• If the fourth submission is returned as unclassifiable, the licensee should submit six additional fingerprint cards to the NRC for the individual. All six cards will be forwarded to the FBI, which will select the best quality prints from each card to make a complete set of fingerprints. An additional processing fee is required, which covers the processing of all six fingerprint cards but does not include an additional resubmission. • If the FBI is unable to obtain classifiable fingerprints from the six cards based on conditions other than poor quality (e.g., medical conditions or physical anomalies that prevent the taking of readable prints), then the NRC will automatically request a background check based on a name search for the individual and will forward the results to the licensee. name search-based FBI identification and criminal history records check as a component in determining the trustworthiness and reliability of the individual in accordance with 10 CFR 73.38(e). 6.3.4. Verification of True Identity Licensees shall, as required by 10 CFR 73.38(d)(4), verify the true identity of an individual applying for unescorted access to SNF in transit to ensure that the individual is who he or she claims to be. The licensee shall review official identification documents (e.g., driver’s license, passport, Immigration and Naturalization Service Form I-9 (if applicable), Government identification, birth certificate issued by a State, province, or country of birth) and compare the documents to personal information data the individual provided to identify any discrepancy in the information. The licensee should verify identity in the following ways: • Compare a valid (not expired) official photo identification (e.g., driver’s license, passport, Government identification) with physical characteristics of the individual. • Cross-check and compare pertinent data from the background investigation with information supplied by the applicant (e.g., Social Security number, date of birth, physical characteristics of the individual). Section 73.38(d)(4) requires the licensee to document the type, expiration, and identification number of the identification or maintain a photocopy of identifying documents on file under 10 CFR 73.38(c), certify and affirm in writing that the identification was properly reviewed and maintain the certification and all related documents for review during NRC inspections. 6.3.5. Employment History Evaluation Section 73.38(d)(5) requires the licensee to document the employment history of the individual seeking unescorted access to SNF in transit. The evaluation shall consist of contacts with previous employers and should include the following information: • verification of claimed periods of employment or unemployment of 30 days or more • verification of periods of self-employment by reasonable methods (e.g., tax records, customers, coworkers) • No further submissions will be required and the licensee may consider the results of the
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