ML19345C266
| ML19345C266 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 10/01/1980 |
| From: | Abel J COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19345C265 | List: |
| References | |
| NUDOCS 8012040284 | |
| Download: ML19345C266 (13) | |
Text
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v Commonwealth Edison e
Accress Reply to Post Office Box 767 72 West Acams Street Chicago 11hnois Chicago. Illinois 60690 i
October 1, 1980 James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U. S.
Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Subject:
Zion Station Units 1 and 2 Response to IE Inspection Report Nos. 50-295/80-09 and 50-302/80-09 NRC Docket Nos. 50-295/30h Reference (a):
R. F. Jane.cek Letter to J.
G.
Keppler Dated July 3, 1980
Dear Mr. Keppler:
The reference (a) letter stated that contractor screen-ing guidelines would be reviewed and streamlined by October 1, 19c0.
The attachment is the result of this process.
A revision of the attachment is in draft which restates the rectirements in more precise language.
This draft will be completed by October 12, 1980, at which time a copy will be for-warded to you for your information.
Sincerely,
/
v J. S. Abel Director of Nuclear Licensing JSA: DES: cmp Attachment e
8 012 04 0 D
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ATTACHMENT
Subject:
Personnel Security Clearance - Clarification of Screening Requirements for Unescorted Access to CECO Operating Nuclear Power Plants The basic screening requirements will not change at this time but we must address a number of problem areas in the contractor personnel screening program which have been identified through selective audits completed by the Quality Assurance Department.
The changes are administrative in nature.
The principal areas of change are listed below:
1.
Standardization of the cancellation of the Unescorted Access Request.
2.
A list of personnel authorized to approve " Request for Unescorted Access" will be required.
3.
Revisions to an approve'd screening prbcedure must be submitted for review and approval.
It would be to your advantage to compare your present screening procedure to the enclosed requirements.
Your revised procedure will be given a prompt review.
Sincerely,
~"
~ David"H'.' Smith
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Nuclei r ' Secu rit'y '
Administrator.
DHS/dmg
- Enclosure.
(0717 A
CONTRACTOR PERSONNEL SECURITY CLEARANCE PROGRAM OPERATING NUCLEAR STATIONS COMMONWEALTH EDISON COMPANY The following shall apply to all Contractor personnel performing work at operating Nuclear Stations of the Commonwealth Edison Company:
1.
The Contractor shall submit a personnel security screening program to meet the requirements of ANSI N18.17-1973,
" Industrial Security for Nuclear Power Plants" Paragraph 4.3 "Employe Screening."
The screening program must be dated and signed.
The_ program will be reviewed by CECO and if found acceptable; approved.. Revisions to an approved screening procedure must be submitted for review and approval prior to implementation.
The personnel security screening program should be submitted to the Commonwealth Edison Company " Nuclear Security Administrator," Room 1230E, P.O. Box 767, Chicago, IL 60690.
2.
The three elements of the screening plan are:
a.
Background Investigation b.
Personnel Behavioral Evaluation c.
Continuous Evaluation 3.
This requirement is necessary for unescorted access into an operating nuclear plant and is authorized by the United States Nuclear Regulatory Commission Rules and Regulations, Parts 73.55, Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors Against Industrial Sabotage.
4.
"The personnel securi'ty screening program may' be subjec't to '
an audit by the Commonwealth Edison Company Quality Assurance Department-and/or the United States Nuclear Regulatory Commission."
It is assential, in the administration of your screening program, that adequate documentation be maintained which verifies adherence to your approved procedure.
Additiontily, it would be appropriate that your employes be advised that such documentation will be made available for inspection upon request by Commonwealth Edison Company or the Nuclear Regulatory Commission.
5.'.Followin'g are. ex'c' 'rpts ' f' om 'thE v'arious NRC.docum'ents,'.to $~e '
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' used in' preparing' the' ker'sonnel'securitv' screening plan':
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a.
ANSI N18.17-1973, " Industrial Security.for Nuclear Power Plants" Paragraph 4.3 "Employe Screening."
Procedures shall be employed for making a determination of the acceptability of candidates for nuclear plant employement and the continuing acceptability of employees with regard to their trustworthiness.
These procedures shall include as a minimum, the following provisions.
(1) an investigation, either' prior to employment or prior to assignment to a position allowing access without escort, to disclose adverse character traits that might bear on his abilities or motivation to discharge his duties in a responsible manner.
(2) examination by a licensed psychiatrist.or physician or other person professionally trained i
to identify aberrant behavior, either prior to employment or prior to assignment to a position i.
allowing access without escort, for the purpose of observing and disqualifying persons displaying indications of emotional-instability such that there is reasonable doubt the person could discharge his duties in a competent manner.
(3) continued observation of all employees and appropriate corrective measures by responsible supervisors for indications of aberrant behavior of personnel in the course of performance of their duties.
b.
10 CFR 73.55 - Paragraph (a) The licensee shall
. establish and maintain an onsite? physical protection system and security organization which will provide
, protection with high assurancegagai.nst successful.
industrial sab6tage by both of the following.
4 Paragraph (a) (2) An internal threat of an insider, including an employe (in any position).
Paragraph (d) Access Requirements - (5)
"A number picture badge identification system shall be used for all-individuals who have authorized access to protected areas without escort.
An individual not' t
employedf by the licensee but who requires frequent and -
6 s.
extended access to protected and vital. areas ma have
'aushori' zed' access to such areas withodt"esdorE'y'
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t pr'rided.that.he receives a picture badge upon i
encrance into the protected area which must be returned upon exit from the-protected area and which
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3-indicates (i) non-employe - no escort required; (ii) arean to which access is r^horized and (iii) the period for which access has an authorized. -Badges shall be displayed by all inc_viduals while inside the protected area."
c.
Background Check - The background check shall, as a minimum, include the following:
(1)
Contact one (1) employment reference and contact two (2) other character references, or (2)
Contact two (2) employment reference and contact one (1) other character reference.
The background check should address reliability &
trustworthiness.
The reference checks should not include relatives.
d.
Personnel Behavioral Evaluations to meet ANSI N18.17-1973, Paragraph 4.3 - (2), testing evaluations similar to "Thurstone Temperament Schedule" by Dr. L. L. Thurstone, Science Research Associates, Inc., 259 East Erie Street, Chicago, IL 60611; or 16 P.F. Test Form A, Institute of Personality and Ability Testing, 1602-04 Coronado Drive, Champaign, IL.
e.
NRC MEMORANDUM FOR:
Reactor Safeguards Licensing Branch Members Division of Operating Reactors FROM:
Robert A. Clark, Chief Reactor Safeguards Licensing
. Branch
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SUBJECT:
SCREENING OF INDIVIDUALS GRANTED.
UNESCORTED ACCESS TO THE PROTECTED AREA.
Review Guidelines #1 DATE:
November 26, 1977 unescorted access to the protected area may be granted to employaes of a licensee and its contractors based on the reliability established by three (3) continuous years of trustworthy employment.
.This method.of establishing' reliability'is considered
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to be equivalent to.the pre-employment ' screening of -
ANSI N18.17-1973, Sections 4.1 and 4.2.
A licensee's program for granting unescorted access to the protected area based on trustworthy employment is acceptable if (a) at least'three continuous years of employment of the individual with the licensee or his contractor is documented and (b) the' trustworthiness-of the individual as determined by a review of the individual's employment record.
4 6.
In order for an employe to gain unescorted access to a nuclear station for work purposes, individual contractors must certify each employe in accordance with one of the following options:
OPTION 1:
Observation by contractor supervision for three years or more while working for the contractor at any location (CECO or non CECO) who will certify to the employe's reliability, or; (See Exhibit I)
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, Three years or more as a union me'mber in good standing with certification by the business agentlor responsible officer of the local union, or; (See Exhibil II) 4s-Three years or more of continuous work exoerience in an operating nuclear station witn satisfactory recommendations f rom all contra: tors with whom the persor. w.s employed during the three year period.
OPTION 2:
v s u-Observation by contractor supervision for one year while working for the contractor at any location (Ceco or non CECO) who will certify to the employe's reliability, or; (See Exhibit III)
One year or more as a union member in good standing with certification by the business agent or responsible officer of the local union, or; (See Exhibit IV)
One year or more of continuous work exoerience in an
' operating nuclear station witn: s-atisf actory recommendations from all contractors with whom the person was employed during the one year period,.and;.,
< a-A background ch6,ck (See Paragraph 5.c) 4 OPTION 3:
g3 A background check (See Paragraph 5.c)
A behavioral evaluation (See Paragraph S.d)
. For each option a program of continued observation must~be c.
established.. A summary of the. requirements for.. Options.1,.
through 3 is shown below.
D 9
. Requirements Summary J'
Less than Less than Three years i
t
one year three years or more (Option 3)
(Option 2)
(Option 1)
Certification by Contractor X
X X
Program for Con'.inued Coservation X
X X
Background
Check X
X Behavioral Evaluation X
7.
We require that all contractors requesting unescorted access for their employes do so on a request form (See Exhibit V).
A list of representatives who are authorized to approve access requests must be furnished.
This list should include a printed name, title and a facsimile signature for each authorized representative.
A " Request for Unescorted Access" will be valid for a period of one year unless cancelled.
Personnel screening is a requirement establishing compliance with performance objectives in Federal Regulations for nuclear station security and provides for assurance that the public health and safety are protected.
Therefore, failure to adherc to procedures for personnel screening, prior to requesting unescorted acce.ss, can be a vi61ation.'of Federal Regulat' ions, '
8.
We require that.all co.ntractors notify ' CECO.immediately of the' termination or change of the reliabi'lity status of any personnel for whom unescorted access has been requested.
This notification will be by telephone or a personal visit followed by a written notification.
(See Exhibit VI) 9.
The Principal Contractor is responsibic for the screening of all Sub-Contractor personnel.
The screening will be completed utilizing the approved screening procedure submitt.ed by the Principal Contractor.
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40717A e
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EXHIBIT I Certification Reliable and Trustworthy Employment XYZ Company The employe listed below has completed three or more years of continuous employment with XYZ Company in positions which have afforded close observation of the employe.
A review of the employe's employment record for the past three years has been completed.
Based on this information, I consider the employe reliable and trustworthy.
I recommend clearance for unescortad access to Commonwealth Edison Company Nuclear Generating Stations.
Name (Last, First & Middle Initial) 4 Social Security Number Date of Employment s.
Manager Date'
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, r 40717A
EXHIBIT II
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Union Certification of Reliable and Trustworthy 2mployment Name of Union Member (Last, First & Middle Initial)
Complete Address Social Security Number Date of Membership The person listed above has completed three or more years as a member of this union.
A review of the member's work record for the past three years has been completed.
Based on this information, I consider this person reliable and trustworthy.
I recommend clearance for unescorted access to Commonwealth Edison Co. Nuclear Generating Stations.
.S Name'of Uni'n' o
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Union Officer / Business Agent
.A-Date 90717A t
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EXHIBIT III Certification Reliable and Trustworthy Employment XYZ Company The employe listed below has completed more than one year of continuous employment with XY" Company in positions which have afforded close observation of the employe.
A review of the employe's employment record for the term of employment has been completed.
Based on this information, I consider the employe relia' ole and trustworthy.
I recommend clearance for unescorted access to Commonwealth Edison Company Nuclear Generating Stations.
Name (Last, First & Middle Initial)
Social Security Number Date of Employment
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Manager
.Date
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a EXHIBIT IV Union Certification of Reliable and Trustworthy Employment Name of Union Member (Last, First & Middle Initial) 1 Complete Address Social Security Number Date of Membership i
The person listed above has completed more than one year but less than three years as a member of this union.
A review of the member's work record for the term of membership has been completed.
Based on this information, I consider this perr.on reliable and trustworthy.
I recommend clearance for unescorted access to Commonwealth Edison Co. Nuclear Generating Stations.
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. Name.of Unioq, l
r Address 1
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' Union Officer / Business Agent Date 90717A 4
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EXHIBIT V
, Request for Unescafted Access Nuclear Power Station Date Commonwealth Edison Company c/o Nuclear Security Administrator 72 West Adams Street, Room 1230 E.
P. O. Box 767 Chicago, IL 60690
Reference:
Approved Procedure No.
, dated The attached list of personnel, employes of (Name of Company)
Address have undergone the screening process established by the referenced procedure and have met the acceptability requiresents.
The records and reportu of the screening process for the above-named are available for inspection upon request
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by the Commonwealth Edison Company and/or the Nuclear Regulatory Commission.
Unescorted access is requested for Nuclear Power Station.
- By.v.irtue, of my,, authority. as.am authorised.
representative of'the afores' aid company or corporation,'I herewith make this.applica.. tion
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By:
Mame:
(Print or Type)
Title:
,,,. cc:., Commonwealti.
dison. Company,,,.
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Nucleas~ Security Administrator it Nuclear Pcser' Station (s)
Page 1 of 2 1
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N EXHIBIT VI e-Cancellation of Unescorted Access Date:
Station Security Administrator Commonwealth Edison Company Dresden Station Quad Cities Stations Zion Station R. R..61 P. O. Box 216' 101 Shiloh Blvd.
Morris, IL 60450 Cordo /a, IL 61242 Zion, IL 60099 11 (Name of Company)
(Address) l Unescorted access is hereby cancelled for the personnel listed below:
Name (Last, First & Middle Initial)
Social Security Number 1
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By,:
Name:
(Print or Type)
Title:
cc:
Nuclear Security Administrator 72 West Adams Street, Room 1230 E.
P.. O. Boy. 767.
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90717A
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