is also unclassified controlled nuclear information (UCNI),
in conjunction with FSS-4117, Processing Unclassified Controlled Nuclear Information (UCNI)
at Portsmouth.

This procedure does not apply to ECI that is also classified information. (While classified
information may also be ECI, “classified” controls take precedence and provide more than
adequate control for ECI; thus, it is not necessary to also apply ECI controls.)

At time of writing, contractors at PORTS could encounter ECI primarily through
decontamination and decommissioning (D&D) records (in hard copy and electronic format),
certain legacy records and documents, and the computerized management systems that house
some of those records/documents or their indexes. Additionally, contractors could potentially
encounter ECI through new documentation (e.g.-such as procurements) and through disposal
(e.g. during D&D). Contractors should contact the WEMS facility support serviced (FSS) export
control coordinator for guidance as needed.
Other Documents Needed
7
 FSS/PORTS-0306, Style Guide
 FSS-4109, Unclassified Controlled Information Manual
for the Formerly Operating Portsmouth Gaseous
Diffusion Plant Piketon, Ohio
 FSS-4330-Reporting Security Incidents and Conducting
Inquires to Incidents of Security Concern
 FSSF-4108, Export Controlled Information (ECI) Cover
Sheet
Identifying ECI
8
 Note: Two major categories of ECI exist — “trigger list” items and “dual
use” items. The following lists provide examples of ECI. However, the
items comprise only general categories; the WEMS FSS export control
coordinator can provide more precise guidance on ECI criteria.
 Major categories of ECI “Trigger List” items that PORTS







contractors may encounter
Unclassified information on gaseous diffusion assemblies and components,
such as:
Barriers
Diffuser housings
Compressors
Gas blowers
Rotary shaft seals
Heat exchangers
Identifying ECI
9
 Unclassified information on gaseous diffusion






auxiliary systems, equipment, and components such
as:
Feed systems
Product and tails withdrawal systems
Header piping systems
Vacuum systems
Shut-off and control valves
Mass spectrometers and ion sources
Identifying ECI
10
 Major categories of ECI “Dual Use” items that PORTS









contractors may encounter
Contractors may encounter dual-use information about:
High-strength aluminum or maraging steel, beryllium, bismuth,
boron, calcium, chlorine trifluoride, “fibrous or filamentary
materials” and pre-pregs, hafnium, lithium, magnesium, radium,
titanium, tungsten, zirconium, nickel powder, tritium, helium-3,
and alpha-emitting radionuclides.
Corrosion-resistant valves
Direct current high-power supplies (100 volts or greater)
Corrosion-resistant pressure instruments
Large vacuum pumps
Certain seals
Pressure transducers
Mass spectrometers
Identifying ECI
11
 NOTE: All personnel should review the major
categories of trigger list and dual-use list items that
may be encountered (shown above), to know when to
invoke ECI reviews. However, only designated
personnel are authorized to perform ECI reviews.
Documents
12
 NOTE: Documents containing ECI must be generated on DOE certified and
accredited computer systems and must be reviewed by a WEMS FSS designated ECI
reviewer [or, for centrifuge or depleted uranium hexafluoride (DUF6) information,
the applicable company’s security personnel] prior to distribution (because all
reviewers must meet applicable security criteria — e.g., a clearance, need to know,
designation as a “US person” [see Appendix A] government direct or subcontract
employment, etc.).
 NOTE: Contractors at PORTS may need to purchase items (e.g., software) that,
once in place, could allow the supplier to gain access to ECI (e.g., electronic
records); such procurements must first undergo ECI review, as many suppliers are
considered foreign persons.

NOTE: Contractors likely will never need to turn ECI over to suppliers during a
bidding or purchase process; if such an occasion arose, ECI controls must be flowed
down to all bidders/suppliers (e.g., via terms and conditions) and an ECI review of
any technical information distributed must be obtained.
Documents
13
Employee/Subcontractor:
 Contact the FSS export control coordinator for guidance before drafting a document
that may incorporate or address any item on the trigger list or dual-use list above.
INFCIRC 254, If in doubt whether your document may address a listed item, then
consult the FSS export control coordinator before initiating a draft.
 If your document involves a procurement action (RFP, RFI, etc.), then also consult
your respective contracts/procurement manager to ensure ECI controls are
properly flowed down to intended recipients.
 NOTE: Some listed items also apply for gaseous centrifuge and DUF6 technologies,
which are controlled by other companies on site and thus fall outside the purview of
the FSS export control coordinator.
 If you receive or intend to reference any listed information pertaining to centrifuge
or DUF6, then contact those companies for guidance regarding use and security
reviews of their ECI (preferably, use the site’s “shared-site process”—but at least
formally document all correspondence via letter or memo, and track resolution).
Documents
14
 If your document likely contains ECI, then obtain
review from a designated ECI reviewer before
distributing the document for review.
 For a list of designated FSS ECI reviewers, consult
the list maintained on the security tab of the WEMS
intranet portal, or contact the FSS export control
coordinator.
 If the classification office deems that the document
contains ECI, then proceed to FSS-4121 section B.1
(to handle the document as ECI). Otherwise, exit
this procedure.
Matter (Materials, Equipment, Tools, Etc.
15
 If you encounter any item on the trigger list or dual-
use list in Section A above (and the item is not
marked or is exempt from marking as a major
system component), then contact the FSS export
control coordinator to obtain an ECI review of the
item.
 If the item is determined to be ECI, then mark the
item per FSS-4121 section B.2.
MARKING ECI
16
Documents
Employee /Subcontractor:


Ensure any document determined to contain ECI has the following markings:
FSS-4109

NOTE: “Cognizant program manager” refers to the appropriate DOE Headquarters program
manager.

EXPORT CONTROLLED INFORMATION
Contains technical information whose export is restricted by statute. Violations may result in
administrative, civil, or criminal penalties. Limit dissemination to US Department of Energy
employees and contractors and other US government agencies. The cognizant program
manager must approve other dissemination. This notice shall not be separated from the
attached document.
Reviewer (Signature): ____________________________
Date: _______________
Figure 1. Example of ECI Document Marking
Marking ECI
17
 Ensure that all documents containing ECI are properly
reviewed and marked with the information in Figure 1 [to
include the reviewer (signature) block and date, on the
front cover or the bottom of the first page of the
document.
 Ensure “Export Controlled Information” or if space is
limited, “ECI,” is placed at the bottom of each page, or on
just those pages containing ECI.
 If desired, attach FSSF-4108, Export Controlled
Information (ECI) Cover Sheet.
Marking ECI
18
 Mark documents (purchase orders, transmittal letters, drawing lists,
etc.) that do not contain ECI, but that transmit or refer to items that
do, as follows:
 Document/material transmitted contains:
information)
(Element [type] of
When separated from enclosures, this transmittal document is not:
(Element [type] of information)
NOTE: ECI handling requirements (e.g., for faxing, emailing, etc.)
still apply to non-ECI documents transmitted with ECI items.
 Ensure that all ECI removable media are marked with the words
“EXPORT CONTROLLED INFORMATION.”
MARKING ECI
19

Caution: The originator of ECI document(s) is responsible for ensuring that the document(s)
are reviewed and properly marked. (These documents may also include item descriptions on
requisitions, drawings, specifications, and statements of work.) Note: In some cases, it may be
advantageous to mark documents as not containing ECI. (Examples may include documents
reviewed for ECI during an audit.) However, use of such markings constitutes a bestmanagement practice and is not driven by regulations or by contract.

At the discretion of the ECI reviewer, mark documents found not to contain ECI as follows, at
the bottom of either the cover or title page:
This document does not contain
export controlled information (ECI).
ECI reviewer:
Date:
Figure 2. Example of Marking To Indicate Document Does Not Contain ECI
(Used Only at the Discretion of the Export Control Coordinator)
Marking ECI
20
 Matter
Employees/Subcontractor:
 Mark ECI or tag ECI matter [e.g., hardware, tools, products,
and materials whose characteristics (dimensions,
configuration, etc.) comprise ECI].
 Exception: Marking and tagging is not required for ECI that
has been destroyed beyond its intended use.
 Ensure ECI markings are securely affixed, legible, and
conspicuous (from more than one angle if appropriate).
 Direct any questions regarding marking and labeling of ECI
matter to the FSS export control coordinator.
 Contact the FSS export control coordinator to identify and
implement any other requirements for ECI matter (e.g.,
concerning visibility, etc.).
Managing ECI Internally
21
 NOTE: This section applies strictly to internal activities (that




is, activities limited to persons who meet all of the following
criteria (per Appendix B):
Is a US person and
Has a need to know (determined by WEMS Security) and
Is an employee, contractor, or subcontractor of:
DOE or
A US federal agency funding DOE work or
A potential supplier to which appropriate ECI controls have
been flowed down
Any external activities (that is, activities involving foreigners;
see Appendix A for examples) require an export license; in
absence of an export license, such activities constitute
unauthorized disclosure and must be reported immediately.
Generating Hard-Copy ECI Documents
22
Employee/Subcontractor:
 Print ECI documents using a standard unclassified
printer, if desired.
 Reproduce ECI documents using a standard unclassified
copying machine, if desired.
 Limit the number of print-outs/copies to the minimum
needed.
FSSF-4108
 Ensure ECI prints/copies are marked and protected in
the same manner as the original(s). FSSF-4108
 Do not leave prints/copies of ECI unattended on the
printer or copying machine.
Generating Hard-Copy ECI Documents
23
 If the printer/copier jams, then ensure all paper paths
are checked/cleared of ECI. FSSF-4108
 Manually clear the printer or copier memory.
NOTE: Do not place ECI in trash cans or recycling bins.
ECI may be placed in locked shred bins authorized for
on- site shredding.
 Destroy any partial prints/copies in accordance with
Section C.4.
 If necessary to have ECI reproduced off-site by a
commercial vendor, then contact
Contracts/Procurement to ensure appropriate controls
are flowed into subcontracts and purchase orders.
Transmitting ECI Documents
24
 Hand-Carrying ECI Documents
Caution: The authorized individual(s) must
prevent unauthorized access to ECI in transit.
Employee/Subcontractor:
 If hand-carrying or personally transporting ECI
(on or off site), then:
Conceal the ECI in a briefcase, piece of hand-carried luggage, or other
opaque covering that will prevent unauthorized access.
Ensure an authorized user remains in control of it during transit.
FSSF-4108
Transmitting ECI Documents
25
 Mailing ECI Documents
Employee/Subcontractor:
 Place ECI in an opaque envelope and seal the envelope. FSSF-4108
 Mark the outside of the envelope with the words “To Be Opened
By Addressee Only.”
FSSF-4108
If transmitting ECI via the unclassified Plant mail system, then place the
marked envelope in a normal intra-plant mailing envelope addressed to the
intended recipient.
FSSF-4108
If sending ECI off site, then utilize the US postal service (first class,express,
certified, or registered mail) or any US commercial carrier that requires a
recipient’s signature (Federal Express; United Parcel Service, etc).
FSSF4108
Transmitting ECI Documents
26
 Faxing ECI Documents
Employee/Subcontractor:
 Before using a standard, unclassified machine to fax ECI, contact
the intended recipient and verify that he/she is available to
receive the fax and control access to it.
FSSF-4108
 Attach a cover sheet to the fax that identifies the intended
recipient, indicates that ECI is being transmitted, and specifies
the total number of pages (including the coversheet).
FSSF-4108
 Immediately after transmitting the fax, contact the intended
recipient again:
Verify that he/she received the fax.
FSSF-4108
Request him/her to manually clear the memory on his/her fax machine.
FSSF-4108
 Manually clear the fax memory on your fax machine.
FSSF-4108
Transmitting ECI Documents
27
 Emailing ECI Documents
Employee/Subcontractor:
 Encrypt all ECI via Entrust before emailing it.
Emails containing or transmitting ECI should be encrypted whenever
possible, regardless of who the recipient is, what email address is used, or
what computer/server the email is sent from/to. If the email itself contains
ECI, then enter verbiage such as “This email contains export controlled
information” in the first line of the message body.
FSSF-4108
If encryption is not available, ECI may be included in a Word or PDF file
that is password protected and attached to the e-mail message. Call the
recipient with the password so that he or she can access the file.
 If the email itself contains no ECI but transmits an attachment that does,
then enter verbiage such as “Attachment contains export controlled
information” in the first line of the message body.
FSSF-4108
Transmitting ECI Documents
28
 Communicating ECI Via Telephone
Caution: Speaker phones should be avoided except in controlled
environments (e.g., closed offices, conference rooms, etc.).
Caution: Cellular (mobile) phones shall not be used to discuss ECI.
Employee/Subcontractor:
 Before discussing ECI by standard, land-line telephone (do not use a
cell phone), ensure the following conditions are met:
Verify that the phone is not on speaker (unless the phone is in a controlled environment).
Verify that the person being called is authorized to receive the information and has a
need to know.
Verify (to the extent practical) that no one without a need to know can overhear the
conversation (e.g., be sensitive to the fact that often sound carries outside of rooms and
through walls even when doors are closed; use caution when discussing ECI in areas
where people have offices nearby or tend to congregate).
Storing ECI
29
 Storing ECI
Employee/Subcontractor:
 Treat suspected ECI the same as ECI.
 Electronic Media
Employee/Subcontractor:
 Use only DOE-owned removable media (CD/DVDs, USB
drives, etc.).
 If you physically control an encrypted, WEMS-managed
laptop, then store ECI on the laptop without further
encryption if desired. (WEMS-managed encrypted
laptops automatically encrypt all data at rest.)
Transmitting ECI Documents
30
 Encrypt all other ECI and suspected ECI with Entrust (or DOE-
authorized equivalent).
Do not store ECI or suspected ECI unencrypted on a company
network (e.g., “M drives,” “home drives,” or departmental areas
unless access is restricted specifically to personnel having a need to
know).
Do not post ECI or suspected ECI (even when you encrypt it first) to
internet sites that are openly accessible to all employees or to the
public.
Encrypt ECI and suspected ECI before storing it on removable
media (e.g., CDs, DVDs, USB drives, etc.).
 Mark and control removable media containing ECI (regardless of
location) to ensure only authorized individuals with a need to know
can access the media.
Storing ECI
31
 Hard Copies
Employee/Subcontractor:
Note: Do not read or display ECI in public places (e.g.,
cafeteria, lobby, public transportation, etc.)
 ECI must be reasonably protected to prevent access by
persons who do not have the need to know the
information to perform their jobs or other DOE
authorized activities.
 Documents must be stored in a locked room or other
locked receptacle (e.g., a locked file cabinet, desk,
bookcase, or briefcase) when not in use.
FSSF-4108
Destroying ECI
32
Caution: In all cases, the person possessing ECI is responsible for protecting it.
Employee/Subcontractor:
 Dispose of ECI documents using a crosscut or strip shredder with residue not
exceeding ¼ inch. Destruction must occur prior to off-site recycling processes.
(Do not place ECI in trash cans or unlocked recycling bins, it may be placed in
the locked shred bins for onsite shredding)
FSSF-4108
 Destroy ECI on CDs/DVDs using a shredder designed to accommodate disks.
 Contact Security to destroy all other types of electronic media.
 Destroy ECI matter (e.g., equipment and materials) beyond its intended use or
design; contact the FSS export control coordinator for specific guidance on
proper destruction methods.
 During destruction, protect ECI from being viewed by unauthorized persons.
DISCLOSING ECI EXTERNALLY
33
 Obtaining ECI Export Licenses
 NOTE: The FSS export control coordinator processes all
requests for export licenses, which can be granted only
by the Department of State, Department of Commerce,
Nuclear Regulatory Commission, or secretary of energy.
(WEMS has no authority to issue an export license.)
 NOTE: Appendix A provides examples of “US persons”
and “foreign persons.”
 Caution: In all cases, the person possessing the ECI is
ultimately responsible for ensuring its protection.
Penalties for unauthorized disclosure of ECI can be quite
severe and include substantial fines (e.g., $1,000,000),
prison terms, or both.
Obtaining ECI Export Licenses
34
 Contact the FSS export control coordinator to obtain
an export license before transferring ECI to:
A foreign national, including one within the US — i.e.,
a “deemed export”
A foreign government
A foreign-owned company
A foreign organization (e.g., United Nations, etc.)
US agents of foreign governments or foreign owned
companies
Do not transfer any ECI until a license is granted.
If a license request is denied, then do not transfer any ECI.
Reporting Unauthorized Disclosure of ECI
35
NOTE: All discussions and documents associated with the incident must be handled in
accordance with the classification determination of an authorized ECI reviewer. (ECI reviewers
can be found on the WEMS Intranet Security page)
Employee/Subcontractor:
In person or by a secure device, immediately notify WEMS Security (per FSS-4330, Reporting
Security Incidents and Conducting Inquires to Incidents of Security Concern) if you suspect
any of the following:
ECI has been released to the public (see FSS/PORTS-0306 for further criteria regarding public
release).
ECI has been released to an entity without a need to know.
Technical information has been released to suppliers without having been reviewed for ECI.
ECI has been released to suppliers without a mechanism in place to flow down ECI
requirements.
ECI has been released to a foreign national or agent of a foreign national without an export
license in place.
Reporting Unauthorized Disclosure of ECI
36
 After notifying WEMS Security, take the following steps as
appropriate to contain the release:
Attempt to retrieve the ECI.
Identify the means of release.
Attempt to identify the persons involved in the release.
Records
Records generated or received must be submitted to WEMS RMDC for
record retention and disposition according to FSS-1300, Record Life Cycle
and Retrieval. WEMS employees and contractors must not conceal or
destroy any information, including non-compliance or potential noncompliance records. (Reference: 18 U.S.C. 2071, Unauthorized Removal
and/or Destruction of Records).
SOURCE DOCUMENTS
37
 10 CFR 110, “Export and Import of Nuclear Equipment and






Material.”
10 CFR 810, “Assistance to Foreign Atomic Energy Activities.”
15 CFR Subchapter C, “Export Administration Regulations,”
Parts 730–774 (especially Parts 734, 744, and 774).
22 CFR 121, “The United States Munitions List.” US
Department of State, Defense Trade Controls – US Munitions
List Categories.
22 CFR Subchapter M, “International Traffic in Arms
Regulations,” Parts 120–130 (especially Category 16).
42 USC Sect. 2011 et seq., “Atomic Energy Act of 1954, as
amended.” August 1, 1946.
DOE O 471.6, Admin change 1, Information Security.
US Department of Energy, Washington, DC. June 20, 2011.
SOURCE DOCUMENTS
38
 FSSF-4108, Export Controlled Information (ECI) Cover Sheet
 FSS/PORTS-0306, Style Guide, rev. 0. Wastren-EnergX Mission Support LLC,





Piketon, OH. December 2010.
FSS/PORTS-0307, Glossary, rev. 0. Wastren-EnergX Mission Support LLC,
Piketon, OH. December 2010.
FSS/PORTS-4109, Unclassified Controlled Information Manual for the Formerly
Operating Portsmouth Gaseous Diffusion Plant Piketon, Ohio. October 2012.
Guidelines on Export Control and Nonproliferation, US Department of Energy,
Office of Nonproliferation and National Security, Office of Arms Control and
Nonproliferation. July 1999.
INFCIRC/254/Rev.5/Part2, Communications Received from Certain Member States
Regarding Guidelines for Transfers of Nuclear-Related Dual-Use Equipment,
Materials, Software, and Related Technology. International Atomic Energy Agency.
May 16, 2003.
INFCIRC/254/Rev.6/Part1, Communications Received from Certain Member States
Regarding Guidelines for the Export of Nuclear Material, Equipment, and
Technology. International Atomic Energy Agency. May 16, 2003.
DEFINITIONS
39














CD — Compact Disk
D&D — Decontamination and Decommissioning
DOE — United States Department of Energy
DUF6 — Depleted Uranium Hexafluoride
DVD — Digital Video Disk
ECI — Export Controlled Information
FSS — Facility Support Services
PORTS — Portsmouth Gaseous Diffusion Plant
RMDC — Records Management and Document Control
UCNI — Unclassified Controlled Nuclear Information
BWCS — Babcock & Wilcox Conversion Services
US — United States
USB — Universal Serial Bus
WEMS — Wastren-EnergX Mission Support LLC
DEFINITIONS
40
 Deemed Export — The release of ECI to a foreign national in the US. (An
export license must be obtained from the appropriate US government
agency prior to the release of ECI to any foreign national, regardless of
where the foreign national is physically located.)
 Dual-Use Items — Items that have both commercial and military or
proliferation applications (that is, items or information on items not
normally used in the production of enriched uranium but that could be
converted for use in the proliferation of nuclear weapons; see Section A of
this procedure for items WEMS may encounter).
Adapted from 15
CFR 772, 734.2(a)
 ECI Matter — ECI in the physical form of materials, equipment,
apparatus, tools, etc.
 ECI Reviewing Official — Individual delegated and authorized inwriting by the DOE representative of Oak Ridge National Laboratories
office of Non-Proliferation and International Security to perform ECI
reviews of unclassified data to ensure protection of national security
against proliferation of nuclear interests.
DEFINITIONS
41
 Export Controlled Information (ECI) — Unclassified technical





information (such as documents, computer media or code, information,
data, material, equipment, apparatus, tools, etc., or some combination
thereof) that is subject to export-control laws (primarily under the Export
Administration Regulations, 15 CFR 730 – 774) and whose unrestricted
dissemination could help proliferants or potential adversaries of the United
States. The Department of Energy requires an ECI review before public
release of such information and may restrict dissemination of it.
Internal distribution — Dissemination to US persons who have a need
to know and who are employees or subcontractors of:
Adapted from
FSS-4110
WEMS or
DOE (the US federal agency funding WEMS’s work) or
A potential supplier to which the WEMS has flowed down ECI controls
Need To Know — A determination made by the WEMS classification
officer or security manager that a prospective recipient requires access to
specific unclassified controlled information to perform his or her job.
DEFINITIONS
42
 Public Release — Release to the public (accessible to any person),





or such widespread internal distribution that release to the public is
likely. Examples of public release include: Adapted from FSS-4110
Request for proposal, expression of interest requests, and purchase
requisitions
Newspaper publications or TV/radio presentations
Publication to an internet web site
Presentation to a conference or committee outside those who have
access authorization and a “need to know,” where the information
could be published or open to the public, specifically foreign
nationals
Any information (drawings, presentations, etc.) forwarded to a
vendor, manufacturing partner, contractor, or potential service
provider with whom WEMS does not have appropriate procurement
controls in place and who may have foreign nationals working for
them (unless a specific exception is authorized in writing by DOE).
DEFINITIONS
43
 Trigger List Items — Items or information on
items determined to be essential to any effort to
proliferate nuclear weapons (see Section A of this
procedure for items WEMS may encounter).
 Unclassified Controlled Nuclear Information
(UCNI) — A DOE administrative control marking,
established by Section 148 of the Atomic Energy Act,
which prohibits the distribution of certain types of
unclassified information to both the general public
and foreign individuals.
Appendix A/ US Persons Versus Foreign Persons
44
Entity
US person *
All Others
Company incorporated in the US (e.g., WEMS)
License not needed
Export license needed
government entity (e.g., DOE, DoD, EPA,
DOT, NRC)
Company incorporated/organized outside the
(e.g., Boeing Toronto, Ltd.; Areva)
Foreign government entity (e.g., Royal Air
Force of the )
Foreign organization (e.g., NATO, UN, EU)
License not needed
Export license needed
Export license needed
Export license needed
Export license needed
Export license needed
Export license needed
Export license needed
Appendix A/ US Persons Versus Foreign Persons
45
* Includes US citizens, US nationals, permanent resident aliens (“green card”
holders), alien refugees, aliens granted asylum, amnesty applicants, and special
agricultural workers.
 Definitions:
US = United States; WEMS = Wastren-EnergX Mission Support LLC; DoD = US
Department of Defense; EPA = US Environmental Protection Agency; DOT = US
Department of Transportation; NRC = US Nuclear Regulatory Commission; UK =
United Kingdom; NATO = North Atlantic Treaty Organization; UN = United
Nations; EU = European Union.
 Terminology explained:
 US citizen – native-born or naturalized citizen of the United States.
 US national – citizen of a US possession that does not have statehood, such as
Puerto Rico, Guam, American Samoa, etc.
 Permanent resident alien – also known as “green card” holder. Holds I-151 or I551 document.
 Alien refugees – granted refugee status; holds I-571 document.
 Alien granted asylum in the US – granted asylee status.
 Special agricultural worker/amnesty applicant – someone admitted for temporary
residence in one of these categories. Holds I-688 document (not I-688A or I-688B).
Appendix B/ Who can Access WEMS ECI
Without a License
46
 Anyone who meets all of the following criteria can have access to WEMS
ECI without an export license:
Is a US person and
Has a need to know (determined by the WEMS FSS security department’s
mission support services manager or the FSS classification officer) and
Is an employee or subcontractor of:
WEMS or
A US federal agency funding WEMS’s work (i.e., DOE) or
A potential supplier to which the WEMS Contracts/Procurement
department has flowed down ECI controls (e.g., via contract terms
and conditions)