IR 05000456/1993017
| ML20046A823 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/22/1993 |
| From: | Belanger J, Creed J, Ervin N, Madeda T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20046A819 | List: |
| References | |
| 50-456-93-17, 50-457-93-17, NUDOCS 9307300102 | |
| Download: ML20046A823 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Reports No. 50-456/93017(DRSS); 50-457/93017(DRSS)
Dockets No. 50-456; 50-457 Licenses No. NPF-72; NPF-77 Licensee:
Commonwealth Edison Company Opus West III 1400 Opus Place Downers Grove, IL 60515 Facility Name:
Braidwood Nuclear Station, Units 1 and 2 Commonwealth Edison Corporate Office, Chicago, Illinois Inspection Dates: June 21-25, 1993 Type of Inspection: Announced Access Authorization Program Inspection Inspectors: h*b
[16 7 '3 M 3 J'ames L. Belanger U
Date Senior Physical Security Inspector
% a w F-M l k'>> hJ T& ry J. Madeda
V Date Physical Security Inspector hf3 P
pcyE.Ervin Date D
tfice of Nuclear Reactor Regulation Approved By:
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/Jafnes R. Creed, Chief Date (Jafeguu. s Section
Inspection Summary Inspection between June 21 and 25. 1993 LRooorts No. 50-456/93017(DRSS):
No. 50-457/93017(DRSSH Areas Insoected:
Routine, announced Access Authorization Program inspection-
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involving Program Administration and Organization; Background Investigation Elements; Psychological Evaluations; Behavioral Observation; Grandfathering, Reinstatement, and Transfer of Access Authorization; Temporary Access Authorization; Denial / Revocation of Unescorted Access; Audits; and Records Retention.
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9307300102 930722 El PDR ADOCK 05000456
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Results:
The licensee's Access Authorization Program provides assurance that
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individuals who are authorized unescorted access to the licensee's nuclear
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plants are trustworthy and reliable, and do not constitute an undue risk to the health and safety of the public as a result of their unescorted access to the nuclear facilities. No violations were noted. The following items were considered program strengths:
Good management oversight, involvement, and support for the e
program at the corporate level (Section 4).
Documentation, research, and process for reviewing access denial
appeals (Section 10).
The following items were considered program weaknesses:
Procedural guidance regarding administration and proctoring of
psychological evaluation tests was not given to cognizant personnel responsible for conducting these activities (Section 6).
The scope of " frequent and direct" association for the developed
character references used during screening for temporary access authorizaticas was not defined (Section 8).
Procedural guidance for the protection of personal information was
not documented (Section 9.a).
Access control vulnerabilities were identified in the personal e
information protection program (Section 9.b).
In the verification of employment history, the question pertaining
to information that would adversely reflect upon the reliability
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and trustworthiness of the individual was not documented (Section 5).
Access authorization procedures did not identify measures to
ascertain activities of individuals who were away from either the licensee's or an approved contractor behavioral observation program in excess of 30 days (Section 7).
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REPORT DETAILS
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1.
Key Persons Contacted In addition to the key members of the licensee's staff listed below, the inspectors interviewed other employees, contractor personnel, and members of the security organization.. The asterisk (*) denotes those
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present at the Exit Interview conducted at the licensee's corporate
office in Downers Grove, Illinois,'on June 25, 1993.
- P. Laird, Director of Corporate Security, Commonwealth Edison Company.
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(CECO)
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- B. Saunders, Supervisor, Nuclear Security Operations, CECO
- R. Morley Jr., Nuclear Security Administrator, CECO
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S. Roth, Station Security Administrator, Braidwood Station, CECO
- F. Wirkus, Access Authorization Program Coordinator, CECO
- D. Ringo, Senior Nuclear Security Specialist, CECO
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- B. Pierson, Nuclear Security Specialist, CECO
- P. Zurawski, Quality Verification, CECO
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- M. Dillingham, Senior Nuclear Security Specialist, CECO
- S. Rooney, Assistant Security Administrator, Braidwood Station, CECO
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- G. Toleski, Fitness For Duty Program Administrator, CECO 2.
Entrance and Exit Interviews
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a.
At the beginning of the inspection, Mr. P. Laird and other members
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of his staff were informed of the purpose of the inspection, its
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scope, and the areas to be examined.
b.
The inspectors met with the licensee representatives, denoted in
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Section 1, at the conclusion of the inspection activities. A
general description of the scope and conduct of the inspection was provided. Briefly listed below are the findings discussed during the exit interview. The details of each finding listed below are
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referenced, as noted, in the report.
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Personnel present were advised that no violations were noted I
during the inspection.
(2)
Program strengths were discussed, including management oversight and the documentation and process for access
denial appeals (refer to Sections 4 and 10 for details).
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(3)
Program weaknesses were discussed including the
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administration and proctoring of psychological tests
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(Section 6); the definition of " frequent and direct" association for developed character references used during i
screening for temporary access authorizations (Section 8);
the lack of procedural guidance and implementation weaknesses in the protection of personal information (Section 9.a and b); the lack of documentation for one of
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the questions used in the employment verification process
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(Section 5); and the need to describe the measures in place that ascertain the activities of an individual away from the licensee's or contractor's behavioral observation program in excess of thirty days (Section 7).
Licensee personnel present noted the inspectors * comments and stated that they would evaluate our findings in a timely manner.
3.
Backaround On April 25, 1991, the Commission published the Personnel Access Authorization Requirements for Nuclear Power Plants, 10 CFR 73.56 (the rule).
This rule requires each licensee authorized, on that date,.to operate a nuclear reactor pursuant to 10 CFR 50.21 to implement an Access Authorization Program by April 27, 1992, to comply with the requirements of 10 CFR 73.56. The program is also required to be incorporated into the licensee's Physical Security Plan. The rule requires that licensees establish and maintain an Access Authorization Program with the objective of providing high assurance that individuals granted unescorted access are trustworthy and reliable, and do not constitute an unreasonable risk to the health and safety of the public, including a potential to commit radiological sabotage.
This inspection, conducted in accordance with NRC Inspection Manual Temporary Instruction 2515/116, Access Authorization, assessed the licensee's Access Authorization Program and its implementation to determine if regulatory requirements were being met.
The inspected Access Authorization Program applies to all Commonwealth Edison nuclear stations. However, program implementation was inspected only at the Braidwood site and Commonwealth Edison's Corporate Security Headquarters.
This was the first inspection of the licensee's Access
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Authorization Program under the criteria of 10 CFR 73.56.
4.
Access Authorization Proaram - Administration and Oraanization
The inspectors interviewed key Access Authorization (AA) personnel and
appropriate management personnel to determine the effectiveness of the
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AA program administration and organization.
i The licensee comwitted in their security plans to implement all elements l
of Regulatory Guide 5.66 to satisfy the requirements of 10 CFR 73.56.
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The Commonwealth Edison AA program is centrally monitored by the Corporate Security Department. The responsibilities for the licensee's
six sites consists primarily of providing appropriate training to site
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personnel and issuing security badges based upon information developed i
and adjudicated by the Corporate Security Department.
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l The AA program responsibilities are broadly described in Corporate
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Procedure No. 150, " Unescorted Access Authorization Program - Nuclear Stations," dated July 31, 1991. The Corporate Security Office had
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developed sixteen security procedures (500 Series of the Corporate Security Guidelines) which implement the AA program.
These procedures were of good quality, clearly written, and sufficient in detail to
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address the major program responsibilities assumed by the Corporate i
Security Department.
Staffing for the Access Authoriz:: tion Program appeared good. Staffing i
included an Access Authorization Program Coordinator, a Senior Nuclear Security Specialist, two Access Authorization Reviewers,- and a Nuclear
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Security Specialist. All personnel interviewed were professional and very knowledgeable of their responsibilities.
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The licensee had contracted with five vendors to act as its agent to complete elements of the background investigation.
However, only licensee's staff adjudicated access authorization decisions.
The inspectors reviewed the written specification for background investigations (Specification No. 92-04 dated April 27, 1992) and found it to be sufficient, except that the rec,uirement to verify foreign
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military service was not included. The inspector verified through an interview with one vendor-investigator that foreign military service would be verified, if applicable. The licensee stated that, to date, there have been no instances of foreign military service being indicated on the personal history questionnaire.
Conclusion Administrative and organizational aspects of the Access Authorization Program were considered to be a program strength.
Staffing was adequate.
Personnel were very knowledgeable of their responsibilities.
I Staffing levels and procedural guidance were sufficient to meet program
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requirements.
The specification to vendors should be revised to include the requirement to verify foreign military service.
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5.
Backaround Investiaations One weckness was noted.
Background investigation (BI) results did not
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document information relative to reliability and trustworthiness of
individuals. This finding was considered an Inspector Followup Item
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(50-456/93017-01; 50-457/93017-01).
The inspectors reviewed records and condected interviews to confirm that
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the licensee's program verified the true identity of an applicant and developed information concerning employment history, educational l
history, credit history, criminal history, military service, and the
character and reputation of an individual prior to granting them unescorted access to protected and vital areas.
The inspectors reviewed the case files of five background investigations completed after the licensee's implementation of 10 CFR 73.56 to determine if the elements involved in background screening were adequately investigated.
Inspection results showed that the scope and
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depth of background investigations satisfied NRC regulatory requirements
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and provided an adequate level of background information on which to base a determination for access authorization.
Reviewed BI files-showed
a "best effort" to obtain and document required information to address an applicant's employment history, education history, credit history,
criminal history, military service, and the applicant's character and reputation.
Background investigations covered the specified time period and the number of required contacts for each element.
In cases where i
derogatory information had been developed, the licensee adequately, and in a timely manner, reviewed and evaluated the derogatory information.
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One weakness was noted in the documentation of specific information asked during the employment history verification process.
Section 6.2.1 l
of NUMARC 89-01 states that employment history must be obtained for the i
past five years through contacts with previous employers by obtaining
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certain information to include "any information that would adversely
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reflect upon the reliability and trustworthiness of the individual as it
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relates to the individual being permitted unescorted access." The
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inspectors confirmed through an onsite interview with one of the vendors
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performing bis that this information was obtained, but the documentation
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checklist provided to the licensee did not reflect that the question was
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asked. This vendor agreed to revise their checklist to include this r
specific question. This licensee should verify that all l
vendors / contractors are asking for this specific information in the.
background investigation process and are properly documenting it.
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Conclusion j
No significant problems were identified. However, a lack of adequate
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documents to verify an individual's reliability and trustworthiness was identified in some personnel case files.
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Psycholoaical Evaluations
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One weakness was noted in this area.
Procedural guidance for
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administering and proctoring psychological assessment tests was not
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given to other organizations that administered the tests.
This finding
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was identified as an Inspection followup Item (IFI 50-456/93017-02;
50-457/93017-02).
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The inspectors reviewed the licensee's procedure and practices for l
completing the required psychological evaluation.
The procedure i
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pertaining to psychological evaluation (Corporate Nuclear Security i'
Guideline No. 503) was reviewed and determined to be sufficient.
The licensee used the Minnesota Multiphasic Personality Inventory' - 2
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(MMPI-2) for initial psychological evaluation.
If necessary, followup i
evaluations were completed by a clinical psychologist contracted by the
licensee.
The inspectors confirmed that the psychologist contracted was
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currently licensed by the State of Illinois.
Interviews with cognizant
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corporate access authorization personnel identified that 20 separate
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organizations (13 licensee and 7 contractor) administer and proctor i
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MMPI-2 evaluations.
Interviews with three individuals from different
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i organizations disclosed that personnel administered the test properly, personnel were properly identified before taking the test, and proctoring practices were appropriate.
The MMPI-2 test booklets observed were kept in secure storage when not in use.
As the result of interviews, the individuals involved with administering the MMPI-2 were not aware of licensee procedural guidance (Guideline
No. 503).
The guideline provided specific instructions on the administration, proctoring, and processing of the MMPI-2. The inspectors verified through interviews with two test administrators and ten test participants that examinations had been adequately controlled and proctored in a manner that generally followed the licensee's
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procedure and did not impact adversely on the validity of the evaluations.
To assure and maintain a level of testing consistency and effectiveness, the licensee will distribute the referenced guideline to all appropriate organizations and conduct training on the procedure for test administrators in those organizations.
Upon completion of testing, all test booklets and answer sheets were sent either directly by overnight mail or through the licensee's corporate security department to the clinical psychologist.
Conclusion The psychological tests were being controlled, administered, and proctored in an adequate manner.
The failure to distribute the required
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guidelines was considered a program weakness caused by inadequate management overview.
The failure did not impact on the validity of the psychological evaluation.
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Behavioral Observation Proaram One weakness was noted in this area. The potential existed that some individuals granted unescorted access may not be subject to a behavior observation program. This finding was identified as an Inspector Followup Item (IFI 50-456/93017-03; 50-457/93017-03).
The licensee's behavioral observation program (B0P) was inspected to
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i determine whether the licensee had a training and retraining program to ensure that supervisors have the awareness and sensitivity to detect changes in behavior which could adversely affect trustworthiness and reliability and to report such to appropriate licensee management for evaluation and action. The program was instituted as part of, and is an element in common with, the licensee's fitness-for-duty program.
In addition, inspection activities were conducted to determine if individuals with unescorted access authorization had been notified of their responsibility to self-report arrests that impacted on the individual's trustworthiness.
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The inspectors reviewed licensee lesson plans and procedures.
In addition, the inspectors interviewed five licensee supervisory management personnel at Braidwood Station.
All had been trained in
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behavioral observation. The inspectors determined from interviews with licensee personnel and review of lesson plans that the program addressed drug and alcohol related behavioral problems and behavior changes involving trustworthiness. However, the emphasis was on drug and alcohol related issues.
Behavior that may be (or indicate) a potential threat to interrupting normal plant operations or that could indicate potential radiological sabotage was not emphasized.
The guidance was too one-sided. All personnel interviewed were knowledgeable of their responsibility to refer behavioral issues to utility management for i
appropriate evaluation and action.
Interviews with ten randomly selected Braidwood site personnel, both supervisory (five) and non-supervisory (five), showed that they were aware of their responsibility to report any arrest that might impact on their trustworthiness.
Inspection results showed that the licensee's procedures do not address measures to be taken for individuals granted unescorted access who are absent from a licensee or licensee approved behavioral observation program 30 days or more.
Section 9.0 of NUMARC 89-01 (an attachment to
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Regulatory Guide 5.66) requires that each individual granted unescorted acces; shall be subject to a behavioral observation program.
Additionally, Section B.3 of Regulatory Guide 5.66 notes that it is reasonable to expect that the licensee will ascertain that whatever
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activities the employee engaged in during his or her absence from a behavioral observation program would not have the potential to affect
the employees's trustworthiness. The licensee stated that the requirement to " ascertain" the individual's activities is conducted; however, the specific actions taken are not procedurally described.
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licensee should verify that all approved contractor programs also meet this requirement.
The requirement applies to individuals currently badged for unescorted access, approved contractor programs and transfers or reinstatements.
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Conclusion The licensee's behavioral observation program was organized and ensured that all applicable supervisors and managers had been trained and retrained as appropriate. The licensee's program addresses behavior that may be a potential threat to interruption of normai operations including sabotage. However, procedures need to address the issue of ascertaining the activities of those individuals absent from a
behavioral observation program for more than 30 days.
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Unescorted Access Authorization
"Grandfatherino." Reinstatement.
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Transfer. and Temporarv
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One weakness was noted in this area.
Licensee procedural guidance did not define the scope of " frequent and direct association" as it applied to a developed character reference being conducted for temporary access
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authorization purposes. This finding was identified as an Inspection
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Followup Item (IFI 50-456/93017-04; 50-457/93017-04).
(NOTE:
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paragraph 7 ' weakness relating to the behavioral observation program also relates to reinstatement.)
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Personnel case files were reviewed to determine if they were correctly
"grandfathering," reinstating, transferring, and granting temporary access authorizations.
The licensee has procedures in their access control program to use the
four categories referenced above. Review of case files and interviews
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with cognizant licensee access control personnel concluded that these procedures were being appropriately implemented by the licensee, except as noted in this report section. The inspectors reviewed the case files of five individuals from each of the categories noted above I
Licensee's records were reviewed to determine that personnel who did not meet the criteria for "grandfathering,"
i.e., those who did not have i
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uninterrupted, unescorted access authorization for at least 180 days on April 25, 1991, had not been granted unescorted access authorization r
without having satisfied the elements of the program. The licensee met
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regulatory requirements as applied to "grandfathering.
The licensee's program for reinstatement of access authorization was reviewed. The program provided for reinstatement of unescorted access if the individual's unescorted access had not been interrupted for a continuous period of more than 365 days and, if the previous access was.-
terminated under favorable conditions, identity was verified, negative
drug test was obtained, and BI information was updated.
If access had
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been interrupted more than 30 but less than 365 days, a suitable inquiry was performed.
Review of five randomly selected case files that involved employee reinstatement showed that the requirements noted above
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were being met and no problems were identified that included ascertaining that interim activities did not adversely impact on
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trustworthiness.
The licensee has also established and implemented access control measures to accept transfer of access authorization from other
licensees. The program required that the receiving licensee confirm
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that the transferee currently holds a valid unescorted access authorization and that cross-checks on information relating to the
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person's identity (i.e., name, social security number, and date of birth) be verified before granting unescorted access. The licensee utilized the transfer form in Appendix B to NUMARC 91-03.
Review of five randomly selected case files of transfer, and interviews with cognizant licensee access control personnel, identified no problems in
this area.
l The inspectors reviewed the temporary Access Authorization Program and determined through a review of records and interviews that licensee case files reflected Access Authorization Program requirements having been
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satisfied prior to the licensee granting of temporary access. The licensee's temporary Access Authorization Program allows the licensee to grant temporary access for a period not to exceed 180 continuous days
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pending completion of a full background investigation and access authorization. Temporary access was granted based on the satisfactory completion of the following conditions:
(1) verification of identity through photo identification; (2) successful completion of a psychological evaluation; (3) completion of a credit check; (4) recommendation of one developed character reference applicant;
(5) submission of fingerprint card; and (6) an employment check for the t
past year. The licensee has a formal system to track personnel granted
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temporary access to ensure that-the 180 day time limit is not exceeded.
During our review of the temporary access program, we learned that
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procedural guidance (Corporate Nuclear Security Guideline No. 500),.
t which addressed " frequent and direct association," only indicated that a character reference needed to know the individual for some time during a five year period. Such procedural guidance does not appear to meet the scope of " frequent and direct association" with the individual if the
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character reference was being contacted for temporary access authorization purposes.
Only one reference check is needed for i
temporary access. Therefore, it is important that this individual have both direct and recent contact with the subject to effectively determine the individual's trustworthiness.
(Reference Section 6.4.d of Regulatory Guide 5.66, " Access Authorization Program For Nuclear Power Plants," dated June 1991.) However, our review of five case files involving temporary access that were completed by the licensee's contract investigation company showed that in each case the developed i
reference had actual direct contact with the individual ranging from a
i few days to three months.
The Corporate Security Director stated that their position was not to i
define the scope of " frequent and direct association," but to review the
obtained information on a case-by-case basis.
It was the inspector's
position that licensee procedural guidance define the scope of what constitutes " frequent and direct association." Because case files are generally reviewed by different licensee investigators, which could lead
to inconsistencies and reduce the effectiveness of the temporary i
unescorted access program, the licensee will review our concern.
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Conclusion j
We concluded that the licensee had established an effective program, i
except for weak procedural guidance relating to establishing a criteria
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to define the scope of frequent and direct association as it applied to a developed character reference for temporary access.
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Protection of Personal Information l
Two weaknesses were identified in this area.
Procedural guidance j
describing the licensee's program for the protection of personal information was very limited in scope (Section a). Access control vulnerabilities could compromise the licensee's program for the protection of personal information (Section b). These findings were considered as Inspector Followup Items (IFIs).
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i The inspectors reviewed the licensee's procedures and practices for the
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protection of personal information collected and assembled for access
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authorization purposes.
Corporate Nuclear Security Guideline, 500 Series contained the i
licensee's procedures for the control of personal information.
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procedures required the protection of Personal History Questionnaire's
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(PHQ) and securing these documents in locked containers in the Office of
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the Director of Corporate Security. Access to PHQs was handled on a
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need-to-know basis.
Physical protection practices were-reviewed.
During normal working hours, file containers were left unlocked and access control was the general responsibility of' cognizant personnel in the office of corporate security. During nonworking hours, the security i
case files were locked. The adequacy of licensee procedures and program implementation for protection of personal information is discussed t
below.
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NRC regulatory requirements (10 CFR 73.56[f]) requires each licensee who
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collects personal information on an employee for the purpose of i
complying with 10 CFR 73.56 shall establish a system and maintain i
procedures for the protection of the personal information.
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a.
Our review showed that specific procedures describing the licensee's program to protect personal information were limited in scope (IFI 50-456/93017-05; 50-457/93017-05).
Licensee procedures
only addressed location and method of storage, and that access to the information was on a need-to-know basis. The procedures did
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not further identify specific information to be protected (i.e.,
completed background investigations, psychological assessments, etc.), other than for completed personal history questionnaires.
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The procedures did not specifically identify the need-to-know criteria.
In addition, the procedure did not adequately address
or describe the physical security measures and access controls-to
protect the information. Also, the licensee's specifications to
contractors and vendors did not address the issue of establishing
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a program to protect this information. The licensee acknowledged our finding and will develop procedural guidance to address the concerns.
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b.
Inspector observation identified several program implementation concerns that could result in personal information compromise (IFI 50-456/93017-06; 50-457/93017-06).
Interviews with senior nuclear corporate security personnel
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determined that the licensee had implemented a security program for the protection of personal information.
This program, as referenced in Section a. above, was not proceduralized. The
program established access controls at two locations; one at the main entrance to the building where posted security personnel
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control general building access by verifying company photobadges and assuring that visitors to the building were acknowledged and verified and badged before allowing them access.
This measure i
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provided general security protection to the building. Additional
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access control measures were established in the Office of the
Director of Corporate Security where the personal files were maintained. This office houses all corporate security personnel.
Access to this area was controlled by personnel that occupy the area by challenging any person not assigned duties or responsibilities toward access authorization. The personnel files which contained approximately 27,000. case files are stored in approximately 20 four drawer filing cabinets located in an open i
area within the corporate security offices. During non-working
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hours, these cabinets were locked and the doors to corporate security were locked. During working hours, the cabinets were unlocked.
Inspector observations were made during work hours. On several occasions, inspectors were able to enter the building and the corporate security office area unchallenged and were able to t
stand unobserved next to the file cabinets containing the personal information. On two of these occasions, security personnel controlling access at building entrances (note:
this building was
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corporate headquarters to many company personnel) allowed the t
inspectors-access to the building without verifying their identity and their need for access.
The licensee acknowledged our findings and will evaluate the inspectors' concern.
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Interviews conducted during the visit to the licensee's background investigation contractor, disclosed that security case files were retained in locked file cabinets during non-working hours.
Inspector observation of file control and protection measures identified no problems.
Conclusion The licensee had implemented a system to provide for the protection of personal information.
Several weaknesses were identified with the
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licensee's program.
Procedures describing the program had not been j
adequately developed and access control practices on several occasions i
were found to be less than effective.
10.
Denial / Revocation of Unescorted Access
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The inspectors reviewed five case files involving access authorization denial s.
Each case resulted in an appeal request by the personnel involved.
The appeal case files were very well documented, detailed in
their explanation for the reason access authorization was denied, and contained denial requests and supporting documents provided by the person requesting the appeal. The appeal board consisted of three
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senior licensee managers from departments independent of the Security
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Department and a licensee medical review officer.
During 1992, 21 individuals were denied access based on access authorization issues.
0f that number, approximately 80 percent of the i
denials were because of criminal history.
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Conclusion The licensee's documentation of its actions concerning the processing of appeals and of its decision to deny access authorization was excellent
and was considered a program strength.
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11.
Audits
s The inspectors reviewed the audits of the licensee's Access l
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Authorization Program to determine that the minimum audit requirements were being met.
Inspection showed that the licensee's corporate security organization
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conducted audits on an annual basis of all vendors and contractors who have approved AA programs. These audits included reviewing training requirements of nuclear investigators, quality verification programs,
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and record retention. Corporate security also verified 5% of the background investigations conducted by vendors.
The audit of the licensee's Access Authorization Program was completed between October 5-9, 1992 (Audit Number CE-92-14), and was performed by the licensee Quality Verification Department. The scope of the audit appeared to be adequate based on a review of the audit report and audit
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checklists, and an interview with the audit team leader.
l Conclusion
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The licensee's audits of the Access Authorization Program and the planned frequency of audits '(annual'y) for the licensee vendors and
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contractors that completed background investigations were adequate.
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Record Retention
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The inspectors reviewed the licensee's record retention activities to ensure that required records were being retained for the appropriate timeframe. Corporate Nuclear Security Guideline 500, " Access Authorization Program," requires record retention for....
Actual documents from the licensee's contractor were retained by the licensee.
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The written agreement with the contractor also stipulated that the licensee will be provided with all records generated from the background investigation process if the agreement was terminated for any reason.
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interviews disclosed that the Corporate Security office was the designated repository for access authorization related records.
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area where the records are stored was within the corporate security office.
Conclusion Access authorization records were being retained as required by the
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rule, the correct retention period had been identified.
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