University of California, Riverside

Human Resources



Fingerprinting & Criminal History Record Check


Individuals with Unescorted Access to Radioactive Material in Quantities of Concern
Fingerprinting & Criminal History Record Check
Campus Procedure

The U.S. Nuclear Regulatory Commission (USNRC) and the State of California have entered into an agreement pursuant to section 274b of the Atomic Energy Act, which identifies additional security requirements applicable to those individuals with unescorted access to radioactive material in quantities of concern.  This campus procedure is designed to ensure the additional requirements, specifically the requirements for fingerprinting and criminal history record checks are compliant with the agreement between the USNRC and the State of California.

  1. RELATED POLICIES & REFERENCES
  2. DEFINITIONS

    Agreement: An agreement between USNRC and State of California per section 274b of the Atomic Energy Act applicable to Licensees who have individuals with unescorted access to predetermined radioactive material in quantities of concern.

    California Radioactive Materials Licensee aka The Licensee: Those businesses, including the University of California, that are authorized to possess radioactive material in quantities of concern, as defined by Order of the California Department of Public Health dated June 5, 2008.

    Individual:  Any faculty, staff, student or visitors present on campus.

    Need-to-Know:  A determination, by a person having responsibility for protecting the Licensee’s sensitive information, that access to the sensitive information is necessary in the performance of official, contractual, or licensee duties of employment.

    Trustworthy & Reliability Official (TRO):  One or more UCR individual who is considered consistently dependable in judgment, character, performance, and does not constitute an unreasonable risk to the public health and safety.  The individual must be identified and deemed to be trustworthy & reliable in writing by the University.

  3. APPLICABILITY

    Any individual who has been identified by Environmental Health & Safety (EH & S) as someone who has a potential to have unescorted access to radioactive material in quantities of concern.

  4. PROCEDURES
    1. TRO Designation and Notification Requirements
      1. Human Resources will certify via a notarized oath & affirmation statement, that the individual(s) are deemed trustworthy & reliable and should be considered TRO(s).
      2. Human Resources will submit a letter to the NRC certifying that a TRO has been identified and deemed trustworthy and reliable. The letter should:
        1. Include a copy of the notarized TRO certification, specifically identifying the name of the individual designated as the TRO;
        2. Be marked with “Sensitive Security Related Information – Withhold from Public Disclosure”;
        3. Be sent to the:

          California Department of Public Health, Radiologic Health Branch
          Radioactive Material Licensing Section
          Increased Controls Program (ICP)
          MS 7610, P.O. Box 997414
          Sacramento, CA  95899-7414

      3. The TRO can then make determinations for other individuals who require unescorted access and are subject to the fingerprinting and criminal history record check requirements, or can designate other TRO(s) for the purpose of reviewing criminal history information.
      4. Certification via the notarized oath & affirmation statement and notification must be processed for each designated TRO.
    2. Fingerprinting & Criminal History Record Check
      1. EH & S will provide the names of individuals who may have unescorted access to radioactive material in quantities of concern to the TRO and will receive a positive determination from the TRO prior to the individual being allowed unescorted access.
      2. The TRO will ensure each applicable individual receives a copy of the California Department of Public Health Letter (June 5, 2008) on the Implementation of Fingerprinting and Criminal History Record Checks for Unescorted Access to Radioactive Material in Quantities of Concern prior to fingerprinting & criminal history record check processing.
      3. The Home Department will:
        1. Schedule an appointment with UCR Police Department for fingerprinting
        2. Prepare a check for $26 per employee (made out to U.S. Nuclear Regulatory Commission).  Note:  UCR Police Department fingerprinting processing charges will also be recharged to the home department.
        3. Ensure employee brings the $26 check to their fingerprinting appointment at UCR Police Department
      4. The Police department will:
        1. Process the fingerprints and criminal history record check per the Agreement;
        2. Submit the $26 check, a copy of the TRO Oath & Affirmation Certification with each submission of fingerprints to the NRC. This letter must specify the name(s) and address of the TRO(s) who will review the criminal history information from the FBI for a given lot of fingerprints.
      5. The TRO will:
        1. Evaluate the results of the fingerprinting/criminal history check, considering:
          1. results of the fingerprinting/criminal history check, using the Guidance for Evaluating FBI ID & Criminal History Record Checks for Allowing Unescorted Access to Certain Radioactive Material document and make a determination – (consult with the Police department in unusual situations)
        2. Review employee personnel file for existing employees
        3. Verify that employment verification and reference checks have been completed by the hiring authority.
        4. Document the results of the evaluation
        5. Notify the individual, the department and EH & S in writing of his/her findings
          1. If the findings are negative, the individual has a right to correct and complete the information, as follows:
            1. Prior to any final adverse determination, the TRO shall make available to the individual the contents of any criminal records obtained from the FBI for the purpose of assuring correct and complete information.  Written confirmation that the information was provided to the individual must be maintained.
            2. If the individual believes the information is incorrect or incomplete and wants to change, correct, or update the alleged deficiency, or to explain any matter in the record, the individual may initiate challenge procedures, including directly challenging the agency (i.e., law enforcement agency) that contributed the questioned information, or direct challenge as to the accuracy or completeness of any entry on the criminal history record to the Assistant Director, FBI.  The individual has ten (10) days from the date the records were provided to the individual to initiate the challenge.
            3. After investigating the challenge, the FBI makes any necessary changes and submits it’s findings to the TRO.
            4. The TRO makes a final unescorted access to certain radioactive material determination based on the correction of the record.
            5. If the final determination is adverse, the TRO shall provide the individual a documented basis for denial.
          2. The individual can still be employed by the University during the evaluation period and/or after a final adverse determination has been made provided he/she does not have unescorted access to radioactive materials in quantities of concern.
        6. Notify the local Radiologic Health Branch Inspection Office (714-257-2031 / 714-257-2025) or the Office of Emergency Services Warning Center (800-852-7550) within 24 hours if the individual is found to be in the FBI’s Terrorist Screening Data Base.
    3. File Access & Recordkeeping

      Human Resources will:

      1. Maintain confidential files which shall not be disclosed to anyone, except:
        1. The individual
        2. The individual’s designated representative
        3. The TRO(s)
        4. The USNRC
        5. Those individuals that have been determined to have a need-to-know status
      2. Maintain confidential files, including the results of the evaluation and all supporting materials for three (3) years post termination, at which time the records are to be completely destroyed.
      3. In the cases where the criminal history record check resulted in negative findings, the written confirmation that the information was provided to the individual must be maintained for one (1) year from the date of the notification.
    4. File Transfer

      The confidential file may be transferred to another campus if the individual makes a written request for the transfer.

    5. Responsibility
      1. Environmental Health & Safety
        1. Establish a method of identifying the individuals who may have unescorted access to radioactive material in quantities of concern, including those individuals who fill vacated positions.
        2. Provide the names of individuals who may have unescorted access to radioactive material in quantities of concern to the TRO.
        3. Maintain a list of the TRO findings for all individuals who may have unescorted access to radioactive material in quantities of concern.
      2. Human Resources
        1. Provide a copy of the California Department of Public Health Letter (June 5, 2008) on the Implementation of Fingerprinting and Criminal History Record Checks for Unescorted Access to Radioactive Material in Quantities of Concern to the individual.
        2. Initiate the fingerprint and criminal history record check process.
        3. Evaluate & document the results of the fingerprinting/criminal history check. Form
        4. Issue a final written determination to the individual, the department and EH & S.
        5. Maintain the required confidential files.
        6. Notify the local Radiologic Health Branch Inspection Office or the Office of Emergency Services Warning Center within 24 hours if the individual is found to be in the FBI’s Terrorist Screening Data Base.
      3. Police Department

        Process the fingerprints and criminal history record check per the Agreement, including submitting a copy of the TRO Oath & Affirmation Certification with each submission of fingerprints to the NRC.

      4. Home Department
        1. Ensure TRO has access to personnel file
        2. Prepare a check for $26 per employee (made out to U.S. Nuclear Regulatory Commission)

More Information

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Human Resources
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Tel: (951) 827-5588
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