U.S. NUCLEAR REGULATORY COMMISSION 

REGULATORY G 

OFFICE OF NUCLEAR REGULATORY RESEARCH 

REGULATORY GUIDE 5.66 

ACCESS AUTHORIZATION PROGRAM 

FOR NUCLEAR POWER PLANTS

A. INTRODUCTION 

In 10 CFR Part 73, "Physical Protection of Plants 

and Materials," Section 73.56, "Personnel Access 

Authorization Requirements for Nuclear Power 

Plants," requires a licensee to establish and imple

ment a program, as a part of its Physical Security 

Plan, for granting unescorted access to protected and 

vital areas of a nuclear power plant. The program ob

jective is to provide high assurance that individuals 

granted unescorted access are trustworthy and reli

able and do not constitute an unreasonable risk to 

public health and safety, including the potential to 

commit radiological sabotage. e 

This regulatory guide provides an approach ac

ceptable to the NRC staff by which the licensee can 

meet the requirements of 10 CFR 73.56 for an access 

authorization program. The "Industry Guidelines for 

Nuclear Power Plant Access Authorization Programs" 

(NUMARC 89-01, August 1989, hereafter referred 

to as "the Guidelines") were prepared by the Nuclear 

Management Resources Council (NUMARC). The 

Guidelines meet the intent and substance of the rule 

except in a few areas in which the rule explicitly dif

fers from the Guidelines. The Guidelines are "pro

vided as an Appendix to this regulatory guide. 

Any information collection activities mentioned 

in this regulatory guide are contained as requirements 

in 10 CFR Part 73, which provides the regulatory ba

sis for this guide. The information collection require

ments in 10 CFR Part 73 have been cleared under 

OMB Clearance No. 3150-0002.

USNRC REGULATORY GUIDES 

Regulatory Guides are Issued to describe and make available to the pub lic methods acceptable to the NRC staff of implementing specific parts of the Commission's regulations, to delineate techniques used by the 

staff In evaluating specific problems or postulated accidents, or to pro vide guidance to applicants. Regulatory Guides are not substitutes for 

regulations, a compliance with them Is not required. Methods and 

olutions .different from those set out In the guides will be acceptable if they provide a basis for the findings requisite to the issuance or continu ance of a permit or license by the Commission. 

This guide was Issued after consideration of comments received from 

the public. Comments and suggestions for Improvements In these 

guides are encouraged at all times, and guides will be revised, as ap propriate, to accommodate comments and to reflect new information or experience. 

Written comments may be submitted to the Regulatory Publications 

Branch, OFIPS, ADM, U.S. Nuclear Regulatory Commission, Washing

ton, DC 20668.

June 1991

UIDE

B. DISCUSSION 

The access authorization program required by the 

rule consists of three elements designed to comple

ment each other: background investigation, psycho

logical assessment, and behavior observation. The 

background investigation is designed to identify past 

actions that are indicative of an individual's trust

worthiness and reliability within a protected or vital 

area of a nuclear power reactor. The psychological 

assessment is designed to evaluate the possible impact 

of any noted psychological characteristics that may 

have a bearing on trustworthiness and reliability. Be

havioral observation is designed to detect behavioral 

changes that, if left unattended, could lead to acts 

detrimental to the public health and safety. 

The Guidelines describe the components of these 

elements and include evaluation criteria for granting 

unescorted access. The Guidelines also provide de

tails for granting temporary access authorization, 

transfer and reinstatement of access authorization, 

grandfathering of access authorization, contractor 

and vendor requirements, and audits. " 

Pursuant to 10 CFR 50.54(p)(2), licensees who 

use this regulatory guide to implement their access 

authorization programs do not need to submit the re

visions made to their Physical Security Plans to the 

NRC for prior approval. However, if a licensee 

chooses to relax requirements for unescorted access 

during cold shutdown as permitted by 10 CFR 

73.56(d), the licensee is to develop compensatory 

measures and submit them to the NRC for review and

The guides are issued In the following ten broad divisions:

1. Power Reactors 

2. Research and Test Reactors 

3. Fuels and Materials Facilities 

4. Environmental and Siting 5. Materials and Plant Protection

6. Products 

7. Transportation 

8. Occupational Health 

9. Antitrust and Financial Review 

10. General

Copies of Issued guides may be purchased from the Government Printing Office at the current GPO price. Information on current GPO prices may be obtained by contacting the Superintendent of Documents. U.S. 

Government Printing Office, Post Office Box 37082, Washington, DC 

20013-7082, telephone (202)275-2060 or (202)275-2171. 

Issued guides may also be purchased from the National Technical Io4-

mation Service on a standing order basis. Details on this service may be 

obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161.
approval pursuant to 10 CFR 50.90 prior to incorpo

rating them in the Physical Security Plan. These com

pensatory measures (e.g., functional testing of secu

rity and reactor systems and components, security 

searches, enhanced access controls into areas re

tained as vital, establishment of alternative access 

requirements) are likely to be extensive and could 

vary dramatically depending on a number of factors, 

including the number of workers involved, the extent 

of devitalization, and the length and nature of the 

plant outage. The licensee would be expected to dem

onstrate that adequate measures will continue to be in 

place to protect new and spent fuel that is onsite. 

Clarifications to the Guidelines 

In developing this regulatory guide and consider

ing public comments on the Guidelines, some provi

sions of the Guidelines seemed susceptible to possible 

misinterpretation. Clarifications of these provisions 

are provided as follows. 

1. The NUMARC Guidelines discuss confirma

tion of military service specifically with regard to serv

ice in the United States military. This is not meant to 

be interpreted as meaning that military service for a 

foreign government should not be considered; a 

proper background investigation would include a 

good faith attempt to verify any claimed military serv

ice for a foreign government. 

2. The NUMARC Guidelines provide for tempo

rary access authorization for 180 uninterrupted days. 

Any longer access authorization is not "temporary." 

Using this provision to allow back-to-back temporary 

access authorizations for an individual by the licensee 

would be a misuse of this provision. 

3. The NUMARC Guidelines allow reinstatement 

of unescorted access authorization within 365 days of 

its termination if the authorization was terminated un

der favorable conditions. Requiring a complete psy

chological assessment and background investigation 

after every break of 365 days or less in the behavioral 

observation program is not feasible. However, there is 

information available to the licensee from other 

sources. For example, if an authorization lapses be

cause an employee took a leave of absence, it is rea

sonable to assume that the licensee has some indica

tion of the intended activities of the employee during 

such leave. Furthermore, prior to reinstatement of 

the access authorization, it is reasonable to expect 

that the licensee will ascertain that whatever activities 

the employee engaged in during his or her absence 

would not have the potential to affect the employee's 

trustworthiness and reliability. 

4. The NUMARC Guidelines provide for 

grandfathering and transferring access authorization. 

The rule provides for grandfathering of access 

authorization at the utility at which an individual is 

actually working when grandfathered.

Exceptions to the Guidelines 

This regulatory guide takes two exceptions to the 

Guidelines: a review procedure for employees and 

grandfathering of unescorted access. The explanation 

for the exceptions is as follows: 

1.'The Guidelines specify a review procedure 

specifically for permanent employees of licensees. 

The rule requires that a review procedure be available 

to all employees of a licensee, contractor, or vendor, 

temporary or permanent, whose employment is ad

versely affected when unescorted access is denied or 

revoked by the licensee. 

2. The Guidelines allow grandfathering of any in

dividual holding a valid access authorization either on 

the date of the implementation of the rule or any time 

during the previous 365 days. This would allow for 

the possibility of grandfathering without either a com

plete screening or a reasonable period of behavioral 

observation. To eliminate this possibility, the rule al

lows grandfathering only for those individuals who 

have had an uninterrupted access authorization for at 

least 180 days on the date the final rule is published 

in the Federal Register. 

C. REGULATORY POSITION 

1. The program given in NUMARC 89-01, "In

dustry Guidelines for Nuclear Power Plant Access 

Authorization Programs," August 1989, is acceptable 

to the NRC staff for meeting the provisions of 10 CFR 

73.56, subject to the following: 

1.1. Section 7.2, "Review Process," of the 

Guidelines does not apply; the review procedure must 

be conducted as specified in 10 CFR 73.56(e); 

1.2. To the extent that the rule differs from 

the Guidelines in Section 11.0, "Grandfathering," the 

rule will prevail. Specifically, 10 CFR 73.56(c)(1) re

quires that individuals who have had an unescorted 

access authorization for at least 180 days on the date 

the final rule is published in the Federal Register 

need not be further evaluated. 

2. Licensees who adopt this regulatory guide 

should make the following statement in their certifica

tion to the NRC that they have implemented 10 CFR 

73.56: 

All elements of Regulatory Guide 5.66 have 

been implemented to satisfy the requirements 

of 10 CFR 73.56. 

Licensees who adopt positions different from this 

regulatory guide should identify these differences in 

their certification to the NRC. Further, positions dif

ferent from the ones in the regulatory guide that 

would decrease the effectiveness of the access 

authorization program should be submitted to the 

NRC in accordance with 10 CFR 50.90.

5.66-2
REGULATORY ANALYSIS

A separate regulatory analysis has not been pro

vided for this regulatory guide. The regulatory analy

sis that was prepared for the rule on access authoriza

tion programs for nuclear power plants, 10 CFR 

"73.56, provides the basis for this regulatory guide and 

examines the costs and benefits of the rule as implemented by this guide. A copy of the "Regulatory 

Analysis for the NRC Nuclear Power Plant Access 

Authorization Program" is available for inspection 

and copying for a fee at the Commission's Public 

Document Room, 2120 L Street NW., Washington, 

DC, under Regulatory Guide 5.66.

5.66-3
NUMARC 89-01

APPENDIX

Industry Guidelines for 

Nuclear Power Plant 

Access Authorization Programs

August 1989 

Nuclear Management and 

Resources Council, Inc. 

1776 Eye Street, N.W. 

Washington, DC 20006-2496
NUMARC 89-01

INDUSTRY GUIDELINES FOR 

NUCLEAR POWER PLANT 

ACCESS AUTHORIZATION PROGRAMS 

AUGUST 1989

Nuclear Management and Resources Council, Inc. 

1776 Eye Street, N.W. 

Suite 300 

Washington, DC 20006-2496
ACKNOWLEDGEMENTS

These industry guidelines were prepared by members of the NUMARC Working Group on Insider Safeguards under to chairmanship of Carlyle (Bud) Fay, Vice President-Nuclear, Wisconsin Electric Power Company, and members of thf NUMARC Working Group on Security under the chairmanship of Bruce Kenyon, Senior Vice President, Pennsylvania Power and Light Company. K

NOTICE 

Neither Nuclear Management and Resources Council, nor any of its employees, members, supporting organizations, \ contractors or consultants make any warranty, expressed or implied, or assume any legal responsibility for the accuracy or completeness of. or assume any liability for damages resulting from any use of, any information, apparatus, method, or 

process disclosed in this report or that such may not infrnge privately owned rights.
TABLE OF CONTENTS 

Page 

1.0 PURPOSE ................... **..... **........*........... 1 

2 ,.0 SCO PE 66......................... .. .. . ............. ...... 1 

3.0 RESPONSIBILITY ....... 01... ......... 

4.0 APPLICABILITY ............................. •e ............... 2 

5.0 GENERAL REQUIREMENTS FOR UNESCORTED ACCESS ................ 2 

6.0 UNESCORTED ACCESS AUTHORIZATION PROGRAM ................... 3 

6.1 Initiation of an Unescorted Access Authorization Program . ... . . . . . . . . . . .. . . .* .. . .. 3 

6.2 Background Investigation Elements ................... 4 

6.2.1 Employment History .......................... 4 

6.2.2 Education History ............................ 5 

6.2.3 Criminal History ............................. 5 

6.2.4 Military Service ......................... 5 

6.2.5 Character and Reputation ..................... 6 

6.2.6 Verification of Identity ..................... 7 

6,.2.7 Credit Check ................................. 7 

6.3 Psychological Evaluation ............................ 7 

6.4 Temporary Unescorted Access Authorization ........... a 

7.0 EVALUATION CRITERIA FOR UNESCORTED ACCESS AUTHORIZATION ............................................. a 

7.1 Criteria ..... .. .. ...... 8• 

7.2 Review Process ...... ... .. . ... .. .... . ... ... .. 10 

8.0 TRANSFER AND REINSTATEMENT OF UNESCORTED ACCESS AUTHORIZATION ........................................ ..... 10 

8.1 Transfer .......................... 10 

8 .2 R e i n s t a t e m e n t . . . . . . . . . . . . . . . . . . . . . . 1 1 

8.3 Update Requirements ....................... ....... 11 

9.0 CONTINUAL BEHAVIORAL OBSERVATION PROGRAM (CBOP) ........... 11 

10.0 SCREENING DURING COLD SHUTDOWN ............................ 12 

10.1 Devitalization of Vital Areas ....................... 12 

11.0 GIRANDFATHERING .. ........................................ 13
12.0 CONTRACTOR AND VENDOR REQUIREMENTS ........................ 13 

13.0 EVALUATIONS AND AUDITS .................................... 13 

13.1 Utility Programs ................................... 13 

13.2 Contractor and Vendor Programs ...................... 14 

14.0 RECORDS ................................................... 14 

Attachment A, Minimum Audit Criteria ................. A-i

K
1.0 PURPOSE

To support the safe operations of licensed nuclear power plants, utilities 

will implement an unescorted 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 authori

zation to the protected and vital areas of utility nuclear power plants are 

trustworthy and reliable and do not pose a potential threat to interrupt the 

normal operation of a nuclear reactor. 

2.0 SCOPE 

These guidelines define the acceptable levels for conducting and 

evaluating the elements of the unescorted access authorization program. Major 

elements include background investigation, psychological evaluation and behav

ioral observation. Additionally, the guidelines (1) provide evaluation criteria 

for the determination of unescorted access authorization, (2) establish 

provisions for accepting unescorted access authorization from other utilities, 

(3) include a grandfathering of personnel who were previously screened, and 

(4) discuss records maintenance, and evaluation and kudits of the access 

authorization program to assure the utility's unescorted access authorization 

program is being met. 

3.0 RESPONSIBILITY 

The final granting and controlling of unescorted access authorization 

is the responsibility of the utility. Each nuclear utility will inform 

contractors and vendors of the existence of these guidelines and of the necessity 

to follow these guidelines. The utilities are responsible to audit non-utilities 

who conduct their own unescorted access authorization program 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.

I
4.0 APPLICABILITY

These guidelines apply to all nuclear utilities, and nuclear utilities 

shall require those contractors and vendors who provide services at the utility's 

nuclear power plant 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 unescorted access to both protected 

and vital areas as needed. 

5.0 GENERAL REQUIREMENTS FOR UNESCORTED ACCESS 

The term "unescorted access authorization, applies to the administrative 

determination of an individual's eligibility to be granted unescorted access. 

The term 'unescorted access' applies to the methodology or mechanism 

(e.g., keycard) that provides a physical means of controlling unescorted 

personnel access to protected and/or vital areas. 

A utility may grant unescorted access authorization to an individual 

following the satisfactory completion of a unescorted access authorization 

screening program (Section 6.0) which consists of a background investigation 

(Section 6.2) and a psychological evaluation (Section 6.3). All of the foregoing 

may be waived if the individual satisfies any of the following: (1) satisfies 

requirements for grandfathering (Section 11.0); (2) has a transferable unescorted 

access authorization from another utility (Section 8.1); (3) has a previously 

granted reinstateable unescorted access authorization from the utility 

(Section 8.2); or (4) will be restricted to protected or devitalized areas 

during cold shutdown or refueling (Section 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 (Section 6.4).

2

1⁄4There may be some variances between utility unescorted access 

/ authorization programs, e.g. more stringent drug testing requirements. For a 

transfer (Section 8.1) of a valid unescorted access authorization from one 

utility to another, all requirements are considered fulfilled as long as the 

minimum requirements of the Fitness-for-Duty Rule and the Access Authorization 

Rule are met. 

6.0 UNESCORTED ACCESS AUTHORIZATION PROGRAM 

6.1 Initiation of an.Unescorted Access Authorization Program 

No element of the unescorted access authorization program may be initiated 

without the knowledge and written consent of the person who is subject to the 

program. 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, and the duration such records are usually retained. 

The applicant shall also be informed of his/her right to review the information, 

and to assure its accuracy and completeness, as well as to whom and under what 

circumstances the information will be released. 

Initial unescorted access authorization program screening requirements 

are applicable to.those individuals who have never been screened for or granted 

unescorted access except as defined in Section 11.0. The initial unescorted 

access authorization program has two components: a background investigation 

(Section 6.2) and a psychological evaluation (Section 6.3). 

An applicant may withdraw consent to a background investigation or a 

psychological evaluation at any time. When withdrawal of consent is made, all 

processing of work in connection with either the background investigation or 

the psychological evaluation must cease as soon as practical. Withdrawal of 

consent shall be deemed withdrawal of the application for unescorted access. 

Information collected under these guidelines may be released 

(Section 14.0) or transferred (Section 8.1) upon the written authorization of 

the individual only on a need-to-know basis. A need-to-know basis means that

3
a recipient's access to information is necessary in the performance of official, 

contractual, or licensee duties in determining unescorted access authorization. 

6.2 Background Investigation Elements 

Except as provided In 10 CFR 73.57, the background investigation 

covers the time period' specified in each sub-element below or since the 

eighteenth birthday, whichever is shorter. Licensees need not fingerprint 

individuals employed at a facility who possess "Q or 'L clearances or possess 

another active government granted security clearances, i.e. Top Secret, Secret, 

or Confidential. This information must be received through the mail from the 

sponsoring facility and not hand carried by the individual. Each utility shall 

make a best effort to obtain required information and to document such attempts 

to address the applicant's employment history, education history, credit history, 

criminal history, military service, and the applicant's character and reputation 

must be addressed in the following manner. 

6.2.1 Emoloyment History 

Except as noted below, employment history must be obtained for the past 

five 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. 

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. 

e. Activities during interruptions of employment in excess of 30 days 

must be verified.

4
A best effort attempt to verify a five-year employment history record is 

required; however, a minimum three year inclusive employment history immediately 

preceding application for unesco rted access is mandatory. Best efforts include 

activities such as documented attempts to contact previous employers, obtaining 

verification by telephone, letter or other means, etc. If the employment history 

check could not be accomplished for the entire five-year period, an explanatory 

statement delineating the reasons must be included. 

Because of the multitude of employments many employees experience during 

a five-year period, such as craft 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 retrospective 

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 post high school 

attendanceleading to a degree regardless of time. 

--Criminal History S6.2.3 

As required by Federal Law (Pub. L. 99-399, "Omnibus Diplomatic Security 

and Anti-Terrorism Act of 19860), the utility shall perform a criminal history 

record check through the Federal Bureau of Investigation in accordance with 

NRC regulations. This check shall include the entire criminal history record 

of the individual as an adult. 

6.2.4 Military Service 

If within the last five years, a military period of service (claimed 

or developed) must be verified by receipt of a Form DD214 or other National

5
Personnel Records Center (NPRC) records. This Information must be obtained 

from the National Personnel Records Center through acquisition and submittal 

of an applicant's authorization for release of military history information. 

The utility may grant unescorted access for 180 days or less to individuals 

prior to receipt of a 0D0214 or other military records if all other applicable 

elements of the guidelines'are met and a record is maintained which documents 

that the request for military history was submitted within 10 working days of 

granting unescorted access. 

The temporary authorization period may be extended in the circumstance 

that NPRC has not forwarded the records to the utility, provided that reasonable, 

documented attempts are made at least every six months to obtain this Information 

until a response from NPRC is received. 

If it becomes known that an individual's discharge is other than honorable 

based solely on receipt of a Form 00214, or a Form 00214 is not available from 

the NPRC, further investigation must be made. 

6.12.5 Character and Reoutation 

The applicant's reputation for emotional stability, reliability and 

trustworthiness must be examined through-contact with two references supplied 

by the applicant and at least two additional references (not related to the 

applicant) developed during the investigation. (It is notnecessary that 

reference's [individually or collectively] associated 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.

6
e. Susceptibility to coercion.

f. Any other.conduct relating to an applicant's trustworthiness or 

reliability to discharge job duties within the environment 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 charac

teristics 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 

Since financial credibility is another measure of an individual's 

reliability and trustworthiness, a check of the applicant's credit history 

must be accomplished. This is normally pursued through local credit bureaus. 

- If this check does not reveal the requested information, the additional step 

of contacting the personal credit references listed by the applicant or those 

developed through other contacts is to be conducted. 

6.3 Psvcholoaical Evaluation 

Reliability and stability must be determined by the result of a reliable 

written personality test or by any other professionally accepted clinical 

evaluation procedure. The results of such test or procedure must be evaluated 

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, and if unescorted 

access is still being considered, a clinical Interview must'be c6nducted by a 

qualified and, if applicable, licensed psychologist or psychiatrist. 

7 

• " :*: " .•.A" 
6.4 Temporary Unescorted Access Authorization

A utility may grant temporary unescorted access authorization on an 

interim basis not exceeding a period of 180 continuous days pending completion 

of the checks required by the unescorted access authorization program. This 

temporary unescorted access authorization cannot be transferred from one licensee 

to another In accordance with Section 8.1 with the exception of the FBI criminal 

history check which may be transferred. This 180-day temporary unescorted 

access authorization may be granted based upon satisfactory completion of the 

following conditions: 

a. Identity verification through one photo identification (e.g. driver's 

license, military I1, passport or similar document). 

b. Passing a psychological evaluation within the past year. 

c. Conduct of a credit check. 

d. Recommendation of one developed character reference who has had 

frequent and direct association with the applicant. 

e. Evidence that a request for a criminal history check of the 

individual by the FBI has been submitted to the NRC. 

f. Conduct of an employment check for the past year. 

7.0 EVALUATION 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

a
the appropriate level of management to evaluate 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 authori

zation. 

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 individual'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 act of sabotage or other act that would pose a threat or reflect 

adversely upon that individual's trustworthiness or reliability. 

g. A psychological evaluation which indicates that the individual is 

a risk in'terms of trustworthiness or reliability. 

h. Any other information that would adversely reflect upon the 

reliability and trustworthiness of the individual as relates to 

the individual being permitted unescorted access.

9
7.2 Review Process

Each permanent employee 1 of a utility whose employment is or will be 

terminated as a direct result of a denial or revocation of unescorted access 

authorization will: (1) be informed of the basis for denial or revocation of 

authorization for unescorted access; (2) have the opportunity to provide any 

additional information; and.(3) have the decision, together with any additional 

information, reviewed by another designated manager of the utility who is 

equivalent or senior to and independent of the individual who made the initial 

decision to deny or revoke unescorted access authorization. The determination 

from this review is final. An alternative review process which is independent 

and impartial is acceptable. Where applicable, grievance review procedures 

contained in collective bargaining agreements covering the bargaining unit of 

which the permanent employee is a member will meet this requirement and may be 

used for this purpose. If an alternative review process is used, the utility 

will include a description of the review process to be used in the procedures 

that meet this guideline. 

8.0 TRANSFER AND REINSTATEMENT OF UNESCORTED ACCESS AUTHORIZATION 

Transfer or reinstatement of unescorted access authorization requires 

verification of the individual's identity by the utility. 

8.1 Tran.fer 

An individual's unescorted access authorization granted by one utility 

in accordance with these guidelines may be transferred to another utility via 

correspondence, computer data transfer, or telecopy If the gaining utility; 

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

unescorted access authorization or had a valid unescorted access authorization 

The term permanent employee refers to a person who Is employed by a 

utility for an undefined term. It does not include employees who are 

temporarily hired for a specific project or other temporary work or 

who are hired under an employment contract with a defined term. 

10
which was terminated under favorable conditions within the previous 365 days; 

/ and (2) cross-checks information such as name, date of birth, social security 

number, sex, and other applicable physical characteristics for identification. 

In order to minimize problems associated with program variances for a transfer 

of a valid unescorted access authorization from one utility to another, all 

requirements are fulfilled as long as the minimum requirements of the Fitness

for-Duty Rule and the Access Authorization Rule are met. 

8.2 Reinstatement 

The utility may reinstate the unescorted access granted an individual 

if the individual returns to the same utility and unescorted access has not 

been interrupted for'a continuous period of more than 365 days and if the 

previous unescorted access was terminated under favorable conditions. 

8.3 Update ReQuirements 

A utility shall not authorize unescorted access where the individual's 

unescorted access 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 Section 6.2 or to the 

period when unescorted access was last held, whichever is less. A temporary 

unescorted access authorization (Section 6.4) may be issued while the background 

investigation update Is occurring. 

9.0 CONTINUAL BEHAVIORAL OBSERVATION PROGRAM (MBOP) 

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

This CBOP applies to all personnel who are granted unescorted access. The 

following must be included in the overall program: 

a. A program with the objective of assuring the detection 

of alcohol and drug abuse and other behavior that may 

be a potential threat to interrupt the normal operation 

2 of a nuclear reactor. 

11
b. A continual behavioral observation program that provides for 

management/supervisory personnel responsibility for observing 

personnel for behavioral traits and patterns that may reflect 

adversely on their trustworthiness or reliability and reporting 

those observations to appropriate utility management. 

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 suspected alcohol and 

drug abuse, which adversely reflects upon the individual's 

trustworthiness or reliability and to refer these persons to the 

utility'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. 

10.0 SCREENING DURING COLD SHUTDOWN 

10.1 Devitalization of Vital Areas 

During refueling or maintenance outages in which all or a part of a 

nuclear power plant is in-a cold shutdown, refueling, or devitalized status, 

the utility may grant unescorted access to the protected and devitalized areas 

for personnel who have not been granted unescorted access authorization in 

accordance with Section 6.0 providing that: 

a. Other requirements of the approved security plan remain in force, 

and the requirements of 10 CFR 73.55 and 10 CFR 73.57, as applicable, 

are followed for unscreened personnel granted unescorted access. 

b. Prior to start-up, a thorough visual inspection of the subject areas 

is made by knowledgeable plant personnel to identify signs of 

tampering or attempted sabotage.

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c. Appropriate procedures. are followed to assure that 

plant systems necessary for start-up and safe operation 

in the subject areas are functioning normally. 

11.0 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 amended 

security plan approval. 

12.0 CONTRACTOR AND VENDOR REOUIREMENTS 

The utility may accept the results of the entire unescorted access 

authorization 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 makes its records available for auditing by the licensee or its 

designated representative in accordance with Sections 13.0 and 14.0. The utility 

retains the ultimate responsibility for assuring that individuals granted 

unescorted access to the facility meet the requirements of the unescorted access 

authorization program. Utility unescorted access authorization programs are 

not intended to modify, subjugate, or abrogate any review rights that currently 

exist for contractor and vendor employees with their respective employers. 

13.0 EVALUATIONS AND AUDITS 

13.1 Utilitt Programs 

An independent evaluation of the unescorted access authorization 

program and its conformance to these guidelines must be made within 12 months 

of the effective date of implementation of the access authorization program. 

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 

.2 three years.

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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 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 recommendations, and corrective action must be provided to the sharing 

utility. 

14.0 RECORDS 

Utilities and contractors and vendors of utilities who conducted 

unescorted access authorization programs in accordance with these guidelines 

shall maintain actual data that establish: 

a. A background investigation and psychological evaluation were 

conducted for each person who is screened under Section 6.0 of 

these guidelines except documentation for a criminal history check 

which can only be maintained by a licensee. 

b. That other persons were granted unescorted access authorization in 

accordance with Section 11.0. 

c. Satisfaction with the conditions of Section 6.4 that 

resulted in the granting of a temporary unescorted 

access authorization. 

The utility, contractor, or vendor shall retain records for each person 

who is granted unescorted access authorization for a five-year period following 

termination of access authorization.

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

information for the purpose of processing unescorted 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 unescorted access.

is
Attachment A 

MINIJM 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 guidelines 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 

contractor conformance with these guidelines, the auditor shall randomly verify 

the following: 

1. Employment History 

Date the verification was made, complete dates of employment, 

position, disciplinary history, reason for termination, eligibility 

for rehire, and any other information which would adversely reflect 

upon the reliability and trustworthiness of the individual. The 

retrospective period for employment history must be reasonably 

attempted for five years; however, due to the nature of employment 

histories of some transient workers, a minimum period of three 

years Is required. 

2. Education 

Copies of transcripts, diplomas, etc., documentation which verifies 

all claimed attendance within the previous five years. In addition, 

the highest post high school attendance leading to a degree must

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be verified 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. Military History 

Date of receipt and copy of a Form DD214 or other military records 

from the National Personnel Records Center if military service 

was within the 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 of 

unescorted access and any follow up requests (e.g. those made at 

least every six months) shall be documented in the access authoriza

tion program files. 

4. Character References 

Dates of contact, names of references, association with applicant, 

period of association and any information relative 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 must contain two listed references and 

two developed references (not related to applicant) as a minimum. 

5. 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. 

6. Credit History 

Date of the credit check(s), name and location of credit bureau or 

other source, and results of Initial check(s). K

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B. PSYCHOLOGICAL EVALUATION

To reasonably assure contractor conformance concerning psychological 

evaluation the auditor must be concerned 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 qualified psychologist or psychiatrist 

and, if applicable, one who is licensed. 

C. CONTINUAL BEHAVIORAL OBSERVATION PROGRAM (CBOP) 

To reasonably assure contractor conformance concerning a CBOP, the auditor 

must review contractor's program to determine compliance with these guidelines, 

specifically to address that supervisors are provided appropriate training to 

recognize a degradation in work performance due to alcohol, and drug abuse, or 

other behavioral traits/patterns that may cause a threat to interrupt the normal 

operation of a nuclear reactor, and to report/refer persons displaying such 

behavior to the utility's management for appropriate evaluation and action. 

D. TEMPORARY UNESCORTED ACCESS AUTHORIZATION 

To reasonably assure contractor conformance concerning temporary unescorted 

access authorizations, the auditor must be concerned with completion dates for 

credit check, reference check, and psychological evaluation (within previous 

year from date unescorted access was granted). The auditor shall follow criteria 

set forth in Section A for credit history and character references and Section 

B for psychological evaluation. 

E. UPDATE REQUIREMENTS 

To reasonably assure contractor conformance concerning updating unescorted 

access authorizations when unescorted access authorizations have been interrupted 

for more than 365 days, the auditor must be concerned with the dates of psycho

logical evaluation and background investigation, and the retrospective period 

of the background Investigation must cover activities from the date of the

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previous background investigation not to exceed the retrospective period of 

Section 6.2 or the period when unescorted access was last held, whichever is 

less. The criteria listed in Section A and B must be met in updating unescorted 

access authorization. 

F. GRANDFATHERING 

To reasonably assure contractor conformance concerning grandfathering, the 

auditor must be concerned with the date of the previous unescorted access authori

zation to determine that the Individual held unescorted access authorization on 

the date security plan amendments in response to these guidelines were approved 

or was granted unescorted access authorization within the 365 days prior to the 

date of amended security plan approval. The auditor must 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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