ML20154D721
| ML20154D721 | |
| Person / Time | |
|---|---|
| Issue date: | 06/04/1987 |
| From: | Brady R NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| To: | AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20154D718 | List: |
| References | |
| NUDOCS 8809160077 | |
| Download: ML20154D721 (6) | |
Text
.
JUN 04 1118F NRC Licensees Authorized to Operate a Nuclear Power Reactor Pursuant to Part 50; or Applicants for a License to Operate a Nuclear Power Reactor fursuant to Part 60
Dear Sir / Madam:
Thisletterconcernsthepropercompletionandsubmissionoffingerprint cards in accordance w th the U. S. Nuclear Regulatory Comission s Criminal History Program (10 CFR Part 73,57).
On April 8, 1987 processing of fingerprint cards under this program comenced.
Based on our proc,essing experience to date, the most prevalent probluns we are encountering are incomplete or improperly completed cards and payment checks made out in the wrong amount. We have highlighted in the ene'osure the 17 Information blocks on the fingerprint card that must 5e propt'ly completed or else the cards may be returned unprocessed to the 1*censee facility.
The amount of the payment check accompanying the cards must equal the sum of $15.00 per card multiplied by th6 number of cards submitted.
Due to the volume of submittals, related resource implications and our accounting requirements, errors of this nature cause significant delays and may require returning the entire package to the submitter unprocessed.
We have identified below more specific recurring fingerprint problems that cause unnecessary processing delays.
These problems could be avoided with a more detailed quality control review of the cards.
Submit only 1 card per person.
In some instances we have received duplicate cards and payments for the same individual.
.To obtain the most thorough search of the FBI files, all personal information blocks such as date of birth (008), right, etc., must be correctly completed. Some cards, for example, have been reheted re-cently because the current date was entered in the 008 blocA instead of the actual date of birth.
The Social Security Number must be legible and must contain all nine digits or the card will be rejected.
The "Rea;on Fingerprinted' block must contain the facility docket number, if more than one dockt:t number is entered, we will return the results of the Criminal History Check by the FBI to the first docket number listed on the card, unless the ' primary" docket number is noted by asterisk or similarly ;ighlighted.
8809160077 870007 PDR REVGP NRCCRCR MEETING 126 PNV ENCLOSURE 9
JUN 0 4 587 2
We also ask that, as specified in 10 CFR Part 73.57(d)(1), all fingerprint card submissions be mailed to the following address only:
Director, Division of Security, U.S. Nuclear Regulatory Comission, Washington, DC 20555 ATTN:
Criminal History Check Section.
Failure to include the ' ATTN:' line will delay processing two-to threc days.
We recognize the need to speed processing of fingerprint cards for individuals who did not have unescorted access or access to Safeguards Information as of April 1, 1987. Accordingly, we recomend licensees identify and transmit such cards, including payment, separate from others sent to NRC.
The exterior of such packages must be prominently marked "SPECIAL HANDLING-NEW HIRES." We will give priority to such fingerprint cards and expedite their processing to the FBI beginning June 5, 1987.
Failure to mark the exterior of these peckages as indicated will result in normal non-expedited processing.
If you have any questions regarding the submission of fingerprint cards, please callBethBradshawon(301)492-4120.
Sincerely.
sAstel W %.
paysm.ad L Rs4 Raymond J. Brady, Director Division of Security Office of Administration and Resources Management
Enclosure:
As stated cc:
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W A SHING TON. D.
,40555 MEPORANDUM FOR: Victor Stello, Jr.
Executive Director for Operations FROM:
Hugh L. Thompson, Jr., Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
POLICY STATEMENT AND NUMARC GUIDELINES ON NUCLEAR POWER PLANT ACCESS AUTHORIZATION PROGRAMS This responds to the Comittee to Review Generic Requirements (CRGR) recomenda-tions on the policy statement which endorses the Nuclear Utility Management and Resource Comittee (NUMARC) "Industry Guidelines on Nuclear Power Plant Access Authorization Program" (hereafter referred to as the Guidelines) and provides a Comission paper for your signature which fomards the policy statement and Guidelines to the Comission.
The principal CRGR concern centers around the granting of unescorted access to temporary workers. The CRGR believes that unescorted access authorization should not be granted these individuals until the results of criminal history checks are received and considered. The Guidelines negotiated between NUMARC and the NRC staff, however, call for only the submission of fingerprints in the perfonnance of a criminal history check prior to granting unescorted i
access to these workers. The Guidelines further call for the completion of credit checks, psychological assessments, and it.6erviews with one developed reference as additional conditions precedent to granting unescorted access authorizat%n. Although there is considerable merit to the CRGR position, the staff beliues that the Guidelines constitute a step fomard in the handling of temporary workers.
For example, there are no present screening requirements in contrast to those stipulated in the Guidelines as described above.
Further, the actual taking of fingerprints is believed to constitute a deterrent effect.
During the development of the Guidelines, NUMARC constantly stressed the tecracticality and needless costs associated with placing temporary workers on
- he payroll to assure their availability while not being able to utilize them f vr an estimated 20-25 days pending the completion of the criminal history check.
It was for this specific reason that other measures were included in the Guidelines.
In an effort to fully assess the scope of this problem, NUMARC wrs requested by letter of January 30, 1987 (Enclosure 1) to provide further details supporting industry views. Tt.e NUMARC response of March 11,1987, (Enclosure 2) provided the following data:
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- an average of 600 temporary workers are employed annually per operating unit (representing 40-45% of all individuals requiring unescorted access authorization)
i Victor Stello, Jr.
- 80% of the utilities polled do not know the identity of a temporary worker until 1-3 days before site access is required (for the remaining 20%, the period ranges from 10-14 days)
- the majority of temporary (workers are employed typically from one to three months criminal history data would be received in most cases before employment was terminated)
- according to the FBI's experience with similar systems, it is expected that approximately 6% of individuals fingerprinted will possibly have a criminal history file
- an estimated 47% of temporary workers held unescorted access at power reactors within the last year and, hence, their access authorization could be transferable under the Guidelines
' the estimated unproductive cost to industry resulting from a 25-day processing period prior to granting unescorted access is
$367 million annually.
The staff continues to believe that the provisions of the Guidelines provide a practical approach to industry's handling of the temporary worker issue and at the same time contributing to the public health and safety.
One further consideration involves the impact of anticipated changes and NRC
~
experience with the program. The FBI projects that within a year revised internal procedures will reduce estimated processing time from approximately 25 days to 1 day.
Industry estimates that the identity of temporary workers is known 1-3 days before reporting to work in 80% of the cases. Accordingly, it may be practical within one year's 'ime for a licensee to receive and consider FBI data on temporary workers prior to granting access.
Further, in the future there is expected to be a reduction in the number of individuals requiring checks in consideration of I
reciprocity.
Finally, NRC operational experience may also impact' policy in this area. For these reasons a provision is included in the Guidelines to reexamine I
this policy in a year to see if it is still appropriate.
Based upon the considerations presented above, it is recusinended that you approve the enclosed Commission Paper forwarding the Access Authorization Policy Statement ed Industry Guidelines to the Comission.
c I
Hugh L. Thompson, Jr., Director l
Office of Nuclear Material Safety and Safeguards
Enclosures:
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1.
Davis to Owen memo dtd 1/30/87 2.
Owen to Thompson memo dtd 3/11/87 3.
Commission paper i
l JAN 30 W OWEN LTR Mr. Warren Owen OISTRIBtf7 ION:
f Imss r/f W8rown Chairman, Steering Cosmittee Nuclear Utility Management and Resources Cosmittee
'SGRT ' r/f A s/f RErickson ETenEyck P.O. Box 724928
.P0wyer.
Atlanta, GA 30339 JYarifunfan RBurnett-
Dear Mr. Owen:
DMausshardt/JDavis VStello During s1NRC management review of a proposed policy statament endorsing the NUMARC "Industry Guidelines for Nuclear Power Plant Access Authorization Program,"
questions were raised concerning the adequacy of the temporary worker screening program as described in the guidelines.
Specifically, the questions pertained to screeninq requirements for unescorted access for temporary workers for situations other than cold shutdown. The view was expressed that results of the Federal Bureau of Investigation (FBI) crimi.na1 history checks and vorification of true identity should be considered as condia; tion precedent to granting unescorted access to temporary workers. This is in contrast to the provision of the guidelines which does not require the results -
of the FBI check or specific verification of the identity prior to authorizing access to temporary workers.
Prior to making a decision on this matter, I believe that more factual information is needed as to certain practical aspects related to the use of temporary workers. Accordingly, I have enclosed a list of questionf, the answers to which are considered essential to our resolving this issue.
Your assistance in this matter is greatly appreciated.
Sincereiy, John G. Davis, Director Office of Nuclear Material Safety and Safeguards
Enclosure:
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TEMPORARY WORKERS
'1.
What are the various typical durations of temporary workers' employment at specifte nuclear sites?
2.
Industry-wide, how many temporary workers are employed on_an annual basis?
3.
Typically, for the various types of employment utilizing temporary workers, how much is pre-planned versus short-term and immediate?
4.
For pre-planned situations, how much advance notice might a utility have
- that a temporary wdrk force is needed?
5.
Typically, what types of data (e.g., radiation exposures, personal data) does a utility maintain on temporary workers?
6.
What would be the impact to industry if all workers are required to be processed under a FBI criminal history cher.k (estimated to take 25 working days) and to verify true identity prior to granting unescorted protected area / vital area access? If the industry used the reciprocity provisions, how would this affect the' impact?
4
' ENCLOSURE
P.O Boa ni99 i i
hlNC 28242 NUCLEAR LITILITY MANAGEMDfr AND RESOURCES CO6 0,R7"rEE March 11,J 987 Mr. Hugh L. Thompson, Jr.
Director. Office of Nucleas Material Safety and Safeguards U. S. Nuclear Regulato *y Commission Washington, D.C.
20553
Dear Mr. Thompson:
Mr. John Davis' lette'r of January 30, 1987, stated that certain questions had been raised regarding the adequacy of screening requirements for r
unescorted access of temporary workers as contained in NUMARC's "Industry Guidelines for Mcclear Power Plant Access Authorization Prograss" and that factual information relating to the industry's use of temporary workers is essential to resolve this matter. The following responds to his request.
g Definitive answers to some of the questions stated in Mr. Davis' letter require an industry survey of each licensee. Based on a conversation between Mr. Bruce Xenyon, chairman of the NUMARC Working Group on Security, and Mr.
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Robert Burnett, it is our understanding that the NRC desires an expeditious resolution of this matter and, to that e..d. would be satisfied with a response based on a representative sampling of utilities. 'Accordingly, we have proceeded on a representative sampling basis.
Our responses are based on a survey of 12 utilities as listed in.
These utilities represent 42 fully licensed operating units of various sizes and organizational structures with at least two licensees from each NRC region. Therefore, the results of this survey should be sufficiently representative of the industry for the r.irpose of responding to the questions.
Detailed responses to the specific questions are contained in Attachment 2.
As an overview, the following are key points relating to the industry's use of
- mporary workers:
o By economic necessity, utilities extensively utilize temporary workers in support of peak work activities, particularly refueling outages and major modifications. The 'urvey indicates that annually over 60,,000 workers are temporarily employed in support of 102 licensed units.
o Post of these temporary workers are craf t personnel who come to the licensee from the local union halls. Altheugh many utilities utilize.
these personnel under what is called a "General President's Agreement" which permits requesting previously authorized personnel
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Mr. Hugh L. Thompson Page 2 by name, unions typically are do' able or willing to commit in t
advance that named workers will be available on a particular day.
Thus, with few er.ceptions', utilities do not know which workers are available until they arrive at the gate. Consequently, questions 3 and 4, which deal with the extent to which utilities are able to anticipate the need for temporary workers and thus alght have a sufficient opportunity to identiff, firgerprint, and clear the necessary temporary work;rs, are,e, psy irrelevant. Even though most major work activitiet requiring temporary workers are known in advance, the availability of pt ticular temporary workers to process for unescorted access is not prc.lded to the utility.
The potential additional requirement, as implied by question e, that temporary workers could not be granted unescorted access until the results of the FBI criminal history check are received by the utility, which NRC estimates would take 25 working days, would have substantial and unacceptable economic and productivity consequences and would, therefore, be vigorously resisted by the utility industry.
Further, the 25 day estimate may be optimistic. In a letter to Itcensees dated January 28, 1987, from Mr. Raymond i
Brady. Division of Security, Office of Administration, states that during the initial six month period, results of the FBI criminal history check should not be expected-for at least 90 days after submission of fingerprints to the NRC. This delay could be anticipated to extend beyond the initial six-month period and result in severe productivity and financial consequences for utilities. The only reasonable assurance that craft workers who report for processing will still be available 25 to 90+ working days later is if they are placed on the utility's, or its contractors', payroll. Otherwise, and very understandably, these workers will continue to seek other employment and only a fraction would be avail,ble one to three months later. Without unescorted access, the usefulness r/ these workers is extremely limited. As stated in the answer to question 6, the economic cost to utilities is estimated, based on a 25-day delay, tr exceed $350 million per year.
If the initial 90-day delay continues, thr. finan>:tal impact could potentially be tripled to well over $1.3 billion annually. Furthermore, as he stated in the answer to I
question 3,14 precent of the industry's temporary workers are needed to support urantic' pated and imediate needs for which a one to three month's delay would be unacceptable.
Beginning in May,1985, the NUMARC Working Group on Security worked with Nuclear Material Safety and Safeguards (NMSS) persone.el to develop an approach to access authorization which would satisfy security objectives and could be implemented in a renonable manner, consistent with the practicalities of operating and supporting nucle ~ar power plants. Revision 7 of th'e Guidelines was strongly endorsed by NUMARC utilities on August 28, 1985.
The Guidelines have been acknowledged by NMSS and the E00 as an acceptable alternative, have been endorsed by ACRS and were approved by the Commission in-lieu of the proposed rule on June 18, 1986.
In its approval, the Commission requested that additional consideration be given to a means for individuals to appeal an
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. Mr. Hugh L. Thompson Page 3 2 ?:S
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access authorization dental. A review process was incorporated and. Revision 8 of the guidelines was again strongly endorsed by NUMARC utt11ttes on October 29, 1986.
After 16 months of joint effort, Commission approval, the belief that all substantive issues had been satisfactorily resolved, and after having twice obtained the commitment of all licensees to an access authorization process, we are sure that you understand an4 perhaps share our consternation regarding what appears to be yet another issue. The industry views the temporary access authorization, as presently defined in the Guidelines, as essential to the proper support of our facilities. To encumber the temporary access authorization process with a requirement to wait for the results of the FBI criminal history check would destroy its value and would exceedingly hamper our ability to properly support our power plants in a timely manner. Based on conversations Wfth MMSS personnel, it is expedted that only 6 percent of all.
workers will have an FBI record. Furthermore, less than 1 percent of the.
records are expected to contain ' substantive information.
It is our opinion that the value of delaying access 25 to potentially 90 days for all workers when less than 1 percent to 6 percent have criminal history records is unacceptable. This risk of allowing unescorted access to all workers for a limited duration, who will be observed in the performance of their duties, compared to-the exorbitant expense ass'Jciated with delaying all workers, is acceptable. We do not argue that the FBI criminal history check provides value to the overall screening progr4m, but waiting for the results for temporary access authorization does not support the unacceptably high cost.
This matter was discussed with NMSS personnel during the developnent of the Guidelines and the industry's rasition was accepted.
We trust that this information provides a sufficient basis to close this matter. Please advise if NUMARC,can be of further assistance in this regard.
Sincerely, M
W. H. Owen Chairman NUMARC Steering Comittee WH0/dem Attachments
- 1. Responses to survey from 12 utilities
- 2. Responses tc specific questions cc:
B. D. Kenyon, PP&L E. R. McGrath, con Ed V. Stello, NRC R. F. Burnet t, NP.C
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I-Attachment.2 REEFCBSES TO QUEFFTORS CW TBSCEt&RT WoaxIRS
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p.. m are the varises typical dorations of temposary workers' employment at 1.
sp aggag unni,sitas?
c The survey identified that the majgrity of temporary workers are esployed t
typically from one to three mouths, the normal duratice of an outage. Survey respondents indicated that the duration of employment for temporary workers is based on the outage duration, i.e. most are needed for the entire outage. In many cases, outages have exceeded the,three month period, and temporary workers continued their employment until outage completion.
The survey results further indicate that very.few temporary workers have access for short durations (less than one month), especially craft who account for 71% of the total temporary worker population.
2.
Industrywide, how many temporary workers are employed on an annual basis 7 t
As ar. operatiossal definition for this survey, temporary workers were defined as non-utility employees who are not permanently assigned to the. facility and who provide only short-term support.- The survey results indicated that an average of 600 t aporazy workers are employed manna 11y per operating unit.
For many utilities, the average number of temporary workers (700-800) utilized exceeds the overall average due to total reliance on ' contract support.
The overall average figure includes some utilities who rely heavily on company _.
resources. Of the 42 units surveyed, a total of 25,116 are employed annually.
Extzapolating this figure to cover the entire industry, an estimated 61,200
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temporary workers are employed annually. This figure is based upon 102 full power licensed units. Terporary workers represent approximately 40-45% of all j
individuals requiring unescorted access authorization.
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3.
Typically, for the various types of employment utilizing temporary workers, how much is preplanrod vs. short-term and immediate?
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Survey results indicated that work performed by temporary workers is predceinately preplanned. Only 14% of temporary votkers were required to support short-term and irmediate needs (forced outages).
Although the respondents indicated that 59% of their.nost recent outages were forced, very few temporary workers were utilized to support this work. 14ost licensees stated that forced outages tend to be of a short duration, and internal..
resources are employed.. Refueling and major maintenance / construction projects are performed during preplanned outages. 86% of all temporary workers are utilized during preplanned work. The concept of creating a pool of screened j
personnel has not been well received by Union of ficia.ls: their primry concern centers on the possible creation of a permanent "blackball" list.
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4.
For prep 1 m ad situations, how' susch advance notice might a utility have.that a;tengorary work force is needed?
i z jd. Preplanned situations may be scheduled by.the. utility as far in advance as year.s Accordiaq1y, the utility,,, cans plasiiprojects/ work to be performed to -
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.tf' include identificatice of the types and the:approximata9 number. ' of' tesperary
'il.wortiers needed to support such projectsM* Although< the majority of projects
,:. can be anticipated, erperience. has proven that. unforeseen projects result once f i ani' outage is in progress. These projects have a significant'effeet on the I
nasbar and the duration of the tosporary work force. Although utilities may preplan many projects, most utilities, ten of the twelve surveyed (80%)
indicated they do not know the specific identity of the testporary worker until one to three days before site access is required. The two utilities which are still not reported receiving more advanced notice (one week to ten dJ.ys) provided with enough notice to, complete ths FBI check in sufficient time.
Even though the above data is based on survey results, the data should represent an industrywide situation. Craft workers who represent 71% of the total work force primarily report from local union halls. 60% of all crafts can be expected to come from local union halls. Utilities uho use union hall personnel, therefore, have virtually no control over the identity of these craft workers.
5.
Typically, what types of data (e.g.
radiation exposures, personal data) does a utility maintain on terwrary workers?
i Data maintained by utilities en temporary workers typically includes name, home address, social security nurb e r, nano of employer, birth date, sex, exposure records to include baseline body count and termination count, training dates, access authorization dates, security clearance data, medical -
records, date of physical, etc.
6.
What would be the impact to industry if all workers are required to be processed under an FBI criminal history check (estimated to take 25 working days) and to verify true identity prior to granting unescorted protected area / vital area access?
If the industry used the reciprocity provisions, how would this af feet the impact?
Under a rrent operating procedures, eight of the tweilve (66%)
aurveyed utilities responded tha t teeporary workers are processed for site accees authorization in less than five days. Conversely, four (33%) of the utilities indicated that processing time exceeded one week. These figures depict a I
representation of the current industry environment. The impact of extending l
th e access authorization process may result in hiring these tengorary workers for an additional 25 days. The cost impact related to direct labor expenses industrywide is $367.2 million anntally.
This figure is based upens (1) 61,200 temporary workers annuallys (2) a $30 hourly rates (3) a 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> work weeks and (4) an additional 25 work days. This expense would be incurred
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for totally nonproductive time due to workers' inability to obtain unescorted access.
Based on the survey results, an estimated 47% of temporary workers had unescorted access authorir.ation at another licensee within the previous 365 days therefore, access authorization for these temporary workers could be
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- t subject tio the' reciprocity prwisions. 12 a1147% of the' temporary, workers' access authorisations, wore transferred,{this would result in an anticipated.
' savings industrywide of $172.6 inillion. With the reciprocity piovisions, the '
wzpense to the industry would bew,$1M.6. million. 53% of the total. '
f, nottasuporary worker populatice would not badtransf.orable. ;. In tparticular,.the do 'not pEide substa'atial,banefit, for cratt workers
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'; An alternative to allowing tamparary workers to wait unproductively for FBI results would be to increase the use of escorts. This is not a practical approach to the probless due to some obvious effects of escorting to include increased manpower costs and increases in exposure rates, a practice inconsistant with ALABA considerations. Additionally, extending the process for tamporary workers during major outages will ultimately effect plaat operations by extending h duration of the outage and adversely effecting plant morales. Ultimately, these s'ffects will be passed on to W ratepayer.
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REFER TOs. M8606133 UNffsDs7ATas 4**
NUC1. EAR REQUR.ATORY COMM8SSRW '
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..Denton Victor Stello, Jr4gn MEMORANDUM FOR:
Executive Director for Operati.ons Taylor GCunningham 6"A.ASamud,al J. Chilk, Secretary Regions i
FROM:
STAFF REQUIREHENTS - AFFIRMATION / DISCUSSION AND'
SUBJECT:
VOTE, 3:30 P.M., WEDNESDAY, JUNE 18,.1986, COMt-MISSI0tfERS' CONFERENCE 200H, D.C. OFFICE (OPEN TO FDBLIC ATTENDANCE)
I.
SECY-85-381 - Insider' Safeguards Rules The Cossais'sion, by a vote of 5-0, has approved the staff's proposed rules on Search Requirements and Miscellaneous Safeguards-Related Amendments.
The statementsfo,f, consideration should be modified as suggested in the OGC memorandtna to* Chairman P=11Wna dated April 14, 1986, to state' that the costs of t.be rule are juztified by a substantial increase in safety an'd the justification of the The Federal Register Notices should be forwarded conclusions.
for signature and publication and the appropriate public and Congressional announcements made.
IfRJYF (HMSS)
(SECY Suspense 7/28/86) i Additionally, the,coannission, by a vote.of 3-2 (with CM n-sioners Roberts, Bernthal, and Zech agreeing),' has disapproved issuing an Access Authorization Rule in favor of a policy The staff is directed,to, develop and submit for sta tement..
ccannission approval, a policy statement,.-in cooperation.with.-
NUMARC, which endorses the NUMARC Guidelines for Nuclear Power The policy statement should Plant Access Authorization.
address the NUMARC comunitment for the licensees to voluntarily of their security incorporate the NUMARC Cuidelines as plans.
The policy should also re e the NRC.. position.that an appeal procedure is an important alsment of this process.
Chairman Palladino and Camissioner Asselstine. approved issuance..
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of the access authorization rule and do not believe it should be a policy statement.
emn (nMss) mmoetmmNnommswn (EDO. Suspense: 10/20/86) cca Chairman Palladino Cossaissioner Roberts ge(d 05.D0 ce===4 esioner Aseelatime le - 3 b -b. -
en-l~ssioner Bernthal' Cossaissioner tech g
cn-ission Staf f Of fices paa _
PDR - Advance DCS - 016 Phillips ENCLOSURE I t.
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October 3, 1986 Rev. 8 i.
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INDUSTRY GUIDELINES i
FOR NUCLEAR POWER PLANT ACCESS AUTHORIZATION PROGRAMS l
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l oo(A 7 ENCLOSURE 4
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TABLE OF CONTENTS
.P.312 1
Purpose...........................................................
1 2
Scope..~...........................................................
1 3
Responsibility....................................................
1 4
Applicability.....................................................
2 5
General Requirements for Unescorted Access........................
2 6
Screening Program.................................................
2 6.1 Initiation of a Screening Program............................
2 6.2 Background Investigation Elements............................
3 6.2.1 Emp l oyme n t H i s t o ry....................................
3 6.2.2 Education History.....................................
4-6.2.3 Criminal History........s.............
4 6.2.4 Military Service......................................
4 6.2.5 Character and Reputation..............................
5 6.2.6 Verification of Identity..............................
5 6.2.7 Credit Check..........................................
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- 6. 3 Psychological Evaluation.....................................
6 6.4 Temporary Unescorted Access Authorization....................
6 7
Evaluation Criteria for Access Auth'orization......................
7 7.1 Criteria......................................................
7 7.2 Review Process................................................
8 8
Transfer and Reinstatement of Unescorted Access Authorization.....
8 8.1 Transfer......................................................
8 8.2 Reinstatement.................................................
9 8.3 Update Requirements...........................................
9 Continual Behavioral Observation Program..........................
9 v.'
Screening During Cold Shutdown....................................
10 10.1 Devitalization of Vital Areas...............................
10 11 Grandfathering....................................................
11 12 Contractor and Vendor Requirements................................
11 13 Evaluations and Audits............................................
11 11 GUIDELINES ACCESS AUTH PROGRAM
TABLE OF CONTENTS (Continued)
Pagg 13.1 Utility Programs..........................................'..
11 13.2 Co,ntractor and Vendo r Programs..............................
11 14 Records...........................................................
12 Attachment A, Minimum Audit Criteria i
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l iii GUIDELINES ACCESS AUTH PROGRAM
1 PURPOSE To support the safe operations of licensed nuclear power plants, utilities will implement an access authorization program in accordance with the following guidelines.
These guidelines have been designed with the ob.jective of achieving high assurance that personnel granted unescorted access authorization to the protected and vital areas of utility nuclear power plants are trustworthy and reliable and do not pose a threat to commit radiological sabotage.
Individual utilities may have additional requirements.
2 SCOPE These guidelines define the acceptable levels for conducting and evaluating th'e elements of the screening program.
Major elements include background investi-gation, psychological evaluation, and behavioral observation. Additionally the guidelines (1) provide evaluation criteria for the determination of access authorization, (2) establish provisions for accepting unescorted access authori-zation from other utilities, (3) include a grandfathering of personnel who were previously screened and (4) discuss records maintenance, and evaluation and audits of the access authorization program to assure the utility's unescorted access authorization program is being tret.
3 RESPONSIBILITY The final granting and controlling of unescorted access authorization is the responsibility of the utility.
Each nuclear utility will inform contractors ad vendors of the existence of these guidelines and of the necessity to follow these guidelines.
The utilities are responsible to audit non-utilities who conduct their own screening and/or implement continual behavioral observation programs (CBOP) to assure these guidelines are followed.
Each utility is responsible for having an independent evaluation conducted of its program in accordance with Section 13.1 of these guidelines.
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4 APPLICABILITY These guidelines apply to all nuclear uti.~ities, ar.d nuclear utilities shall require those contractors and vendors who provide services at the utility's nuclear power. plants to also follow them.
One level of permanent unescorted access authorization will be gric..wd to personnel who have been processed in accordance with these guidelines.
Such unescorted access authorization will allow access to both protected and vital areas as needed.
5 GENERAL REQUIREMENTS FOR UNESCORTED ACCESS A utility may grant unescorted access authorization to an individual following the satisfactory completion of a screening program (6.0) which consists of a background investigation (6.2) and a psychological evaluation (6.3).
All of the foregoing may be waived if the individual satisfies any of the following:
(1) satisfies requirements for grandfathering (11.0); (2) has a transferable access authorization from another utility (8.1); (3) has a previously granted reinstateable access authorization from the utility (8.2); or (4) will be restricted to protected or devitalized areas during cold shutdown or refueling (10.1).
Also, a utility may grant a temporary nontransferable unescorted access authorization valid for no more than 180 days based on a psychological evaluation and a limited background check (6.4).
6 SCREENING PROGRAM 1
Initiation of a Screenina program l
l tia element of the screening program may be initiated without the knowledge and written consent of the person who is subject to such screening.
The applicant for unescorted access authoritation shall be informed of the types of records that may be produced and retained, wnere such records are normally maintained, the duration such records are usually retained, the applicant's rights concern-ing access to the information, and to whom and under what circumstances the information will be released.
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Initial screening requirements are applicable to those individuals who have never been screened or granted unescorted access authorization except as defined in Section 11.0.
The initial screening program has two components:
a background investigation (Section 6.2) and a psychological evaluation (Section 6.3)'.
An applicant may withdraw consent to a psychological evaluation or background investigation at any time. When withdrawal of consent is made, all processing of work in connection with either the psychological evaluation or background investigation must cease as soon as practical.
Withdrawal of consent must be deemed as withdrawal of the application for unescorted access authorization.
Information collected under these guidelines may be released only on a need-to-know basis.
6.2 Background Investiaation Elements The background investigation covers the time period specified in each element below or since the eighteenth birthday, whichever is shorter.
The applicant's --
employment history, education history, credit history, criminal history, mili-tary service, and the applicant's character and reputation must be addressed in the following manner.
6.2.1 Employment History Except as noted below, employment history must be obtained for the past five years through contacts with previous employers, by obtaining the following nformation:
a.
Verification of claimed periods of employment of 30 days or more; b.
Disciplinary history; c.
Reasons for termination and eligibility for rehire; 3
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Any other information that would adversely reflect upon the reliability and trustworthiness of the individual as it relates to the individual being permitted unescorted access; and e.
Activities during interruptions of employment in excess of 30 days must be verified.
NOTE:
Because of the multitude of employments many employees experience
- ring a five year period, especially craf t and trade workers, verification of all such employments may not be possible.
Consequently, utilities may consider these applicants for unescorted access based upon an inclusive three year retro-spective employment check if the entire five year period cannot be covered.
Under no circumstances may unescorted access be granted based on an employment check of less than three years, and attempts should be made to include the entire five year period.
6.2.2 Education History Verify any claimed enrollment at an educational institution during the previous ~'
five years.
In addition, verify the highest claimed cost high school attendance or degree regardless of time.
6.2.3 Criminal History As required by Federal law (Pub. L.99-399, "Omnibus Diplomatic Security and Anti Terrorism Act of 1986"), the utility shall perform a criminal history record check through the Federal Bureau of Investigation in accordance with NRC
-Julatiens.
6.2.4 Military Service If within the last five years, military period of service (claimed or developed) must be verified by receipt of a Form 00214 or other National Personnel Records Center (NPRC) records.
This information must be obtained from the NPRC through acquisition and submittal of an applicant's authorization for release of mili-tary history information.
The utility may grant unescorted access for 180 days 4
or less to individuals prior to receipt of 00214 or other military records if all other applicable elements of the guidelines are met and a record is main-tained which documents that the request for military history was submitted within 10 working days of granting unescorted access.
If it becomes known that an individual's discharge is other than honorable based solely on receipt of a 00214, further investigation must be made.
6.2.5 Character and Reputation The applicant's reputation for emotional stability, reliability and trustworthi-ness must be examined through contact with two references supplied by the applicant and at least two additional references (not related to the applicant) developed during the investigation.
(It is not necessary that reference's (individually or collectively] association with or knowledge of the applicant for unescorted access cover the entire five year retrospective period.)
Emphasis must be placed on:
a.
Identified psychological problems; b.
Criminal history; c.
Illegal use or possession of a controlled substance; d.
Abuse of alcohol; I
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Susceptibility to coercion; and f.
Any other conduct relating to an applicant's trustworthiness of reliability to discharge job duties within the environment of a nuclear power plar.t.
6.2.6 Verification of Identity Identity must be verified thrm.gn means such as photograph, social security number, date of birth, or comparison of applicant's physical characteristics l
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with employment, education, military and other records and/or employer and character references who have a personal acquaintance with the applicant.
6.2.7 Credit. Check A check of the applicant's credit history must be performed through checks with credit bureaus and/or credit references.
6.3 Psycholoaical Evaluation Reliability and stability must be determined by the result of a reliable written personality test or by any other professionally accepted clinical evaluation procedure.
The results of such test or procedures, must be evaluated by a qualified and, if applicable, licer. sed psychologist or psychiatrist.
If the results of the written test or other procedure identify any psychological abnormalities which may indicate emotional instability, unreliability, or untrustworthiness, or the results need further clarification, a clinical interview must be conducted by a qualified and, if applicable, licensed psychologist or psychiatrist.
6.4 Temporary Unescorted Access Authorization A utility may grant unescorted access authorization not exceeding a period of 180 continuous days based on a temporary authorization.
This temporary authori-zation cannot be transferred from one licensee to another in accordance with Section 8.1 with the exception of the FBI criminal history check which may be transferred.
The 180-day temporary authorization may be granted based upon disfaction of the following conditions:
a.
Passing a psychological evaluation within the past year; l
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Conduct of a credit check; c.
Recommendation of one developed character reference who has had frequent and direct association with the applicant; and 6
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Evidence that a request for a criminal history check of the individual by the FBI has been submitted to the NRC.
7 CVALUATION CRITERIA FOR UNESCORTED ACCESS AUTHORIZATION 7.1 Criteria In its decision to grant an individual authorization for unescorted access, the utility shall consider information obtained during the background investigation and psychological evaluation.
This information must be reviewed using the guidelines specified in this section.
Each utility shall define the appropriate level of management to adjudicate matters covered by these criteria.
In making a determination of trustworthiness or reliability, the following must be considered:
a.
Willful omission or falsification of material information submitted in support of employment or request for unescorted access authoriza-tion to protected or vital areas; b.
Illegal use or possession of a controlled substance or abuse of alcohol without adequate evidence of rehabilitation; c.
A criminal history without adequate evidence of rehabilitation which establishes untrustworthiness or unreliability; d.
History of mental illness or emotional instability that may cause a significant detect in the individual's judgment or reliability; Any evidence of coercion, influence or pressure that may be applied e.
by outside sources to compel an individual to commit any act of sabotage or other act which would adversely reflect upon the indivi-dual's trustworthiness or reliability; f.
Evidence that the individual has committed or attempted to commit, or aided or abetted another who committed or attempted to commit, any 7
s act of sabotage or other act that would pose a threat or reflect adversely upon that individual's trustworthiness or reliability; g.
A psychological evaluation wHch indicates that the individual is a risk in terms of trustworthiness or reliability; and h.
Any other information that would adversely reflect upon the reli-ability and trustworthiness of the individual as it relates to the individuals being permitted unescorted access.
7.2 Review process Each permanent employee 1 of a utility whose employment is or will be termi-nated as a direct result of a denial or revocation of access authorization will; (1) be informed of the basis for denial or revocation of unescorted access; (2) have the opportunity to provide any additional information; and (3) have the decision, together with any additional information, reviewed by F
another designated manager of the utility who is equivalent or senior to and independent of the individual who made the initial decision to deny or revoke unescorted access.
The determination from this review is final.
An alterna-tive review process which is independent and impartial is acceptable.
If an alternative review process is used, the utility will include a description of its review process in its plan which meets this guideline.
8 TRANSFER AND REINSTATEMENT OF UNESCORTED ACCESS AUTHORIZATION transfer or reinstatement of unescorted access authorization requires verifica-tion of the individual's identity by the utility.
8.1 Transfer An individual's unescorted access authorization granted by one utility in accordance with those guidelines may be transferred to another utility via 3The term "permanent employee" refers to a person who is employed by a utility for an undefined term.
It does not include employees who were temporarily hired for a specific project or other temporary work or who were hired under an employment contract with a defined term.
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correspondence, computer data transfer, or telecopy if the gaining utility; (1) verifies or receives confirmation that the individual currently holds a valid unescorted access authorization or had a valid unescorted access authori-l zation which was terminated under favorable conditions within the previous 365 days, and (2) cross-checks information such as name, date of birth, social security number, sex, and other applicable physical characteristics for identi-fication.
8.2 Reinstatement The utility may reinstate the unescorted access authorization granted an individual if the individual returns to tr., same utility and unescorted access authorization has not been interrupted for a continuous period of more than 365 days and if the previous unescorted access authorization was terminated under favorable conditions.
O 8.3 Update Requirements A utility shall not authorize unescorted access where the individual's unes-corted access authorization has been interrupted for more than 365 calendar days unless the psychological evaluation and the bsckground investigation is updated to cover the individual's actisities from the date of the previous background investigation, not to exceed retrospective periods in 6.2, or to the period when unescorted access 6as last held, whichever is less.
A temporary unescorted access authorization (6.4) may be issued while the background investigation update is occurring.
i CONTINUAL BEHAVIORAL OBSERVATION PROGRAM (C80P) 1 Each individual granted unescorted access shall be subject to a C80P.
This CBOP applies to all personnel who are grarited unescorted access.
The following must be included in the overall program:
a.
A program with the objective for assuring the detection of alcohol and drug abuse and other behavior that may evidence a threat to com-mit radiological sabotage; 9
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A continual behavioral observation program that provides for manage-rwat/ supervisory personnel responsibility for otserving personnel for behavioral traits and patterns that may reflect aJversely on their f
trystworthiness or reliability and reporting those observations to L
aporopriate utility management; and c.
A training pr3 gram which reasonably assures that management /
supervisory personnel have the awareness and sensitivity to detect j
and report changes in behavior, to include suspected alcohol and drug abuse, which adversely reflect upon the individual's trust-1 worthiness or reliability, and to refer these persons to the util-it/'s management for appropriate evaluation and action.
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l Individuals with unescorted access authorization must be notifi9d of his/her responsibility to report any arrest that may impact upon his/her trustworthiness.
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r 10 SCREENING LURING COLD SHUTOOWN 10.1 Otvitalization of Vital Areas f
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"uring refueling or maintenance outage in which all or a part of a nuclear q
power plant is in a cold shutdown, refueling, or devitalized status, the utility may grant unescorted access authorization to the protected and devitalized areas for personnel who have not been screened in accordance with Section 6.0 provid-ing that; a.
Thw unescorted and unscreened person is restricted to the protected or devitalized areas; b.
Other requirements of the approved security plan remain in force, and the requirements of 10 CFR 73.55 are followed for unscreened personnel granted unescorted access; Prior to start-up, a thorough visual inspection of the devitalized area is made b/ knowledgeable plant personnel to identify signs of
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tampering or attempted sabotage; and
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Appropriate safety start-up procedures are followed to assure that all operating and safety systems are functic.ing normally.
11 GRANDFATHER!NG F e stility may grant unescorted access authorization to individuals if they
!.aic a valid unescorted access authorization on the date security plan
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amendments in response to these guidelines are approved or have been granted urescorted access authorization within the 365 days prior to the date of amended security plan approval, i
12 CONTRACTOR ANO VENDOR REQUIREMENTS i
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The utility may accept the results of the entire screening program or any part j
tnereof conducted by a contractor or vendor, provided that the contractor or j
vendor meets the requirements of these guidelines and that it makes its records available for auditing by the licensee or its designated representative in j
accordance with Sections 13 and 14.
The utility retains the ultimate responsi-t bility for assuring that individuals granted unescorted access to the f acility --
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have been subjected to the screening elements of this program.
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13 EVALUATIONS AND AUDITS I
13.1 Utility Programs I
An independent ealua',ioi1 of the access authorization program and its conform-1 ance to these guidelines must be made within 12 months of the effective date of I
' plementation of the 3 mended security plan which commits to these guidelines.
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' ereaf ter, an independent evaluation must be conducted at least once every i
24 fronths.
The utility shall retain all reports of evaluation for a period of I
three years.
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13.2 Contractor and vendcr Programs f
The utility or its designated representative shall conduct annual asdits of i
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contractor and vendor access authorization programs to ensure cumpliance with l
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6 these guidelines.
Other utilities may accept the originating utility's audit and need not reaudit the same contractor or vendor for the same period of time providing the scope of the audit meets the minimum auditing criteria contained in Attachment A.
A copy of the audit report, to include findings, recommenda-l tions and corrective action must be provided to the sharing utility.
i 14 RECOR05 l
Utilities and contractors and vendors of utilities who conducted screening programs in accordance with these guidelines shall maini.ain actual data that; a.
A background #avestigation and psychological evaluation were conducted for t
t each person wh,
$. screened under Section 6.0 of these guidelines, i
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b.
Other persons were granted unescorted access authorization in accordance I
with Section 11; and
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Satisfaction with the conditions of Section 6.4 which resulted in the l
granting of temporary unescorted access authorization.
i The utility, contractor, or vendor shall retain records for each person who is granted unescorted access for a thret year period following termination of j
access authorization.
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j Each utility or utility's contractor or vendor who collects personal informa-
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j tion for the purpose of processing access authorizations shall establish and l
l sintain a system of files and procedures for the protection of the personal i
n'ormation.
This information must not be disclosed to persons other than the l
tject or his/her representative, utility counsel and officers, auditors whose i
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- urpose for review would be to inspect program conformance, other utilities if I
an individual's access authorization is transferred, and those individuals who have a need to have access to the information in performing assigned duties in
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the process of granting or denying access authorization.
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MINIMUM AUDIT CRITERIA The following information must be reviewed during the conduct of an audit of a contractor / vendor screening program to meet the objective that the intent of these cuidelines have been met.
A.
Background Investigation The auditor shall review screening activities by examining records and conducting interviews with appropriate personnel to determine that screening activities were accomplished in a correct and accurate manner.
In conducting an audit of the background information to reasonably assure con-tractor conformance with these guidelines, the auditor shall randomly verify the following:
1.
Employment History Date the verification was made, complete dates of emplcyment, posi-tion, disciplinary history, reason for ter.aination, eligibility for i
rehire, and any other information which would adversely reflect upon
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I the reliability and trustworthiness of the individual.
The retro-I spective period for employment history must be reasonably attempted for five years; however, due to the nature of employment histories of l
some transient craft workers, a minimum period of three years is required.
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2.
Education I
1 Copies of transcripts, diplomas, etc., documentation which verifies all claimed attendance within the previous five years.
In addition, i
the highest post-high school attendance or degree must be verified I
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10/03/86 1
Attachment A J
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o regardless of time.
Records must' include, as a minimum, dates of check, dates of attendance, highest level of attendance, and reason for leaving, i.e., graduation, transfer, expulsion, etc.
3.
Criminal History Date of check and results of FBI criminal history records ch6ct.
If temporary unescorted access authorization was granted, evidence of submittal of request for FBI criminal history records prior to granting unescorted accass.
4.
Military History Date of receipt and copy of Form 00214 or other military records from the National Personnel Records Center if military service was within previous five years.
If unescorted access was granted prior to receipt of NPRC records, evidence of submission of request for military history within ten working days of granting unescorted access shall be contal.ied in the access authorization file.
5.
Character References Dates of contact, names of references, association with applicant, period of association and any information related to identified psychological problems, criminal history, illegal use or possession of a controlled substance, ab1se of alcohol, susceptibility to coercion and any other conduct relating to applicant's trustworthiness and reliability.
Each file must contain two listed references and two developed references (not related to applicant) as a minimum.
6.
Verification of Identity How verification of identity was accomplished through such means as photograph, social security number, date of birth, and comparison of applicant's physical characteristics with records and/or references.
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Attachment A s
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Credit History Date of the credit check (s), name and location of credit b'ureau or other source, and results of initial check (s).
8.
Psychological Evaluation To reasonably assure contractor conformance concerning psychological evalua-tion, the auditor must be concerned with the date of the testing and that a 2
psychologist / psychiatrist reviewed the evaluation.
Contractor records must
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include a copy of the report signed by a licensed, if applicable psychologist /
psychiatrist.
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Continual Behavioral Observation Program (CBOP)
To rea'.onably assure contractor conformance concerning a CBOP, the auditor must r
review contractor's program to determine compliance with these guidelines, specifically to address that supervisors Ore sensitized to alcohol and drug i
i abuse and other behavioral traits / patterns which may cause a threat to commit i
radiological sabotage, and to report / refer persons displaying such behavior to t
the utility's management for appropriate evaluation and action.
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Temocrary Unescorted Access Authorization To reasonably assure contractor conformance concerning temporary unescorted access authorization, the auditor must be concerned with completion dates for tredit check, reference check, psychological evaluation (within previous year a date unescorted access was granted) and date of submission to the NRC o f
' criminal history check.
The auditor shall follow criteria set forth in i
lection A for credit history and character references anti Section B for ps) cho-l e
logical evaluation.
Evidence of submist, ion of FBI criminal history request or receipt of results transferred from another utility or received directly from f
the NRC must be contained in access authorization file.
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Attachment A t
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E.
Update Requirements a
To reasonably assure contractor conformance concerning updating access authori-zations when access authorizations have been interrupted for more than 365 days, j
the auditor must be concerned with the dates of psychological evaluation and background investigation, and the retrospective period of the background inves-i tigation must cover activities from the date of the previous background investi-l gation not to exceed the retrospective period of Section 6.2 or the period when unescorted access was last held, whichever is le u.
The criteria listed in Sections A and 8 must be met in updating unescorted access authorization.
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Grandfatherino To reasonably assure contractor confermance concerning grandfathering, the l
auditor must be concerned with the date of the previous unescorted access authorization to determine that the individual held unescorted access authoriza-l tion on tne date security plan amendments in response to these guidelines were approved or was granted access authorization within the 365 days prior to the date of amended security plan approval.
The auditor must be concerned that no l
individuals were grandfathered earlier than the 365 days prior to the date of
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amended security plan approval or subsequent to the date of amended security plan approval.
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Attachment A
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