Information Notice No. 88-91: Improper Administration and Control of Psychological Tests

                                  UNITED STATES
                          NUCLEAR REGULATORY COMMISSION
                      OFFICE OF NUCLEAR REACTOR REGULATION
                             WASHINGTON, D.C.  20555

                                November 22, 1988


Information Notice No. 88-91:  IMPROPER ADMINISTRATION AND CONTROL OF 
                                   PSYCHOLOGICAL TESTS 


Addressees:

All holders of operating licenses or construction permits for nuclear power 
reactors and all fuel cycle facility licensees who possess, use, import, 
export, or transport formula quantities of strategic special nuclear material.

Purpose:

This information notice is being provided to alert addressees to identified 
weaknesses in the administration and control of psychological tests used in 
personnel screening programs.  It is expected that recipients will review the 
information for applicability to their programs, including their contractor 
programs, and will consider actions, as appropriate, to avoid similar 
problems.  However, suggestions contained in this information notice do not 
constitute NRC requirements; therefore, no specific action or written response 
is required.

Description of Circumstances:

Recently there have been a number of reported incidents involving improper 
administration and control of psychological tests used to assist licensees in 
determining acceptability of candidates for unescorted access into pro-tected 
areas (PAs) and vital areas (VAs) of nuclear facilities.  

One incident involved a licensee who administered a modified version of a 
psychological test.  The licensee's modified test contained only 414 of 566 
questions required for the complete test.  When the licensee evaluated the 
modified test results, after adding an appropriate correction factor to ac-
count for grading questions that were not used in the modified test, an error 
rate of nearly 10 percent was found.  

In other cases, individuals were allowed to take onsite tests unproctored or 
were allowed to take the tests home to complete.  To date, 148 contractor 
employees have been retested as a result of identified unproctored tests.  One 
hundred of these individuals had already been granted unescorted access to PAs 
and VAs.  At least 49 of the 100 individuals required follow-up interviews 
with a psychologist.  Employment for 2 of the 49 individuals was subsequently 
terminated.  





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Discussion:

Requirements concerning psychological determinations for nuclear facility 
security personnel are indicated in 10 CFR Part 73, Appendix B.  Although no 
regulations specifically require employee screening at nuclear power plants, 
NRC published a statement in the Federal Register (42 FR 10836) on February 
24, 1977, recommending that "....applicants and licensees continue to use the 
employee screening guidance from the American National Standard, ANSI N18.17, 
'Industrial Security for Nuclear Power Plants'."  General expectations 
concerning the psychological testing of nuclear facility personnel are also 
published in ANSI/ANS 3.3-1982 and in Nuclear Management and Resources Council
(NUMARC) Industry Guidelines For Nuclear Power Plant Access Authorization 
Programs.  It is important that licensees choose measurement techniques and 
instruments that are highly reliable (i.e., produce consistent results) and 
valid (i.e., measure what they purport to measure).  NUREG/CR-2075, "Standards
for Psychological Assessment of Nuclear Facility Personnel," provides 
standards and criteria for assessing emotional instability as well as a 
description and analysis of some psychological testing methods and advances in
the state of the art.  Licensees are required to meet their commitments 
relating to psychological testing as specified in their license conditions.  

As indicated by the examples above, valid results cannot be assured from 
psychological tests unless these tests are properly administered.  It is 
important that recipients of this notice review their security screening 
programs, and those of their contractors, to ensure proper administration and 
control of test materials and testing environments.  Some of the actions taken
by licensees in response to improper administration and control of 
psychological tests include retesting in a controlled environment and 
suspension of unescorted access to PAs and VAs pending evaluation of 
retesting.  

Failure to ensure reliable and valid measurement techniques and instruments 
could compromise nuclear safety.  Enforcement action has been taken in recent 
events in which a licensee failed to meet security program plan commitments 
regarding administration of psychological tests.

No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical 
contact listed below or the Regional Administrator of the appropriate regional
office. 




                                   Charles E. Rossi, Director 
                                   Division of Operational Events Assessment 
                                   Office of Nuclear Reactor Regulation 

Technical Contact:  Nancy E. Ervin, NRR 
                    (301) 492-0946

Attachment:  List of Recently Issued NRC Information Notices 
.                                                            Attachment 
                                                            IN 88-91 
                                                            November 22, 1988 
                                                            Page 1 of 1

LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
_____________________________________________________________________________
Information                                  Date of 
Notice No._____Subject_______________________Issuance_______Issued to________

88-90          Unauthorized Removal of       11/22/88       All NRC licensees 
               Industrial Nuclear Gauges                    authorized to 
                                                            possess, use, 
                                                            manufacture, or 
                                                            distribute 
                                                            industrial nuclear 
                                                            gauges. 

88-89          Degradation of Kapton         11/21/88       All holders of OLs
               Electrical Insulation                        or CPs for nuclear
                                                            power reactors. 

88-88          Degradation of Westinghouse   11/16/88       All holders of OLs
               ARD Relays                                   or CPs for nuclear
                                                            power reactors. 

88-87          Pump Wear and Foreign         11/16/88       All holders of OLs
               Objects in Plant Piping                      or CPs for nuclear
               Systems                                      power reactors. 

86-106,        Feedwater Line Break          11/10/88       All holders of OLs
Supp. 3                                                     or CPs for nuclear
                                                            power reactors. 

88-86          Operating with Multiple       10/21/88       All holders of OLs
               Grounds in Direct Current                    or CPs for nuclear
               Distribution Systems                         power reactors. 

88-85          Broken Retaining Block        10/14/88       All holders of OLs
               Studs on Anchor Darling                      or CPs for nuclear
               Check Valves                                 power reactors. 

88-84          Defective Motor Shaft         10/20/88       All holders of OLs
               Keys in Limitorque Motor                     or CPs for nuclear
               Actuators                                    power reactors. 

88-83          Inadequate Testing of Relay   10/19/88       All holders of OLs
               Contacts in Safety-Related                   or CPs for nuclear
               Logic Systems                                power reactors. 

88-82          Torus Shells with Corrosion   10/14/88       All holders of OLs
               and Degraded Coatings in                     or CPs for BWRs. 
               BWR Containments 
_____________________________________________________________________________
OL = Operating License
CP = Construction Permit