ML20043C357

Industry Guidelines for Nuclear Power Plant Access Authorization Programs

ML20043C357
Person / Time
Issue date:	10/03/1986
From:	NRC
To:
Shared Package
ML20042D000	List: ML20042C999 ML20043C341 ML20043C357
References
FOIA-89-546 NUDOCS 9006050099
Download: ML20043C357 (19)

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G INDUSTRY GUIDELINES FOR' NUCLEAR POWER PLANT ACCESS AUlTORIZATION PROGRAMS t

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TABLE OF CONTENTS Page

1. 0 ' P URPO S E........................................................

1 2.0 SCOPE..........................................................

1 3.0 RESPONSIBILITY.................................................

1 4.0 APPLICABILITY..................................................

2

.5.0 GENERAL REQUIREMENTS FOR UNESCORTED ACCESS.....................

2 6.0 SCREENING-PROGRAM

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2 6.1 Initiation of a Screening Program.........................

2 6.2 Background Investigation Elements.........................

3 6.2.1 Employment History.................................

3 6.2.2 Edu c a t ion H i s to ry..................................

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6. 2. 3 ' C ri m i n a l H i s t o' ry...................................

4 6.2.4 Military Service 4

6.2.5 Character and Reputation...........................

5 6.2.6 Verification of Identity...........................

6 6.2.7 Credit Check.......................................

6 6.3 Psychological Evaluation...................................

6 6.4 Tempora ry Unescorted Acce ss Authorization.................

6 7.0 EVALUATION CRITERIA FOR UNESCORTED ACCESS' AUTHORIZATION........

7 7.1 -Criteria..................................................

7 "7. 2 Review Process............................................

8 8.0 TRANSTER AND REINSTATEMENT OF UNESCORTED ACCESS AUTHORIZATION..

9 8.1 Transfer..................................................

9 8.2 Reinstatement 9

8.3 Upd a t e Re qu i r e me n t s.......................................

9 9.0 CONTINUAL BEHAVIORAL OBSERVATION PROGRAM (CBOP).................

10 10.0 SCREENING DURING COLD SHUTDOWN.................................

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10.1 Devitalization of Vital Areas............................

10 11.0 GRANDFATHERING.................................................

11 12.0 CONTRACTOR AND VENDOR REQUIREMENTS.............................

11 13.0 - EVALUATIONS AND AUDITS 12 13.1 Utility Programs.........................................

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13.2 Contractor and Vendor Programs...........................

12 14.0 RECORDS........................................................

12 At ta chme n t A, Mini mum Au d i t C rit e ri a.................................

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l-1.0 PURPOSE To support the safe operations of licensed nuclear power plants, utilitias will implement an access authorization program in accordance with the fo'11owing guidelines. These guidelines have been designed with the objective of achieving high assurance that personnel granted unescorted access au,thorization to the protected and vital areas of utility nuclear power plants are trustworthy and reliable and do not pose a threat to commit radiological sabotage.

Individual utilities may have additional requirements.

2.0 SCCPE

- These guidelines define the acceptable levels for conducting and evaluating the elements of the screening program.

Major elements include background investigation, psychological evaluation and behavioral obse rvation.

Additionally, the guidelines (1) provide evaluation criteria for the dete rmination of access authorization, (2) establish provisions for accepting unescorted access authorization from other utilities, (3) include a

grandfathering of personnel who were previously screened, and (4) discuss records maintenance, and evaluation and audits of the access authorization program to assure the utility'c unescorted access authorization program is being met.

3.0 RESPONSIBILITY The final granting and controlling of unescorted access authorization is the responsibility of the utility. Each nuclear utility will inform contractors and vendors of the existence of these guidelines and of the necessity to.

follow these guidelines.

The utilities are responsible to audit non-utilities who conduct their own screening and/or implement continual behavioral observation programs (CBOP) to assure these guidelines are followed. Each utility is responsible for having an independent evaluation conducted of its program in accordance with Section 13.1 of these guidelines.

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, Gja 3 4.0 APPLICABILITY These guidelines apply to all nuclear utilities, and nuclear utilities shall require those contractors and vendors who provide services at the utility's nuclear. power plants to also follow them.

on,e level of permanent unescorted access authorization will be granted to personnel who have been processed in accordance with these guidelines.

Such une scorted access authorization will allow access to both protected and vital areas as needed.

5.0 GENERAL REQUIREMENTS TCR UNESCCRTED ACCESS A utility may grant unescorted access authorization to an individual following the satisfactory completion of a screening program (6.0) which consists of a background investigation (6.2) and a psychological evaluation (6.3).

All of the foregoing may be waived if the individual satisfies any of the following:

(1) satisfies requirements for grandf athering (11.0): (2) has a transferable access authorization from another utility (8.1): (3) has a previously granted reinstateable access authorization from the utility (8.2): 'or (4) will be restricted to protected or devitalized areas during cold shutdown or refueling (10.1).

Also, a utility may grant a temporary nontransferable unescorted

. access authorization valid for no more than 180 days based on a psychological evaluation and a limited background check (6.4).

6.0 SCREENING PROGRAM 6.1 Initiation of a Screening Program No element of the screening program may be initiated without the knowledge and written consent of the person who is subject to such screening. The applicant for unescorted access authorization shall be informed of the types of records that may be produced and retained, where such records are normally maintained, the duration such records are usuelly retained, the applicant's rights l

. ; : c' s concerning access to the information, and to whom and under what circumstances the information will be released.

Initial screening requirements are applicable to those individuals who have never been screened or granted unescorted access authorization except as defined in Section 11.0.

The initial screening program has two components:

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.l ba,ckground investigation (Section 6.2) and a psychological evaluation (Section 6.3).

An applicant may withdraw consent to a psychological evaluation or background-investigation at any time. When withdrawal of consent is made, all processing of work in connection with either the psychological evaluation or background investigation must cesse as soon as practical. Withdrawal of consent shall be deemed withdrawal of the application for unescorted access authorization.

Information collected under these guidelines may be released only on a need-to-know basis (Section 14.0).

1 6.2 Background Investigation Elements The background investigation covers the time period specified in each element-below or since the eighteenth birthday, whichever is shorter. The applicant's employment histo ry, education history, credit history, criminal history, military service, and the applicant's character and reputation must be-addressed in the following manner.

6.2.1 Employment History Except as noted below, employment history must-be obtained for the past five years through contacts with previous employers by obtaining the following i

information a.

Verification of claimed periods of employment of 30 days or more.

b.

Disciplinary history. _

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Reasons for termination and eligibility for rehire.

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Any, other information that would adversely reflect upon the reliability and trustworthiness of the individual as it relates to the individual being permitted unescorted access.

e., Activities during interruptions of employment in excess of 30 days must be verified.

NOTE: Because of the multitude of employments many employees experience during a five-year period, especially craf t and trade workers, verification of all such employments may not be possible.

Consequently, utilities may consider these applicants fer unescorted access based upon an inclusive three-year retrospective employment check if the ei., Are five-year period cannot be covered.

Under no circumstances may unescorted access be granted based on an employment check of less than three years, and attempts should be made to include the entire five-year period.

6.2.2 Education History Verify any claimed enrollment at an education institution during the previous five years.

In addition, verify the highest clairc3 post high school attencance or degree regardless of time.

6.2.3 Criminal History As required by Federal law (Pub. L.99-399, " Omnibus Diplomatic Security and Anti-Tet.ecism Act of 1986"), the utility shall pe r form a criminal history record vbeck through the Federal Bureau of Investigation in accordance with NRC regulations.

6.2.4 Military Service a

If within the last five years, military period of se rvice (claimed or developed)' must be verified by receipt of a Form DD214 or other National Personnel Records Center (NPRC) records.

This information must be obtained w

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/f i from the National personnel Records Center through acquisition and submittal of an applicant's authorization for release of military history information.

The utility may grant unescorted access for 180 days or less to individuals prior to receipt of a DD214 or other military records if all other applicable elements of the guidelines are met and a record is maintained which documents that the request for military history was submitted within 10 working days of granting unescorted access.

If it becomes known that an individual's discharge is other than honorable based solely on receipt of a form DD214, further investigation rust be made.

6.2.5 Character and Reputation The applicant's reputatici, for emotional stability, reliability and trustworthiness must be examined through contact with two references supplied by the applicant and at least two additional references (not related to the applicant) developed during the investigstion.

(It is not necessa ry that reference's

[ individually or collectively) association with or knowledge of the applicant for unescorted access cover the entire five-year ' retrospective period.)

Emphasis must be placed on a.

Identified psychological problems, b.

Criminal history.

c.

Illegal use or possession of a controlled substance.

d.

Abuse of alcohol.

e.

Susceptibility to coercion, i

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Any other conduct relating to an applicant's' trustworthiness or reliability to discharge job duties within the environment of a nuclear power plant.

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6.2.6 Verification of Identity Identity must be verified through means sdch as photograph, rocial security number, date of birth, or comparison of applicanc's physical characteristics with employment, education, sdlitary and other records, and/or cuployer and character references who have a personal acquaintance with the applicant.

6.2.7 Credit Check A check of the applicant's credit history must be performed through checks f

with credit bureaus and/or credit references.

6.3 Psychological Evaluation Reliability and stability must be determined by the result of a reliable written personality test or by any other professionally accepted clinical evaluation procedure. The results of such test or procedure must be evaluated f

by a qualified and, if applicable, licensed psychologist or psychiatrist.

If the results of the written test or other procedure identify any psychological abnormalities which eay indicate emotienal instability, unreliability, or unt rustworthine s s, or the results need further clarification, a clinical interview murt be renducted by a qualified and, if applicable, licensed psychologist or psychiatrist.

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A utility may grant unescorted access authorization not exceeding a period of duass 3 g,0 180 continuous days based on a temporary authorization.

This temporary j

authorization cannot be transferred from one licensee to another in accordance with Section 8.1 with the exception of the FBI criminal history check which may be transferred. This 180-day temporary authorization may be granted based upon sattsfaction of the following conditions:

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Passing a psychological evaluation within the past year.

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Conduct of a credit check.

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Recommendation of one developed character reference who has had frequent and direct association with the applicant.

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Evidence that a request for a criminal history check of the individual by the FBI has been submitted to the NRC.

7.0 EVALUATKON CNITIRIA POR UNESCORTED ACCESS AUTHORIZATION 7.1 Criteria in its decision to grant an individual authorization for unescorted access, the utility shall consider information obtained during the background investigation and psychological evaluation. This information must be reviewed using the guidelines specified in this section, cach utility shall define the appropriate level of management to adjudicate matters covered by these criteria.

In making a determination of trustworthiness or reliability, the following must be considered:

a.

Willful emission or falsification of material information submitted in support of emp1byment or request for unescorted access authorization to protected or vital areas.

b.

Illegal use or possession cif a controlled substance or abuse of alcohol without adequate evidence of rehabilitation, c.

A criminal history without adequate evidence of rehabilitation which establishes untrustworthiness or unreliability.

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History of mental illness or emotional instability that may cause a significant defect in the individual's judgment or reliability.

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Any evidence of coercion, influence, or pressure that may be applied by outside sources to compel an individual to commit any act of sabotage or other act which would adversely reflect upon the individual's trustworthi-ness or reliability.

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Evidence that the individual has committed or attempted to commit, or aided or abetted another who committed or attempted to commit, any act of sabotage or other act that would pose a threat or reflect adversely upon that individual's trustworthiness or reliability.

g.

A psychological evaluation which indicates that the individual is a tisk in terms of trustworthiness or reliability, b.

Any other information that would adversely reflect upon the reliability and t rustworthiness of the individual as relates to the individual being -

permitted unescorted access.

7.2 Review Process III Each permanent employee of a utility whose employment is or will be terminated as a direct result of a denial or revocation of access authoriza-tion will (1) be informed of the basis for denial or revocation of unescorted access (2) have the opportunity to provide any additional informa-tions and (3) have the decision, together with any additional information, reviewed by another designated manager of the utility who is equivalent or senior to and independent of the individual who made the initial decision to deny or revoke unescorted access.

The determination from this review is l

final.

An alternative review process which is independent and impartial is acceptable.

If an alternative review process is used, the utility will include a description of its review process in its plan which meets this guideline.

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The term permanent employee refers to a person who is employed by a utility for an undefined term.

It does not include employees who are temporarily hired for a specific project or other temporary work or who are hired under an employment contract with a defined term, f.,

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i 8.0 TRANSTER AND REINSTATEMENT OF UNESCORTED ACCESS AUTHORIZATION l

Transfer, or reinstatement of unescorted eccess authorization requires verification of the individual's identity by the utility.

8.1 Transfer 7

An individual's unescorted access authorization granted by one utility in accordance with these guidelines may be transferred to another utility via P

correspondence, computer data transfer, or telecopy if the gaining utility:

(1) verifies or receives confirmation that the individual currently holds a i

valid unescorted access authorization or had a valid unescorted access t

authorization which was terminated under favorable conditions within the previous 365 days and (2) cross-checks information such as name, date of

birth, social security number,

sex, and other applicable physical characteristics for identification.

8.2 Reinstatement The utility may reinstate the unescorted access authorization granted an individual if the individual returns to the same utility and unescorted access authorization has not been interrupted for a continuous period of more than 365 days and if the previous unescorted access authorization was te rminated under favorable conditions.

8.3 Update Requirements A utility shall not authorize unescorted access where the individual's unescorted access authorization has been inte rrupted for more than 365 calendar days unless the psychological evaluation and the background investigation is updated to cover the individual's activities from the date of the previous background investiga' tion, not to exceed retrospective periods in 6.2 or to the period when unescorted access was last held, whichever is less.

A tempora ry, unescorted access authorization (6.4) may be issued while the background investigation update is occurring.

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..o 9.0 CONTINUAL BEHAVIORAI, OBSERVATION PROGRAM (CBOP)

Each individual granted unescorted access shall be subject to a CBOP.,

This CBOP applies to all personnel who are granted unescorted access. The following must be included in the overall programs a.,-

A program with the objective for assuring the detection of alcohol and drug abuse and other behavior that may evidence a threat to commit i

radiological sabotage.

b.

A continual behavioral observation program that provides for management /

supervisory personnel responsibility for observing personnel for behavioral traits and patterns that may reflect adversely on their trustworthine ss or reliability and reporting those observations to appropriate utility management.

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A training program which reasonably assures that management / supervisory j

personnel have the awareness and sensitivity to detect and report changes in behavior, to include suspected alcohol and. drug abuse, which adversely reflect upon the individual's trustworthiness or reliability and to refer these persons to the utility's management for appropriate evaluation and l

action.

Individuals with unescorted access authorization must be notified of his/her l

responsibility to report any arrest that may impact upon his/her trustworthiness.

i 10.0 SCRfENING DURING COLD SHUTDCMN 10.1 Devitalization of Vital Areas I

During refueling or maintenance outages in which all or a part of a nuclear power plant is in a cold shutdown, refueling, or devitalized status, the utility may grant unescorted access authorization to the protected and devitalized areas for personnel who have not been screened in accordance with Section 6.0 providing that:

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The unescorted and unscreened person is restricted to the protected or 1

devitalized areas.

b.

Other requirements of the approved security plan remain in force, and the I

I requirements of 10 CTR 73.55 are followed for unscreened personnel granted unescorted access.

c.' Prior to start-up, a thorough visual inspection of the devitalized area is made by knowledgeable plant personnel to identify signs of tampering or attempted sabotage.

d.

Appropriate safety start-up procedures are followed to assure that all operating and safety systems are functiening normally.

l 11.0 GRANDFATHERING The utility may grant unescorted access authorization to individuals if they hold a valid unescerted access authorization on the date security plan amendments ira response to these guidelines are' appr: Vi d or have been granted uncscorted access authorization within the 365 days prior to the date of amended security plan approval.

s 12.0 CONTRACTOR AND VENDOR REQUIREMENT _S_

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The utility may accept the results of the entire screening program or any part thereof conducted by a cor tractor or vendor, provided that the contractor or vender meets the requirements of these guideline s and that it makes its records available for auditing by the licensee or its designated representa-L tive in accordance with Sections 13.0 and 14.0.

The utility retains the I

ultimate responsibility for assuring that individuals granted unescorted access to the facility have been ubjected to the screening elements of this program.

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13.0 EVALUATIONS AND AUDITS 13.1 Utility Programs l

An independent evaluation of the access authorization program and its conformance to these guidelines must be made within 12 months of the effective j

date of implementation of the amended security plan which commits to these l

guidelines.

Thereaf ter, an independent evaluation must be conducted at least once every 24 months. The utility shall retain all reports of evaluation for a period of three years, 13.2 Contractor and Vendor Programs The utility or its designated representative shall conduct annual audits of contractor and vendor access authorization programe to ensure compliance with these guidelines. Other utilities may accept the originating utility's audit and need not reaudit ths same contractor or vendor for the same period of time pr doing the scope of the audit meets the minimum auditing criteria contained in Attachment A.

A copy of the audit report to include findings, recommenda-tions, and corrective action must be provided to ~the sharing utility.

14.0 RECORDS Otilities and contractors and vendors of utilities who conducted screening programs in accordance with these guidelines shall maintain actual data that establish:

a.

A background investigation and psychological evaluation were conducted for each person who is screened under Section 6.0 of these guidelines.

b.

That other persons were granted unescorted access authorization in accordance with Section 11.0.

c.

Satisfaction with the conditions of Section 6.4 which resulted in the L

granting of a temporary unescorted access authorization.

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The utility, contractor, or vendor shall retain records for each person who is granted unescortsd access for a three-year period following termination of access adthorization.

Each utility or utility's contractor or vendor who collects personal.

information for the putrase of processing access authorizations shall establish and maintain a system of files and procedures for the protection of the personal information. This information muct not be disclosed to persons other than the subject or his/he r representative, utility counsel and officers, auditors whose pu rpose for review would be to inspect program conformance, other utilities if an individual's access authorization is transferred, and those individuals who have a need to have access to the information in performing assigned duties in the process of granting or denying access authorization.

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Attachment A MINIMUM AUDIT CRITERIA The following information must be reviewed during the conduct of an audit of a 7

contractor / vendor screening program to meet the objectivw that the intent of these guidelines have been met.

t A.

BACKGROUND INVESTIGATION i-The auditor shall review screening activities by examining records and conducting interviews with appropriate personnel to determine that screening activities were aceemplished in a correct and accurate manner.

In conducting an audit of the background informatien to reasonably assure contractor conformance with these guidolines, the auditor shall randomly verify the following:

1.

Employment History Date the verification was made, complete dates of employment, position, disciplinary history, reason for termination, eligibility for rehire, and any other information which would adversely reflect upon the reliability and trustworthiness of the individual. The retrospective period for employment history must be reasonably attempted for five years; however, due to the nature of employment histories of some transient craft workers, a minimum period of three years is required.

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2.

Education l

Copies of transcripts, diplomas, etc.,

documentation which verifies all claimed attendar.ce within the previous five years.

In addition, the highest l

l post high school attendance or degree must be verified regardless of time.

Records must include, as a minimum, dates of check, dates of attendance, l

highest level of attendance, and reason for leaving, i.e., graduation, transfer, expulsion, etc.

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Criminal History Date of check and results of FBI criminal history records check.

If temporary unescorted access authorization was granted, evidence of rubmittal of request for FBI criminal history records prior to granting unescorted access.

4.

Military Historv Date of receipt and copy of Form DD214 or other military records from the

.:stional Personnel Records Center if military service was within previous five years. If unescorted access was granted prior to receipt of NPRC records, evidence of submission of request for military history within ten working days of granting unescorted accesr shall be centained in the access autheriratien file.

5.

Character References Dates of contact, names of references, association with applicant, period of association and any information relative to identified psychological problems, criminal hi story, illegal use or possession of'a controlled substance, abuse of alcohol, susceptibility to coercion and any other conduct relating tv applic nt's t rustworthine ss and reliability.

Each file must contain two lasted references and two developed references (not telated to applicant) as a minimum.

6.

Verification of Identity How ve rification of identity was accomplished through such means ac photograph, social security number, date of birth, and comparison of applicant's physical characteristics with records and/or references.

7.

Credit History Date of the credit check (s),

name and location of credit bureau or other source, and results of initial check (s).

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PSYCHOLOGICAL EVALUATION i

To reasonably assure contractor conformance concerning prychological evaluation the auditor must be concerned with the date of the testing and that a peychologist/ psychiatrist reviewed the evaluation. Contractor records 'must

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include a

copy of the report signed by a licensed, if applicable,

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peychologist/ psychiatrist.

C.

CONTINUAL BEHAVIORAL OBSERVATION PROGRAM (CBOP)

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To reasonably assure contractor conformance concerning a CBOP, the auditor must review contractor's program to dete rmine compliance with these guidelines--specifically to address that supervisors are sensitized to alcohol and drug abuse and other behavioral traits / patterns which may cause a threat f

to commit radiological sabotage, and to report / refer persons displaying such behavior to the utility's management for appropriste evaluation and action.

D.

TEMPORARY UNESCORTED ACCESS AUTHORIZATIONS To teasonably assure contractor conformance concerning temporary unescorted access authorizations, the auditor must be concerned with completion dates for credit chewk, reference check, psychological evaluation (within previous year from date unescorted access was granted), and date of submission to the NRC of FBI criminal history check. The auditor shall follow criteria set forth in Section A for credit history and character references and section B for psychological evaluation, tvidence of submission of TBI criminal history l

request or receipt of results transferred from another utility or received directly from the NRC must be contained in access authorization file.

E.

UPDATE REQUIREPDITS To reasonably assure contractor conformance concerning upos ting access authorizations when accsas authorizations have been interrupted for more than 365 days, the auditor must be concerned with the dates of psychological evaluation and background investigation, and the retrospective period of the background investigatio:

must cover activities from the date of the previous A-3

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background invertigation not to exceed the retrospective period of section 6.2 or the period when unescorted access was last held, whichever is less. The criteria, listed in sections A and B must be met in updating unescorted access authorization.

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F.

GRANDFATHERING To reasonably assure contractor conformance concerning grandf athering, the auditor must be concerned with the date of the previous une scorted access authorization to determine that the individual held unescorted access authorizat. ion on the date security plan amendments in response to these guidelines were approved or was granted cecess authorization within the 365 days prior to the date of amended security plan approval. The auditor must be f

conce rned that no individuals were grandfathered earlier than the 33.5 days prior to the date of amended security plan approval or subsequent to the date of amended security plan approval.

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