ML20148E828

Rev 8 to Industry Guidelines for Nuclear Power Plant Access Authorization Programs

ML20148E828
Person / Time
Issue date:	10/03/1986
From:	NRC
To:
Shared Package
ML20148E825	List: ML20148E820 ML20148E828
References
FRN-53FR7534, RULE-PR-50, RULE-PR-73 PROC-861003, NUDOCS 8803250332
Download: ML20148E828 (19)

Text

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October 3, 1986 Rev. 8 4

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' APPENDIX A  !

INDUSTRY GUIDELINES FOR t NUCLEAR POWER PLANT  ;

ACCESS AUTHORIZATION PROGRAMS l 1

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i 8803250332 PDR PR 880304 '.

j 50 53FR7534 P DR '- 9 i c I i i  !

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I TABLE OF CONTEN_T_S bit 1

1 Purpose ...........................................................

1 2 Scope .. ..........................................................

1 3 Responsibility ....................................................

2 4 Applicability .....................................................

2 5 General Requirements for Unescorted Access ........................

2 6 Screening Program ................................................. 1 2

6.1 Initi ation of a Screening Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 6.2 Background Investigation Elements ............................

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

4 6.2.2 Education History .....................................

4 6.2.3 Criminal History ......................................

4 6.2.4 Military Service ...................................... 5 6.2.5 Character and Reputation ..............................

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

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

6 6.3 Psychological Evaluation ..................................... 6 6.4 Temporary Unescorted Access Authorization ....................

7 7 Evaluation Criteria for Access Authorization ......................

7 7.1 Criteria...................................................... 8 7.2 Review Process........ .......................................

8 l 8 Transfer and Reinstatement of Unescorted Access Authorization ..... 1

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8 l 8.1 Transfer...................................................... 9 8.2 Reinstatement................................................. 9 8.3 Update Requirements...........................................

C 9 Continual Behavioral Observation Program ............... ..........

10 10 Screening During Cold Shutdown .................................... i i

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10.1 Devitalization of vital Areas ............................... )

11 11 Grandfathering ....................................................

11 l 12 Contractor and Vendor Requirements ................................ 1 11 i 13 Evaluations and Audits ............................................

11 GUIDELINES ACCESS AUTH P l

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o TABLE OF CONTENTS (Continued)

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11 13.1 Utility Programs............. ...............................

11 13.2 Contractor and Vendor Programs ..............................

12 14 Records ...........................................................

Attachment A, Minimum Audit Criteria i

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I 111 GUIDELINE $ ACCESS AUTH PROGRM

1 PURPOSE To suppor+ 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 objective of achieving high assurance that personnel granted unescorted access authorization to the '

prctected and vital areas of utility nuclear power plants are trustworthy and reliable and do not pose a threat to commit radiological sabot;

. Individual utilities may have additional requirements.

2 SCOPE These guidelines define the acceptable levels for conducting and evaluating the elements of the screening program. Major elements include background investi-gation, psychological evaluation, and behavir.,ral observation. Additionally the guidelines (1) provide evaluation criteria for the determination of access authorization, (2) establish provisions fo. accepting unescorted access authori-zation from other utilities, (3) include a grandfathering of personnel who were l previously screened and (4) discuss records maintenance, and evaluation and audits of the access authorizatien program to assure the utility's unescorted access authorization program is being met.

l 3 RESPONSIBILITY The final granting and controlling of unescorted access authorization is the l responsibility of the utility. Each nuclear utility will inform contractors and vendors of the existence of these guidelines and of the necessity to follow l 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 indepandent 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 utilities, and nuclear utilities shali require those contractors and vendors who provide services Et the utility's nuclear power plants to also follow them.

One level of permanent unescorted access authorization will be granted 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 satisf actory 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 6.1 Initiation of a Screening Program No element of the screening program say be initiated without the knowledge and written content of the person who is subject to such screening. The applicant for unescorted access authorization shall be informed of the types of records that may be produced and retained, where such records are normally maintained, the duration scch 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 backgrouni investigation at any time. When withdrawal of consent is made, all processing ,

of work in connection with either the psychological evaluation or background l l

investigation must cease as soon as practical. Withdrawal of consent must be deemed as withdrawal rf the application for unescorted access authorization.

Infortnation collected under these guidelines may be released only on a need-to- l know basis.

6.2 Background Investigatio, Elements The background investigation covers the time period specified in each element below or since the eighteenth birthday, whichever is shorter. The applicant's eeployment history, education history, credit history, criminal history, mili-t.ary service, and the applicant's character and reputation must be addressed in the foilowing manner.

6.2.1 Employment History l Except as noted below, employment history must be obtained for the past five l I

years through contacts with previous employers, by obtaining the following information:

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

b. Disciplinary history;

c. Reasons for termination and eligibility for rehire; 3 l l

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d. 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 l

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

Because of the multitude of employments many employees experience l NOTE:

during a five year period, especially araft 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 j check of less than three years, and attempts should be made to include the entire five year period.

Education History  ;

6.2.2 Verify any claimed enrollment at an educational institution during the previcus five years. In addition, verify the highest cisieed post 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 i Anti-Terrorism Act of 1986"), the utility shall perform a criminal history l

record check through the Federal Bureau of Investigation in accordance with NRC regulations. l 1

I 6.2.4 Military Service If within the last five years, military period of service (claimed or developed) aust 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 wo.-king 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 problers; i

b. Criminal history; i

c. Illegal use or possession of a controlled substance;

d. Abuse of alcohol; l

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e. Susceptibility to coercion; and

f. Any otrer conduct relating to an applicant's trustworthiness of l reliability to discharge job duties within the environ:aent of a nuclear power plant.

6.2.6 Verification of Identity Identity must be verified through means such as photograph, social security number, date of birth, or comparison of applicant's physical characteristics 5

t 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 Psychological Evaluation Reliacility 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, licensed 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-

'3 accordance with zation cannot be transferred from one licensee to another 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 satisf action of the following conditions:

a. Passing a psychological evaluation within the past year; .

b. Conduct of a credit check;

c. Recommendation of one developed character reference who has had frequent and direct association with the applicant; and i 6

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

7 EVALUATION CRITERI A 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 defect in the individual's judgment or reliability;

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

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g. A psychological evaluation which indicates that the individual is a risk in terms of trustworthiness or reliability; and

h. Any other information that would advarsely 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 l of a utility whose employment is or will be terai-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 inforsation; and (3) have the decision, together with any additional information, reviewed by another designated manager of the utility who is equivalent or senior to and independent of the individual who made the initial decision to deny or revoke 1

l unescorted access. The determination from this review is final. An alterna-tive review process which is indepenaent 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.

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8.1 Transfer ,

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

line 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 i

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 unescorteC access authori-2ation 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.

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

8.3 Update Recuirements 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 background investigation is updated to cover the individual's activities from the date of the previous background investigation, not to exceed retrospective periods in 6.2, or to the~

period when unescorted access was last held, whichever is less. A temporary unescorted access authorization (6.4) may be issued while the background investigation update is occurring.

9 CONTINUAL BEHAVIORAL OBSERVATION PROGRAM (CBOP)

Each individual granted unescorted access shall be subject to a C80P. This CBOP applies to all personnel who are granted 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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b. A continual behavioral observation program that provides for manage-ment / supervisory personnel responsibility for observing personnel for behavioral traits and patterns that may reflect adversely on their trustworthiness or reliability and reporting those observations to appropriate utility management; and

c. A training program which reasonably assures that management /

supervisory personnel have the awareness and sensitivity to detect and report changes in behavior, to include saspected alcohol and drug abuse, which adversely reflect upon the individual's trust- ,

worthi.1ess or reliability, and to refer these persons to the util-ity's management for appropriate evaluation and action.

Individuals with unescorted access authorization must be notified of his/her responsibility to report any arrest that may impact upon his/her trustworthiness.

i 10 SCREENING OURING COLD SHUTDOWN 10.1 Devitalization of Vital Areas During refueling or maintenance outage in which all or a part of a nuclear power plant is in a cold shutdown, refueling, or devitalized status, the utility j say grant unescorted access authori:ation to the protected and devitalized areas for personnel who have not been screened in accordance with Section 6.0 provid-ing that; i

a. The 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;

c. Prior to start-up, a thorough visual inspection of the devitalized area is made by knowledgeable plant personnel to identify signs of tampering or attempted sabotage; and 10

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

11 GRANDFATHERING The utility may grant unescorted access authorization to individuals if they hold a valid unescorted access authorization on the date security plan amendments in response to these guidelines are approved or have been granted unescorted access authorization within the 365 days prior to the date of j amended security plan approval.

12 CONTRACTOR AND VENDOR REQUIREMENTS The utility may accept the results of the entire screening program or any part thereof conducted by a contractor or vendor, provided that the contractor or vendor meets the requirements of these guidelines and that it sakes its records l

available for auditing by the licensee or its designated representative in accordance with Sections 13 and 14 The utility retains the ultimate responsi-bility for assuring that individuals granted unescorted access to the facility have been subjected to the screening elements of this program.

13 EVALUATIONS AND AUDITS l

13.1 Utility Programs An independent evaluation of the access authorization program and its conform-ance to these guidelines must be made within 12 months of the effective date of implementation of the amended security plan which commits to these guidelines.

Thereafter, an independent evaluation must be conducted at least once every 24 months. The utility shall retain all reports of evaluation for a period of three years.

13.2 Contractor and Vendor Programs The utility or its designated. representative shall conduct annual audits of contractor and vendor access authorization programs to ensure compliance with 11

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-  !

tions and corrective action must be provided to the sharing utility.

14 RECORDS ,

l Utilities and contractors and vendors of utilities who conducted screening  ;

programs in accordance with these guidelines shall maintain actual data that;

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

b. Other persons were granted unescorted access authorization in accordance with Section 11; and

c. Satisfaction with the conditions of Section 6.4 which resulted in the granting of temporary unescorted access authorization.

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

Each utility or utility's contractor or vendor who collects personal informa-tion for the purpose of processing access authorizations shall establish and maintain a system of files and procedures for the protection of the personal information. This information must not be disclosed to persons other than the subject or his/her representative, utility counsel and officers, auditors whose purpose for review would be to inspect program conformance, other utilities if an individual's access authorization is transferred, and those individuals who ]

have a need to have access to the information in performing assigned duties in the process of granting or denying access authorization, j 12 1

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1 MINIMUM AUDIT CRITERIA The followi'ng 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 guidelines have been met.

i A. Background Investication The auditor shall review screening activities by examining records and conducting interviews with appropriate personr.el to determine that screening activities were i 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 employment, posi .

tion, disciplinary history, reason for termination, eligibility for rehire, and any other information which would adversely reflect upon j the reliability and trustworthiness of the individual. The retro- l spective period for employment history must be reasonably attempted for five years; however, due to the nature of employment histories of i

some transient craft workers, a minimum period of three years is required.

2. Education Copies of transcripts, diplomas, etc. , documentation which verifies all claiwed attendance within the previous five years. In addition, the highest post-high school attendance or degree must be verified 1

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 If Date of check and results of FBI criminal history records check.

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

4. Military History Date of receipt and copy of Form 00214 or other military recerds from the National Personnel Re ords 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 contained 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, abuse of alcohol, susceptibility to coercion and any other conduct relating to applicant's trustworthiness and reliability. Each file aus't contain two listed refe,rences and two developed references (not related to applicant) as a minimum.

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6. Verification of Identity

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l 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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7. Credit History Date of the credit check (s), name and location of credit bureau or other source, and results of initial check (s).

B. Psychological Evaluation To reasonably assure contractor conformance concerning psychological evalua-tion, the auditor must be concernef with the date of the testing and that a psychologist / psychiatrist reviewed the evaluation. Contractor records must include a copy of the report signed by a licensed, if applicable psychologist /

psychiatrist.

C. Continual Behavioral Observation Program (CBOP)

To reasonably assure contractor conformance concerning a CB0P, the auditor must review contractor's program to determine compliance with these guidelines, j specifically to address that supervisors are sensitized to alcohol and drug I

abuse and other behavioral traits /petterns which may cause a threat to commit radiological sabotage, and to report / refer persons displaying such behavior to the utility's management for appropriate evaluation and action.

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D. Temporary Unescorted Access Authorization To reasonably assure contractor conformance concerning temporary unescorted ,

access authorization, the auditor must be concerned with completion dates for credit check, reference check, psychological evaluation (within previous year from date unescorted access was granted) and date of submission to the NRC of FBI criminal history check. The auditor shall follow criteria set forth in Section A for credit history and character references and Section B for psycho-logical evaluation. Evidence of submission of FBI criminal history request or receipt of results transferred from another utility or received directly from the NRC must be contained in access authorization file, i

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E, Update Requirements To reasonably assure contractor conformance concerning updating access authori-zations when access authorizations have been interrupted for more than 365 days, the auditor must be concerned with the dates of psychological evaluation and background investigation, and the retrospective period of the background inves-tigation must cover activities from the date of the previous background investi-gation not to exceed the retrospective period of Section 6.2 or the period when untscorted access was last held, whichever is less. The criteria listed in I

Sections A and B must be met in updating unescorted access authorization.  !

F. Grandfathering l To reasonably assure contractor conformance concerning grandfathering, the auditor must be concerned with the date of the previous unescorted access authorization to determine that the individual held unescorted access auth tion on the date security plan amendments in response to these guidelines were approved or L : granted access authorization within the 365 days prior to the date of amended security plan approval,. The auditor r.ust be concerned that no individuals were grandfathered earlier than the 365 days prior to the date of amended security plan approval or subsequent to the date of amended security plan approval.

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