DOE Property Order Update – Changes for High Risk Property Krystee Conaway Global Nuclear Security Technology Oak Ridge National Laboratory
2Managed by UT-Battelle for the U.S. Department of Energy DOE Property Order Update Objectives When does this become effective? What are the significant changes concerning high risk property? What does this mean for your facility?
3Managed by UT-Battelle for the U.S. Department of Energy DOE Property Order Update New revision took effect on March 30, 2012 Implementation date up to your OPMO and CO Some sections are tied to 3.3 of the acquisition guide
4Managed by UT-Battelle for the U.S. Department of Energy DOE Property Order Update Accountable Property Records Requirements High Risk Personal Property Identification and Control Disposition of Property / End-Use Certificates Foreign Transactions Package Requirements Significant Changes
5Managed by UT-Battelle for the U.S. Department of Energy DOE Property Order Update High Risk Designation Export Control Jurisdiction Relevant Export Regulation Citation* Accountable Property Records * ECCN or Munitions List #, etc. Accountable Property Records Requirements
6Managed by UT-Battelle for the U.S. Department of Energy DOE Property Order Update If the ECCN requirement becomes official, you may not be very popular with some of your co-workers (procurement, researchers, etc.) YOU EVERYBODY ELSE
7Managed by UT-Battelle for the U.S. Department of Energy DOE Property Order Update NEW High Risk Personal Property Identification and Control High Risk Personal Property Identified at acquisition Identified at modification Controlled through disposition
8Managed by UT-Battelle for the U.S. Department of Energy DOE Property Order Update Form Trigger List items Exemption from Destruction Transfers, Sales, Other Dispositions Form Trigger List items Form Dual-Use List items Previous version of Order Current version of Order New Requirement for DOE End-Use Certificate Form Disposition of Property / End-Use Certificates
9Managed by UT-Battelle for the U.S. Department of Energy DOE Property Order Update New Requirement for DOE End-Use Certificate Form *Could cause significant problems for auctions Storing until approval Buyers reluctant to complete form – reduce sales Collecting and handling PII Disposition of Property / End-Use Certificates
10Managed by UT-Battelle for the U.S. Department of Energy DOE Property Order Update Forms and Letters Complete Package May not need to complete package if item is on pre-approved “procurement list”. FOREIGN TRANSACTIONS PACKAGE REQUIREMENTS
11Managed by UT-Battelle for the U.S. Department of Energy DOE Property Order Update 1. Request to transfer, abandon or loan2. High Risk Certification (unless purchased by a third country3. Include description, quantity and acquisition cost4. Export control and hazardous reviews5. Copy of international agreement6. Foreign entity property acceptance letter7. Completed property loan agreement F HQ program office concurrence letter9. OPMO review and approval letter for DOE. (not applicable for NNSA)10. CO concurrence (if applicable, not required for NNSA) FOREIGN TRANSACTIONS PACKAGE REQUIREMENTS
12Managed by UT-Battelle for the U.S. Department of Energy DOE Property Order Update Questions or Comments? It all depends on what you negotiate with your OPMO and CO The bottom line is