Information Notice No. 82-46: Defective and Obsolete Combination Padlocks

                                                            SSINS No: 6835 
                                                            IN 82-46  

                               UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION 
                    OFFICE OF INSPECTION AND ENFORCEMENT 
                           WASHINGTON, D.C. 20555 

                              November 26, 1982

Information Notice No. 82-46: DEFECTIVE AND OBSOLETE COMBINATION PADLOCKS

Addressees: 

All facilities licensed pursuant to 10 CFR Parts 50 and 70, and other 
facilities or persons to whom 10 CFR Part 95 is applicable. 

Purpose: 

This information notice is provided as a timely notification of significant 
problems with combination padlocks commonly used in the protection of 
classified information (10 CFR Part 95) and otherwise sensitive information 
(10 CFR 73.21). It is expected that recipients will review the information 
for applicability to their facilities. No specific action or response is 
required. 

Description of Circumstances: 

The NRC has recently received information regarding problems with 
combination padlocks utilized for the protection of sensitive and classified 
information. The combination padlocks are manufactured by Sargent and 
Greenleaf (S&G) of Nicholasville, KY (and formerly, of Rochester, NY). The 
relevant Federal Specification is FF-P-110. The use of these combination 
padlocks is noted in Regulatory Guide 5.12 and are an acceptable means of 
complying with 10 CFR 95 and 10 CFR 73.21. These padlocks have been supplied 
under several manufacturers' model numbers and several Federal Stock 
Numbers. The current NRC-acceptable unit is S&G Model 8077A. 

Design Deficiency-1981 

The Interagency Advisory Committee on Security Equipment (GSA) identified a 
deficiency in the 1981 production units of Model 8077A. The back plate needs
to be replaced for continued acceptability. The deficient back plate is 
clearly marked "1981." The replacement back plates are available (at no 
cost) from the manufacturer at either: 

                         Sargent and Greenleaf, Inc.
                         Attn: Bill Floyd  
                         One Security Drive 
                         Nicholasville, KY 40356 
                         (606)885-9411 




8208190256 
.

                                                           IN 82-46  
                                                           November 26, 1982 
                                                           Page 2 of 3 

                         Safemasters Inc.
                         Attn:  Tom Black 
                         1800 Martin Luther King, Jr. Ave., S. E.
                         Washington, D.C. 20020 
                         (202)678-1800 

Quality Assurance Deficiency:  

A utility reported receiving a shipment of Sargent and Greenleaf (S&G) 
combination padlocks which were found to be defective. It returned the 
shipment to the supplier and was provided a replacement shipment. The 
replacement units also were defective. In light of the quality assurance 
problems associated with the S&G combination locks, the use of an acceptable
key operated padlock is a viable alternative. Acceptable key operated 
padlocks produced and qualified under Interim Federal Specification 
FF-P-001480 (GSA-FSS) (and by extension MIL-P-43607 and MIL-L-29151) have 
been tested and certified under performance criteria (surreptitious and 
forcible entry) exceeding the acceptance criteria of Federal Specification 
FF-P-110, under which the combination pad locks are produced. Further, locks
approved under Interim Federal Specification FF-P-001480 (GSA-FSS) (and by 
extension MIL-P-43607 and MIL-L-29151) have been identified in the 
Information Security Oversight Office (ISOO) Implementing Directive for 
Executive Order 12356 as acceptable for the protection of classified 
information. Regulatory Guide 5.12 states that padlocks should meet the 
minimum requirements of Underwriters' Laboratories, Inc. Standard, UL 437. 
The test requirements of the above key lock specifications exceed those of 
the UL Standard. Coincidentally, in recent years, all units produced under 
the Military Specifications have also been certified and listed by the 
Underwriters' Laboratories, Inc. 

Obsolete Combination Padlocks 

As noted above, combination padlocks have been supplied under various model 
numbers and Federal Stock Numbers. The current NRC-acceptable combination 
padlock is Sargent and Greenleaf Model 8077A. Its predecessor design was 
identified as Model 8088, appears to be currently available and is in use at
some licensee facilities. The Model 8088 units can be easily defeated, do 
not meet the terms of Executive Order 12356, are not approved by GSA, and 
are not acceptable for the protection of either classified material or 
safeguards information*. 

*Specific exceptions may be granted pursuant to 10 CFR 95.5 and 95.11 for 
 classified material, and to 10 CFR 73.2 (mm)(4) and 73.21(d)(2) for 
 Safeguards Information. 
.

                                                           IN 82-46  
                                                           November 26, 1982 
                                                           Page 3 of 3 

If you have any questions regarding these matters, please contact the 
Administrator of the appropriate Regional Office or this Office. 



                         Richard C. DeYoung, Director 
                         Office of Inspection and Enforcement 

Technical Contact:  R. F. Blackmon 
                    301-499-8081 

Attachment: 
List of Recently Issued IE Information Notices