9. Do I need the licensees, You do not need the licensees, vendor’s, or applicant’s NRC authority the vendor’s, or applicant’s permission to retain these photographs for training purposes if Atomic Energy Act of permission to keep these you believe these photographs would be helpful in carrying out 1954 photographs? NRCs regulatory responsibilities. Requests by the licensee, vendor, or applicant to review photographs for classified, safeguards, or SUNSI (personal privacy or proprietary information) information should normally be honored to ensure proper classification. 10. Are training photographs Yes. MD 3.1, Freedom of subject to FOIA? Information Act 11. How should the Photographs that contain proprietary information must be 10 CFR 2.390 photographs be identified? labeled as such in accordance with 10 CFR 2.390(b) and 36 CFR 1237.28(h). should include the date and name of the facility or facility Photographs should be documented and classified as they are produced. USING PHOTOS FOR INFORMAL TRAINING QUESTION ANSWER SOURCE 12. If the photographs Yes, but only if absolutely necessary and only if the IMC 0620, “Inspection contain classified and photographs support an inspection finding (REMINDER, Staff Documents and safeguards information can reviewing such photographs must possess the appropriate Records” they still be used for training clearance levels and have a need to know). If this is the case, purposes? such photographs and or digital cameras that contain MD 12.1, NRC Facility classified and safeguards information must be secured and Security Plan agency guidance followed. Follow guidance in IMC 0620 regarding licensee, vendor, or applicant review of such MD 12.2, NRC photographs. Classified Information Security Program
9. Do I need the licensees, vendor’s, or applicant’s permission to keep these photographs? You do not need the licensees, vendor’s, or applicant’s permission to retain these photographs for training purposes if you believe these photographs would be helpful in carrying out NRCs regulatory responsibilities. Requests by the licensee, vendor, or applicant to review photographs for classified, safeguards, or SUNSI (personal privacy or proprietary information) information should normally be honored to ensure proper classification. NRC authority the Atomic Energy Act of 1954 10. Are training photographs subject to FOIA? Yes. MD 3.1, Freedom of Information Act 11. How should the photographs be identified? Photographs that contain proprietary information must be labeled as such in accordance with 10 CFR 2.390(b) and should include the date and name of the facility or facility Photographs should be documented and classified as they are produced. 10 CFR 2.390 36 CFR 1237.28(h). USING PHOTOS FOR INFORMAL TRAINING QUESTION ANSWER SOURCE 12. If the photographs contain classified and safeguards information can they still be used for training purposes? Yes, but only if absolutely necessary and only if the photographs support an inspection finding (REMINDER, Staff reviewing such photographs must possess the appropriate clearance levels and have a need to know). If this is the case, such photographs and or digital cameras that contain classified and safeguards information must be secured and agency guidance followed. Follow guidance in IMC 0620 regarding licensee, vendor, or applicant review of such photographs. IMC 0620, “Inspection Documents and Records” MD 12.1, NRC Facility Security Plan MD 12.2, NRC Classified Information Security Program
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