ML20137B780

List of Escalated Enforcement Activities

ML20137B780
Person / Time
Site:	Salem, Hope Creek
Issue date:	03/11/1996
From:	AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20137A635	List: ML20137A631 ML20137B780
References
FOIA-96-492 NUDOCS 9703240061
Download: ML20137B780 (5)

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' '*- ATTACHMENT 6 )

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3. ESCALATED ENFORCEMENT ACTIVITIES e

The NRC issued a Level III Violation on March 8.1994, documented in NRC Inspection Report 50-272 and 311/93-23:

50-354/93-25. The

- violation was based on multiple examples of PSE&G's failure to related activities. follow procedures and their failure to properly con The NRC issued four Level III and two Level IV violations and imposed a Civil Penalty of $500.000 on October 5, 1994. The violations were documented in NRC Letter EA 94-112 and w on the licensee's performance prior to and during the April 7 1994 event, e

On February 8.1995. PSE&G met with NRC at Region I in King of Prussia to discuss the findings of the Office of Investigation relative to assertions of violations involving 10 CFR 50.5

" Deliberate Misconduct." and 10 CFR 50.7 " Employee Protection."

o On July 28. 1995, a pre-decisional enforcement conference reviewed numerous violations for potential escalated enforcement. These violations were combined and aggregated under one enforcement action. . This action resulted in the issuance of six Severity level III violations with an aggregated civil penalty of $600.000.

The violations involved:

o thirteen examples of inadequate corrective action including failure to promptly resolve a known safety issue associated with the pressurizer overpressure protection system, failure to correct inoperable RHR recirculation valves for both trains of RHR at Salem Unit 2. and failure to correct inoperable switchgear supply fans at Salem Unit 1:

o failure to control a modification to insure that it was correctly implemented (installing the loop drains for the pressurizer code safety without insuring that the drain I valves were properly aligned, or insuring that post i

. modification testing verified that the drain performed its intended functionh and o

,a repeat failure to comply with the Technical Specification

, action statement requirement for an inoperable PORV.

9703240061 970314 PDR FOIA SOLOMON 96-492 PDR h[. )

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HOPE CREEK ENFORCEMENT

SUMMARY

iWUfiM@ !$59siYM ENSIEfi6NEf?f E$ $ $E$#!$ 92 % 65si5iii5 N 5 0@ $$$$IE f$iN s${@$NdiWBER@s MLEVtiGik i$$MN#4$$h @k$$k!!$$!$$$$$h$$35$$$MI$N3E$$$d8k O'95-05 Ill OPS Associated with April 5,1995 effluent release Ul95-05 Ill OPS Associated with April 5,1995 effluent release n195-05 Ill OPS Associated with April 5,1995 effluent release U395-05 Ill OPS Associated with April 5,1995 effluent release (2)EA 95-160 IV OPS No SRO in the control room (3'EA 95-37 IV OPS Failure to ensure info submitted to NRC was complete for individual performing as NSSISTA (1) The investigation and escalated enforcement action for the April 7,1994 release began last SALP period, however, the violation was issued this period.

(2) This event occurred in 1993 but was not discovered until 1995. The 01 report, 1-94-048, is included resulted in the inspection report portion of this document.

(3) The event occurrad during last SALP period and was the subject of 01 report 1-94-016 which is included in the inspection report portion of this document.

HOPE CREEK' ENFORCEMENT

SUMMARY

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EfANUiiiBEMj$$ !!N M g? M!$fdRE4if$$$$bb, . .

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95-81 Ill OPS Shutdown cooling bypass event 95-81 Ill OPS Shutdown cooling bypass event i i

95-81 lil OPS Shutdown cooling bypass event ,

95-81 Ill OPS Shutdown cooling bypass event i

95-19 IV END inoperable snubber on SACS systern 95-19 IV ENG Ineffective corrective actions for SACS 95-11 IV MAINT Inadequate testing of ECCS actuation instrumentation 95-10 IV OPS Loss of shutdown cooling 95-10 IV ENG Hiller Actuator problems t IV MAINT Missed TIP surveillance for explosive squib valves 95-10 i 95-10 IV OPS FSAR not being maintained current i

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HOPE CREEK ENFORCEMENT

SUMMARY

I I * .. r 96-80 IV MAINT Failure to follow procedures when disassembling the SW strainer 96-08

• PLT SUP Apparent violations in the securtity area 96-07 IV ENG Failure of OSRG to review safety evaluations in  !

accordance with TSs 96-07 IV ENG Failure to evaluate changes to TACS supply isolation valve in accordance with 50.59 96-06 111 ENG Vulnerability of the safety-related service water system to potentially not perform its safety function under certain postulated conditions 96-04 IV OPS Failure to meet staffing requirements for OSR and SRG 96-04 IV MAINT Did not account for all known SSLM failures in accordance with license condition t 96-03 IV PLT SUP Failure to use ALNORS during RCA entries ,

i 96-03 til MAINT Failure to adequately conduct post-maintenance testing fer control rods as prescribed in TSs 96-03 til MAINT inadequate corrective actions in establishing control-rod movement speed limitations in procedures 7

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.' Emeroency Diesel Generator Load Marain 1

Emergency Diesel Generators (EDGk are used to provide a reliable source of i i backup power to energize certain safety related loads when offsite power is lost or.becomes unavailable. Many of the safety related loads involve large  !

] emergency core cooling system pumps which must be run in accident conditions.  !

! For the Salem units, the total power requirements for these loads is very i close to the ultimate capability of the EDGs. The licensee has made a number of changes to recover available load margin, including the shifting of certain

-loads to non-safety related electrical busses, and the installation of six new .

i i service water aumps with lower power requirements. While these changes have i helped, availa)1e margins are still small. Another consideration relates to

! the loads that are designed to receive auto start signals or to be manually

started since these minimal margins may have precluded the auto loading of i M otentially essential loads like the component cooling water (CCW) system

pumps. These and other related issues will be discussed further at a March 6, i 1997 management meeting between PSE&G and the NRC staff.

Adeauacy Of Desian Basis Conformance 1

l l Since May 1996, the NRC staff has completed two significant inspections that i provided useful insights into the licensee conformance to the design and

! licensing basis. The first effort, a special team inspection (STI). J

! discovered that the design and licensing bases of the Salem Unit 2 control i air, fuel handling ventilation, and containment cooling systems were not well ,

j understood. After this was reemphasized with the licensee in a June 1996

management meeting, the licensee embarked on a " Final Safety Analysis Report

(FSAR). Project" to examine licensing bases conformance of various plant i systems, processes, and programs in a systematic manner, After a series of  !

! subsequent ins 3ection and management efforts, the staff concluded the 4

)' licensee's FSAR Project was a substantial effort that was well managed. The  !

Project included well-focused elements of independent confirmation. To j further test the veracity of this-conclusion, the staff initiated a December

! 1996 Safety System Functional Inspection (SSFI) to evaluate the component

! cooling water (CCW) system, with particular emahasis on the design,

! configuration control. and testing adequacy. T1e team found that significant u i w improvements were made to the CCW system during the current outage. Two-mJer 1 k [he f%d Mgs were noted. The first pertained to a single failure of a ventilation

M system that could affect two of three CCW pumps, while the second involved a L pump runout concern that occurs while shifting suction points. These and other related issues are being addressed by the licensee and will be discussed l further at a March 6. 1997 management meeting between PSE&G and the NRC staff.

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m-i UNITED STATES ATTACHMENT 5

- NUCLEAR REGULATORY COMMISSION g w m ua m .o.c. m as i

k***** PUBLIC SERVICE ELECTRIC & GAS COMPANY AND ATLANTIC CITY ELECTRIC COMPANY -

i - ' DOCKET NO. 50-354 .

HOPE CREEK GENERATING STATION l FACILITY OPERATING LICENSE

License No. NPF-57 i

1. The Nuclear Regulatory Comission (the Comission or the NRC) has found l that:

i

! A. The application for,a license filed by the Public Service Electric &

l Gas Company, acting on behalf of itself and Atlantic City Electric Company (the licensees), complies with the standards and requirements

! of the Atomic Energy Act of 1954, as amended (the Act), and the Commis-i sion's regulations set forth in 10 CFR Chapter I, and all required i notifications to other agencies or bodies have been duly made; i

l B. Construction of the Hope Creek Generating Station (the facility) j has been substantially completed in conformity with Construction

Permit No. CPPR-120 and the application, as amended, the provisions of

< the Act and the regulations of the Comission; JW i C. The facility will operate in conformity with the application, as

amended, the provisions of the Act, and the regula,tions of the l Comission (except as exempted from compliance in Section 2.D. below);

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! D. There is reasonable assurance: (1) that the activities authorized by h1 this operatina license can be conducted without endangering the health e

4 and safety of the public, and (ii) that such activities will be ]$j i conducted in compliance with the Comission's regulations set forth in

10 CFR Chapter I (except as exempted from compliance in Section 2.D. M; t=y ,

l below); E/ l 1

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! E. Public Service Electric & Gas Conpany* is technically qualified to [.} 3 s

engage in the activities authorized by this license in accordance with .e

: ,

j the Comission's regulations set forth in 10 CFR Chapter I; r, (;

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! F. The licensees have satisfied the applicable provisions of 10 CFR Part .&

1 140, " Financial Protection Requirements and Indemnity Agreements," of the Comission's regulations; sjaW;n E[ 5 i

3 .s .e E G. The issuance of this license will not be inimical to the comon i defense and security or to the health and safety of the rublic; 1

I *Public Service Electric & Gas Company is authorized to act as agent for Atlantic

! City Electric Company and has exclusive responsibility and control over the physical construction, operation and maintenance of the facility. ,

my.

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l E. PSE&G shall fully implement and. maintain in effect all provisions of the _ l

, physical security, guard training and qualification, and safeguards l contingency plans previously approved by the Comission and all amend- I ments and revisions to such plans made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). These plans, which contain safeguards

, infonnation protected under 10 CFR 73.21, are entitled: " Hope Creek

Generating Station Security Plan," with revisions submitted through i March 20, 1986, " Hope Creek Generating Station Security Training and Qualification Plan," with revisions submitted through July 18, 1984, and " Hope Creek Generating Station Security Contingency Plan," with j revisions submitted through July 23, 1985.

l F. Except as otherwise provided in the Technical Specifications or Environ-mental Protection Plan, PSEAG shall report any violations of the

! requirements contained in Section 2.C of this license in the following i manner: initial notification shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC j Operations Center via the Emergency Notification System with written followup in 10 CFRwithin thirty)(cdays 50.73(b), , andin(e).

accordance with the procedures described

! G. The licensees shall have and maintain financial protection o'f such type and in such amounts as the Comission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

H. This license is effective as of the date of issuance and shall expire at I midnight on April 11, 2026. '

FOR THE NUCLEAR REGULATORY COMMISSION l

l n Harold R. Denton, Director

! Office of Nuclear Reactor Regulation i

Enclosures:

! 1. Appendix A - Technical *

' Specifications (NUREG-1202) l i 2. Appendix B - Environmental

! Protection Plan Date of Issuance: July 25,1986 l .

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UNITED STATES p

g NUCLEAR REGULATORY COMMISSION g g. - WASHINGTON, D. C. 20888

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PUBLIC SERVICE ELECTRIC AND GAS CGlPAW_

- . . ;, _ PHII.ADELPHIA ELECTRIC LDiPANY . -

j DELERVA POWER AND LIGHT CO6tPAW ATIAN'"IC CITY ELECTRIC C21PANY -

DOCKET NO. 50-272 SALEM TJCLEAR GENERATING STATION, UNIT NO.1 1

.. FACILITY OPERATING LICENSE - LI:4ITED OPERATION FOR TESTING

i.T.[6 7 ,

License No. DPR-70 l.. @e Nuclear Regulatory Comission (the Comission) having found that:

A. Se application for license filed by the Public Service l Electric ard Gas Company, Philadelphia Electric Company, l

, Delmarva Power and Light Company, and Atlantic City l g,,

• Electric Company (the licensees) complies with the i standards and requirements of the Atomic Energy Act (the  !

Act) of 1954, as amended, and the Comission's rules and regulations set forth in 10 CFR Chapter I and all' required notifications to other agencies or bodies have been duly made; B. Construction of the Salem Nuclear Generating Station,

. - - Unit No.1 (facility) has been substantially completed .

j +  : /.

. in conformity with Provisional Construction Permit No.

CPPR-52 and the application, as amended, the provisions of the Act and the rules and regulations of the Comission; l C. We facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Comission; D. Were is reasonable assurance: (1) that the activities authorized by this operating license can be con:1ucted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the rules and regulations of the Comission;

. ,; / E. We licensees are technically and financially qualified to

" engage in the activities authorized by this operating license

in accordance with the rules and regulations of tne Comis91on;

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D.- Paragraph ?.D. has been combined with paragraph 2.E. per Amendment No.

, 86, June 27, 1988.

} E. The licensees shall fully implement and maintain in effect all provisions l of the Connission-approved physical security, gua a training and

, qualification, and safeguards contingency plans including amendme.nts.made pursuant to provisions of the Miscellaneous Amendments and Search j Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to-the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which

contain Safeguards Information protected under 10 CFR 73.21, are entitled: " Salem Nuclear Generating Station Physical Security Plan,"

with revisions submitted through September 4,1987; " Salem Nuclear

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Generating Station Guard Training and Qualification Plan," with revisions submitted through September 4,1987; and " Salem Nuclear Generating Station Safeguards Contingency Plan," with revisions submitted through December 2, 1986. Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein.

F. In accordance withethe requirement imposed by the October 8,1976, order

of the United States Court of Appeals for the District of Columbia Circuit in Natural Resources Defense Council v. Nuclear Reaulatory, i'

Commission, No. 74-1385 and 7T-BW, lh'affhe Nuclear ReguTal~orf Connission "shall make any licenses granted between July 21, 1976 and i such time when the mandate is issued subject to the outcome of the 4

proceedings herein," the license amendment issued herein shall be subject a to the outcome of such proceedings.

G. Prior to startup following the first regularly scheduled refueling outage, Public Service Electric and Gas Company shall install, to the ,

satisfaction of the Commission, a long-term means of protection against l reactor coolant system over-pressurization when water-solid.

H. This amended license is effective as of the date of its issuance.

j Facility Operating Licer.se No. OPR-70, as amended, shall expire at midnight, August 13, 2016.

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a Amendment No..#,,3rp,125 I

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[e PSE&G NUCLEAR DEPARTMENT rage _L.or_a_

SP4 - REY. 3 i

! PERSONNEL ACCESS PROGRAM i

SPONSOR ORGANIZATION: Site Protection - Security i

1 l REVISION

SUMMARY

i In addition to the revisions listed below, the procedure is changed in format and to satisfy l the biennial review requirements of NC.NA-AP.ZZ-0001(Q).

j Section 2, References Page 3: Adds Ref. 2.10 - NLR-N91005, to satisfy an NRC conunitment l for random Fitness-for-Duty testing of persons with infrequent access.

l Section 3.2.1, Applicability. Pages 4: Adds reference to Section 6.4 for further information.

j Section 3.5, Administration of the Personnel Accem Proaram, Pages 5 & 6: Editorial change j to duty description of the Screening Supervisor. Changes to the duties of Photobadge

! Clerks. Adds reference to a revised form, the Photobadge Application / Change of Access i Status form. Changes to the responsbilities of *:he Emergency Preparedness Manager. Adds

Designated Medical Review Officer as an alternate for the Medical Director - Nuclear; adds

the term " medical evaluations," adds 'for-cause" to drug an alcohol screening.

e l Section 4.1, Temocrary Clearance. Pages 6 & 7: Adds refemce to 10 CPR 73.56. Editorial i

changes.

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Section 4.3.17 Clearance Recuirements. Page 7: Adds reference to a revised fonn, the l Photobadge Application / Change of Access Status form. l 1

Section 4.3.1, Full Clearances. Page 7: Adds reference to a revised form, the Photobadge

APPi lcation/ Change of Access Status form.

, Section 4.3.3, Ellalbility for Temporary Clearance Pages 8 & 9: This section is added to enumerate factors which may be grounds for dental of a temporary clearance.

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APPROVED

N/A General Manager - Quality Assurance #fudear Safety Review Date APPROVED: __ /04'l-7'/

Gener ger - Salem Operations Date i APPROVED: , ll)///f' General Managdr - Hope Creek Operations Date l

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! . PSE&G NUCLEAR DEPARTMENT rase _2 t s i

SP4 - REY. 3 l

PERSONNEL ACCESS PROGRAM SPONSOK ORGANIZATION: Site Protection - Security j

' l i l l REVISION

SUMMARY

(Continued) i i i Section 4.8.1, Transfer of Unescorted Access Authorization Pages 15 &l6: New wording require 'sultable inquiry" to be done for reinstatement of clearances when the person has j not been under a Behavior Observation Program for more than thirty days.

Section 4.8.2, Transfer of Unescorted Access Authorization Page 16: Adds reference to l Section 4.3.2, relative to minimum transfer requirements. I I

i Section 4.9, Reinstatement of Clearances Intermoted for Not More 'lhan 365 Days Page 17:

Adds the phrase "beyond the 180 day period initially granted," to clarify that a temporary i

! clearance can not be extended. l l

l Section 4.10, Full Clearance Update Beautrements, Page 17: Specific update requireraents I i are clarified in paragraph 4.10.1. I 1

i Section 4.11, Behavioral Observation Proaram Page 18: Editorial change. Specifies, under l

! items 1 & 2 that is each person granted unescorted access is subject to the Behavior

Observation Program and assigns responsibilities for ensuring compliance.

1 Section 4.12 - Self-Reportina of Adverse Infonnation, Pnge 19: Language is added to clarify l self-reporting requirements and the potential consequences of failure to do so.

l Section 4.13 - Inactivattna a Clearance, Page 20: Adds suspension 'for cause" to the j description of the process of inactivating a clearance when the subject may be within the i Protected Area.

Section 5.2 - Consent of Sublects, Page 21: Editorial change.

Section 6.1 - Persons Recuirina Personnel Access Clearances,(PACS) Page 25: Re-states in part, the criteria established in Section 3.2.1, that all personnel seeking or previously granted unescorted access authorization to enter the Protected Area or Vital Areas of Salem or Hope Creek Generating Stations must be processed for personnel access clearance.

Section 6.1.2, Page 26: Changes Reference 2.7, to 2.8.

Section 6.3 - Division / Departmental PAP Reauest and Maintenance, Page 27: Adds reference to a revised form, the Photobadge Application / Change of Access Status form.

Adds a summary of the duties of the Departmental Access Coordinator.

Section 6.4 - Reauestina Personnel Access Clearances, Pages 27 - 29: Section 6.4.1 is extensively revised to clarify the requirements for and process involved in the granting of a personnel access clearance.

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, PSE&G NUCLEAR DEPARTMENT rase _ L of 3

! SP4 - REY. 3 i

j PERSONNEL ACCESS PROGRAM i

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SPONSOR ORGANIZATION: Site Protection - Security i

REVISION

SUMMARY

(Continued) 1 Section 6.4.3 - Contractors and PSE&O Seasonal / Summer / Temporary Employees, Page 30:

! Minor language changes to clarify processing requirements and specify the early submittal

{ of the PSE&O Initial Data Form and the Request for Background Investigation, in addition

to the Personnel Access Questionnaire.

Section 6.5 - Changes of Employer Page 31

Editorial changes for clarity.

j Section 6.6 - Maintainino Personnel Access Clearance, Page 31 - 32: Adds a Long-term j Conunitment Tracking item (SP-PAP-94-01) To help ensure fitness-for-Duty and Behavioral

Observation Program requirements are met, review, on a nominal monthly basis, each individual's frequency of unescorted access to the Protected Area. IndMduals not available l for PPD random testing or under behavior observation on the Job by PSE&O Nuclear

! Department supervision, due to infrequent site access as indicated by 60 days with no l Protected Area entries, shall have their PAC inactivated.

Section 6.6.2, Page 32: Adds in the Note, the phrase *otherjob qualifications."

Section 6.6.3, Page 32

Adds reference to a revised form, the Photobadge Application / Change of Access Status form.

l l 6.7 - Personnel Access Clearance Plannino Pactors, Page 33: Specifies the advance time-  !

! frame required for completion of processing requirements, to preclude delays in gaining i access.

Section 7.4 - Adiudication When Adverse Information is Presented Pages 34 & 35:

, Describes a change to the adjudication process, including the composition of the new Site

Access Committee (SAC) regarding persons previously granted unescorted access. In the l case of a PSE&O pre-employment applicant, adds the phrase 'If the applicant is hired." l

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l Section 7.5 - Processina a Clearance Denial Page 35: Adds Medical Review Officer and

! Psychologist to those able to make a determination that a person may not be suitable for i

unescorted access.

Section 7.6 - Suspension for Cause , Page 36, Changes the number of days a clearance suspension may be extended for fact-finding, etc. to 60 days. l Section 8.3 - Actions by the Appeals Officer, Page 40: Adds Site Access Committee as being

! able to make a decision on the appeal of an access dental decision.

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ARTIFICIAL ISLAND l SECURITY PLAN PROCEDURES ..

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SP4

. PERSONNEL ACCESS PROGRAM i > 1. PURPOSE AND SCOPE i

l The primary purpose of the Artificial Island Personnel Access Program is to provide high assurance of the trustworthiness and reliability of personnel granted j unescorted access to the Protected and Vital Areas of the Artificial Island nuclear j facilities. The Personnel Access Program is the implementation component of the

! Artificial Island Security Plan designed to meet the requirements of the Code of Federal Regulations,1T) CPR 73.56 and 10 CFR 73.57. The Security Plan and its

implementing components are designed to protect the public health and safety by precluding acts of radiological sabotage which could result in a radiological release in excess of the limits described in 10 CFR 100. The goal of the Personnel

! Access Program, in coqlunction with the Fitness-for-Duty Program, is to eliminate

! the threat of an insider, including an employee in any position, committing an act

{ which could result in radiological sabotage by identifying individuals with such a j behavior potential.

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2. REFERENCES l 2.1 10 CPR 26 - Fitness-for-Duty Rule.

I l 2.2 10 CPR 73.56 - Access Authorization Program for Nuclear Power Plants.

j 2.3 10 CPR 73.57 - Requirements for Criminal History Checks.

l 2.4 Regulatory Guide 5.66 " Access Authorization Program for Nuclear Power Plants."

2.5 Arti.icialIsland Security Plan.

2.6 NC.VP-PO.ZZ-016(Q), Vice President - Nuclear Procedure " Security."

) 2.7 NC.NA-AP.ZZ-0033(Q), Nuclear Administrative Procedure " Nuclear i Security Program.

SP4 1of40 Rev.3 L ,

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' 22 NC.NA-AP.ZZ-0042(Q), Nuclear Administrative Procedure "Pitness-for- l

. Duty Program." l j 2.9 Corporate Personnel Practices Manual. I N I*hMh$MTdId@l!MNbYMM$FNWOY'h ,

i v G *Lalih%ifGilYv91E@STd?ifMiORbd MK M A M iuO5 i

l 3. GENERAL PROGRAM REQUIREMENTS AMD RFSPONSIBILITIES i

l Providing high assurance that the risk of a threat from an insider has been

! minimized requires implementation of a multi-faceted site access program. 'lhls i section provides an overview of the Public Service Electric & Gas (PSE&O) Artificial i Island Personnel Access Program (PAP) and its component parts and establishes j responsibilities for their implementation.

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! 3.1. Component Parts of the Personnel Access Proaram '

1

The PAP consists of the following interrelated parts

{ 3.1.1. Processes to implement the Access Authorization Rule (10 CFR 73.56)

{ including:

4 l + Background Investigations and 10 CFR 73.57 Fingerprinting and l Criminal History Requirements

. + Psychological Evaluations

+ Behavior Observations

+ Access Denials and Appeals i

j 3.1.2. Related PSE&O processes for:

j + Medical Evaluations i

j + Pre-employment Applicant Checks 4

+ Security Photobadging 4

+ Dosimetry Activities

+ Site Access Training 3.1.3. The PAP also encompasses completion of those administrative J

requirements necessary to obtain and maintain unescorted access to the Artificial Island Protected Area and Vital Areas. 'Ihe major administrative requirements are described in sections 4.3 and 6.0 of this document.

SP4 2 of 40 Rev.3

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3.1.4. 'lhe Pitness-for-Duty (PPD) Progmm is not pad of the Personnel Access Pro-j gmm. However, many of the elements of the PPD Pmgmm do inter-relate with the j PAP and effect PAP Implementation. In addition, PAP processes are used to j implement some PPD Program requirements. Related elements of the PPD l Program and the applicable sections of the Pitness-for-Duty Rule (10 CPR 26) are: ,

j + Drug and Alcohol Testing (26.24)

I + Sultable Inquiries (26.3 and 26.27) '

+ Training on PPD Policies and Behavior Observation Techniques (26.21 l

l and 26.22) 4

+ Management Sanctions and Appeals (26.27 and 26.28)

{

j 3.1.5. Individuals having successfully completed the above pre-access processes and associated administrative requirements are granted a PSPAQ j Personnel Access Clearance. Such individuals are granted unescoded access to the Protected Area via a security photobadge and shall be subject to those

requirements necessary to maintain unescorted access. Those requirements are j specified in detail throughout sections 4 and 6 of this document.

l 3.1.6. Individuals possess an unescorted access authorization when they have

' completed those above processes which are transferable between licensees and not dependent on site specific requirements or administrative actions. Transfers

! of the results of background investigations, fingerprint checks, psychological l evaluations, PPD tests, suitable inquiries, generic training, medical evaluations' l and dosimetry activities are acceptable provided that they have been completed j to regulatory or respective industry standards and the individual has executed a l signed release form to authorize such transfer.

, CAUTIOM: Transfer of unescorted access authorization element information does

not represent that all regulatory or PSPAQ Personnel Access Cleamnce I

requirements have been met. Many elements have expiation dates, or require updating, or site specific additions, or administrative actions, i.e. suitable j inquiries, training, PPD testing, photobadging processes, etc. All the clearance l requirements specified in section 4.3 of this document shall be met to obtain a l PSPAQ Personnel Access Cleamnce unless a waiver in accordance with section 4.7 applies.

3 j 3.2 ADDIICabilltY a

j 3.2.1 All elements and requirements of the Personnel Access Program and its

] component parts shall be applicable to persons seeking or previously granted j SP4 3 of 40 Rev.3 I

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unescorted access authorization to enter the Protected or Vital Areas of the Artificial Island Salem or Hope Creek Genemting Stations. MM of this document describes such persons further.

3.2.2 Persons administering FFD Program elements shall complete, as a minimum, those elements of the PAP required b CFR 26. [ejidisj$58)MS[MJhTsilidiiss]y section are provided 2.3 of in section Appendix 6.1.2 of A this document.

3.2.3 Persons who have established a need to know Safeguards Information and do not possess or need to obtain unescorted access are required by law to  !

complete as a minimum the fingerprint and criminal history requirements of 10 l CFR 73.57 prior to being gmnted access to Safeguanis Information. We methods PSE&O uses to complete the requirements are described in section 6.2 of this document.

3.2.4 Persons required to repod to the Emergency Operations facility (EOF) in accordance with Emergency Plan assignments, who do not possess or need to obtain unescoded access to the Protected Area, are subject to elements of the FFD Program. Rese individuals are subject to random drug and alcohol testing and the annual training requirements of 10 CFR 26. In addition,10 CFR 26.2 requires pre-assignment drug and alcohol testing, suitable inquiries, and FFD training.

Here is no regulatory requirement for individuals with only Emergency Plan EOF assignments to meet any portion of the PAP other than these inter-related FFD elements which are accomplished by PAP process implementation.

3.3 Administration of the Personnel Access Procram he Site Access Administator, utilizing the Site Access Group staff, shall be responsible for PAP implementation. The Site Access Administrator coordinates with the Medical Director- Nuclear to assure the applicable elements of the FFD Program and the activities of the Psychological Services Group are incorporated into the PAP as appropriate. Responsibilities for PAP and related FFD Program ele:ments are:

Manaaer - Site Protection: Sets policy and provides management overview of the PAP.

Site Access AdmtgJstrator: Directs the Site Access Group's activities; 13 responsible for coordinating the day-to-day implementation of the PAP and its interaction with related FFD and other site access processing activities; and SP4 4 of 40 Rev.3

1 coordinates appeals of decisions to deny access to the Protected Area with the management individual designated as the Appeals Officer.

Screenina Supervisor: Responsible for administratively determining a person's eligibility to be granted unescoded access to the Artificial Island Protected Area; supervises the activities of the Screening and Badging personnel; evaluates background investigation repods to determine suitability for unescorted access authorization; provides relevant information discovered during the screening process to Psychological Services for their review and ac(Judication; has functional responsibility to deny access to the Protected Area; and initiates the administrative actions to deny access when persons are determined to be unsuitable M under any element of the PAP or FFD Programs.

Backaround Investiaation Case Workers: Responsible for assuring that the screening process is initiated, conducted, and completed for assigned Individual personnel access cases in accordance with Site Access Group implementing procedures.

Photobadae Clerks: Nesponsible for product hotobadges and administrative processing of access control information; chan es to the 31 Dag i lis t h__ ___ _ _ . .

c gnee w Coanizant the authori a_nd Department Head:

responsibility to sign 'lhe the P_h6,6- responsibillty t' tniiddd- hpiladi6r --

cenLer,rnanage 6

, request a PSE&O Personnel Access Clearance, revalidate the need for access every'31 days, and notify the Screening Supervisor when access is no longer required.

Departmental Access Coordinator: Designated within a responsibility center g

as the lead contact point for coordination of access related issues.

Process Coordination Clerk: Responsible for $$IfjE$ the in-processing or requalification needs of each person seeking or previously granted a PSE&O Personnel Access Clearance and scheduling attendance at activities required to obtain or maintain their clearance.

Em einency PrtDaredneM Manager: Responsible for infonnin the Site Access Adrministrator of all individuals assigned EOF duties, wmemm) ent to facilitate compliance with section 3.2.4 of this docurnent. ns Norag g $i$75

% d id E }l u $}U iid I E l f d E E ElII E$ [l A Ei{I[l[i i d N $ E jiE N isliid EE [ fii N N h d b M M h N!htkNIdrMill$1g ak EiTIkrgedd[MN) am bi}let$

SP4 5 of 40 Rev.3 l

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Medical Director - NuclearltWsiifmem-F w w_ m e M E i ta m o rrre w - n u n U ]:

Responsible for routine and pre-access $J$dM and for implementing the PPD Program including pre-access, random, gjg5M and follow-up drug and alcohol screening as it relates to the PAP; responsible to ensure the Site Access Group is notified immediately of persons falling to meet these requirements to '

facilitate suspension of the individual's clearance and preclude further access to the Protected Area; and responsible to inform the Site Access Administra-tor / designee of those individuals involved in PPD Program administration to facilitate compliance with the requirements referenced in section 3.2.2 of this document.

Psycholoalcal Services Administrator: Responsible for administration and implementation of the pre-access psychological evaluation which consists of a recognized assessment instrument and a clinical interview as required; responsible for ensuring the results of these evaluations are provided to the Screening Supervisor in a timely fashion; responsible for administration and implementation of th9 Behavior Observation components of the PAP and FFD Programs.

ADDeals Officer: Responsible for conducting the impartial review of Personnel Access Clearance denial decisions upon appeal; affirms or recommends reversal of the clearance denial decision.

3.4 Evaluations and Audits

, An independent evaluation of the Personnel Access Program shall be co$ ducted at lea t every 24 moriths in accordance with the requirements of 10 CPR 73.56.

The PAP may be audited annually as a component of the Security Plan in accordance with 10 CFR 73.55. Those elements of the PAP applicable to FFD Program implementation shall be audited as required by 10 CFR 26. Evaluation and audit reports shall be ava!!able for inspection by the NRC and retained for three years.

4. PERSONNEL ACCESS CLEARANCES There are two Personnel Access Clearance categories:

4.1 TemDorary Clearance This clearance category permits unescorted access on an interim basis for a period up to 180 continuous days, while a full background investigation is being Clearance are found completed.

in section 4.3.2 of The this completion requirements document. In accod$iiE$ moi $$ for a Temporary $?eNdi$$

SP4 6 of 40 Rev.3 au.-s .

E, temporary clearances shall not be renewed or extended. %dWA persons granted a Temporary Clearance ' arocessed for a Full Clearance unless consent is withdrawn prior to completion . Section 5.2 of this document addresses the consent process.

4.2 Full Clearance .

Full Clearances are proe-d for applicable personnel as specified in section 3.2 of this document. 'The completion requirements for a Full Clearance are found in section 4.3.1 of this document. A Pull Cleamnce shall be granted as soon as all Pull Clearance requirements have been completed. Situations where a Pull CJearance may be granted prior to completion of the full background investigation requirements of section 4.3.1 are found in sections 4.4.3 and 4.4.4 of this document.

Full Clearances rernain active provided they are maintained in accordance with the requirements of section 6.6 of this document. Full Clearances remain eligible for reinstatement if unescorted access is interrupted under favorable conditions for less than 365 days. ' Die reinstatement process is described in section 4.9 of this document. When unescorted access is interrupted for more than 365 days, the requirements fora clearance update described in section 4.10 of this document shall be satisfied before the clearance can be reactivated.

4.3 Clearance Reautrements 4.3.1 Pull Clearances A Pull Clearance is gninted upon satisfactory completion of the following criteria:

1. Submittal of a [h[o[@$MIMMMMitA6$M signed by the Cognizant PSE&G Department Head within 30 days preceding photobadging.

2. Successful completion of a written psychological evaluation (Minnesota Multiphasic Personality Inventory - 11 [MMPl] or equivalent) and, if applicable a satisfactory interview with a doctoral level licensed clinical psychologist within 365 days preceding photobadging.

3. Successful completion of drug / alcohol screening within 60 days preceding photobadging, except as provided for in Reference 2.8.

4. Successful completion of a medical evaluation within 365 days preceding h

P go , badging *lf%fEEEfd5[lIit$E[NI[$$I$IE[diiEdMEE$IiiEi NkN MIIUdbekhb-SP4 7 of 40 Rev.3 1

5. Successful completion of General Employee Training (OET) within 365 days preceding photobadging.

6. For contractors, submittal of documentation of employment.

7. Por PSPAQ employees, confirmation of employment status.

8. Successful completion of Pitness-For-Duty (PPD) training within 365 days preceding photobadging. .

9. Successful completion of the background investigation elements described in section 4.4 of this document.

4.5.2 Temocrary Clearance Reference 2.4 to this document restricts the issuance of Temporary Clearances in certain situations. Sections 4.1, 4.8, 4.9, 6.1, 6.2, and 7.7 of this document describe situations when the use of a Temporary Clearance is prohibited, restricted, or has limited application within PSPRO's Personnel Access Program.

Except as controlled by those sections, a Temporary Clearance may be granted upon successful completion of the following while the remainder of the full background Investigation requirements are being completed:

1. Items 4.3.1.1 through 4.3.1.8 above and completion of all of the following in lieu of item 4.3.1.9 above.

2. Recommendation from one developed reference who has had frequent and direct association with the access applicant.

3. Pingerprints must have been recorded and transmitted to the NRC for a PBI criminal history check.

4. Identity verification via one photo identification (e.g. drivers license, military ID, passport or similar document).

5. A satisfactory employment check for the past year.

6. A credit check which does not reveal significant financial irresponsibility.

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4.4 Backaround Investiaation Elements The background investigation covers the past five years except as modified in each element below or since the eighteenth birthday, whichever is shorter. A documented best effort attempt shall be made to obtain the required information described in each element below conceming the indMdual's employment history, educational history, credit history, professional credentials, criminal history, military service and character / reputation for the required period. The individual shall complete a Personnel Access Questionnaire (PAQ) to facilitate completion of the background investigation.

In addition to providing requested information on the PAQ concerning each of the background investigation elements, the individual shall be required to indicate via a certirication statement any prior history of FFD concems. The Individual shall also answer in written form the questions listed in item 7 of section 4.4.1 of this document. Falsification or omission of significant facts regarding the individual's SP4 9 of 40 Rev.3

1 PFD, criminal, or previous unescorted access history shall be sufficient basis for denial of a Personnel Access Clearance.

4.4.1 Employment History Except as noted below, employment history shall be obtained for the past five

~

yeam through contacts with previous employem and/or other somtes by obtaining as much of the following information as is available:

1. Verification of identity of access applicant by name, title, SSN, DOB or other characteristics.

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

3. Disciplinary history.

4. Reasons for termination and eligibility for rehire. -

5. Verification of activities during interruptions of employment in excess of 30 days. ,

6. Any information that reflects upon the reliability and trustworthiness of the person as it relates to granting unescorted access.

7. In coqjunction with the above questions, in order to meet 10 CPR 26.27 requirements, a suitable inquiry of each employer, at a minimum shall be completed. Sultable inquhy questioning shall detennine if, to the best of the employer's knowledge, the individual has ever: .y

+ Been denied access at any nuclear power plant in accordance with any fitness-for-duty policy.

+ Been removed from any position requiring unescorted access or an emergency team assignment at a nuclear power facility due to fitness-for-duty concems.

+ Been subject to a plan for treating substance abuse (except for self-referral for treatment).

+ Tested positive for drugs or alcohol or been found to be impaired while on duty.

Employment History of Craft Workers - Because of the multitude of employments that cmft, trade or other workers may experience during a five-year period, verification of all such employments may not be possible. A Full Clearance may be granted based upon an inclusive three-year retrospective employment SP4 10 of 40 Rev.3

.__ _ _.. - _ _ . . . ..=

s check if the entire five-year period cannot be covered. Under no circumstances may a Pull Clearance be granted based on an employment check ofless than three years. In all cases, a documented attempt shall be made to cover the entire five-year period. An explanatory statement shall be included in the file delineating the reasons for an employment check covering less than a five-year period.

4.4.2 Educational History g Claimed enrollment at an educational institution during the previous five years and the highest claimed post high school attendance leading to a. degree, regardless of time, shall be verified.

4.4.5 Criminal History in accordance with 10 CFR 73.57, all persons shall be fingerprinted and criminal history checks processed through the Federal Bureau of Investigation (FBI) covering the individual's entire adult life (period since the 18th birthday). When the FBI criminal history check shows a felony arrest for which no disposition is indicated, a check of coud records shall be performed to ascedain the disposition of the case in accordance with the provisions of 10 CPR 73.57 (c) and (e).

As permitted by Federal, State or other applicable law, a criminal history record check through appropriate law enforcement agencies and/or coud records may be performed to supplement the FBI report when conditions warrant, i.e. no disposition indicated, delays in FBI report receipt, misdemeanor verification, etc.

Such checks normally cover the previous five years or since age 18 whichever is shoder. If there is otl)er evidence of criminal actMty prior to the specified period, such activity shall be investigated.

A Full Clearance may be granted in those instances where FBI criminal history checks result in unreadable fingerprints, provided:

1. Efforts are documented that the fingerprints were resubmitted in a timely manner;

2. The FBI indicates that no undeclared criminal history exists based on name and Social Security Number; and,

3. No other indication of criminal history exists based on the PAQ or other f background element checks.

If such indication does exist, the Screening Supervisor shall determine, based on his/her expertise, whether local law enforcement checks, transfer of fingerprint results from other licensees, etc. shall be completed prior to granting a Full SP4 11 of 40 Rev.3

Clearance. In this instance, any resubmitted fingerprint criminal history results received from the FBI shall be considered upon receipt.

4.4.4 Military Service If occurring within the last five years, military service (claimed or developed) shall be verified by receipt of a Ponn DD214 or other National Personnel Records Center (NPRC) records. 'This information is obtained from the NPRC through acquisition and submittal of the individual's authorization for release of military history information. Ifit becomes known that a person's discharge is under other than honorable conditions based on PAQ responses, other background element completion, or the Form DD214, or the DD214 is not available from the NPRC, further investigation shall be made prior to granting a Full Clearance.

A Pull Clearance may be granted prior to receipt of a Fonn DD214 or other military record, provided:

1. Other clearance requirements are satisfied,

2. It is documented that the request for military history was submitted to the NPRC within ten worldng days of granting the temporary clearance,

3. No indication of a discharge under other than honorable conditions exist, and

4. Reasonable documented attempts are made at least every six months to obtain this information from the NPRC until a response is received. Any records received after a clearance is granted shall be considered upon receipt.

4.4.5 Character and ReDutation The access applicant's reputation for emotional stability, reliability and tmstworthiness shall be examined through contact with two references supplied by the access applicant and at least two additional developed references (not relatives). NOTE: The intent is that references not be a known relative or live in the same household as the individual applying for unescorted access and the references not be closely related to each other to assure that their knowledge and opinion of the access applicant's character are Independent. The references' individual or collective association with or knowledge of the access applicant need not cover the entire five year retrospective period. Emphasis is placed on questioning and documenting on a standardized form the reference's knowledge of:

1. Identified psychological problems.

2. Criminal history.

SP4 12 of 40 Rev.3

. T-- i l 3. lilegal use or p-mlon of a controlled substance. l j 4. Abuse of alcohol.

l j 5. Susceptibility to coercion.

. 6. Any other conduct relating to an access applicant's trustwodhiness or , i

[

t reliability to dischargejob duties within the nuclear plant environment.

i 4.4.6 Verification of Identity .

Prior to granting unescorted access, identity (ID) shall be verified through means l such as photographic ID, social security number, date of bidh, or comparison of

! the individual's physical characteristics with employment, education, military,

driver's license, and other records and/or employer and character references who

have personal acquaintance with the individual. Verification of identity is ultimately established through the collecth'e records and ID consistency.

4.4.7 Credit Check j A check of the individual's credit history shall be performed to identify significant

financial irresponsibility. Credit history information may be obtained through i j checks with credit bureaus. If credit bureau checks do not reveal the requested l I information, a documented best effort attempt shall be made to contact personal l credit references provided by the individual or developed.

l

! 4.5 Psycholoa_lcal Evaluations l 'Ihe objective of the psychological evaluation program is to assess an individual's j behavioral reliability, trustworthiness and overall psychological well-being. 'Ihe

! background investigation provides significant relevant information conceming a

! person's past conduct when determining eligibility for a Personnel Access l Clearance. The psychological evaluation complements the background j investigation by producing information concerning the persons's present l emotional / social functioning and possible future behavior. This includes, but is j not limited to: addictive potential, proclMty to engage in impulsive acts including j radiological sabotage, and susceptibility to extemal manipulation by persons or

! organizations.

A licensed clinical psychologist conducts the psychological evaluations required j by the Personnel Access Program. Each psychological evaluation consists of

administration of the Minnesota Multiphasic Personality inventory - 11 (MMPI), or j equivalent to each access applicant. In addition, a clinical interview may be j conducted if MMPI results or other information warrants it. Upon conclusion of the I SP4 13 of 40 Rev.3 1

e f evaluation, the psychologist determines whether the person is acceptable for i unescorted access, and reports the determination to the Screening Supervi-l sor/ designee prior to photobadging the individual. Documentation of the

determination and actions taken shall be incorporated into the subject's

! personnel access file. Details on how the program is administered are within the l Psychological Services Group's implementing procedures. -

l l 4.6 lipn-Licensee iContractorNendor) Proarama i .

PSPAQ may accept the results of the entire or any portion of a non-licensee i i contractor / vendor unescorted access authorization program, provided that the j l contractor or vendor program meets the requirements of the 10 CFR 26,10 CPR j 73.56, and the PSPAQ Personal Access Program. Each non-licensee whose l l unescorted access authorization program is accepted by PSPAQ shall make their i

records available for auditing. PSPAO or it's designated representative will j conduct an audit every 12 months of approved non-licensee unescorted access l authorization programs. PSPAQ may share the results of audits conducted under l other licensees' programs to meet this annual contractor audit requirement.

l PSPAQ retains the ultimate responsibility for assuring that persons granted l

. unescorted access to the ArtificialIsland Protected Area meet the requirements of l the 10 CFR 26,10 CFR 73.56, and the PAP. A non-licensee shall submit its unescorted access authorization program to the Site Access Administrator for i review and approval at least sixty days prior to requesting access for its employees l

covered under its program. He Manager - Site Protection shall notify the non-licensee in writing of the Program's acceptability. "

l  :

i -

l 4.7 Walvers i

j There are three provisions for waivers of the PAP requirements:

l 4.7.1 Provisions to waive the fingerprinting and FBI criminal history check j requirements in certain instances for specific individuals exist in 10 CFR 73.57 (b) l and (f)(3). When these provisions are used, documentation shall be retained in the l personnel access filesjustifying the basis for any walver allowed by 10 CFR 73.57.

All other requirements of the PAP shall be completed for such individuals unless

! walved elsewhere within this document.

! 4.7.2 he requirements for a Full Clearance, or any portion of the requirements

{ in section 4.3.1 of this document for a Full Clearance, may be waived based upon j receipt of a letter from the cognizant NRC office certifying an individual is suitable 3

for unescorted access. He NRC certified individual may complete, or may sign a i

SP4 14 of 40 Rev.3 i

i,

waiver of the requirement for, Access Tmining and other PAP actMtles appropriate to their access needs.

4.7.3 A waiver is provided in 10 CFR 73.56(c) of the requirement to do a background investigation and psychological evaluation in order to retain unescorted access by those individuals having uninterrupted unescorted access .

authorization on April 25,1991 for at least 180 days (i.e., from October 27,1990).

Such indMduals shall be classified as " grandfathered" personnel and are eligible for the tmnsfer, reinstatement, and update processes as described in 5ections 4.8, 4.9, and 4.10 of this document.

4.8 Transfer of Unescorted Access Authorization 4.8.1 In lieu of PSE&G's completion of the clearance requirements specified in items 4.3.1 and 4.3.2 of this document, unescorted access authorization (UAA)

Infomtation from another nuclear licensee may be transferred to PSE&O via direct correspondence, computer data transfer, or telecopier provided:

1. The person holds or had UAA which was terminated under favorable conditions within the previous 365 days.

N: Tmnsfer of some UAA information for individuals terminated under UNFAVORABLE conditions ma be restricted due to federal orstatelaw. smasce namn T&ie%l5? man unesco taccesslak

$dkNk ConverscEy, the thander oiMk unfEvorable FFD.

Sultable Inquiry information is required by 10 CFR 26.27 and 26.29

2. $$$I the individual's UAA has been terminated under favomble conditions for more than thirty calendar days, the following are required to utilize the UAA transfer:

+ The Individual's activities since unescorted access was terminated shall be ascertained to meet the requirements of Reg. Oulde 5.66, Clarification 3.

+ li[tY$5EINEIEddlTES$ -

ygg u te w aag a a ui m ague m Jpe E I$$dI8rkis$$kNEl$ 19 Weactinen@$$$$$'2hMf[h$NM!!kk _._

+ The Ind,ivi_ dual shall complete a Restart PAQ to facilitate [5SEEWd me requiremefits. 'Ihe Restart PAQ's Sullable inquiry, criminal history, SP4 15 of 40 Rev.3 i

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and othereccess related lons shallcddress f

L

3. The sending licensee certifies the individual's clearance meets the .

requirements of 10 CPR 73.56 either via completion of those .

j requirements or the "grandfathering" criteria described therein. If the j individual's UAA at the sending licensee is based upon completion of ~

l

only the Temporary Clearance criteria described in section 4.3.2 of this

! document the following conditions of CALITION shall be noted: '

l + Re individual may be transferred to one or more other sites before i the background investigation can be completed; and therefore, l + The initiating licensee retains the responsibility for completion of  ;

i the full background investigation, retention of records, notification l i to receiving licensee (s) of any disqualifying adverse information i

! developed during the background investigation process that would-l have precluded unescorted access and notification of the final i

! access authorization determination:

+ The 180 consecutive day period must be continuous beginning with j the date that the initiating licensee granted the temporary access L authorization, regardless of the number of transfers; and

+ At a minimum, the criminal history or military history information j is most,likely still pending and the results shall be tansmitted to the receiving licensee (s) upon receipt.

l

! 4. A check of information such as name, date of birth, social security l l number, sex, and other applicable physical characteristics of the access applicant shall be made to establish identity.

5. The individual has signed a release form authorizing the transfer.

4.8.2 Transfer of UAA information does not constitute granting of a PSPAQ

, Personnel Access Clearance. Other elements and administrative actMtles

! required by regulation may be transfen ed or may need to be completed by E i prior to photobadging, i.e. FFD testing, tmining, dosimetry, etc. %e activities and i their acceptance criteria are specified in procedures or other documents specific j to those activities. The requirements listed in section 4.3.1 @@ of this document are the minimum which shall be satisfied to establish a PSPAQ i Personnel Access Clearance.

I SP4 16 of 40 Rev.3 i

r

. .. - . . ., -m- - _ _ _

4.0.3 PSIWO may transfer UAA information to other licensees provided the l i applicable requirements of section 4.8.1 above which are PSIWQ's responsibilities i are met.

i 4.9 Reinstatement of Clearances Interrupted for Not More Than 365 Days i i

Clearances inactivated due to interrup'tlon of UAA which were originally granted '

{ by PSEacQ may be reinstated provided:

~

I 1. Unescorted access was ugl intemipted at this facility for a continuous j period of more than 365 days. Temporary Clearances shall not have

exceeded 180 days from date of original issuance to be eligible for

! reinstatement. Only the remainder of the 180-day $$$$Ni?g,EM i

! period may be utilized. The Tem Clearance l orextended hNjld83N$pora 'M.may not , t3be renewed '

l 2. Previous unescorted access was tenninated under favorable conditions.

) (See section 7.7 of this document when terminated under I is

,RABLE [iha conditions.)N...

M _ __ . _ . _ _ _

1

3. All other requirements of the PAP shall be up to date or shall be updated I

(see section 4.3 of this document).

! 4.10 Full Clearance Update Reautrements

! A Full Clearance shall not be reinstated or tmnsferred when unescorted access l authorization has been inactivated for more than 365 days. @@

l [ , a Full Clearance Update shall be completed to regain unescorted access. 'Ihe Update requirements are: l l 1. A background investigation (BI) update which meets the requirements of i Reference 2.4 of this document to cover the person's activilles from the I

date of the previous background investi rpugggtegacceptable BI exists, jp Q allon avA x mu SI@gi

, g I_ indhgai$lijBl shall be done at this time. A PAQ shall be l con ipleted by the individual to facilitate the Bl. The scope of the B1 l update shall meet the requirements of section 4.4 of this document in all I ways other than the time period %ElIM 'dE5fdI~ the ate I process. N .' EfEE l

G"uiPsMlIftedidWiATdEf[s$Ni$fi$Il$d*$IEd WF5e82WMWeilli" g a g w. w -Jsig n .n y g w i R e mn m time $dymg.v.nmpgamdyiow,everA10$FR7347 peri (needpot boedone does A require i

SP4 17 of 40 Rev.3

3 W m rinting process be repeated M

2. Completion of a psychological evaluation using a recognized assessment l Instrument (MMPI - 11 or equivalent) and its review by a licensed l psychologist. .

3. All other PSPAQ Clearance requirements shall be up to date or shall be updated (see section 4.3 of this document). .

i j A Temporary Clearance may be issued after completing section 4.3.2 i requirements while the B1 is being updated. Transfer of UAA information is l pennitted to assist in meeting the requirements ofitems 1 and 3 of this section.

l 4.11 Behavioral Observation Proaram i

i Trustworthiness, psychological suitability, and continued compliance with all l requirements of the Personnel Access Program and the Fitness-for-Duty Progmm

! are among the conditions for continuation of a person's Personnel Access

! Clearance. M[@3 each pemon granted unescorted access shall be subject to the Behavior Observation Program (BOP). Unescorted access may be suspended or denied when credible information is received indicating that a i person's conduct has created reasonable doubt about the individual's j trustworthiness or physical, mental or emotional suitability for access. Such information may be obtained from the BOP or other sources. The BOP is a component of both the Personnel Access Program and Pitness-for-Duty Program ,

i and is administered by the PSE&G's Psychological Services Group. The

! Behavior Observation Program consists of the following elements:

i

! 1. A tmining program that develops in appropriate personnel, awareness

and sensitivity to detect and report changes in behavior, included i suspected alcohol and dru abuse or other waming signs of possible FFD l concerns. IRSR managers E supervisors l M3 any individual with access to the Protected Area or

{ assigned Em4rgency, Plan duties within the Protected Area or EOF, shall l receive _JsMME training.

2. A program, (described in detall in Reference 2.$ of this document)

! providing for the reporting of performance degradation or behavioral i changes, traits and/or patterns that may reflect adversely on a person's j trustworthiness and reliability which, ifleft unattended, could lead to acts i detrimental to public health and safety. 'Iheprgm includes a required I

monitoring process for individuals [$MIk6isysatii unescorted access SP4 18 of 40 Rev.3

4

[ who require periodic follow-up (documented observation and/or PPD a result of a FFD incident orliiff.is f When changes in behavior are detected, Reference 2.8 of this document requires, j in various situations, the cognizant Department Head, the Medical .

l Department - Nuclear, and the Security Supervisor be h1 formed. The

! Security Supervisor has the ability and responsibility to escort the individual

outside the Protected Area if necessary and inactivate the individual's security l photobadge to terminate immediate Protected Area access. Eacfi of the l Individuals listed abow

have the shared responsibility to infonn the Site Access

Administrator / Screening Supervisor when suspension or dental of access j occurs or may be warranted. The Site Access Administrator / Screening l Supervisor shall initiate the administrative actions necemary to prohlblt further l Protected Area access. Sections 4.12, 5.5, 7.4, 7.5, 7.6, 7.7 and Appendix A l describe situations when suspension, denial, or reconsideration of access may be warranted and how th,ese actions shall be accomplished.

l 4.12 Self-Reporting of Adverse Information ld nce 2

]

,Regu,la,to_ry MpMM Gu,M,e, M Hy . 5.66_(Re_fe_re,$_1diilj_.4 6(MMMIs " Individuals with unescorted of this _

j access authorization must be notified of hisMer responsibility to report any arrest j that may impact upon his/her trustworthiness." 'The following guidance is

! established by the PAP to ensure that this notification responsibility is understood.

! All penions applying for Temporary or Full Clearances shall re rt all st arrests on the Personnel Access Questionnaire M. Ej$Isltsu_

be re direct -to the Screening Supervisor, a ----- ----

y. m m

. . ~ ~ , ......-.- - .- .- .-- - . .--

. For the purpose of this duty to notify, an arrest is defined as being detained or taken into custody by someone with lawful authority, such as a pogogegoggry of answering a criminal charge. This includes arrestsminrpons/m@slwaMM for felonies, misdemeanors, disorderly persons offenses and quasi-criminal charges such as a traffic ticket or court n alcohol or controlled substances ( al or appeagnce ageganginvo,lg

~

Iti$ Is[EIN N $ $N$iihIE$$ -= Neni5f$ $

up - - - - - - -- $^$N511 befehaahmdj oe Moreover the obilgation to report all arrests includes the obligation- - -

to report all continuing steps in the processing of criminal charges, such as release on ball, Indictment, and Judicial determinations to dispose the case SP4 19 of 40 Rev.3

l Including sentencing, work release assignments, probation, pre-trial intervention j

in lieu of any of the preceding, or otherjudicial action of s.imilar nature. ] }

p f It@ h3kMEd$?

l The Screening Supervisor may verify the accuracy of the information provided .

l and shall evaluate the individual's unescoded access status. The Psychological

! Services Group may assist in the evaluation. Continuation, suspension, or denial .

i of unescorted access shall be in accordance with PAP requirements as described

! In section 7.0 of this document.

! 4.13 Inactivatina a Clearance When a person granted unescorted access terminates employment or no longer

, requires access to the site Protected Area, the Cognizant Department shall l notify the Screening Supervisor within two workina days. The Screening l Supervisor ensures the administrative actions required to inactivate the security j photobadge and Personnel Access Clearance are accomplished. If the individual's l access is suspended or denied under section 7 or the individual is terminated or suspended for cause, notification shall be immediate to the Security

, Supervisor. If the individual is in the Protected Area, Security Force personnel i

shall escort the individual out of the Protected Area, prior to or concurrent with informing the individual of their termination or suspension @E. If

terminated for cause, the Individual shall be immediately placed In'an Access P Review Required status (see Section 5.5) which includes, at a minimum, 4 l prohibiting access ase visitor until the conditions for reconsideration of section I 7.7 have been met.

5. PERSONNEL ACCESS PROGRAM POLICIES j The PAP shall be administered in accordance with the following policies:

l 5.1 Use of Information l Information obtained through the PAP is only intended to be used to determine

' a person's eligibility to be granted a Personnel Access Clearance. When a background investigation discloses that a subject may have committed a crime

, and that this allegation is unknown to the law enforcement agency or agencies l having jurisdiction over the offense, the checking process shall be terminated i immediately and all infonnation reported to the Manager - Site Protection. The

] matter shall be reviewed with corporate counsel, who may direct that the matter j be referred to the appropriate law enforcement agency. The background investigation shall be held in abeyance and the Access Review Required process SP4 20 of 40 Rev.3 l

described in section 5.5 of this document utilized pending resolution of the matter by the law enforcement agency, and if applicable, by court disposition.

5.2 Consent of Sublects i

j No ITD evaluation, psychological evaluation, or background investigation shall be ,

{ initiated without the prior knowledge and written consent of the subject of the j evaluation or check. A suidect may withdraw consent at any time. Withdrawal of

! consent must be made in writing, and shall be effective following its receipt by the i Screening Supervisor. Withdmwal of consent results in the termination of the l conduct of a PPD evaluation, psychological evaluation, and/or background j investigation as soon as notification of withdrawal of consent is accomplished.

l Work already accomplished is reported to the Screening Supervisor. The reports shall be retained in the subject's personnel access file. Withdrawal of j consent preclud,es granting a Personnel Access Clearance. If access has already l been granted, g shall be terminated immediately. Access to the Artificial Island Protected Area as a visitor shall be orohibited if consent is withdrawn.

{ 5.3 Dissemination ofInformation

A personnel access file shall be established for each person for whom a request j for a PSPAQ pre-employment applicant check or a Personal Access Clearance is submitted. The term " access applicant" is used throughout this document to j describe both types of persons indicated here. The term " subject" refers to the l specific individual covered by a file or the individual undergoing the processes described in the remainder of this document. This file may contain the following j documents as anolicable

+ Application for Photobadge

+ Request for Security Clearance

+ Personnel Access Questionnaire

+ Nuclear Background Investigat'on Report

+ Subject interview Reports

+ Access Authorization or Denial Records l 4

+ PBI Arrest Record Reports

+ Credit Reports

+ Military Records

+ Associated Correspondence and Administrative Reports SP4 21 of 40 Rev.3

1

+ Appeal Requests

{ + Appeal Resolutions i

l Except as provided for in this section, Information contained in personnel access l j files may be made available only to the Manager -Site Protection, Site Access ~

, Administator, Screening Supervisor, designated Screening and Badging f Personnel and, under certain circumstances specified in this program, to a

! limited number of other company personnel who require access to the j information for professional review or management decision.

NRC inspectors, law enforcement omclals and other persons pursuant to court

]

j order, and persons designated to conduct audits of the Personnel Access Program j may have access to a personnel access file to conduct their omclat duties.

l However, prior to making copies or extracts of the substantive (non- )

administrative) portions of any file the need for copies or extracts shall be discussed with the Site Access Administrator. ' Die Site Access Administrator shall review the Corporate Personnel Practices Manual and regulatory 1 l requirements found in 10 CFR 26 and 73 in each case and ensure their i requirements have been met prior to allowing any reproduction of files.

( 4

The subject of personnel access files, their appointed counsels or third parties l accompanying the subject, may review the subject's personnel access file in the j offices of the Site Are*== Group, in the presence of an authorized member of the l l Screening and Badging staff in accordance with Coroorate Personnel Practices l Manual requiremen,ts. Except as authorized by 10 CPR 26 and 73, no other l persons shall be permitted direct or indirect access to substantive information i

contained in a personnel access file without the prior knowledge and written

consent of the subject. The results of background investigations, psychological l evaluations, suitable inquiries, and FFD testing shall be tmnsferable only to extent j permitted by these regulations and their implementing guidance documents i following completion of a signed release by the individual authorizing the transfer.

4 All persons, except the subject of the file and their appointed counsel, who have access to personnel access files are obligated to protect the confidentiality of the files. All persons, including the subject of the file, who request access to a l

j personnel =. cess file shall be required to provide identification. The subject may j make written excerpts from his/her own personnel access file. Because the Site j Access Group is responsible for protecting and maintaining the confidentiality of these records, photocopies and/or reproduction of any material contained in l

4 the file shall not be authorized to those persons covered by this paragraph, unless 4

SP4 22 of 40 Rev.3 l

l . .

4 j approved by the Site Access Administator after review of regulatory and Corporate Personnel Practices Manual requirements.

l In addition to all of the above methods to protect the confidential information

contained in the personnel access files, physical security of the background i screening ofHce and its record storage area shall be maintained. This requires a --

l member of the Site Access Group' staff he present whenever files are not

! secured. When the staff is not present these facilities or the files shall be locked or otherwise secured.

Contractors and subcontractors conducting the background investigations for

PSPAQ are obligated to protect the confidentiality of any substantive files they j create on a subject. They are prohibited from fumishing information acquired l through a psychological evaluation or background investigation to any third l person, or to a private or public agency except as required and authorized by law l [see 10 CFR 26.29 and 10 CFR 73.56 (f)).

} '

i 5.4 Conduct of Backa_round Investlantionit -

l Background investigations shall be conducted to meet the highest ethical and

professional standards and in accordance with regulatory guidance. In addition to regulatory guidance, the guidance which follows shall be used when derogatory j or adverse information is developed during background investigations.

I

~

When adverse information is developed during the course of a background j investigation, the subject usdally is interviewed by the Screening Supervisor / designee. The subject shall be informed of the nature of the j adverse information, given full opportunity to refute or elaborate upon the j information, informed of the right to remain silent and his/her right to terminate

! the interview at any time, and that suspension of access may result from the

! exercise of this right. This allows the subject to be reasonably aware of findings i which could result in the dental of a Personnel Access Clearance, and to present evidence or information which the subject may wish to have considered in acUudication. A subject may be accompanied by counsel during interviews, hu.1 l counsel may not answer auestions or make statements for the sublect L

Usually, a subject interview is not conducted until all other inquiries have been

! completed. Ifinformation presented during the interview requires verification or otherwise indicates a need for additional information, further inquiries shall be

conducted. More than one subject interdew may be conducted.

i SP4 23 of 40 Rev.3

l l Subject interviews shall be conducted at the direction of the Screening l l

Supervisor / designee. 'the Screening Supervisor does not direct that a j s sutdect interview be conducted if the adverse information upon wh!ch it is i

! predicated is:

i l 1. Unsubstantiated / lacking in credibility, -

! 2. Minor to the degree that it would not preclude granting a clearance, l 3. Or could result in the subject's identification of a source who has requested confidentiality, j 4. Or would interfere with the progress of an investigation being conducted i by a law enforcement or intelligence agency, j 5. Related to a medical condition, knowledge or discussion of which would

! adversely affect the subject's health.

Subject interviews may be assigned to contract investigative agencies. This is j likely in cases where th'e subject resides or has worked outside the PSPAQ service ,

{ territory. All the requirements of section 5.4 of this document apply to contract l Investigators assigned subject interviews. A request for subject interview is sent to the agency to address the issues in question, to outline the specific questions that require resolution during the interview, and to set a target date for the report ]

of interview findings, i 5.5 Restrictina Access via the Access Review Process In situations described in sections 4.11 and 4.12 of this document, individuals pmwing a Personnel Access Clearance may have their access to the Protected Area suspended in certain instances. Suspension of Protected Area access initially includes suspension of access as an escorted visitor. In addition, persons seeking unescorted access (processing of the clearance is not yet complete) may also be prohibited access as a visitor to the Protected Area in unusual pre-access situations; i.e. withdrawal of consent, receipt of significant adverse information by the background screening or psychological services groups, for-cause PFD testing during in-processing (but not as a result of random or pre-access FFD testing),

cheating on written access training exams, etc. Restrictions on access to the Protected Area shall continue until completion of further testing, interviews, appeals, receipt of additional Information or other relevant processing actions resolve the situation in accordance with section 7.6 of this document and other PAP requirements. When informed of the need for access restrictions, the Screening Supervisor shall initiate administrative actions to place the individual SP4 24 of 40 Rev.3

_ _ _ _ . . _ _ . . _ _ _ _ . _ . _ . _ _ . __.__ ..~ _ . _ _ . _ _ _ _ _ . _ _ . . _ _ _ _ _ _ ..

1 I i

l

} In an Access Review Required status so as to prohibit Protected Area access l (escoded god unescorted). %e administrative process used to prohibit the access j i of any individual in the Access Review Required status may be used to control I j access as an escoded visitor when the Nuclear Secudty Manager determines an i individual has abused the visitor privilege. .

! 5.6 Records Retention

! The PSE&G Site Access Screening Group, Medical Department, and

! contractors / vendors whose unescorted access authorization programs have j been approved by PSPAO, shall retain records for each person who is granted or l denied unescoded access authorization, or otherwise covered by the scope of the j PAP as described in section 3.2 of this document, for five years following such l denial or tennination of access authorization / coverage.

l 1. To facilitate compilance with this regulatory requirement, at the time j destruction of records is being considered, each record holder shall j ascertain whether the indMdual who had records generated under the PAP is no longer within the record retention requirements of 10 CFR 26 i or 73 Drlor to destruction of those records.

j 2. This determination shall also apply to records of individuals whose j unescoded access authorization has been transferred under section 4.8

! of this document. As such, records shall be retained until five years after tennination at the transferred facility (or subsequent facility) or the i records shall be transferred to such facility.

6. DEPARTMENTAL PERSONNEL ACCESS PROGRAM COORDINATION Cogni=nt Department Heads and contractors who require Personnel Access l Clearances for their employees shall plan and act to ensure that requirements for

gmnting and maintaining clearances are accomplished by the time access is l required %1s section explains who needs a Personnel Access Clearance (PAC),

i how a PAC is requested and maintained, discusses process planning factors, and provides to all personnel additional information about the program.

6.1 Persons Reauiring Personnel Access Clearances l iib i

M Niidstated in section 3.2.1 of this document, El@YiEINIi$EIE U"neiI:$deidic8IdEidifiiEE$EdfiftIfM -

[$INE$$

s($EEiM ce. In addition, Full Clearance background, psychological, medical j access clEa$ran$hEMsfiMilsiMII&MMEsEML3 j and FFD evaluations shall be conducted for two other types of personnel.

i SP4 25 of 40 Rev.3 I

l l 6.1.1 Applicants for PSFAQ employment shall be proceaed in accordance with '

i section 6.4.1 of this document at the time of hire in anticipation of future, job l assignments requiring unescorted access or access to Safeguards Information.  ;

j The Employment and Placement Department (EacP) shall be informed if pre-  !

l employment applicants fall to successfully complete any PAC requirements. The _ l

{ EarP Department in conjunction with the hiring RC manager and l l Employec/ Industrial Relations Department then determine if the hiring  !

! process may continue or if the conditional offer of employment will be withdrawn. j i

j 6.1.2 in accordance with 10 CFR 26 requirements, persons involved in any FFD )

i Program administration are required to complete the background investigation, l fingerprinting, and psychological evaluation processes described in section 4 of  ;

j this document for assignment to such dulles. 'Ihe other requirements of sections  !

! 4.3.1 need only be completed if unescorted access is needed. At a minimum, the j' j background investigation elements needed to qualify for a Temporary Clearance i (described in items 4.3.2.2 thru 4.3.2.6 of this document) and the psychological

! evaluation process must be completed prior to assignment to such duties.

CAUTION: Reference 2.$ of this document may establish other qualifications (training, credentials, medical and/or FFD evaluations) for such assignments.

~

In addition, for these persons to retain such assignments, the following l requirements from 10 CFR 26 Appendix A, section 2.3 must be met:

1 l (a) An appropriate background investigation and psychological evaluation

! shall be completed on these persons at least every three years, i (b) 'Ihe individual shall be covered by the behavioral observation program described in section 4.11 of this document. This requirement indicates the individual's supervision, at a minimum, shall complete the annual FFD training requirements.

6.2 Persons Reautrina Access to Safeauards Information Persons who require access to Safeguards Information as defined in 10 CFR 73.21, but do not need unescorted access to the Protected Area, require completion of the fingerprinting / FBI criminal history check as specified in 10 CFR 73.57(b). Since in most instances the results of the FBI check will not be received in a timely manner, PSFAO's Security Plan allows completion of all background investigation elements required for a Temporary Clearance (see items 4.3.2.2 through 4.3.2.6 of this document) to gain access to Safeguards Information once a need to know has been established. A full background investigation in SP4 26 of 40 Rev.3

t .

i j accordance with section 4.4 of this document shall subsequently be completed in this instance, but this does not include completion of other Full Clearance requirements (i.e. psychological evaluation, training, PPD testing, etc.) unless l unescorted access to the Protected Area is also needed.

I 6.3 Division /Denartmental PAP Responsibilities ~

j Departments with direct management responsibility for those contmetor and l

} PSPAQ personnel who need a Personnel Access Clearance must apisoint persons j to perform the following functions:

j 1. Cognizant Department Head / alternates - must be designated in l writing and signature samples provided to the Screening Su avisor.

l ones accepted on the lM.

1 E

These signatures " M M 73 only $tiRMM and as reviewer are the l the 31 Day Access Revalidation List. Details on how each of these j responsibilities are carried out are provided throughout the remainder i

i of section 6 of this document.

i 2. Departmental Access Coordinator - Acts as the lead contact between

! the Site Access Group and the responsibility center. Departmental Access Coordinatons should be familiar with Site Access requirements i

to assure effective coordination in @@EWY5fWsI@

. 94 Q aa mm.< t ...

--" ~ E- Yi@lfh---@-iElfigs $ilisM ]

~- -

s..._w.-..,~~... ..m a ag 7 og g Nd _.. _2.b..Y_id.._i._m._.. . . _ ._n __.

, n,.c _

a r

! MOTE: To assure cognizant Department Heads / alternates / Department Access Coordinators are knowledgeable in all aspects of PAP administration, the

, Site Access Administrator / designee shall provide training on the PAP. Such i training will be provided upon request.

.c l SP4 27 of 40 Rev.3 6

l 1

l i

6.4 Reauestina Personnel Access Clearances 6.4.1 PSE&G Nuclear Department Premmoloyment Annlicants and Transfers into the Nuclear Department from PSE&G Non-Nuclear l l

Locations l l

These types of permanent employees shall be processed as follows: l l

1. Employment and Placement (E&P) schedules medicaland psychological 4 evaluation and forwards a ,

i go$p_,latw n -

% through the " - - - - - - -

cJ "PSE&O Initial Data form" and a " Request for Background 1

brYb0*N?$k* hk pgspJineLSlesM jheAMessi ll hhYgsghjel. This request shall contain:

l + Applicant's full name and social security number I + Position aglied forEdd'sfifI!E$r$$EIdESii$E[ddNEir[EiIdES i EIdtlon hi$i}mNew)[PIEIN$i}[0$ilM$$1fgh$i$$N3h$lhNd Nw.iequ

- - - - - - - - - - - - - - - ~

+ H1 ring department $dS[ tie @7MMi!Nn[aMdis3

+ Copy of Employment Application f5dN$klI[d

+

NNhhtESEOShhhd$$ENh5Sbhb$N

. EnsklBsMinreseMaBeMMM@I ~bIh~$

+ Scheduled dates for Medical / Psychological Evaluations i

2. E&P provides the applicant with the Personnel Access Questionnaire (PAQ) which shall be com SupervisorME[$pleted dh3idjdkyh and retumed

. EthiI5}E[d[jd. b the applicant The PAQ to the Scre l should be returned by the applicant prior to,[ ihidU$[$Ithe date of the j medical / psychological evaluations. Applicants NIMNOEEi3 pynj l acce It$ptable identification (photo nMdfoYdjMMIiddlA$. Delaying IDthe prefened) completion and of bethefingerprinted ID and a fingerprint processes to the medical evaluation date will delay the screening i process and delay the employment start date,

3. Upon successful completion of the psychological evaluation including an interview based on the MMPI-!! (or equivalent) results and the medical exam, the Medical Department forwards a completed " Request for Security Clearance" to the Screening Supervisor. The Screening Supervisor, the j Process Coordination Clerk, and the E&P Department shall be informed SP4 28 of 40 Rev.3

i

)

l by the Medical Department if the individual does not qualify for nuclear site access or employment.

I l 4. %e Scutening Su rvisor completes the requirements of section 4.4 of this j document with . . modifications:

+ Yhe current employer is not queried at_this time EE@ the '

employment check. '

l _

! + Pending receipt of the FBI criminal history check results, the Screening i Supervisor may utilize local law enforcement and mot'or vehicle record l l

checks $$giqKMiljii{$MR$$$3fMM '

if timely hiring is required.

l + A professional credentials check verifying claimed licenses, registrations, j

and certifications which establish professional qualifications is completed If the applicant's intended employnient position warrants.

The Scree Supervisor approves the Re uest For Securi Clearance  !

l gg background investigation i_

and forwards the results to ERP to allow establishment of l

I 1

access . _ .

an employment start date. Upon acceptance by the individual of an employment start date, E&P informs the Screening Supervisor of this acceptance. This allows completion of the current employer background check element after the individual has been provided th uni o_give

"~

I notice of termination to the current em r.

l -

m Q'  ; , q,g .

l AL. --

5. %e Cognizant Department Head sends an Application for Photobadge to the Screening Supervisor if the applicant accepts a position requiring j unescorted Protected Area access.

! 6. ERP schedules training through the Process Coordination Clerk l approp late to the position's access needs. Individuals accepting positions 2

not requiring unescorted Protected Area access should receive the training courses provided by Actee Processing organizations related to the Nuclear

{ Department's personal safety and Fitness for Duty policies.

t i

4 1

1

, SP4 29 of 40 Rev.3 i

i

j i . .

{ .

j d.4.2 Other PSE&G Denartments and Nuclear Department Employees j MOT Currently Badged l Personnel Access Clearances for PSE&O employees assigned to departments other

) than the Nuclear Department who will remain in a non-nuclear department, or for j Nuclear Department employees not currently badged, shall be requested by: -

a i 1. The Department Access Coordinator scheduling Personnel Access Clearance activities through the Process Coordination Clerk.

2. The Cognizant Department Head of the sponsoring Nuclear j Department organization forwarding a completed Application for

Photobadge to the Screening Supervisor.

I j 6.4.3 Contractors and PSE&G Seasonal /SummerfremDorary Employees a

Personnel Access Clearances for these personnel types shall be requested by:

1. Scheduling these personnel for clearanc_e activities throu _

the Process

~

! Coordinatio'n Clerk.- 5NE ,

"" n .

~ . ~ ~ . ~ ~ . - - ~ . n...-~.~ u -~~.wan.m .~.

! a. EMMNt3a or other temporary vendors / contractors shall j be processed upon start of a work assignment using the processes described in Sections 4.3.2, 4.8,4.9, or 4.10, as appropriate.

j b. Contracted security force personnel shall be processed in a manner j

similar to PSE&O em a

ees as described g in section 6.4.1 of this j document. __ .

gggesj the security force contractor j representative shall, for security force applicants, perform the l actions of ERP assigned in section 6.4.1.

, c. PSE&O seasonal / summer / temporary employees ma be processed

, EtifidMW7&2FEMIlifMMLW - 4WI614H01 l which means a psychological interview need only be done if MMPI-Il l results require it and o the Tem Cleamnce process need i be com leted ESE ~

.The j submittal i for this type of PSE&O em should be co rior to the i

first dagof employment. Mi$

MM[ tiri d h h k., _. Y __ _Nh i, E_4. !69_iiie.l.m_..

i i

SP4 30 of 40 Rev.3 r

-- - . - - - -- ..-. ,---wa

i . .

l . .

j 2. %e Cognizant Department Head forwarding a completed Application l for Photobadge to the Screening Supervisor for each person.

i 3. We Contractor employer retuming a form letter verifying employment and satisfying Fitness-for-Duty Sultable Inquiry requirements for each L access applicant to the Screening Supervisor. E&P will provide -

l employment verification documents for the PSPhO seasonal / summer /

l temporary employees to the Process Coordination Clerk. .

l 6.5 Channes of Emnloyer Changes of employer for contractor employees that do not result in a break in

{ access, e.g. resign from Company A and begin employment with Company B l- within two business days, shall be coordinated through the Process Coordination Clerk for the security photobadge., to remain in an active status.

The Process Coortlination Clerk shall determine which PAP requirements need i be completed at this time per sections 4.3.1 and E. At a minimum the new employer shall be required to return a form letter verifying employment and the

Cognizant Department Head shall submit an Application For Photobadge to i establish area access authorization and responsibility center assignment. Breaks in access beyond two business days shall require the security photobadge to be made inactive per section 4.13. When the security photobadge is inactive, E

.EM FFD Rule pre-access requirements as described in Reference 2.8 l shall be met, in addition to the above specified forms M prior to i reinstatement of unescorted access.

6.6 Maintainina Personnel Access Clearance

} A Personnel Access Cleamnce (PAC) may remain active provided:

' 6.6.1 Personnel continue to meet the on-going requirements of the Fitness-For-Duty and Behavioral Observation Progmms. %Is includes but is not limited to the indMdual meeting all requirements of the FFD testing program (random, j for-cause, follow-up, etc.).

3 _

j' SP4 31 of 40 Rev.3 3

3 _. _,

1 j . j j

) NOTE: In additJon to the specific responsibilities listed E in section 3.3, l management responsible for PAP administration have the general responsibility l to inactivate a PAC when they detennine any on-goin re utrements are not met.  :

l The Artificial Island Security Plan requires -

i ..

j management to inactivate a PAC when aberrant behavior, lilegal activity, or l security violations are suspected. The individual, his/her superviscr, employer, " I l '

l and/or Cognizant Department Head need not be informed prior to the PAC l being inactivated. -

6.6.2 Personnel requalify in General Employee Training and FFD training topics l prior to annual expiration. NOTE

Other access training courses or j requalification actMtles beyond these regulatory training requirements exist. All

existing commitments freg,ulatory and administrative) #

shall be met to retain 7

unescorted access . ,o.gf.e..d. To....f. . uSI)lf. ..t..kigq.

f l

6.6.3 Access authorization is revalidated every 31 days by the Cognizant l

l Department Head / designee and the need for unescorted access continues j between revalidations'. To accomplish revalidation, every month the Screening l

Group provides the Cel=nt Department Head / designee a listing of PSPAQ l employees and contractors assigned to the department's responsibility center j (IW). The Cognizant Department Head / designee shall review the list to:

1. Identify any discrepancies and/or changes such as terminations, l

! additions, and/or transfers to or from the IW. NOTE: Additions to future

! IVC revalidation listings'shall be made by completing an M

! NMEN[M[@@M and forwarding it to the Screening Supervisor.

l

2. Inform the Screening Supervisor immediately of terminations and l transfers from the IW which have exceeded the 48-hour notification l requirement of section 4.13 of this document.

j 3. Verify the need for personnel access to each Vital Area currently j authorized. NOTE: Changes to area access authorizations shall be made l by completing a I3)i@MdEhMEMMMTj@

l and forwarding it to the Screening Supervisor.

l 4. Note expiration dates which may indicate expiration of a temporary l clearance or General Employee Training. If any are noted, communicate j with the Department Access Coordinator and/or Process j Coordination Clerk to determine appropriate action is being taken.

i

)

1 l SP4 32 of 40 Rev.3 l

l 5. Sign the list, after review, verifying each Individual continues to need unescorted access for the next 31-day period covered by this revalidation and then returns the list in a timely manner. NOTE: 'Ihe Individual's  !

need for unescorted access is described in 10 CPR 73.55(d)(5) as applying to an individual 'who requires frequent and extended access. *

'the Security Plan commitments denoted in sections 4.13,6.5, and E l of this document regarding termination of access are based on that

description. '

j 6.7. Personnel Access Clearance *1anning Factors l Cognizant Department Heads of employees and contractors for whom it is i j required that Full Clearances be obtained prior to unescorted access (or it is a pre-E employment condition) shall request clearances at least 30 days prior to the need j for the clearance. In certain cases more time may be required to complete the background investigation due to number and location ofleads to be verified. In ediate I l

those unescorted instances when only_a Temp, access,"M~M should ora,ry,C,learance be EM~ is necessaryl I W at leasikdays in alivance of the need esdorted7o~k^un$

~~

access  !

, m- -

S IdE T$ . ..E l__l j"$9M]

-. _ l _

l A person may be granted escorted access as a visitor for up to five days if they do not p== a PAC. Rare exceptions beyond this five-day limit may be granted by

the Nuclear Security Manager / designee. M01E: Sections 4.11,4.12,4.13,5.1, 5.2, 5.5, 7.5, 7.6, 7.7 and 8.0 of this document describe situations where individuals are prohibited access as visitors.

6.8 Motice to Access Applicants and Resultant Actions Each access applicant can freely decide whether to participate or not in the PAP.

When a person decides not to participate in any aspect of the PAP, the Cognizant Department Head and Scutening Supervisor shall be immediately notified.

r Copies of any letters of notification and written statements by the subject shall be incorporated in the subject's personnel access file. Withdrawal of consent during initial access processing or after a PAC has been granted is addressed further in section 5.2 of this document. Access applicants who agree to

]

participate in the program shall complete the Personnel Access Questionnaire and all related forms and releases without modification of their stated wording, i

., SP4 33 of 40 Rev.3

l 7. ADJUDICATION OF CLEARANCES AMD DEMIAL, SUSPENSION OR

}

RECONSIDERATION OF UNESCORTED ACCESS .

l j This section describes the procedures to be followed in the administrative j aqludication of information developed by background investigations during the

processing of a PAC or a Pre-employment Applicant Check; the denial of access - l l as a result of adverse information determined during the PPD, Psychological, and l l 15ackground Screening evaluations; suspension of unescorted access for cause; i i

and reconsideration of access following suspension or denial of access.

'Ihis section does not addmss the disposition of employment status of any person l when a PAC is denied or there is little likelihood that a pre-employment applicant j would be granted a PAC. Actions pertaining to the disposition of employment l status of employees and pre-employment applicants are within the purview of the l Human Resourt:es and Employee / Industrial Relations Groups. Actions

{ pertaining to the employment status of contractor / vendor employees are the l

purview of the contractor / vendor.

e j 7.1 Adludication in Absence of Adverse Information 1

if a review of a completed background investigation and medical / psychological

! evaluation including drug and alcohol testing discloses no adverse information i j regarding the person's trustworthiness or reliability, the Screening l j Supervisor / designee grants a PAC, or in the case of a Pre-employment applicant, l l advises Eaer that there is a high probability that if hired by the company, the l

! person would be granted a clearance.

i i

7.2 Determination of Sufficiency i -

! In granting a clearance or evaluating a pre-employment applicant check, the l Screening Supervisor assures that the background investigation meets program l policy, procedural and scope requirements. Deviation may be allowed when legal l constraints or external limitations preclude full compliance, provided the j deviations are cited and Justifled in the background investigation report or in administrative memoranda included in the subject's personnel access file.

7.3 Agmilcation of Criteria f

Adverse information is any information which Indicates the subject has a j potential for behavior which could present an unnecessary risk to the health, j safety and security of the public or PSP &O, or that the subject has engaged in any j act listed in Appendix A of this document. In evaluating information, the i

l i SP4 34 of 40 Rev.3 1

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l Screening Supervisor takes into consideration the credibility and overall import l of the facts in terms of the access denial criteria listed in Appendix A.

l 7.4 Adiudication When Adverse Infomtion is Presented If the background investigation discloses adverse information, the Screening j Supervisor decides whether to grant or deny a PAC utilizing his/her expertise, '

Appendix A, and any other available regulatory or industry guidance. In the case

] of a PSPAQ pre-employment applicant, the Screening Supervisor reviews the

case and detennines if there is a high or low robabill of obtainin an access I

clearance based on the same guidance  !

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ha l i 7.5 Processina a Clearance Denial

De sutdect shall be advised via interview when a determination has been made l by either the Medical @2$rME, the $@o3M, or the Screening l

{ Supervisor that the results of the medical examination, including FFD evaluation, j the psychological evaluation, or the background investigation, may be j unacceptable for unescorted access authorization. %is interview shall be

! conducted by the authorized representative of the evaluating department to j provide the subject with the opportunity to provide any further information that j may affect the outcome of the evaluation. This interview should be face to face, l but telephone interviews are permissible. If the subject declines the interview when offered, the remainder of this section shall be utilized on the basis the l

individual is not acceptable for unescorted access.

1 Upon final determination that a subject is not acceptable for unescorted access

authorization following such an interview, the evaluating department if not the Site Access Screening Group, shall notify the subject and the Screening Supervisor / designee or, in their absence, the Site Access Administrator of the 3

SP4 35 of 40 Rev.3 i

4

j basis for unescorted access denial and all of the following information E

{ . %e Screening Supervisor / designee / Site j Access Administrator then conducts a PAC denial meeting with the subject j informing the sutdect of the decision and basis used to deny access, the Access j Denial Appeal process, the period, and extent of site access restrictions

(Protected Area and Owner Controlled Area as appropriate) and the conditions to l be met prior to reconsideration. If the conditions are PPD related the IndMdual shall be provided that information by Medical Department pe"rsonnel in accordance with the requirements of Reference 2.8 of this document! If the subject is unavailable for the denial meeting, a letter shall be sent to the subject indicating these facts.

f I %e Scatening Supervisor / designee / Site Arene Administrator performs the

{ actions contained on the Personnel Access Clearance Denial Checklist, concurrent l with the access denial meeting. De checklist includes providing the subject with

! a summary of the Access Denial Appeal process, restricting access via the l Access Review Required process (section 5.5 of this document), and informing j the employer of th,e subject's status.

7.6 Suspension For Cause l

j The previous section of this document describes actions taken once sufficient j information exists to make a decision to deny unescorted access. As described j in sections 4.11,4.12 and 5.5 of this document, concems may also develop

! regarding an individual's trustworthiness and reliability during pre-access

! processing or after unescorted access has been granted which require l action /Information/ evaluation to determine if access dental is warranted.

1

! %e Site Access Administrator, Screening Supervisor, Security Supervisor,

) or the Muclear Security Manager may temporarily suspend access to the l Protected Area (or inform appropriate management that work assignment

! restrictions are warranted for personnel covered by sections 3.2.2 through 3.2.4 i of this document) when credible information is received that an individual's j condud, reliability, or trustworthiness is in doubt.

Utilizing the processes and criteria of sections 5.4, 5.5, 7.3, and 7.4 of this j document, any investigative resources available, and FFD and/or psychological i evaluation processes if appropriate, the individual's clearance shall be inactivated

!; Immediately and his/her status reviewed within @ business days. If resolution m

) of the individual's suspended clearance status cannot be accomplished within ten l business days because of extraordinary circumstances, these facts will be t

SP4 36 of 40 Rev.3

documented, the case reviewed with appropriate management, and the clearance suspension extended up to E days. Escorted access as a visitor may be granted after review if appropriate. Unescorted access may be restored during the above periods as soon as a favorable ac(Judication is reached and any required pre-access paperwork and PPD testing are completed. If favorable ac(judication cannot be reached within E days, the access denial process (section 7.5 of this -

document) is initiated and section 7.7 of this document applies to this indMdual.

Documentation of the information prompting the suspension, any'information developed during the review process, and the resolution of the ternporary suspension status (access restored or access denied) shall be incorporated into the individual's personnel access file.

7.7 Reauestina Unescorted Access for Individuals Previously Suspended or Denied Access Suspensions For Cause shall re: main in effect until resolved as described in section 7.6. Personnel Access Clearance denials shall remain in effect until all conditions for reconsideration are m a ss d_enia

._ _ is complete.

The following actions are required ihisjoits kr[u_et

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the effective periods are complete.

7.7.1 The Cognizant Department Head of the individual previously suspended, denied, or having access terminated under unfavorable conditions shall request through the Site Access Administrator / Screening Supervisor that the ladividual's unescoded access authorization be reconsidered. The Site Access Administrator / Screening Supervisor may request documentation of the individual's status to suppod the reconsideration request.

7.7.2 If theindividual's unescorted access authorization has been terminated for more than 365 days under unfavorable conditions (access denied at any nuclear facility), a psychological evaluation (MMPI and interview) and a background investigation shall be completed prior to scheduling other processing activities listed in section 4.3.1. A Temporary Clearance shall not be granted to a person applying for reconsideration. A Full Clearance background investigation (section 4.4) covering the period of time since the last Full Clearance background investigation was completed to Reg. Oulde 5.66 criteria shall be completed prior to access being granted.

7.7.3 If the individual's unescorted access authorization has been terminated under unfavorable conditions for less than 365 days the location of the termination shall determine the required process for reconsideration as follows:

SP4 37 of 40 Rev.3

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1. If the cccess denial occuned at PSPAO's Artificial Island, e psychological

evaluation (MMPI or other testing and/or interview) and PAQ must be

completed. The Screening Supenisor will evaluate the completed PAQ

! and initiate those background investigation activities appropriate based i on the information provided and current regulatory and industry ~

! guidance.

i j 2. If the access dental occurred at any nuclear facility other than PSPAO's l l within the last 365 days, the process described in section 7.7.2 above i must be completed, i

l 7.7.4 Prior to the PAC being activated, any follow-up PPD testing and behavior l observation processes required by Reference 2.8 of this document shall be in l

! place.

j 8.0 IlfE ACCESS DENIAL APPEAb PROCESS

} PSPAQ and contractor employees denied a Personnel Access Clearance may appeal that decision provided the person has a reasonable basis upon which to i believe the decision was incorrect. The Access Denial Appeal process herein l complies with industry and federal regulatory standards for the NRC's Access l Authorization and Fitness-For-Duty Programs,10 CFR 73.56 and 10 CPR 26 i

! respectively.

l

! Individuals denied unescorted access shall not be oranted escorted access to the l Protected Area as a visitor ,

1. Prior to sub'mitting an appeal;

2. While the appeal is being considered, or

3. After appeal, if the original access denial decision is upheld; until the i denial period is complete and until a Full Clearance is subsequently l successfully obtained.

i l 8.1 Actions bySublect/EmDloyer/ Business Agent i

i 'Ihe subject has sole responsibility to initiate an appeal, and meet the following

{ requirements for an appeal request to be considered by PSPAQ management:

l 1. Submit a legibly written or typed request stating clearly the reasons the

! subject believes the access denial decision was incorrect. Disagreement l

with written company policy or requirements in federal or state regulations is not an acceptable reason for an appeal.

2

! SP4 38 of 40 Rev.3 i

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1 j 2. Submit the request for appeal within 10 calendar days of receipt of i notification of access denial.

, 3. Submit the request to the Site Arream Administrator. A copy should be submitted to the Employee Relations Manager if the subject

! affected is or was a PSE&O employee at the time of access denial.

l 4. Submit the request through their employer or business agent if the subject was not a PSE&O employee at the time of access denial. The subject may submit the appeal request directly to the Site Access

! Administrator if no longer employed by the employer / trade union of

) record.

j 1he employer / business agent should attach a cover letter to the appeal request if they decide to sponsor the appeal stating their sponsorship of the appeal, if l'

they decline to sponsor the appeal request they should inform the subject. In

either case, they should forward the appeal request to the Site Access

{ Administrator within two business days of receipt, so as to meet the intent of the i

10-day submittal period stated above.

i 8.2 Actions by the Site Access Administrato_r The Site Access Administrator / designee reviews the appeal request for compliance with the above requirements and forwards the request to the Appeals j Officer. The S!te Access Administrator may forward to the Appeals Omcer j any additional information germane to the case at this time. The appeal request may be retumed to the subject if it is not submitted in accordance with the

) requirements of section 8.1 above.

\

i 8.3 Actions by the Appeals Omcer The Appeals Omcer reviews the subject's access processing files and may

]

conduct or have conducted additional inquiries as necessary to achieve an

]; Independent evaluation of the available facts. The Appeals Omcer should review l

and/or consider the following during this independent evaluatiom

1. Information provided by the subject at the time of the original adverse l

j information interview, the access denial interview, or in the appeal l request, or subsequent to the appeal request; i

j 2. A copy of any documentation the subject received which provided j notification of the access denial decision or its basis;

)

i j SP4 39 of 40 Rev.3 i

i a

w Other communication relative to the eubject including notes of oral 3.

j discussions / Interviews and written documents whether received or

! provided; and

4. The department's documented process used to affect the decision; 1.e.

I departmental implementing procedures.

i i The Appeals Omcer documents actions taken to address the appeal request,  ;

l j and amrms or recommends reversal of the dental decision. If the clearance denial l j decision is amrmed by the Appeals OMcer, the subject.is informed by certliled i

letter. i i

If reversal of the clearance denial decision is recommended by the Appeals I l

l Omcer, the Site Access Administrator is informed of the rational for reversal ,

' and has the opportunity to concur, or escalates the reversal recommendation to the Manager-Site Protection'MAA@ Mis' giii_ogiilistie. p If the Site Access Mmindstrator does not concur and escalates the recommendation, the subject

! is not. informed of the outcome of the appeal until the Manager - Site Protection

! aM makes a ddclsion on the appeal. If the Site Access Mministator i concurs with the reversal or when the Manager - Site Protection 'M resolves the Site Access Administrator's concerns, the subject is informed by l

letter of the conditions under which unescorted accem will be reconsidered. 'Ihe Medical Dhector - Muclear shall concur with the conditions established in

} accordance with the requirements of Reference 2.8 of this document if the subject was denied unescorted access for Fitness-for-Duty or other medical / psychological l

concerns. .

40 of 40 Rev.3 SP4

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PSE&G PERSONNEL ACCESS PROGRAM i APPENDIX A l CRITERIA FOR DENYING PERSONNEL SECURIW CLEARANCES The decision to deny a cleamnce h based upon a comprehenstw, common sensejudgement, made i after consideration of all relevant information, favorable and unfavorable, as to whether the granting ~

j of the clearance would be clearly consistent with the necessity to maintain the physical security of

. the Artificial Island nuclear facilities. To assist in making appropriate determinations, this appendix identifies several specific types of adverse information. These are not all inclusive, but contain

! many of the factors which may rabe legitimate questions as to a person's eligibility for a Personnel Access Clearance. When a background investigation reveals information that reasonably establishes l concerns in one or more of the following criteria, such information is referred to the Screening 1 Supervisor for full consideration and adjudication.

l l

1. Willful omission or falsification of information submitted in support of employment or request j for Personnel Access Clearance for unescorted access.

E i ' 2. lilegal use or possession of a controlled substance or abuse of alcohol without adequate

evidence of rehabilitation.

5. A criminal history without adequate evidence of rehabilitation which establishes

! untrustworthiness or unreliability.

4. History of mental illness or emotional instability that may cause a significant defect in the person'sjudgement or reliability.

5. 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 l

upon the person's trustworthiness or reliability.

1 l 6. Evidence that the person 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 person's trustworthiness or reliability.

l 7. A psychological evaluation which indicates that the person is a risk in terms of trustworthiness

or reliability.

8. Willful violation of security regulations at a nuclear facility or of past or present employers.

4

! 9. Evidence the individual has engaged in any other conduct, or is subject to any other f circumstances, including demonstrated financial irresponsibility and immoral acts, which tend to show that tl e person is not reliable or trustworthy, or which furnishes reason to believe that l

the person may act in a manner contrary to the best interest of the safety and/or security of l

! Public Service Electric and Oas Company at Artificial Island.

t

10. Knowingly held membership, affiliation or association with the specific intent of furthering the l

aims of, or adherence to an association, movement, group or combination of persons which l unlawfully advocates or practices the commission of acts of force or violence to prevent others i from exercising their rights under the Constitution or laws cf the United States or any State or subdivision thereof by unlawful means. A  %. :. .

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