Questions and Answers (Q&A) with Regards to Fingerprinting and Criminal History Records Checks
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Fingerprinting and Criminal Background Check Q&A UPDATED 16 April 2008 Questions and Answers (Q&A) with Regards to Fingerprinting and Criminal History Records Checks (including supplemental q&a) Modified for N.C Licensees Table of Contents No. QUESTION/TOPIC AREA PAGE No. 1. Information on how I would be required to respond to this notice when I receive it does not appear to be included with the implementing guidance? Will my response include sensitive information? 4 2. Why is the NRC/Agreement State now requiring fingerprinting and criminal history records checks as part of the Increased Controls trustworthiness and reliability requirements? 4 3. Does a National Agency Check (NAC) satisfy the provisions of the Order? 4 4. Can the Human Resources department be designated as the licensee’s Trustworthiness and Reliability (T&R) Officials to review criminal history records? Do they have to be fingerprinted to be able to review and approve others? 4 5. What is a Trustworthiness and Reliability (T&R) Official? Who can be a T&R Official? 4 6. Can I take my own fingerprints or can someone else at my company fingerprint me? 5 7. Can a notary act as a witness when I take my fingerprints? 5 8. Where can I have my fingerprints taken? 5 9. I was only provided a few fingerprint cards, where can I get more? 5 10. What information do I need to include on the card? 5 11. I was able to get more fingerprint cards from my local law enforcement agency, can I use those instead? 5 12. How can I make sure that my fingerprints are classifiable (readable)? 6 13. Who do I send my fingerprints to? 6 14. Is there a fee associated with the NRC/Agreement States processing the fingerprints? 6 15. What method of payment does the NRC accept? 6 16. My facility is currently not implementing the Increased Controls requirements because it does not possess radioactive materials quantities of concern. Can we implement the fingerprinting Order? 6 17. If I do not have the quantities of material in Table 1, in aggregate or individually, do I need to implement the requirements in this Order? 6 18. When are licensees required to submit fingerprints to the NRC/Agreement States? 6 19. Will guidance be provided on how to determine trustworthiness and reliability based on FBI identification and criminal history records checks? 6 20. Can employees continue to have unescorted access until they are approved or denied based on the results of their fingerprints? 7 21. My fingerprints have been returned several times as unclassifiable, can I get an extension to submit my fingerprints? 7 22. Our radioactive material is in a room where several people have unescorted access, even though they do not work directly with the radioactive material (i.e. custodial staff), do they need to be fingerprinted? 7 23. What does unescorted access to the material mean? 7 24. If I decide that based on a federal criminal records history check one of my employees previously granted unescorted access should not have unescorted access to radioactive material what actions can I take? 7 25. Does the denial of unescorted access create legal liability for the licensee? 7 26. At this time our Human Resources department make the trustworthy and reliability determination for unescorted access. Since they make this decision, do they need to be fingerprinted? 8 27. How far back do the criminal history record checks go? Can the NRC provide guidance on what types of information could be considered when granting unescorted access? 8 28. Is there a process to request an exemption from fingerprinting? Do employees that have been fingerprinted in the past need to be fingerprinted again? 8 29. Is fingerprinting meant to replace the trustworthiness and reliability determination? 9 30. How will compliance with the fingerprinting component be verified? 9 31. Is there financial aid or funding available to assist in the implementation of the fingerprinting requirements? Will the licensees be compensated in any way? 9 32. Will there be a reevaluation period? 9 33. The Order requires that the licensee shall provide under oath or affirmation a certification that the T&R Official is deemed trustworthy and reliable. What does it mean to submit documents to the NRC “under oath or affirmation”? 9 S1. Process for appointing T&R Officials who require unescorted access 10 S2. New hires and employees changing positions who require access 11 S3. Who can perform the task of fingerprinting? 11 S4. Initial T&R determination for licensee custodians, initiators, or applicants 12 S5. Certification of the Trustworthy and Reliability (T&R) Official 13 S6. The “YOUR NO. OCA” field of the fingerprinting card 13 S7. The “TCN” field when making payments on pay.gov 13 S8. Submitting fingerprints electronically to NRC 13 S9. Providing the Oath or Affirmation when submitting fingerprints electronically 14 S10. How the NRC processes fingerprint cards 14 S11. T&R Official certification for Agreement State Licensees 14 S12. Licensees under multiple jurisdictions 14 S13. Notifying North Carolina of an Individual on the Terrorist Screening Database 14 1. Information on how I would be required to respond to this notice when I receive it does not appear to be included with the implementing guidance? Will my response include sensitive information? For NRC Licensees, the information on how to respond to the NRC Order requiring implementation of the fingerprinting requirements is contained in the Order itself. For Agreement States Licensee, the information on how to respond will be provided separately by each Agreement State licensing organization, based on the method chosen to execute legally binding requirements. The NRC Orders are not considered sensitive information. Examples of previous Orders can be found by searching ADAMS or NRC’s website. Licensee responses to the fingerprinting Order is considered sensitive information and should be marked appropriately with “Withhold from Public Disclosure Under N.C.G.S. 104E-9(a)(4)”. 2. Why is the Agency now requiring fingerprinting and criminal history records checks as part of the Increased Controls trustworthiness and reliability requirements? The requirement for fingerprinting for unescorted access to radioactive materials quantities of concern was included in Section 652 of the Energy Policy Act of 2005. The NRC has determined that the requirement for fingerprinting should not wait for rulemaking and should be issued as Orders or legally binding requirements. 3. Does a National Agency Check (NAC) satisfy the provisions of the Order? If the NAC has been conducted within the past five calendar years and the employee can provide documentation of favorable results to the licensee’s T&R Official, then this would satisfy the provisions of the Order. 4. Can the Human Resources department be designated as the licensee’s Trustworthiness and Reliability (T&R) Officials to review criminal history records? Do they have to be fingerprinted to be able to review and approve others? The requirements for fingerprinting and criminal history records should be incorporated into the licensee’s current program of reviewing and approving background information of its employees. The duties of a T&R Official can be delegated to the Human Resources department or any other appropriate department as long as the individuals involved in the determining of an employee’s trustworthiness and reliability have been determined themselves to be trustworthy and reliable by the licensee. T&R Official shall only be fingerprinted if his/her duties require unescorted access to radioactive materials quantities of concern. 5. What is a Trustworthiness and Reliability (T&R) Official? Who can be a T&R Official? A T&R Official is an individual who the licensee determines to be trustworthy and reliable, based on the three minimum requirements for background checks of the Increased Controls (i.e., employment history, education, and personal references). Fingerprinting and criminal history checks are only needed if the T&R Official has, or will have, unescorted access to radioactive material quantities of concern. N  OTE: 6., 7., and 8., have been Superceded by Supplemental Q&A S3
6. Can I take my own fingerprints or can someone else at my company fingerprint me? Licensees cannot take their own employee fingerprints. Licensees must have their employee fingerprints taken by local law enforcement (or a private entity authorized to take fingerprints) because an authorized Official must certify the identity of the person being fingerprinted. 7. Can a notary act as a witness when I take my fingerprints? No, fingerprints must be taken by local law enforcement (or a private entity authorized to take fingerprints). 8. Where can I have my fingerprints taken? Most local law enforcement facilities can take your fingerprints. 9. I was only provided a few fingerprint cards, where can I get more? You can request more fingerprint cards by writing to the Office of Information Services, U.S. Nuclear Regulatory Commission, Washington, DC 20555, by calling (301) 415-5877, or by e-mail to forms@nrc.gov. 10. What information do I need to include on the card? Incomplete fingerprint cards will not be processed and will be returned to the licensee. Licensees need to include the following information on each card: a. Last name, first name, middle name b. Signature of person being fingerprinted c. Residence of person being fingerprinted d. Date e. Signature of official taking the fingerprints f. Employer and address g. Reason for being fingerprinted h. Aliases i. Citizenship j. Social security number and any of the other corresponding numbers requested on the card if applicable k. Date of birth l. Place of birth m. Sex
n. Race o. Height p. Weight q. Eye color r. Hair color
Director, Division of Facilities and Security U.S. NRC Two White Flint North 11545 Rockville Pike Rockville, MD 20852-2738
The current fee to process each fingerprint card is a $36.00 per card. Additional fees may be charged by the entity taking the fingerprints. 15. What method of payment does the NRC accept? The NRC only accepts electronic payments through http://www.pay.gov. Please refer to the instructions on the Order for details on how to pay electronically. 16. My facility is currently not implementing the Increased Controls requirements because it does not possess radioactive materials quantities of concern. Can we implement the fingerprinting Order? No. The requirements of Section 149 of the Atomic Energy Act only apply to facilities that have radioactive materials in quantities of concern, as identified by the Commission. 17. If I do not have the quantities of material in Table 1, in aggregate or individually, do I need to implement the requirements in this Order? No. Implementation is only required if you possess radioactive material quantities of concern (i.e., at or above the thresholds of Table 1) individually or in aggregate. You may request that your license be amended to lower your possession limits below the Table 1 quantity so that requirements are not applicable. If you anticipate that you will exceed the Table 1 quantities, in aggregate or individually, you must implement the Increased Controls requirements (EA-05-090) and fingerprinting requirements prior to actual possession of the material. 18. When are licensees required to submit fingerprints to the NRC? Licensees are required to fingerprint and review the criminal history results for all individuals who currently have, or will require, unescorted access to radioactive materials quantities of concern to the NRC within 180 days after the license is amended. 19. Will guidance be provided on how to determine trustworthiness and reliability based on FBI identification and criminal history records checks? Guidance is included with the Order documents; however, it will ultimately be the decision of the licensee’s T&R Official to determine whether an individual should be granted unescorted access to the radioactive material, based on the results of the criminal records history check, and the other trustworthiness and reliability requirements of the Increased Controls. 20. Can employees continue to have unescorted access until they are approved or denied based on the results of their fingerprints? During the implementation period (i.e., up to 180 days after the license is amended) employees who have unescorted access at the time the Order is issued may continue to have unescorted access in accordance with the requirements of the Increased Controls until they are fingerprinted and continued access is approved or denied based on the review of their FBI identification and criminal history record. After the expiration of the implementation period, no one may have unescorted access until they are fingerprinted and receive approval from the T&R Official based upon a review of their FBI identification and criminal history record. 21. My fingerprints have been returned several times as unclassifiable, can I get an extension to submit my fingerprints? On a rare case that a licensee needs additional time to implement the fingerprinting requirements beyond the 180-day implementation time, the Agency (in consultation with the NRC) will consider granting extensions only on a case by case basis. Licensees must take the appropriate actions to minimize any potential impacts in delays from receiving the criminal history results from the NRC. In a rare case that an extension is needed, the request must be date-stamped before the deadline to implement the requirements and must include the licensee’s justification as to why additional time is needed beyond the 180-day implementation period and the appropriate compensatory actions that will be implemented until the fingerprints are processed. 22. Our radioactive material is in a room where several people have unescorted access, even though they do not work directly with the radioactive material (i.e. custodial staff), do they need to be fingerprinted? Yes. Other personnel (both licensee and non-licensee) that have job duties that require unescorted access to the room where the materials are used or stored must be fingerprinted and determined to be trustworthy and reliable by the T&R Official based on the evaluation of the individual’s criminal history record and the other trustworthiness and reliability requirements of the Increased Controls. 23. What does unescorted access to the material mean? Unescorted access to the material means that an individual can exert some physical control over the material or device while they are alone. 24. If I decide that based on a federal criminal records history check one of my employees previously granted unescorted access should not have unescorted access to radioactive material what actions can I take? The licensee is ultimately responsible to determine the best course of action. 25. Does the denial of unescorted access create legal liability for the licensee? The NRC and Agreement States acknowledge that employer liability potentially exists through the process for determining trustworthiness and reliability, just as employer liability potentially exists throughout the hiring process. A finding that results in denying someone employment may be actionable on the part of the employee/employee candidate, and this is no different. 26. At this time our Human Resources department make the trustworthy and reliability determination for unescorted access. Since they make this decision, do they need to be fingerprinted? Only individuals that have unescorted access to radioactive materials quantities of concern are required to be fingerprinted. Therefore, individuals that make trustworthy and reliability determinations that do not have unescorted access do not need to be fingerprinted. However, they are still required to be determined trustworthy and reliable per the requirements in the Increased Control Order (EA-05-090). 27. How far back do the criminal history record checks go? Can the NRC provide guidance on what types of information could be considered when granting unescorted access? The criminal history records check provides information on all arrests since the individual’s eighteenth birthday. Guidance on criminal offenses that could be considered is included with the Order. However, the list of offenses is not inclusive. There may be additional offenses not listed in the guidance that the licensee wants to consider as part of unescorted access approval process. It is the licensee’s ultimate business decision as to what criteria it uses for the bases of the trustworthiness and reliability determination. 28. Is there a process to request an exemption from fingerprinting? Do employees that have been fingerprinted in the past need to be fingerprinted again? Fingerprints for unescorted access need not be taken if an employed individual (e.g., a Licensee employee, contractor, manufacturer, or supplier) is relieved from the fingerprinting requirement by 10 CFR § 73.61, or any person who has been favorably-decided by a U.S. Government program involving fingerprinting and an FBI identification and criminal history records check (e.g., National Agency Check, Transportation Worker Identification Credentials in accordance with 49 CFR Part 1572, Bureau of Alcohol Tobacco Firearms and Explosives background checks and clearances in accordance with 27 CFR Part 555, Health and Human Services security risk assessments for possession and use of select agents and toxins in accordance with 42 CFR Part 73, Hazardous Material security threat assessment for hazardous material endorsement to commercial drivers license in accordance with 49 CFR Part 1572, Customs and Border Patrol’s Free and Secure Trade Program1 within the last five (5) calendar years, or any person who has an active federal security clearance (provided in the latter two cases that they make available the appropriate documentation2). Written confirmation from the Agency/employer which granted the federal security clearance or reviewed the FBI criminal history records results based upon a fingerprint identification check must be provided. The Licensee must retain this documentation for a period of three (3) years from the date the individual no longer requires unescorted access to certain radioactive material associated with the Licensee’s activities. 29. Is fingerprinting meant to replace the trustworthiness and reliability determination? No, fingerprinting is only one component of the trustworthiness and reliability determination. A trustworthiness and reliability determination should be based, at a minimum, by verifying employment history, education personal references and a federal criminal history check. All four of these components need to be considered when making a T&R determination. 30. How will compliance with the fingerprinting component be verified? Compliance will be verified at the time the licensee’s trustworthiness and reliability program is inspected by the Agency. 31. Is there financial aid or funding available to assist in the implementation of the fingerprinting requirements? Will the licensees be compensated in any way? The NRC will not provide financial aid and there is no funding available to assist in the implementation of the fingerprinting requirements. 32. Will there be a re-evaluation period? At the moment there is no reevaluation period. The re-evaluation of criminal history records will be addressed during the NRC’s (and ultimately North Carolina’s) rulemaking process. 33. The Order requires that the licensee shall provide under oath or affirmation a certification that the T&R Official is deemed trustworthy and reliable. What does it mean to submit documents to the NRC “under oath or affirmation”? The requirement to submit documents to the NRC or Agency under oath or affirmation may be satisfied by using a notary public to authenticate oaths or affirmations and to certify that the information provided is correct and true. An alternate method for complying with the oath or affirmation requirement is presented in the United States Code, Title 28, Section 1746 (28 USC 1746). This method allows use of the following unsworn declaration to satisfy the oath or affirmation requirement: I declare [or certify, verify, state] under penalty of perjury that the foregoing is true and correct. Executed on [date] [Signature] When applying this declaration, it must be used verbatim. Licensing documents accompanied by this unsworn declaration satisfy the requirement that such documents be submitted under oath or affirmation. S1. What is the process for appointing a Trustworthiness and Reliability (T&R) Official if they require unescorted access to radioactive materials? Section II, Paragraph A.2 of Agency document “Fingerprinting and Criminal Background Check Requirements for Unescorted Access to Certain Radioactive Material” states: “Within ninety (90) days of the date of this Order, the Licensee shall provide under oath or affirmation, a certification that the Trustworthiness and Reliability (T&R) Official (an individual with the responsibility to determine the trustworthiness and reliability of another individual requiring unescorted access to the radioactive materials identified in Attachment 2) is deemed trustworthy and reliable by the Licensee as required in paragraph B.2 of this Order.” Paragraph B.2 states in part: “If the T&R Official requires unescorted access, the Licensee must consider the results of fingerprinting and the review of an FBI identification and criminal history records check as a component in approving a T&R Official.” The Licensee must also consider the three minimum requirements of the Increased Controls (i.e. employment history, education and, personal references) in approving a T&R official. Procedure for appointing a T&R Official who requires unescorted access to radioactive material: Step 1: The Licensee should submit one completed, legible standard fingerprint card (Form FD-258, ORIMDNRCOOOZ) for the individual nominated to be the T&R Official and who requires unescorted access to radioactive materials. Step 2: Submit to the NRC’s Division of Facilities and Security, 11545 Rockville Pike, ATTN: Criminal History Program, Mail Stop T-6E46, Rockville, MD 20852. Overnight mail is preferred. Step 3: Include the name and address of the individual to whom the nominated T&R Official’s criminal history records should be returned for review. The results and information should be reviewed by someone other than the nominated T&R Official and should be the individual who will be submitting the certification under oath and affirmation. The reviewer would preferably be the same person who initially approved the T&R Official for the original Increased Controls requirements, but may be the custodian or initiator of the license. Step 4: Once the NRC receives the FBI identification and criminal history records check results, it will forward the results to the individual identified in Step 3. Step 5: Once the Licensee receives the information, they should consider the results of the fingerprinting along with the trustworthiness and reliability requirements of IC. 1. of the Increased Controls Order (EA-05-090 or applicable license condition) in determining the trustworthiness and reliability of the T&R Official. Step 6: If the nominated T&R Official is deemed trustworthy and reliable by the licensee, the licensee must submit to the NRC, under oath or affirmation, a certification that the named T&R Official is deemed trustworthy and reliable as required by Order EA-07-305. The requirement to submit documents to the NRC under oath or affirmation may be satisfied by using a notary public to authenticate oaths or affirmations and to certify that the information provided is correct and true. An alternate method for complying with the oath or affirmation requirement is presented in the United States Code, Title 28, Section 1746 (28 USC 1746). This method allows use of the following unsworn declaration to satisfy the oath or affirmation requirement: I declare [or certify, verify, state] under penalty of perjury that the foregoing is true and correct. Executed on [date] [Signature] When applying this declaration, it must be used verbatim. Licensing documents accompanied by this un-sworn declaration satisfy the requirement that such documents be submitted under oath or affirmation. The initial certification must be submitted to the NRC within ninety (90) days of the date of the Agency letter dated March 20, 2008 via one of the acceptable methods specified in the letter. Certifications should be addressed to: I.C. Coordinator, Radioactive Materials Branch, 1645 MSC, Raleigh, NC 27699-1645. In addition, a copy of this certification must be submitted with all subsequent fingerprints submitted to the NRC. Additionally, each time a new T&R Official is appointed, a new certification must be provided with the next submittal to the Agency. S2. Can additional employees (e.g., new hires or existing employees changing positions within the company who did NOT have unescorted access prior to the date of the Order) be granted unescorted access to radioactive materials quantities of concern prior to the establishment of a fingerprinting program and certification that the Trustworthiness and Reliability Official is deemed trustworthy and reliable? No. Prior to being granted unescorted access to material, all additional employees the licensee identifies after the Agency letter dated March 20, 2008 as requiring unescorted access, must be determined to be trustworthy and reliable based upon the requirements of the Increased Controls and the review of their FBI identification and criminal history records. The license condition also requires that within 90 days of the date of the Order that licensees establish a fingerprinting program and provide under oath or affirmation a certification that the Trustworthiness and Reliability Official (T&R Official) is deemed trustworthy and reliable by the licensee. Only after the T&R Official has been certified to be trustworthy and reliable, can the T&R Official make trustworthiness and reliability determinations for any employee who requires unescorted access after the issuance of the Agency letter of March 20, 2008. Each submittal of fingerprints to the NRC must be accompanied with a copy of this certification. See question 33 and supplemental question S1 for guidance on appointing and certifying a Trustworthiness and Reliability Official. **This Q&A (S3) supersedes Q&As 6, 7, and 8 above** S3. Who can perform the task of fingerprinting for my employees? Licensees must have their fingerprints taken by an authorized official, such as a representative from a local law enforcement agency. However, an authorized official, for the purposes of taking fingerprints, could be available through private entities, contractors, or an established on-site fingerprinting program. If a licensee has fingerprints taken at a facility other than that of a recognized Federal, State, or local law enforcement agency, the licensee should ensure that the prints are taken legibly and match the identity of the individual named on the fingerprint card. In these cases, the individual taking fingerprints should at a minimum: 1) Be trained to take fingerprints (Training to take fingerprints is offered through the FBI, or may be available from local law enforcement agencies and some professional associations.); 2) Verify the identity of the individual being fingerprinted by checking a government-issued picture identification (e.g. a passport or driver’s license) and that the name on the card matches the government issued identification. 3) Sign the block on the fingerprint card labeled “SIGNATURE OF OFFICIAL TAKING THE FINGERPRINTS.” The licensee must ensure that complete and accurate information is provided in accordance with 10 CFR 30.9. available at: http://www.nrc.gov/reading-rm/doc-collections/cfr/part030/part030-0009.html For additional related information, also see Q&A 9, 10, 11, Section III “Specific Requirements Pertaining to Fingerprinting and Criminal History Records Checks” and Section IV “Procedures for Processing Fingerprint Checks,” of Agency document entitled “Fingerprinting and Criminal Background Check Requirements for Unescorted Access to Certain Radioactive Material”. **This Q&A (S3) supersedes Q&As 6, 7, and 8 above** S4. How is the initial trustworthiness and reliability (T&R) determination and certification made (based on fingerprints and a criminal history record check) if the individual to be designated as the T&R official is also the license custodian, initiator, or applicant, and has unescorted access? In most cases, there will be no one within an organization or company, above the custodian or initiator of a license (“licensee”), previously determined trustworthy and reliable for purposes of evaluating background check and criminal history information and making the initial determination as to whether a designated T&R official is trustworthy and reliable. Within the licensing process, there are a series of screening criteria used by the reviewer to assess information regarding the applicant. The purpose of the screening criteria is to provide reasonable assurance that radioactive material will be used as intended. The fact that a regulatory authority, using established processes, has authorized the individual applicant to possess radioactive material quantities of concern provides the basis for allowing the applicant to appoint T&R officials. Where the licensee or applicant requires unescorted access and intends to designate himself or herself as the T&R Official, the licensee or applicant should submit fingerprints to the NRC and indicate that the results of the criminal history record check be returned directly to him or her, specifying the appropriate address. Once the criminal history information has been received by the licensee or applicant, the results must be reviewed and filed by the licensee or applicant and made available to NRC inspectors for ensuring compliance with the fingerprinting requirements. The licensee or applicant must then submit a letter to the NRC certifying under oath and affirmation that he or she is the initial T&R official for the license. The licensee or applicant can then make T&R determinations for other employees who require unescorted access subject to the fingerprinting requirements, or designate other T&R officials for the purpose of reviewing criminal history information. A letter certifying a T&R official under oath and affirmation must accompany each additional submission of fingerprints to the NRC. This letter must specify the name(s) and address of the T&R official(s) who will review the criminal history information from the FBI for a given lot of fingerprints. S5. Must the certification for the Trustworthiness and Reliability (T&R) Official required by Section II, Paragraph A.2. of Agency document “Fingerprinting and Criminal Background Check Requirements for Unescorted Access to Certain Radioactive Material” specifically identify the T&R Official by name, or can it apply generically to the position within the company that is designated as the T&R Official (e.g., the Security Officer or a Human Resources position)? The certification that the T&R Official is deemed trustworthy and reliable must specifically identify the name or names of the individual(s) designated as the T&R Official(s). This applies to the initial certification required by Section II, Paragraph A.2. as noted above and the certification provided with each fingerprint submission required by Section III, Item 4. of the “Specific Requirements Pertaining to Fingerprinting and Criminal History Records Checks.” If the licensee has designated multiple individuals to serve as the T&R Official, the licensee may either provide separate certifications for each T&R Official, or provide a single certification that identifies each of the T&R Officials by name. The certification provided with each fingerprint submission need only identify the T&R Official to whom the licensee specifies the results should be returned (see Section IV, Item 3 “Procedures for Processing Fingerprint Checks”). A copy of the initial certification is acceptable if it includes the name of the specified T&R Official. If the name of the T&R Official changes, a new certification must be prepared that includes the name of the new T&R Official and be provided the next time fingerprints are submitted. S6. When completing the fingerprint cards, NRC Licensees should use their NRC docket number in the field “YOUR NO. OCA.” Since Agreement State Licensees do not have NRC docket numbers, what should they use to complete the field? Agreement State Licensees should use their two letter State abbreviation followed by a dash and the Licensee’s license number (e.g. CA-123456). S7. When making a payment to the NRC through Pay.gov for processing of fingerprints, Pay.gov requires a TCN. What is a TCN and what information should go in this field? TCN stands for “Transaction Control Number” and it identifies payment for the processing of fingerprints for any given individual. The TCN is a tool for Licensees to track their submissions and may include any number of identifying information that would be useful for that purpose. For instance, Licensees can include the names of one or more individuals for whom payment is being made, Licensee’s name and/or date of submittal. S8. Can I submit my fingerprints electronically to the NRC? Yes. Some Licensees may choose to make arrangement with the NRC to submit fingerprints electronically to the NRC. However, for many Licensees this option may be prohibitive, due to the cost associated with the purchase of electronic fingerprinting equipment. To establish an electronic fingerprinting program with the NRC, please contact NRC’s Facility Security Branch at 301-415-6511. Please note that electronic submission of fingerprints to the NRC must come directly from the Licensee. S9. If I submit fingerprints electronically, how should I provide an electronic copy of the oath or affirmation that is required to accompany each submission? Copies of oaths or affirmations can be submitted by fax to 301-415-5118 or by email sent to Doreen.Turner@nrc.gov with a “.pdf” format attached. Each submittal should indicate the names of the individuals for whom the oath or affirmation is being provided. S10. What happens to the fingerprint cards after the NRC receives it from the Licensee? The NRC scans the fingerprint cards to transmit to the FBI electronically. The cards are retained and secured for approximately a month after which time they are destroyed in accordance with federal guidelines. S11. Does the initial Trustworthiness and Reliability Official certification go to the Agreement State for Licensees in Agreement States? Yes. Agreement State Licensees will implement fingerprinting requirements in response to a State’s legally binding requirements, such as license conditions. The Agreement State Licensees must submit their initial Trustworthiness and Reliability Official certification to the State regulatory authority or licensing agency that imposed the requirements. S12. How should large companies that are licensed in multiple jurisdictions respond to the fingerprinting requirements? The fingerprinting requirements are imposed based on the license, not the company. If a company holds multiple licenses subject to the fingerprinting requirements, it must respond for each license. For example, if a company holds two NRC licenses, it must respond for both licenses. If convenient, the company may submit a combined response covering both licenses, but the response must address each of the licenses (i.e., “Joe Smith, RSO for both of our licenses, will serve as the T&R Official for both licenses XX-XXXXX-01 and XX-XXXXX-02.”) Companies licensed in multiple jurisdictions must respond to each jurisdiction in which it holds a license subject to the fingerprinting requirements. S13. Whom should I notify if the results from a FBI identification and criminal history records check indicate that an individual is identified on the FBI’s Terrorist Screening Database? North Carolina licensees are required to notify the Radioactive Materials Branch (RMB) within 24 hours after discovery as noted in the table below:
North Carolina licensees should not call the NRC Operations Center to report this information. 1 The FAST program is a cooperative effort between the Bureau of Customs and Border Patrol and the governments of Canada and Mexico to coordinate processes for the clearance of commercial shipments at the U.S. - Canada and U.S. - Mexico borders. Participants in the FAST program, which requires successful completion of a background records check, may receive expedited entrance privileges at the northern and southern borders. 2 This documentation must allow the T&R Official to verify that the individual has fulfilled the unescorted access requirements of Section 149 of the AEA by submitting to fingerprinting and an FBI identification and criminal history records check. Directory: rms -> docs rms -> Tubb, K. B., & Brodie, N. (editors), 2001. Illicit Antiquities rms -> Ceremony in the Royal Castle in Warsaw on the 50th Anniversary of the Convention of 14th May 1954 on the Protection of Cultural Property in the Event of Armed rms -> Review of the Convention for the Protection of Cultural Property in rms -> Male Female I am: Single Married Engaged Divorced Other rms -> Create charts with the headings "Greece" and "Rome" and five additional rows. They should label the rows with the following terms: houses, clothing, food, tools, and water. Research rms -> Best Biography / Autobiography for College-Bound Middle and High School Students rms -> Newton’s Laws Internet Scavenger Hunt Explore the links below for an introduction to Sir Isaac Newton and his accomplishments in the scientific world. Answer the questions that go along with each of the websites using complete sentences docs -> Fingerprinting and criminal background check requirements for unescorted access to certain radioactive material Download 85.6 Kb. Share with your friends:
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