September 28, 2006 TO: All Personnel Requiring Unescorted Access (Badging) FROM: Nuclear Security In-Processing Teams SUBJECT: In-Processing at all Exelon Nuclear Power Plants The following are the “Expectations and Requirements” for In-Processing (badging) of personnel at Exelon Nuclear Power Plants. The requirements apply to both outage and non- outage periods and will be strictly enforced. Requirements A. Not Currently Badged at any Exelon Site The site the individuals(s) will be in-processing at must have an “SY-AA-103- 511”, Attachment 1, submitted to the In-Processing Department no later than 2½ working days prior to the hire day (Examples: Wednesday at 10:30 a.m. for Monday hire days and Friday at 10:30 a.m. for Wednesday hire days). Individuals will not be processed without submittal on the appropriate form. (NO substituting personnel on start day of In-Processing) B. Currently Badged at any Exelon Site (Non-Outage) The site the individuals(s) will be in-processing at must have an “SY-AA-103- 511”, Attachment 1, submitted to the In-Processing Department no later than 1 FULL working day prior to the hire day. Individuals will not be processed without submittal on the appropriate form. (NO substituting personnel on start day of In-Processing) C. Identification All individuals MUST arrive with valid government issued picture identification. IF they do not arrive with this identification, activities will not start and the individual will be returned to the contractor. Expectations and Requirements 042804.doc D. Work History When an individual reports for In-Processing, proof MUST be shown that he/she has a 3-year work history or work history from last unescorted access. IF he/she does not bring this information, activities will not start and the individual will be returned to the contractor. E. In-Processing Activity Completion In-Processing activities for individuals that have met identification and work history requirements MUST complete ALL activities no later than 12:00p.m. on the first hire day. IF they are unable to complete all activities, In- Processing will cease and he/she will be returned to the contractor. It is at the contractors discretion to allow the individual to process on the next available hire day. The Site In-Processing Coordinator (Site Security Analyst) may make adjustments to the completion time during heavy hiring periods. The following are the activities that are required to be completed by 12p.m.: 1) Updated since last unescorted access or 3 Year Personal History Questionnaire (PHQ) 2) Fingerprint Form 3) Psychological Assessment 4) Pre-Access Drug Screen 5) Picture/Biometrics F. Fitness for Duty (FFD) 1) Individuals requiring a Pre-Access Drug Screen (urinalysis/breathalyzer) must fully cooperate with the testing process. Any refusal or deliberate attempt to evade the detection of substance abuse (subversion or adulteration) shall be considered a violation of the Exelon Fitness for Duty Program. A violation of this type may also be considered a trustworthy and reliability issue and additional sanctions may be imposed up to and including permanent denial of unescorted access. If an individual is pending results of the Pre- Access Drug Screen, he/she will be allowed to complete all training before being returned to the contractor for disposition of status, but will NOT be allowed to enter the PA as a visitor. 2) A first confirmed FFD violation for a contractor will result in immediate denial of unescorted access for a minimum of three years. After a three-year period, approval by the Medical Review Officer is required prior to reinstatement of unescorted access. A contractor who is seeking INITIAL unescorted access and has had a NON-NUCLEAR positive drug/alcohol test is not eligible to apply for unescorted access at an Exelon Nuclear Station until three (3) years have passed with NO drug/alcohol arrests or violations. Expectations and Requirements 042804.doc 3) Individuals will be assigned test times and it is imperative that they arrive promptly. Once the individual has entered the testing facility he/she cannot leave until all tests are completed. Failure to stay in the facility will be considered a refusal to test, and a violation of the FFD Program. G. Psychological Assessment Individuals requiring a psychological interview will be offered the opportunity to have one conducted. The individual will be notified that a psychological interview is required. If the individual refuses to submit to a psychological interview, Nuclear Security will place the individual on Temporary Hold and all activities will STOP. If the individual agrees to an interview, the individual will be scheduled for an interview with an Exelon Psychologist some time during his/her regularly scheduled activities. An access determination will be made immediately after the interview has been conducted. IF the Psychologist releases the individual, he/she will continue activities. If the Psychologist does not release the individual, all activities will STOP and he/she will be returned to the contractor. H. Court Documentation On day one, individuals MUST bring arrest documentation and/or including final court disposition for ANY arrest occurring within the last (5) years. IF additional documentation is required it MUST be submitted at the start of business on day two. IF the individual does not have the required documentation, activities will STOP and the individual will be returned to the contractor. Reviewing Official(s) will adjudicate documentation in accordance with the SAFEGUARD procedure SY-AA-103-507. I. Foreign Nationals 1. If a Foreign National has been badged at a PADS sites within the last year they must bring their work history since their last unescorted access. 2. If a Foreign National has not had unescorted access at a PADS site within the last year, he/she MUST bring the following information, or In- Processing activities will stop and he/she will be returned to the contractor. a) 3-Year Work History b) State or Government Issued Picture ID (If picture is on a valid Drivers License that may be sufficient) A Passport may also be requested. c) Financial Statement from an entity (e.g. Bank) within his/her country of record that is written or translated into the English language. Expectations and Requirements 042804.doc J. Fingerprints IF an individual has completed ALL activities including Training, but fingerprints have NOT been returned by the NRC/FBI, he/she will be returned to the contractor for disposition of status. K. N-GET / NEIT The individual must pass “Nuclear General Employee Training” (N-GET) and Nuclear Employee In-Processing Training (NEIT), with a score of 80% or better. (See Exelon procedures TQ-AA-118 and TQ-AA-102.) The individual must also successfully demonstrate the ability to don and remove protective clothing when required. Individuals will be allowed two (2) attempts at passing any section of N-GET or NEIT within a calendar quarter. After two failed attempts of RWT the individual will be placed on Temporary Hold and will not be allowed to have escorted access as a visitor. If there is any allegation of cheating on any test, Exelon Security will place the individual on Temporary Hold and all In-Processing activities will cease while the allegation is investigated. The individual may be denied UA pending investigation results. 1. N-GET Criteria a. If the individual has successfully completed N-GET within the past two (2) years at any nuclear facility, he/she will be eligible to Requal/Challenge the N-GET exam. If the individual is scheduled for Computer Based Training (CBT), the expectation is that the individual be familiar with the information and a short self-review is sufficient prior to testing. The paper Requal/Challenge will be used as the preferred means during heavy In- Processing and outage scheduling. Exelon reserves the right to schedule either means of Requal/Challenge accordingly. b. If the individual has not successfully completed N-GET within two (2) years of expiration, he/she will be required to complete the initial N-GET course. c. If Initial Rad Worker N-GET is required the individual will also be required to successfully complete Dress Out training. L. Hours of Operation In-Processing hours will be determined by each individual site and conveyed to various departments and Union Halls. Start times will be vigorously enforced. Once In-Processing activities have started (directions are being given), late individuals will not be processed unless the individual or the contractor has notified the Site In-Processing Coordinator. (i.e., car trouble, etc.) Expectations and Requirements 042804.doc M. Prior Unresolved In-Processing Issues All personnel that have been placed on Hold because “additional information” is required, (i.e., employment gaps, insufficient references, etc.), will not be allowed to process until the information requested by Nuclear Security has been received and verified. This process may take 5-10 business days. Individuals may call Nuclear Security Reviewers at the following numbers to address an issue: Site Reviewer Corporate # Site # Braidwood Rosario Khan (630) 657-2913 (815) 458-7518 Byron Tish Martin (630) 657-2926 (815) 406-2903 Clinton Tish Martin (630) 657-2926 (217) 937-3694 Dresden Rosario Khan (630) 657-2913 (815) 458-7518 LaSalle Rosario Khan (630) 657-2913 (815) 458-7518 Limerick Brenda Secrest (610) 765-5017 (610) 718-5121 Oyster Creek Brenda Secrest (610) 765-5017 (609) 971-4272 Peach Bottom Steve Henry (610) 765-5016 (717) 456-3473 Quad Cities Tish Martin (630) 657-2926 (309) 227-4913 SHC Steve Henry (610) 765-5016 (717) 456-3473 Three Mile Island Brenda Secrest (610) 765-5016 (610) 718-5121 Upon clearance by Nuclear Security the individual may process on the next In- Processing hire day, IF the contractor deems necessary. N. Badge Issuance As workers are approved for Unescorted Access, their security badges are fabricated and turned over to the Security Training Scheduler or designee, who will issue the badges after all training has been completed. (In the East, badges may be issued in the Gatehouse.) O. Out-Processing All personnel are responsible for following the Out-Processing Checklist (Procedure # SY-AA-103-518). Failure to check out properly may result in a security restriction for One (1) to five (5) years and may affect the individual’s ability to work within the nuclear industry. P. Non-Outage In-Processing Schedule During non-outage periods In-Processing will be held only on Monday each week. Sites may opt to rotate In-Processing with another site (i.e., Byron and Quad) during non-outage periods. If a holiday falls on a Monday, sites may cancel In-Processing that week. The Site In-Processing Coordinator will notify the site by placing an article in the station newspaper in advance. Expectations and Requirements 042804.doc Q. Outage In-Processing Schedule During outage In-Processing sites will process according to the “Standard In- Processing Schedule Template for Outages”. (See Attachment 2) Expectations A. When a contractor is processing more than ten (10) individuals in any given hire day, the expectation is that the contractor assigns one (1) cognizant person to interface with the Site In-Processing Coordinator should any problems arise. B. All individuals are expected to stay at the In-Processing Facility until the badging process is complete unless the contractor determines otherwise. ____________________________ Exelon Nuclear In-Processing Team Attachments Expectations and Requirements 042804.doc Attachment 1 Exelon In-Processing Checklist Listed below are items that individuals In-Processing at one of our Nuclear Facilities shall arrive with on their hire day. The following are items that are required: ™ State or Government Issued Picture ID (If picture is on a valid, e.g., not expired, etc. Drivers License that will be sufficient) ™ Social Security Card/Work Visa #/Naturalization Certification # ™ Location and date of last Unescorted Access to any nuclear station in the US ™ Education Institutions, city & state addresses, dates attended (information should include high school) ™ Four personal references (must be available for contact) ¾ Names, addresses & telephone numbers (day/evening) (References cannot be related to the individual or residing in their home) ™ Employment History (3 years or since last unescorted access) ¾ Company names, addresses & telephone numbers ¾ Dates employed (from & to) (Must include Month/Day/Year) ¾ Name of a contact person for each company ™ Unemployment Periods ¾ Dates Unemployed (From & To) (Must include Month/Day/Year) ¾ Must be verified by a personal reference (can be related) with a telephone number ™ Credit History ¾ Must List 1 creditor (VISA, Master Charge, etc.) and explain any credit difficulties. Foreign Nationals must bring in a credit report from Country of Origin. ™ Residences for Last 5 Years or since last unescorted access ™ Arrest Documentation ¾ All Arrests, since your 18th birthday, need to be reported (you may omit speeding tickets or parking offenses). • You Must Bring the Arresting papers & Final Court Disposition for any arrest occurring within the last 5 years. • If It Is a single DUI Arrest within 365 days, you must bring copies of the Arresting papers, the Court Disposition, the Evaluation by a Certified Addiction Counselor and any treatment requirements. • Any PENDING DUI Arrests must have a current Evaluation by a Certified Addiction Counselor. • You may be required to provide documentation for any arrest. ™ Fitness for Duty ¾ All persons must successfully pass a Pre-Access Drug & Alcohol Test All persons applying for Unescorted Access MUST Indicate: ♦ If you have ever been denied unescorted access at any nuclear power plant. ♦ If you have ever been removed from or made ineligible for unescorted access to any nuclear facility, Technical Support Center (TSC) or Emergency Operations Facility (EOF) for a violation of a Fitness For Duty Program. ♦ If you have violated an employer’s drug and alcohol testing program. ♦ If you have subverted or attempted to subvert a drug or alcohol testing program or refused to take a drug or alcohol test. ♦ If you have used, sold or possessed illegal drugs or abused illegal drugs. ♦ If you have had legal or employment action taken for alcohol or drug use. ♦ If you have been subjected to a plan for substance abuse treatment (except for self- referral) ♦ If you have tested positive for illegal drugs or use of alcohol that resulted in on duty impairment, or pre-employment testing. Expectations and Requirements 042804.doc Attachment 2 Standard In-Processing Schedule Template for Outages WEEK MONDAY TUESDAY WEDNESDAY THRUSDAY FRIDAY SATURDAY SUNDAY T-6 X T-5 X X T-4 X X T-3 X X T-2 X X* X X* X* T-1 X X* X X* X* X* X* T-0 (Unit comes down this week) X X Criteria for Hire Days 1) The preferable hire days for all individuals are Monday and Wednesday. 2) All Priority 1’s (not badged within last 365 days or never badged) must in-process on Monday or Wednesday, the Site In-Processing Coordinator and Maintenance Support Manager must approve any other days. 3) * Days other than Monday or Wednesday we can process Priority 2’s with the approval of the In-Processing Coordinator. When making a determination, the Coordinator should confer with the Lead Inprocessor, Lead Scheduler and Lead Badge Fab Supervisor to assure their organizations can handle the additional hires. 4) Walk-Ins must have approval of the Site In-Processing Coordinator and Maintenance Support Manager, but are NOT typically allowed 5) T-1 and T-0 weeks may change dependent upon dates unit comes down. Expectations and Requirements 042804.doc ATTACHMENT 3 PROBLEM ACTION(S) REQUIRED FOR INDIVIDUAL TO BE CONSIDERED FOR ACCESS DRUG AND ALCOHOL RELATED ISSUES Individual has a one or more DUI arrests and/or convictions or any pending DUI arrest: Individual must show up on site with disposition of court case and documentation of any effective chemical dependency evaluation by a Certified Additions Counselor* and/or treatment following each event. Individual has three (3) or more DUI arrests, resolved or unresolved: Individual may not be eligible for unescorted access. Contact the appropriate Exelon Security Reviewer prior to arriving on site to process. Individual has a non-nuclear Fitness for Duty violation. Individual must provide documentation of a Certified Addictions Counselor’s evaluation, completion/progress of treatment or rehabilitation prior to arriving on site to apply for unescorted access. In order to be approved, contact the appropriate Exelon Security Reviewer prior to showing up on site. Individual has ever been refused or discharged from employment for a violation of a Fitness for Duty Program. Individual must provide documentation of a Certified Addictions Counselor’s evaluation, completion/progress of treatment or rehabilitation prior to arriving on site to apply for unescorted access. Approval to be determined by Exelon Security Reviewer. Individual has been subjected to a plan for treating substance abuse except for self- referral for treatment over any period of time. Individual must show up on site with documentation of a Certified Addictions Counselor’s evaluation, completion/progress on treatment or rehabilitation. Approval to be determined by Exelon Security Reviewer. Individual has tested positive for illegal drugs or use of alcohol that resulted in on duty impairment. Individual must provide documentation of a Certified Addictions Counselor’s evaluation, completion/progress of treatment or rehabilitation prior to arriving on site to apply for unescorted access. In order to be approved, contact the appropriate Exelon Security Reviewer prior to showing up on site. PSYCHOLOGICAL ISSUES Individual requires a clinical interview due to results of the MMPI. Individual must have a clinical interview and the resulting evaluation must be favorable. Exelon will set up the appointment and cover the expense of the interview. Individual will be expected to comply with the instructions provided by Security. CRIMINAL HISTORY ISSUES Individual should be prepared to list all arrests (e.g., Criminal Charges, Convictions or Proceedings) since their 18th birthday or since their last unescorted access whether convicted or not convicted. Individuals should list all felony, misdemeanor, traffic or military criminal history to include court martials or non-judicial punishment. This includes guilty pleas and nolle contendere, any suspended sentences, pre-trial diversions, dismissals, nolle prosse, or first offender cases. (Individuals may omit speeding tickets or parking tickets) All alcohol related arrests must be listed. Individual must show up on site with documentation of disposition of court case(s) and may require an interview by Exelon Security. Documentation may be required for any arrest outside of the 5 year scope as deemed necessary by the Exelon Security Reviewer. Results of fingerprints from the FBI will be received prior to granting Unescorted Access. Expectations and Requirements 042804.doc ATTACHMENT 3, CONTINUED MISCELLANEOUS ISSUES Individual has other than “Honorable Discharge” from the Armed Services. Individual must contact the appropriate Exelon Security Reviewer for an interview and supply any additional information required. Individual has been denied access at any nuclear facility over any period of time. Individual must contact Exelon Security for an interview prior to individual’s arrival on site and supply any additional information required as appropriate by the Exelon Security Reviewer. CONTACT WITH EXELON SECURITY REIVEWER REQUIRED Probation, parole or work release. MUST contact the appropriate Exelon Security Reviewer prior to arrival on site. Individual has any Fitness for Duty violations, nuclear, non-nuclear or a combination of the two. MUST contact the appropriate Exelon Security Reviewer prior to arrival on site. Individual has any drug related arrests. MUST contact the appropriate Exelon Security Reviewer prior to arrival on site. Individual has an arrest and/or conviction for the sale, delivery or manufacture of illegal drugs. MUST contact the appropriate Exelon Security Reviewer prior to arrival on site. *Certified Addictions Counselors may be found in the yellow pages of your phone book or contact your nearest addictions center or hospital for referral. Expectations and Requirements 042804.doc ATTACHMENT 4 Food Products Can Cause Positive Drug Tests Recently a local newspaper article discussed the new marijuana-flavored lollipops that are showing up on the shelves of convenience stores around the country. These lollipops have such names as Purple Haze, Acapulco Gold and Rasta. The confections are legal because they are made with hemp oil, a common ingredient in health food, beauty supplies and other household products. The oil imparts marijuana’s grassy taste but not the high. Merchants are calling them a harmless novelty for adults. Due to this recent article we would like to remind you of the following: Health Food Stores are selling more and more products made from hemp, specifically hemp seed oil which boasts that it is a good source of omega fatty acids and will reduce cholesterol. Hemp can be found in salad oil, coffee, bakery goods, body lotions and beauty supplies. The Medical Review Officer (MRO), under the advice of the Federal Office of National Drug Control Policy and the American Association of Medical Review Officers, will not accept hemp product ingestion as an alternative medical explanation for a positive THC (marijuana) test. There are no additional tests to perform to determine if the positive derived from marijuana use or hemp product ingestion. While consuming products containing hemp seed oil create no psychoactive effect, the level of THC present would be high enough to cause a positive urinalysis test for marijuana. In addition to hemp, there is an herb named Kava Kava that is found in health food stores and has been used, like valerian root, as an over the counter “prescription” for stress relief. In April 2000, the State of California charged a man who had been drinking kava tea with a DUI because the drink made him impaired. Coca leaf tea contains cocaine in quantities sufficient to cause a positive test for cocaine, and the MRO will not accept coca leaf product ingestion as an alternative medical explanation for a positive cocaine test. Employees need to understand that each is responsible for her/his fitness and must be aware of the effects of each food, herb, or drug ingested. Just because a substance, food or health supplement is reported ‘good’ for you and is legal, does not mean it is wise or safe to take and operate machinery at work or at home. Individuals are responsible to read the labels and be aware of the foods they ingest. Expectations and Requirements 042804.doc Expectations and Requirements 042804.doc ATTACHMENT 4, CONTINUED If the person is going to try a new supplement, herb, health food, body building product: 1. Take the first few doses in a safe environment where the person can be observed and any unusual behavior or evidence of impairment noted. 2. Notify the family physician before using the product if the person is taking any other medication. 3. Discuss the product with the store salesman, in stores with trained staff, and read all the literature carefully before using the drug. 4. Understand that some health food products may cause a positive test at some companies depending on the technology. 5. THC from hemp products cannot be distinguished from THC from marijuana. 6. Poppy seeds contain morphine and codeine in quantities sufficient to cause a positive test for morphine and codeine depending on the technology. 7. Valerian root may cause a positive test for benzodiazepines (Valium-like drugs). 8. Some herbal compounds from other countries have measurable levels of arsenic and other harmful chemicals. 9. Coca leaf tea contains cocaine in quantities sufficient to cause a positive a positive test for cocaine. 10. Read the labels and ask questions before the product is purchased and certainly before the product is used. 11. Report all products and supplements ingested to the MRO, if tested, before the results come back. Please refer to SY-AA-102-208 “Notification of Fitness For Duty Test Results”, step 4.6.1 “The MRO will not accept the ingestion of hemp seed oil or other products containing hemp, including cookies or other baked goods, as an alternative reason for a positive test for marijuana.” This is also mentioned in NGET training.