ML20027C077
| ML20027C077 | |
| Person / Time | |
|---|---|
| Issue date: | 10/06/1982 |
| From: | Norry P, Scott R NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | |
| Shared Package | |
| ML20027C071 | List: |
| References | |
| OMB-3150-0002, OMB-3150-2, NUDOCS 8210120383 | |
| Download: ML20027C077 (18) | |
Text
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REQUECT FOR Of.*B REVIEW (Under the Papera ork Reductice Ac' and bccutive OrJct 1 29:)
Import:nt - Ra d mstructions (SF-83 A) before completing this 0:f:ce c,f Inf ormation and Mwiatn y Aff airs form Submit the cautred number of copies of SF 83.togetner Of tice of Manaaer"ent uts %dqc' with th3 material f or whlCh revtew is requested to.
Washington.D C 20503
- 1. Department / Agency and Bureau / Office onginating request 3 Name(s) and telephone numbertd of person (s) who can best U.S. Nuclear Regulatory Comission R*." Y C $ El b "* h k "4 N - U l'1 2.6-digit Agency / Bureau number (firstpart of 11 digit Treasury 4.3-digit f unctional code (last part of 11-argit Treasury Account Account No)
No.)
_3_ _1.._5 _.0 _ _
L _2 _ _ft
- 5. Tstis of information Collection or Ruf emaking C. Is tnts a rutemanong suomission under Section 3504th) of P.L.96-511 ? (Check one) 10 CFR 73, Physical Protection of 1xxNo <section 3so7 submission)
Plants and Materials 20 Yes NPRM. Expected date ot oubiication
- 6. A. ls any mtormation coIIection (reporting or recor0 keeping) 3 O Yes. final ru\\e. Expectea cate ct pubiicatnon involved ? (Check one)
Ef tectave catc 1 EX Yes and proposal as attached for review D. At what Dhase of rulemakingis this submission made?
(Check onel 2 O Yes but proposalis not attached - skip to ouestion D 3 0 No - skip to cuestion D 1XXNot applicabic B Ara the respondents primanly educationalagencies or 2 0 Manor rule. at NPRM stage institutoOns oris the purpose related to feoeral education 3 0 Major Final rule for whsch no NrRM was oubiished programs ?
4 O Major Final rule atter publication of NPRM O Yes KI No s O Nonma nr rule.at NPRM stage 6 O Nonmaior ruie. at Final stage a
COMPLETE SHADED PORTION IFINFORMATION COLLECTION PROPOSAL!S ATTACHED 7.Currsnt (or former) OM B Number 8 Hequested 12 Agency report form number (si 3150-0002 Expaation Date N/A Espiration Date 13 Are r.tspendents only Federat agencies?
1 5/,31L83.
5/.31/.8%
O Yes b No
- 9. ls prcposed informatica ccilection listed in 11 T ype at reauest (ChecA one) the information collectic n budget'?
tX Yes O No 1 O preiiminaf y phn
- 10. Wili tnts proposed information collection 2 O ww motprnmustyamma n'nmes mom man e -rems cause the agency to exceed its infor nation acol collection tiudget allowanc.e 7 (t/ yes, attach O Yes EX No 3 (X revis;cn amendment request 1 om & gcncy head I 4 a e,,,ns,on tatustme-f to tuwn onty1
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- 11. Number of repcrt forms submitted for approal 5 0 citens on eno chargd None 6 0 reinstaterrent tenpirea wtino t. months I 1 s.
le classification of Cr.snoein Burden leuptarn on supportung statement) e ruovormate sete nt on...me m uer..e, N/A NO Cf bespon!FS No of Rept np Hours Cost to the PubhC e sirne..:"'"
N/A
- a. In inventory 389 I
50d17 5
__JZL O67 101,8.11 I5 e 5lg,u;eeret b As proposed ncord 6 eeper, pe' v"'
169
- c. Dif ference (b-a)
__ 876,628
_ __51_,694 5
d riipons annually Dy each Explanation of d.fference (indicate as many as appfyl Varies Adjustments
- 0. Tot;linnvoi responses d conecuan-enor l _,
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+
tem esc.13,i 877,067 e conectionestimate 1 i
15 f r.,,m eeo..e,.,e 876,6L8 51.69.4 "T**#"'"
memome Varies
- f. Change in use i
f 4 s Program changes e E stim;tec totelhoves ennausi bu'*" '"
l+
+$
- g. increase 4
rese t vene 101,811
- h. Decrease l-
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Standard Form 83 (Rev.3-81) * <
t 8210120383 821008 PDR ORG EU90MB For use Beginning 4enst PDR
' 17 Abstr:ct-Nccds cnd Uses (50 words cricss)
Lic'nsees ara reqair::d to provid; information to ensura that an adequate level f
cf protection is provided for nuclear facilities and materials.
- 18. Ret:ted report form (s) (psve OMB number (sl. IRCN(s).
i2o Catalog of Federal Domestic Assistance Program Number Int:rnal agency report form number (s} or symbol (s))
yjg N/A 121. smail business or organization O Yes X No
. 19. Type of affected public (Check as manyas apply) 122. Type of activity of af fected public-indicate 3-digit Standard
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l lo."' check 1 O individuals orhouseholds O Multiple or O All 2 O state orlocalgovernments 3O farms I
e C businesses or otherinstitutions (except farms) l
_B.
1 9_
- 23. Brief description ot affected public le g." retail grocery stores."" State education agencies.' " households on S0 taroest SMS A s")
Nuclear facility licensees 24 Purpose (Check as many as apply. If more than one. indicate
- 26. Collection method (Check as many as appsy' pr: dominant by an asterisk) 1 Q mail self-administered
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1 O application for benefits 2 O other self-administerec 2 O program evaluation 3O telephoneinterview 4
- 3 0 generalpurpose statistics 4 O persona:interviev.
4 JO regulatory or compliance 5 0t recoroneeping requirement 5 O program planning or management Required retention periodVar_ies_ years 6 O research 6 O other-describe 25 Frecuencyof Use 127 Cottection agent (Check cU ~
t O Nonrecurring j
1 X requesting Department ~Acency Recurring / heck as many as apply >
O cther Federal Departr ent< Agency C
2 :X on occasion 6 O semiannually 3 O crivate contractor 3 O weekly 70 annualls 4 O recordkeepmg reauirement l
5 O other-descrice.
4 O monthly 80 bienniatif 5 O quarterly 90 otner-cescribe-28 Authority for agency for information collection ci 30 Do you promise confidebahty?
rullmaking-indicate statute. regulation. judicial decree.
(11 yes. explain basis for pleave Atomic Energy Act of 1954
'" # "9 '* * "" "
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as amended j 31. Will the proposed information Collect Cn Create a new or become part of an existing Privacy Act system of records" 29 Respondent's obligation to repiy (Check as many as apply)
(11 yes attach FeacralRegester notice orproposed craf:cf 1 O voluntary notice 1 O Yes DCNo 2 O required to obtain or retain benefit
- 32. Cost to Federal GovernmenicI 3 CX mandatory-cite statute, not CFR (attach copy of information collection or rulemaking s 960 0_0_0 1
statutory authority)
COMPLETE ITEMS 33 THRU 35 ONLY lF RULEM AKING SUBMISSION 33 Compliance costs to the public
! 34. Is there a regulatory impact
- 35. ls there a statutory or Judicial analysis attached?
deadline af fecting issuance?
s O Yes O No O Yes. Enter date O No CERTIFICATION BY AUTHORIZED OFFICI ALS SUBMITTING REOUEST-We certif y that it'e information collection or rulematung submitted for -
review is necessary for the proper performance of the agency's f unctions. that the proposal represents the minimum Dublic burden ar'd Federal ccs consct:nt mt5 need. and is consistent with apphcable OMB and agency policy directives. Signature and title of
- APPROVING POL, Y OFFICIAL FoR AGE Ncv DATE SUBuli fiNG OH sci AL cATL b
h/
/o-rfr3-s
- i. i Patricia G. Norry
- R.' StepherhScot't' '
O, d' Y, ' -
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SUPPORTING STATEMENT FOR 10 CFR PART 73
" PHYSICAL PROTECTION OF PLANTS & MATERIALS" A. 1.
Justification (i) 10 CFR Part 73 contains numerous reportino, recordkeeping, and application requirements, including requirements for submittal of security plans, security recordkeeping reouirements for compliance purposes, and security reporting and notification procedures for compliance and response purposes.
In _all cases, the requirements are necessary to help ensure that an
-adequate level of protection is provided for nuclear facilities and material.
Essentially, all of the reporting requirements are' necessary for one of the three reasons listed below:
f 1)
Information describing the content and planned operation of the licensee's physical protection system (e.g., Security Plan or Contingency Plan) - Essential data for NRC decision of adequacy of licensee's planned. system in meeting regulatory requirements.
g 2)
Information describing the normal operation of the physical protection system (e.g., access authorizations, equipment performance logs)
Essential data for NRC assurance that the physical protection system operates in accordance with the regulatory requirements.
3)
Information notifying the NRC of the occurrence of and circumstances concerning abnormal events (e.g., Report of Theft, Sabtoage. or Overdue Shipment) - Essential data to provide fulfillment of NRC 6-responsibilities to respond, investigate, and correct situations which adversely affect public' health and safety or the common defense and security.
The currently effective information collection requirements of 10 CFR Part 73 are identified and explained below:
73.20(c)(1) Revised Protection Plan. The plans required by this section are used to review the adequacy of a licensee's intended security system, and serve as an enforceable document for enforcement and compliance purposes. The submittal is necessary for an initial review of a licensee's intended security system upgrade efforts required by the more stringent regulations effective 3/25/80.
73.24(b)(1) Shipment Logs, General. The information ik necessary to ensure that there are not two or more shipments of special' nuclear inaterial in transit at the same time which together would enstitute a formula quantity, and to ensure verification of arrival of the shipments.
73.25(b)(1)-(3) Restrict Access and Activities, Transportation. These procedures are.to restrict access to and activity in the vicinity of '
transports and strategic special nuclear material in order to protect that material while in transit.
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t 2t 73.25(c)(1)-(4) Unauthorized Entry or Unauthorized Materials.
These procedures are to prevent or delay unauthorized entry or introduction of unauthorized materials into, and unauthorized removal of, strategic special nuclear material from transports in order to protect that material while in transit.
73.25(d)(1)-(4) Respond to Safe' guards Contingencies, Transportation.
These procedures are to assure proper response to safeguards contingencies and emergencies in order to engage and impede adversary forces until local law enforcement fortas arrive in order to protect strategic special nuclear material while in transit.
73.26(b)(3) Security Arrangements. This infonnation is required in order for NRC to assure compliance with the safeguards transportation protection plan.
73.26(d)(3)(i) Written Security Procedures. Assures compliance with I
the safeguards transportation protection plan.
73.26(d)(3)(ii) Written Approval. Assures that responsible individual complies with the safeguards transportation security plan.
73.26(d)(4) Security Training. Assures that security organization members are properly qualified in accordance with the safeguards transpor-
_.tation protection plan.
i 73.26(e)(1) Safeguards Contingency Plan. The purpose of this plan is to assure the adequacy of the licensee's response to different ccntingencies as required by the safeguards transportation security plan.
73.26(h)(6) Transportation Security. The review assures the program is up to date and that documentation is retained for five years.
73.26(i)(S) Convoy Communication. This is a procedure required of the licensee responsible for protecting the in-transit material to assure timely notification to NRC of any missing material so that a trace investigation may be started.
73.26(k)(4) Rail Shipment Lost Material Report. This is a procedure required of the licensee responsible for protecting the in-transit material to assure timely notification to NRC of any missing material so that a trace investigation may be started.
73.27(a)(1) Departure Notification. This assures that the consignee will comply with the safeguards transportation protection plan.
73.27(a)(2) Arrival Notification. This is a procedure required of the licensee responsible for protecting the in-transit material to assure timely notification'to NRC of any missing material so that a trace
~ investigation may be started.
73.27(b) No'tification to NRC. This is a procedure required of the licensee responsible for protecting the in-transit material to assure timely notification to NRC of any missing material so that a trace investigation may be started.
3 73.27(c) Lost Haterial Report. This is a procedure required of the licensee responsible for protecting the in-transit material to assure timely notification to NRC of any missing material so that a trace investigation may be started.
73.37(b)(2) Spent Fuel Shipment Damage. Assures adequacy of the licensee's response to different spent t,uel shipment contingencies as required by the safeguards transportation security plan.
73.37(b)(3) Spent Fuel Shipment Instructions. Assures adequacy of the license's response to ditferent spent fuel shipment contingencies as required by the safeguards transportation security plan.
73.37(b)(5) Spent Fuel Shipment Log. Maintenance of a written log will serve as an inspectable record oy which effectiveness can be assessed and performance measured.
73.37(b)(7) Advance Approval. This is a procedure to assure adequacy of the licensee's selection of routes for spent fuel shipments.
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73.40(b) Contingency Plan for Fixed Sites. The purpose of this report is to provide a written record of the licensee's plans for dealing with contingencies as outiined in Appendix C to 10 CFR Part 73. The plan is used in the licensing approval process to ensure sufficient scope and depth in the contingency planning area and also serves as a compliance benchmark during the inspection process.
73.40(c)(2) Detail Site Procedures. This information is required in
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order for NRC to assure compliance with the fixed site security contingency plan.
73.40(d) Independent Audit of Fixed Site Contingency Plan. This require-ment establishes an annual audit of the fixed site contingency plan and requires documentation to be kept for,two years.
73.45(b)(2)(i),(ii) Access Authorization Controls. These procedures are required in order for NRC to assure compliance with the fixed site physical protection plan.
73.45(c)(1)(1),(iii) Detection Unauthorized Activities. These procedures are required in order for NRC to assure compliance wilh the fixed site
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physical protection plan.
73.45(d)(1)(i)-(iv) Detection Unauthorized Placement. These procedures are required in order for NRC to assure compliance with the fixed site physical protection plan.
73.45(e)(1)(ii) Detection Unauthorized Removal. These procedures are required in order for NRC to assure compliance with the fixed site physical protection plan.
73.45(e)(2)(i)-(iii) Confirm Quantities of SNM. These procedures are required in order for NRG to assure compliance with the fixed site physical protection plan.
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1 73.45(f)(1)(ii) Unauthorized Access Assessment. These procedures are I
required in order for NRC to assure compliance with the fixed site physical protection plan.
73.45(f)(2)(i),(ii) Unauthorized Access Attempts. These procedures are required in order for NRC to assure compliance with the fixed site physical protection plan.
73.45(g)(2) Response Plan. The purpose of this plan is to assure the adequacy of the licensee's response to different contingencies as required by the fixed site physical protection plan.
73.46(b)(1) Security Organization.
In event contractor is used for security force, this requirement assures that the licensee will infom the contractor of his responsibilities. In addition, these requirements are essential for NRC to assure compliance with the fixed site physical S
protection plan.
73.46(b)(3)(i) Security Procedurer. This record keeping equirement is part of a management system required of licensees to document the structure of the security organization and describe the functions of the organization's components.
It also serves as an inspectable record by which effectiveness can be assessed and performance measured.
~ "73.46(b)(3)(ii) Organization Written Approval. These procedures are
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required in order for NRC to assure compliance with the fixed site
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physical protection plan.
73.46(b)(4) Requalification Record, Fixed Site. The purpose of this requirement Ts to prcvide a record of security force requalification as required by Appendix B of 10 CFR Part 73. This record serves as inspectable verification that requalification has occurred and also documents individual requalification perfomances.
73.46(d)(3) Access Control Procedures. These procedures are required in order for NRC to assure compliance with the fixed site physical protection plan.
73.46(d)(10) Container Examination. These procedures :are required in order for NRC to assure compliance with the fixed site physical protection plan.
73.46(d)(11) Verify Container Contents. These procedures are required in order for NRC to assure compliance with the fixed site physical protection plan.
73.46(d)(13) Visitor's Log. All escorted visitors entering a.. facility
. are required to supply identification infomation in response to this requirement. This 'infomation is necessary in order to determine who had access and serves _as an inspectable document to verify that access control requirements are met.. It can also facilitate any subsequent investigation of irregular events.
73.46(g)(5) Service Notification. These procedures are required in order for NRC to assure compliance with the fixed site physical protection plan.
73.46(g)(6) Independent Audit of Fixed Site Security Program. This requirement establishes an annual audit of the fixed site security systen, which must be documented and retained for five years. The purpose of this audit is to ensure that security system perfomance is independently assessed periodically. Such an assessment provides the licensee with a self-correction mechanism.
73.46(h)(1) Contingency Plan for Fixed Sites. The purpose of this report is to provide a written record of licensee's plans for dealing The with contingencies, as outlined in Appendix C to 10 CFR Part 73.
plan is used in the licensing approval process to ensure sufficient-scope and depth in the contingency planning area and also serves as a compliance g
benchmark during the inspection process.
73.46(h)(2) Documentation of LLEA Arrangements. Licensees are required to establish and document a response agreement with local law enforcement authorities. The agreement is used to verify law enforcement response capabilities and to ensure a clear understanding by both parties of what is expected and what will be provided in the way of law enforcement
... assistance-in case of an emergency. The document also serves as verifica- -
. tion of compliance with the requiremdht.
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73.46(h)(3) Armed Personnel. These procedures are required in order for NRC to assure compliance with the fixed site physical protection plan.
73.50(a)(3) Security Documentation. The written security procedures serve as an inspectable record by which effectiveness can be assessed and pefomance r;easured.
73.50(a)(4) Spent Fuel Security Force Requalification. The purpose of this requirement is to provide a record of security force requalification, as required by Appendix B of 10 CFR Part 73. This record serves as inspectable verification that requalification has occurred and also documents individual requalification procedures.
73.50(c)(5) Information Registrat h - All escorted visitors entering a facility are required to supply itification information in response to this requirement. This infoma i is necessary in order to detemine who had access and serves as an insg.ctable document to verify that access control requirements are met. It can also facilitate any subsequent investigation of irregular events.
- 73.50(g)(1) Safeguards Contingency Plan. The purpose of this report is to provi_de a written record of -licensee's plans for dealing with contingencies.
The plan is used in licensing approval process to ensure sufficient scope and depth in the contingency planning area and also serves as a compliance benchmark during the inspection process.
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73.50(g)(2) LLEA Arrangement for Spent Fuel Storage Facilities.
Identical to 73.46(h)(2).
(Different group of licensees) 73.50(h) Update Guard Qualification and Training Plan. This section requires preparation of a plan (submitted for NRC approval) for spent fuel storage facility security forces training and qualification. It serves as the basis for NRC assessments of licensee adequacy in security force training and qualification areas and serves as an inspection criterion in verifying licensee performance.
73.55(b)(1) Reactor Security Organization. In event contractor is used for security force, this requirement assures that the licensee will inform the contractor of his responsibilities.
In addition, these requirements are essential for NRC to assure compliance with the reactor physical protection plan.
b 73.55(b)(3)(i) Security Procedures, Reactors. Justification is identical to that for 73.46(b)(3)(i).
(Different group of licensees) 73.55(b)(3)(ii) Reactor Procedures Approval. The written approval is required in order for NRC to assure compliance with the reactor physical protection plan.
.. - - - --73.'55(b)(4) Requalification Record, Reactors. The purpose of this requirement is to provide a record of security force requalification, as required by Appendix B of 10 CFR Part 73. Thi's record serves as inspectable verification that requalification has occurred and also documents individual requalification procedures.
73.55(d)(6) Visitor's Log.
All escorted visitors entering a facility are requi ed to supply identification,information in response to this requirement. This information is necessary in order to determine who had access and serves as an inspectable document to verify that access control requirements are met.
It can also facilitate any subsequent investigation of irregular events.
73.55(g) Independent Audit Review, Reactors. This requirement establishes an' annual. audit of the power reactor security system,,which must be l-documented and retained for five years. The purpose of this audit is to ensure that security system performance is independently assessed periodi-cally. Such an assessment provides the licensee with a self-correction mechanism.
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7 73.55(h)(2) Reactor Liaison LLEA. The agreement is used to verify law enforcement response capabilities and to ensure a clear understanding by both parties of what is expected and what will be provided in the way of law enforcement assistance in case of an emergency. The document also serves as verification of compliance with the requirement.
73.67(c)(1) Security Plan. This is a document prepared by the licensee to describe the security systems and procedure proposed to meet the I
applicable safeguard regirements in the Code of Federal Regulations.
Security plans are justified on the basis that they:
(1) allow the NRC to make a determination as to the adequacy and completeness of a licensee's-proposed safeguards system, and (2) provide documentation of. a satisfactory safeguards system which can be inspected by the NRC.
73.67(d)(ll) Class II Response Procedures. This assures that the licensee has developed procedures for dealing with contingencies regarding threats or thefts of special nuclear material of moderate strategic significance while at a fixed site.
73.67(e)(1)(1) Class II Advance Shipment Notification. This is a procedure used to alert the intended receiver of an impending shipment of SNM of moderate or low startegic significance. The following types of information are provided: (1) mode of transport, (2) estimated time of arrival, (3) location for transferring material, (4) name of carrier, and (5) transport identification. Advance shipment notification is justified on the basis that it: (1) requires the shipper to preplan the transportat. ion of the material, (2) requires that the receiver be alerted to an impending shipment and the needed information for assuring proper receipt, and (3) helps ensure traceability of any. missing material.
73.67(e)(1)(ii) Class II Receiver Confirmation. This is a procedure used to ensure that the receiver is aware of the impending shipment at the planned time and location and has acknowledged the mode of transport.
Receiver confirmation is justifieC in,that it helps the shipper to be assured that the receiver is ready to accept the shipment of material at the time, location and mode of transport indicated. This helps assure positive control of the material at all transfer points.
73.67(e)(2)(ii) Class II Receiver Notification. This is a standard report form which the licensee must complete and send to the shipper within 10 days of accepting receipt of the material. Receiver notification is justified in that it: (1) ensures that knowledge of the current location of all SNM is available, and (2) formally informs the shipper that the material has been received.
73.67(e)(3)(iv) Class II In-transit Response Procedures. This assures that the licensee has developed procedures for dealing with contingencies regarding threats or thefts of special nuclear material of moderate strategic significance while in-transit.
73.67(e)(3)(v) Class II Arrival Notification. This is a procedure used for notifying the licensee responsible for in-transit physical protection that the material either arrived safely or is missing. Notification of arrival is justified in that it gives the responsible licensee a firm basis for initiating a trace. investigation in the event a shipment beccmes delayed or lost.
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73.67(e)(3)(vi) Class II Trace Investigation. This is a procedure required of the licensee responsible for protecting the in-transit material for notifying the NRC of any missing material and the steps
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initiated to recover it. Lost material notification is justified in that it ensures that the NRC, the shipper, or the receiver, as appropriate, are notified as soon as possible of any missing material. This allows them to use their available resources to begin a trace investigation.
73.67(e)(4) Class II Exporter Requirements. The justification is similar to that of 73.6/te)(1)(1), /3.6/te)(1)(fi), and 73.67(e)(3)(vi) but shipper is exporting material.
73.67(e)(5)(i) Class II Importer Requirements. The justification is similar to that of 73.67(e)(1), 73.67(e)(2)(ii), and 73.67(e)(3)(vi) but receiver is importing material.
73.67(e)(5)(ii) Class II Exporter Notification. This is a procedure required of importer for infonning exporter of receipt of the material.
Exporter notification is justified in that it ensures that the exporter will receive notification of receipt of material.
73.67(e)(6)(i) Class II Additional Information. This notification provides the NRC with advance notice of scheduled shipments that may be
_ _necessary in order to do a proper review of shipment details.
73.67(e)(6)(ii) Class II NRC Notification. This notification provides the NRC with proper notice that a shipment has arrived.
73.67(f)(4) Class III Fixed Site Response. This assures that the licensee has developed procedures for dealing with contingencies regarding threats or thefts of special nuclear material-of low strategic significance while in-transit.
73.67(g)(1)(i) Class III Advance Shipment Notification. This is a procedure used to alert the intended receiver of an impending shipment of SNM of low strategic significance. The following types of infonnation are provided:
(1) mode of transport, (2) estimated time of arrival, (3) location for transferring material, (4) name of carrier, and (5) transport identification. Advance shipment notification is justified on.the basis that it:
(1) requires the shipper to preplan the transportation of the material, (2) requires that the receiver be alerted to an impending shipment and the needed information for assuring proper receipt, and (3) helps ensure traceability of any missing material.
73.67(g)(1)(ii) Class III Receiver Confirmation. This is a procedure used to ensure that the receiver is aware of the impending shipment at the planned time and location and has acknowledged the mode of transport.
Receiver confirmation is justified in that it helps the shipper to be assured that the recei.ver is ready to accept the shipment of material at the time,. location and mode of transport indicated. This helps assure
- positive control of the material'at all transfer points.
9 73.67(g)(2)(ii) Class III Receiver Notification. This is a standard report fom which the licensee must complete and send to the shipper within 10 days of accepting receipt of the material. Receiver notification is justified in that it:
(1) ensures that, knowledge of the current location of all SNM is available, and (2) formally informs the shipper that the mattrial has been received.
73.67(g)(3)(i) Class III In-transit Response. This assures that the licensee has' developed procedures for dealing with contingencies regarding threats or thefts of special nuclear material of low strategic significance while in-transit.
73.67(g)(3)(ii) Class III Arrival Notification. This is a procedure used for notifying the licensee responsible for in-transit physical protection that the material either has arrived safely or is missing. Notification of arrival is justified in that it gives the responsible licensee a firm basis i
for initiating a trace investigation in the event a shipment becomes delayed or lost.
73.67(g)(3)(iii) Class III Trace Investigation. This is a procedure required of the licensee responsible for protecting the in-transit material for notifying the NRC of any missing material and the steps initiated to recover it. Lost material notification is justified in that it ensures that
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"the NRC, the shipper, or the receiver as appropriate, are notified as soon v
as possible of any missing material. This allows them to use their available resources to begin a trace investigation.
73.67(g)(4) Class III Exporter Requirements. The justification is similar to that of 73.67(g)(1)(i), 73.67(g)(1)(ii) and 73.67(g)(3)(vi) but shipper is exporting material of low strategic significance.
73.67(g)(5)(1) Class III Importer Requirements.
The justification is similar to that of 73.67(g)(1), 73.67(g)(2)(ii), and 73.67(g)(3)(vi) but receiver is importing material of low strategic significance.
73.67(g)(5)(ii) Class III Exporter Notification. This is procedure required of importer for infoming exporter of receipt of material of low strategic significance. Exporter notification is justified in that it ensures that the exporter will receive notification of receipt of the material.
73.70(a) Record of Authorized Individuals. This documentation serves as a means of. identifying those who have responsibility for surveillance of
- SNM, and of minimizing the number of individuals with such reponsibility. It serves to establish facts concerning who could have had access if an investi-gation proves necessary and serves as a means of verification for inspection purposes in seeing that designation and access control procedures are being properly conducted.
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10 73.70(b) Record of Access Authorization. This record serves to provide formal access control authorization for access to vital and meterial areas.
It serves as verification that access control requirements are being met and serves to minimize the number of individuals with such access.
73.70(c) Visitor's Log. This' requirement reiterates that of 73.55(d)(6).
Justification is identical (Different group of licensees affected).
73.70(d) Access Log for Unoccupied Vital Areas. This. record serves as a means for establishing and verifying who had access to vital. areas. It serves as an inspection tool to access licensee performance in minimizing unnecessary access and can provide data to aid subsequent investigation of an irregular event.
73.70(e) Documentation of Test and Maintenance This requirement provides a record of test and maintenance and is used to ensure that the frequency of tests and prompt maintenance of failures is verifiable by inspection. It
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also serves to provide a maintenance history of equipment useful in evaluating operating performance.
73.70(f) Alarm Documentation This document provides verfication that alarms are operating properly, that licensees respond properly, and that operational checks are conducted in accordance with the regulations.
It is also useful for evaluating the long tenn reliability of aamrm systems.
73.70(g) Record of SNM Shipment Details. The purpose of this requirement ~
is to assure that the licensee maintains records concerning the shipment of SNM. Such records are valuable in verifying information reported to the NRC and provide an audit trail and experience base for evaluating the transporta-tion process at a later time. Such records also serve as a part of the material control system in their role as a record of bulk inventory change at any given plant.
73.70(h) Access Procedure Documentation. This recordkeeping requirement serves to aid access control and lock and key control. It is an inspectable record of the licensee's. performance in minimizing access and providing adequate control of key and lock operations.
73'.71(a). Trace Investigation. This requirement calls.for immediate telephone notification to NRC, reporting the results of a. trace ~ investigation of an unaccounted for shipment, and also requires a followup written report to NRC. This information serves as an essential initial statement of facts concerning an unaccounted for shipment and for subsequent ir.vestigation and recovery efforts.
sw 4
a.-
['.
11 73.71(b) Theft Rennrt. This report serves as notification to NRC that an incident has occurred and establishes initial facts necessary for subsequent investigation.
73.7)(c) NRC Event Report. The report serves as notification to NRC that an event has occurred which significantly threatens or lessens the effectiveness of a licensee's physical security system. This establishes initial facts necessary for a subsequent investigation if required.
73.72 Advance Notice of Shipment. This notification provides the NRC advance notice of scheduled shipments and details their itinerary.
It is used to allow review time of shipment details, schedule appropriate monitoring of the shipment, and serves as a means to verify shipment details during the inspection process.
Part 73, Appendix B General Criteria for Security Personnel. This appendix sets the minimum requirements for security personnel.
It serves as a basis to assure licensee adequacy in security force training and qualification 4'
areas and also serves as an inspection criterion in verifying licensee performance.
Part 73, Appendix C Licensee Safeguards Contingency Plans. This appendix
-sets the minimum requirements for licensee safeguards contingency plans.
The plans are used in the licensing approval process to ensure sufficient scope and depth in the contingency planning area and also serve as a compli-ance benchmark during the inspection process.
~
For all of the above there is no duplication with any other Federal Agency reporting requirements.. For all of the reports, the reporting time of each should be less than 1/2 hour.,For each of the reports, the respondent is not required to submit more than three copies of the response.
2.
Description of Information Collection.
The reporting requirements of 10 CFR Part 73 affect approximately 169 licensees. The information collection requirements do not involve surveys. The licensees either make the reports available.at their place of business or send the reports to NRC at its headquarters or regional office. Reports are only required as occasioned by the occurrence of-specified events such as the receipt or transfer of licensed material or actual or attempted theft of licensed material, or for checking the licensee's procedures. Other requirements involve the submission of safeguard information in connection with applications for the issuance, renewal or amendment of a license. No information of a personal nature is requested or collected. The information submitted to NRC by licensees in response to the application, recordkeeping and reporting requirements is available for public inspection in accordance with 10 CFR Part 9.
e e
L ld
. 3.. Tine schedule for information Collection and Publication.
Required reports are collected and evaluated on a continuing. basis as events occur. Applicat. ions for new licenses or amendments may be submitted at any time. The information submitted is not compiled and published. However, with the exception of certain safeguards or proprietary information, it is generally available to the public for inspection and copying.
4.
Consultation outside the agency.
The application, recordkeeping, and reporting requirements in 10 CFR Part 73 have been the subject of formal rule making proceedings.
Public comments were received and rule changes were made where appropriate.
5.
Estimation of compliance burden.
During the past 3 years, NRC has, through amendmerd; of 10 CFR Part 73, imposed approximately 10 reporting requirements upon licensees which were one-time only requirements. For instance, sections 73.20(c)(1),
73.40(b), 73.55, and 73.67(c)(1) imposed a significant reporting burden on licensees which was of a one-time only nature. Since KRC licensees have complied with these one-time only reporting requirements, they cannot be carried over as estimated future burden. Thus, past one-time-L
~
only burden has been' deleted from the burden totals identified in this clearance renewal request. Th~e burden estimates presented here cover all of the continuing. reporting requirements currently expected to affect'NRC licensees in the coming 3 years.
Please see attached Table 1 for a breakdown of burden estimates by section.
6.
Sensitive Questions.
No sensitive information is requested or collected.
- 7.. Estimate of Cost to the Federal Government.
All of the sections will have either no separable cost or negligible cost to the Federal Government except for the following.
Section 73.26(b)(3):
120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> / year or $2880/ year for GG-13 Section 73.26(b)(4):
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / year or $576/ year for a GG-13 Section 73.46(d)(1):
144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br /> / year or $3456/ year for GG-13 Section 73.55(b)(1):
144 hours0.00167 days <br />0.04 hours <br />2.380952e-4 weeks <br />5.4792e-5 months <br /> / year or $3456/ year for GG-13 75% of the computer cost of $1,200,000 and 75% of the 1.5 staff years used in obtaining information for the computer and analyzing the output can be attributed to Part 73. Thus the cost to the Federal Government attributable to Part 73 is.75X1,200,000+75X24X1.5X8X230&l0,668=
900,000+50,000+10,000 or $960,000/ year.
- d...
1 ESTIMATED LICENSEE REPORT! 8URDEN 1
[411MTED NO. UF
[511 MATED TUTAL t311mTED TR S:
ON REQUIREENT STAFF / HRS.
LICEN$EES FREQUENCY ANNUAL STAFF / HRS.
/3.20(c)(1)
Revisad Protection Plan ONE TIME ONLY SURDEN WHICH IS COMPLETED 13.24(b)(1)
Shipment Logs. General
.2 34 8
54.4 r3.25(b)(1)-(3)
Restrict Access and Activities. Transportation Contained in 73.26 4
2
'3.25f e'"
- 84)
Unauthorized entry or Unauthertzed Materials contained in 73.26 4
2 r3.25(u)(1)-(.,
Respond to Safeguards Contingencies. Transportat16n Contained in 73.26 4
2 13.26(b)(3)
Security Arrangements 5
4 2
40
- 13.26(d)(3)(1)
Written Security Procedures 1
4 2
8 I/3.26(d)(3)(11)
" Written Approval
.5 4
2 4
13.26(d1(4)
Security Training 1200 1
1 1200
,13.26(e)(1)
Safeguards Contingency Plan 100 4
2 800 t '3.26(h)(6 )
Transportation Security 5
4 2
40 1,13.26(1)(6)
Convoy Communication 18 4
2 144
{13.26(k)(4)
Rail Shipment Lost Material Report Negligible
!r3.27(a)(1)
Departure Notification
.1 4
2
.8
- /3.27(a)(2)
Arrival Notification
.5 4
2 4
s l73.27(b)
Notification to NRC
.5 4
2 4
13.27(c)
Lost Material Report Negligible 3
i l13.37(b)(2)
Spent Fuel Shipment Damage
.3 20 2
12 i3.37(b)(3)
Spent Fuel Shipment Instructions
.2 20 2
8 t
!73.37(b)(5)
Spent Feel Shipment Log
.2 20 2
8
'13.37(b)(7)
Spent F9e1 Shipment Advance Approval
.2 20 2
8 S+
6 3
(
a i
+
E511m TED NO. OF L511 mTED TOIAL [511MAltu CFR SECTION REQUIREENT FTAFF/ HRS.
LICENSEES FREQUENCY ANNUAL STAFF / HRS.
73.40(b)
Update Contingency Plan ONE TIME ONLY BURDEN WHICH !$ COMPLETED 73.40(c)(2)
Detail Site Procedures l00 8
1 800 73.40(d)
Independent Audit of Fixed $1te Contingency Plan 5
90 1
450 73.45(b)(2)(1),(11)
Access Authorization Controls 100 5
1 500 73.45(c)(1)(1) (111)
Detection Unauthorized Activities 100 5
1 500 73.45(d)(1)(1).(tv)
Detection Unauthorized Placement 100 5
1 500 73.45(el(1)(1f)
Detection Unauthorized Removal 100 5
1 500 73.45(e)(2)(fl.(iff)
Confirm Quantitles of SNM 100 5
1 500 73.45(f)(1)(11)
Unauthorized Access Assessment 100 5
1 500 73.45(f)(2)(1),(ti)
Unauthorized Access Attempts 100 5
1 500 73.45(g)(2)
Response Plan 100 5
1 500 73.46(b)(1)
Securfty Organization Contained in,73.45 73.46(b)(3)(1)
Security Procedures 160 12 1
1920 73.46(b)(3)(ft)
Organization Written Approval Contained in 73.45 73.46(b)(4)
Requalification Record. Fixed Site 16 12 1
192 73.46(d)(3)
Access Control Procedures Contained in 73.45 73.46(d)(10)
Container Examination Contained in 73.45 73.46(d)(11)
Verify Container Contents contained in 73.45
! 73.46(d)(13)
Visitor's Log
'.1 12 500-600
' 73.46l 1(5)
Service Nottfication Contained in 71.45 I 73.46( )(6)
Independent Audit of Ftxed $1te Security Program 8
12 1
96 73.46( )(1)
Contingency Plan for Fixed $1tes 10 90 1
900 73.46th)(2)
Documentation of LLEA Arrangement
.3 12 1
3.6 73.46(h)(3)
Armed Personnel Contained in 73.45 73.50(a)(3)
Security Documentation 100 2
1 200 73.50(a)(4)
Spent Fuel Security Force Requalf fication 16 4
1 64 73.50(c)(5)
Information Registration
.2 2
200 80
! 73.50(g)(1)
Safeguards Contingency Plan 100 2
1 200 73.50(g)(2)
LLEA Arrangement for Spent Fuel Storage Fact 11ty
.3 4
1.2 73.50(h)
Update Guard Qualification and Training Plan 600 4
1 2400 g
k+
9
LhilMAIED NO. UP Lhl! MILD IDIAL Lhilm TED
- R SECTION REQUIREENT STAFF / HRS.
LICENSEES FREQUENCY ANNUAL STAFF / HRS.
50b 76 1
38000 3.55(b)(1)
Reactor Securf ty Organization 1.55(b)(3)(1)
Security Procedures. Reactor 16 76 1
1216 3.55(b)(3)(1f)
Reactor Procedures Approval 175 76 1
13300 3.55(b)(4).
Requalification Record Reactors 16 76 1
1216 3.55(d)(6)
Visitor's Log
.1 '
76 500 3800 3.55(g)
Indepeadent Audit Review, Reactor 8
76 1
608 3.55(h)(2)
Reactor Lf alson LLEA 20 N
1 1520
,3.67(c)(1)
Securfty Plan ONE TIE ONLY 8URDEN WHICH IS COMPLETED 3.67(d)(11)
Class II Response Procedures 4
40 1
160 3.67(e)(1)(1)
Class II Advance Shipment Notification 2
37 10 740 3.67(e)(1)(11)
Class II Receiver Confirmation 1
37 10 370 3.67(e)(2)(1f)
Class II Receiver Notification 1
37 10 370 3.67(e)(3)(fv)
Class II In -Transit Response Procedures 1
10 5
50 3.67(e)(3)(v)
Class II Arrival Notification
.5 37 10 185 3.67(e)(3)(vil Class II Trace Investigation 1
37 1
37 3.67(e)(4)
Class II Exporter Requirements 1.5 37 8
444 3.67(e)(5)(f)
Class II Importer Requirements 1
37 5
185 3.67(e)(5)(11)
Class II Exporter Notification 1
37 5
185 3.67(e)(6)(1)
Class II Additional Information Negifgible 3.67(e)(6)(11)
Class II NRC Notification Negligible 3.67(f)(4)
Class III Fixed Site Response 4
50 1
200 3.67(g)(1)(1)
Class III Advance Shipment Notification 2
7 10 140 3.67(g)(1)(ff)
Class III Receiver Confirmation 1
7 10 70 3.67(g)(2)(11)
Class III Receiver Nottffcation 1
7 10 70 i
3.67(g)(3)(f)
Class III In-transit Response Neg11gible
' 3.67f 1(3)(11)
Class III Arrival Notification 1
7 10 70
, 3.67( )(3)(111)
Class III Trace Investigation 1
7 10 70 3.67( )(4)
Class III Exporter Requirements 1.5 7
8 84 3.67(g)(5)(1)
Class III Importer Requirements 1
7 5
35 3.67(g)(5)(ff)
Class III Exporter Notification 1
7 5
35 l' 3.70(a)
Record of Authorized Individuals
.5 14 20 140 3.70(b)
Record of Access Authorizations
.5 4
100 200
- 3.70(c)
Visitor Log
.2 3
500 300 4
3.70(d)
Ac' cess Log for Unoccupied Vital Areas
.03 81 700 1701 3.70(e)
Documentation of Test t.9 Maintenance
.5 84 30 1260 3.70(f)
Alarm Documentation
.02 84 9125 15330 3.70(g)
Record of SNM Shipment Details 2
2 20 80 J.70(h)
Access Procedure Documentation 24 84
,1 2016 I
9 4
t.5TIMATED NO. W DIIRnILD ICIAL E5T3 MATED rR SECTION REQUIREl(NT STAFF / HRS.
LICENSEES FREQUEldCY AINRIAL STAFF / HRS.
3.7I(a)
Trace Investigation 24 46 3
3312 J.71(b)
Theft Report 24 169 1(A11 Licensees) 24 3.71(c)
HRC Event Report 44 20
.05 40 s.72 Advance Notice of Shipment
.2 6
5 6
ppendra a General Criteria for Security Personnel Contained in previous sections opendia C Licensee Safeguards Contingency Plans Contained in prevleus sections Totals: Annual Burden: 101,811 i
I s
1 I
g 4
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5 9
e
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