ML20197C558
| ML20197C558 | |
| Person / Time | |
|---|---|
| Issue date: | 06/28/1985 |
| From: | Burnett R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Jennifer Davis NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20197C372 | List: |
| References | |
| FRN-49FR30726, RULE-PR-50, RULE-PR-73 AA36-2-024, AA36-2-24, AB17-2-23, NUDOCS 8611060253 | |
| Download: ML20197C558 (6) | |
Text
.
-h M3b'b m v maar .my w w .ary y
~
DISTRIBUTION:
slUN2g D 56PR rlf
/f RUurnett MBiORANDUM FOR: John G. Davis, Director Office of Nuclear Material Wety and Safeguards FRG4: Robert F. Burnett, Director Division of Safeguards, NMSS
SUBJECT:
INSIDER SAFEGUARDS RULES Enclosed for your signature is a transmittal mmocrindum requesting Office review of the Insider Safeguards Rules in draft final fcnn as raccmmended by the Safeguards staff. .
This rulemaking package is comprised of the 'f.1 Ac:Ess Authorization llul e, (2) Search Requireraents, and (3) Miscellanect. /sendments. Revisions to the Access Authorization Rule have been made to c;'Irify the ruie's 'grandfcther" provision, include provision for interim acces peniing final cicarance, and to make minor ciarifications requested by put ;ic commant. The Miscellaneous Amendments have been revised by deleting the v:tal island concept and inde-pendent vital island provision on an interim % sis pending final recommen-dations of the Vital Area Committee (VAC). "O sigrafic?nt Coraments ware received regarding the Search Requirements, herica, nu ravisior:s have been made to this rule.
Please note that the draft Commission Paper vites the rationale fcr tne staff recommendation against the Nuclear Utility Management and Human Resource Committee (NUMARC) proposal. As a matter of irf ormation, the staff is working with the Cost Analysis Group (CAG) of the Of *tce of Rescurce Management on Value/ Impact considerations as well as .with Tfice of Management and i,udget (0:13) on some issues related to the proposed rule. de anticiuate no problents in these areas.
Please let me know if you wish to be briefed on the package.
g, A 8611060253 86110e Robert C. Burnett, Director s
[49$30726 s , afegua d , W FDR
Enclosure:
I Insider Safeguards Rule w,, .
"C"I .. .... ... .. / .. . .. .... ...... ............. . ... . .... . ... .. .. .... ................. . . ........... . ...
-HRym/.c.v.... ...G,Mc,Co r,k,1),,,RBu , ne g,,,,,,, ,,,,,,,,,,,,,,,, , ,, ,,, , ,,,,,,,,,,,,, , ,,,, ,,,,,, ,,,,,,, ,,,,,,,,,,,,,, ,,,,
ers) 6 M 6./.g/.85
........... 6../. 2.(./.8
. . . ./. . . . ./. 3 5. . . . . . .
.. 5 ...................l....................
.................j...............
- rocu sia no,semacu o2a OFFICIAL RECORD COPY sr v4.m 2 Sue v
h ~
L MA Nuclear Records Aionagement Association Inc.
October 3, 1984 Mr. Jeffe'rson B. Hill
-Executive Office of the President Office of Management and Budget Room 3228, New Executive Office Building k'ashington, DC 20503 49FR30726 ACCESS AUTHORIZATION PROGRAM Per your verbal request, a review and analysis was performed on the impact of 49FR30726, proposed rule on Access Authorization and the associated Draf t Regulatory Guide, dated September,1984 SG-301-4. Approximately 10 nuclear utility and related organizations were contacted to assist in this review. A sunary of the results of the review and analysis (attached) is provided for your information. This information is not intended to be an official position of the NRMA (Nuclear Records Management Association) or any organization contacted. It is, howeve , general information.which you may or may not choose to utilize as part of your evaluation of this proposed rule.
Should you have any questions or require additional it. formation, please
, contact me at (617) 589.-1092.
D. M. Oman NR".A - 0.".3 Liaison
REVIEW AND ANALYSIS SDiMARY I. SCOPE In order to determine the scope of the record requirements for the proposed rule, an in depth review and analysis was conducted of (47FR30726), Access Authorization Program, and the associated Draf t, Regulatory Guide, same subject.
II. RECORDS REVIEW AND ANALYSIS The review identified a potential for forty-three new record types (see attached list). An analysis of the identified record types was made to determine volumes. This analysis included average number of-pages, number of copies required, personnel affected, number of revisions and percent of personnel turnover. The results indicated that a paper volume in excess of 50,000 sheets /pages per year would be generated per nuclear generating station (one to two units) to support the program. This volume of records will place an additional burden on the licensee, contractors, and suppliers.
Utilization of empirical data to identify personnel requirements identified that the following additional staff would be required; four supervisory personnel, seven administrative specialists, and five entry level clerk typists. One additional person would be required fe*:
processing records within a records management program. The total additional personnel needed to support the propossd program would average 17 persons per year per licensee.
III. COST IMPACT The total labor cost for add'itional access authorization requirements contained in the Proposed Rule is approximately S750,000.00 per year /
per utility. The overall impact on the nuclear utility industry is estimated in excess of $70,000,000 per year.
Other additional costs, not factored into the above total, are incurred when initially establishing the program. Tasks, e.g.
procedure development, training program development, criteria development, and establishment of an audit program, will result in an additional estimated cost of over $30,000 per year per utilitsf.
IV.
GENERAL COMMENT
S All of the organizations responding to our survey, were currently involved in and supporting a background investigation program, tery few performed a psychological assessment, and none performed a continual behavior observation program. The general consensus of those interviewed, was that the successful implementation of the Behavioral Observation Program may not be possible. Areas of concern included training supervisors to identify behavior changes, effect on collective bargaining agreements, resistance.to " Big Brother" tactics, and the time and cost to implement and maintain the program.
All interviewees agreed that the proposed rule would result in a substantial increase in paperwork and associated costs.
IDENTIFIED RECORD TYPES SOURCE DOCUMENT Draft Regulatory Guide SC-301-4
- 1. Access Authorization Program Plan Page 1, Paragraph 2
- 2. Background Investigation Procedures
- 3. Background Investigation Records Contents may include:
- a. copy of birth certificate
- b. fingerprint card
- c. photograph
- d. past military service record
- 4. Investigative Criteria Page 4, Paragraph,2.2 1
- 5. Interim Unescorted Access Authorization Page 7, Paragraph 3
- 6. Authorination to furnish military Page 8, Paragraph I history information directly to licensee
- 7. Background Investigation Criteria Page 9, Paragraph 1 Training
- 8. Information Evaluation Criteria Page 9, Paragraph 2.3
- 9. Psychologist or Psychiatrist Page 12, Paragraph 1 Assessment Evaluation Sheet
- 10. Phychological Assessment Procedures
- 11. Psychological Assessment Record
- 12. Personality Test (MMPI) Page 15, Paragraph (d)(1)
Record
- 13. Clinical Interview Form Page 15, Paragraph (d)(2)
- 14. Psychiatrist or Psychologist Page 16, Paragraph I recommendation on suitability
- 15. Behavioral Unreliability Criteria Paga 16, Paragraph 2 Behavioral Reliability Criteria Page 17, Paragraph 4
- 16. "Second" personality test (16PF) Page 18, Paragraph 2
- 17. Continual Behavioral Observation Procedures
- 18. Continual Behavioral Observation Record e - --. , -,-
?' . 2
\
- 19. Employee Assistance Program Page 24, Paragraph 3
- 20. Employee Assistance Referral Form Page 24, Paragraph 3
- 21. Temporary Suspension of Access, Page 25, Paragraph 3 Letter
- 22. Reinstatement of Access, Letter Page 25, Paragraph 3
- 23. Revocation of Access, Letter Page 25, Paragraph 3
- 24. Behavioral Observation Training Page 26, Paragraph 3 Program
- 25. Supervisor Training Records
- 26. Supervisor Training Examinations
- 27. Supervisor Training Evaluation Record
- 28. Licensee evaluation of training form Page 27 Paragraph 2
- 29. Supervisor notification of major Page 27, Paragraph 3 incidents of Senior Management
- 30. Supervisor personnel minor incident Page 27, Paragraph 3 record sheet
- 31. Behavioral Observation Report for Page 28, Paragraph 3 each subordinate
- 32. Behavioral Observation Criteria Page 29, Paragraph 7
- 33. Transmittal of Eligibility of Access Page 31, Paragraph (F)(1)
Authorization
- a. Photograph
- b. Written verification (certification) 34 Receipt of Eligibility of Access !
Authorization
- 35. Teaporary Unescorted Access Authorization Page 31, Paragraph (F)(3)
- 36. Grievance Review Procedure Page 35, Paragraph 9
- 37. Access Authorisation Denial or Page 35 Paragraph 9 Revocation Review Form
- a. Multiple copies for Collective. I Bargaining Review Board i
l 1
- "* .
- i 3
- 38. Audits - on entire program, e.g quality Page 37 Paragraph 1 assurance training protection of information, contract records, etc.
- 30. Privacy Protection Program Page 38, Paragraph 1
- a. Consent Form
- 40. Basis for Use of Psychrometric Page 41 Measurement Instrument
- 41. Unescorted Access Records
- 42. Unescorted Access Logs
- 43. Security Plan, changes and/or incorporation of Access Program f
1
)
- - . . , --