ML20137A374
| ML20137A374 | |
| Person / Time | |
|---|---|
| Issue date: | 08/13/1985 |
| From: | Norry P NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | |
| References | |
| OMB-3150-0062, OMB-3150-62, NUDOCS 8508210395 | |
| Download: ML20137A374 (11) | |
Text
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DESIGNATED ORIGUTAL-5"" '* 8 3 Request for OMB Rgvigw* >
cm (Rev Se:teetme 1983)
Cert fie important Read instructions before comptetirig form. Do not use the same SF 83 Send three copies of this form, the material to be reviewed, anti fa t) request both an Eiecutae Order 12291 review and approval under paperwork-three copies of the supporting statement, tt the Paperwork Reduction Act.
Answer all questions in Part 1. If this request is for review under E.O.
Office of Information and Regulatory Affairs 12291. complete Part 11 and sign the regulatory certification. If this Office of Management and Budget r Quest is for approval under the Paperwork Reduction Act and 5 CFR Attention: Docket Library, Room 3201 1320. skip Part II. compiete Part ill and sign the paperwork certification.
Washington. DC 20503 PART l.-Complete This Part for All Requests.
- 1. Department / agency and Bureaufof f ace onginating request
- 2. Agency coce
~
U.S. Fluclear Regulatory Coimiission 3 1 3 0
- 3. Name of person who can best answer questions regarding this request Telephone numi;er Russell R. Rentschler (Til ) 4?7_a761 _
- 4. Title of information collection or rulemaking 10 CFR Part 11 - Criteria and Procedures for Determining Eligibility for Access to or Control Over Special ilulcear Material S. Legal authonty for intormatron collect >on or rute (crie Unsted States Code. Pubtsc Law. or becutive Orcer) 42 2201(o) use
.or
- 6. Affected pubhc(check allthJtapply) 5 0 rederaiagenciesorempioyees 1 O individuaisorhousenoids a O rarms e O Non-profitinstitutions 2 O stateoriocaigovernments 4 Q susinesses or other for profit 7 0 smaiibusinessesororganiaations PART ll.-Complete This Part Only if the' Request is for OMB Review Under Executive Order 12291
- 7. Regulation identifier Number (R!N) or. None assigned O
~
Type of revsew requested
- g. Type of submissson (check one on each category) u.
Classification
$tage ofdevelopment 1 O standard 1 O uajor 1 O proposedordraft.
2 O pending 2 O Nonmajor 2 O rinatorinterimfinai.witheriorproposai 3 O Emergency W
3 0 rina orintenm finai. thout enor proposai 4 O statutoryoriudiciaideadiine
- 9. CFR section affected CFR
- 10. Does this regulation contain reporting or recordkeeping requirements that require oMB approval under the paperwork Reduction Act
. O ves Ou and 5 CrR 1320?
I O ves 2On
- 11. If a maior rule..s there a regulatory impact analysis attached?
3 0 ves 4Du if"No " did oMB waive the analysis?
C:rtification for Regulatory Submissions in submitting this request for oMB review, the authonzed regulatory contact and the program official certify that the requirernents of E.o.12291 and any appl. cat +
pohcy directives have been comphed with, Date signature of program official signature of autnonzed regulatory contact 8508210395 850813 PDR ORG EUSOMB cate PDR
- 12. f 0A18 use only)
Pew.own edet ons etisowte 83 to8
[er t
NsN 7saOOO 634-4oJ4 5 CrR t300 aa-r 0. -
S PART lil.-C:rnplIta This Ptrt Only if tha Raquest is far Approvalof a Cellzcti:n of Inforrnation Under the Paperwork Reduction Act and S CFR 1320.
- 13. Abstract-Desenbe needs. uses and af fected pubhc in 50 words or less A proposed amendment to 10 CFR Part 11 will permit yRC to use information already collected by other Federal ajencies for similar access aut:iorization programs.. Section 11.16 would require that licensees promptly notify llRC of the withdrawal or cancellation of a request for access authorization.
- 14. Type of information collection (check only one)
Intermation coMeetions not sentainedin rules
'l Regular submission 2 O Emergencysubmissiaa(certificationattached)
Intermation eeNections containedin rules
' 3 O Es.stingregui tion (nochangeproposed) 6 rinai or interim finai without prior upRM
- 7. cnter date of e pected or actuar reder.:
4 Notice of proposed rulemaking(NPRM)
A @ Regular submission Register publication at this stage of ruleman 5
Finai. NPRM was previously published B O Emergency submission (cerfsfication attached)
(month, day, year):
- 15. Type of review requested (check only one) 4 O Reinstatement of a previousty approved coii ction for which app,o, 1
New collection has expired 2 @ Revision of a currently approved collection 3 0 t= tension of the espiration date of a currently approved collection 5
Ex; sting collection in use without an oMB control number without any change en the substance or in the method of collection
- 16. Agency report form number (s)(include standard / optional form number (s)) -
- 22. Purpose of information collection (check as many as apply) 1 O Application for beness N/A 2
Program evaluation
- 17. Annual soportang or disclosure tu,rden 3
General purpose statistics
' IU 4
Regulatory or compliance 1 Number of respondents...
1C 5
Program planning or management 2 Number of responses per respondent,
?d 6
Research 3 Total annual responses (line I times Jine 2)
Q_G 7 O Audit-4 Hours per response 5 Total hours nine 3 times line 4)
??A
- 23. Frequency of recordkeeping or reporting (check all that apply)
Ig. Annualrecordheepingburden 1 O Recordkeeping 1 umber of recordkeepers Reporting 2 Annual hours per recordkeeper.
3 Total recordkeeping hours (!ine 2 tunes im 2) '.
2 @ onoccasion years 3 O weekiy 4 Recordkeeping retention period 19.Totalannual burden 4
Monthly
??R
$ O Quarterfy 1 Requested (line 17:Splus Nne 18 3).
277 6
Seneannually 2in current oM8 inventory 3 Difference (line 14essline 2). ^
+
1 7 O Annonier Esplanation e(dWerence '
o,
8 Siennially
-- 4 Program change _......'......
+
1 9 0 other(descriee>:
5 Adjustment.
- 20. current (most recent) oMB control number or comment number
- 24. Respondents
- obligation to comply (check the strorqgest obligation that stigd 3150-0062 3
y,iont,,y 2
Required to obtain or retain a benefit
- 21. Requested empiration date Three years after aoproval 3 [B Mandatory
- 25. Are the respondents primarily educational agencies or institutions or is the primary purpose of the collection related to Federal education prcgrams?
YesQ
- 26. Does the agency use samphng to select respondents or does the agency recommend or prescribe the use of samphng of statistical analysis ves O by tesponoents?
- 27. Regulatory authonty for the information collection 1G CFR II I6
- or FR
- or,other(speedy):
Paperwork Certification in submitting this request for oMB approvat, the agency head. the senior off cial or an authorized representative. certifies that the requirements of 5 CFR 1320.
Pnvacy Act, statistical star'dards or directives. and any other apphcable information pokcy direct:ves have been comphed with.
Date s gnature of program offic.as cate s gnature of agency heaa. tne senior ort.ciai ur an aanureco representative Patricia G. : lorry, Director M:
/2 jf MW pM OU1ce of !uainieraann V
OMB SUPPORTING STATEMENT FOR AMENDMENT OF 10 CFR PART 11 CRITERIA AND PROCEDURES FOR DETERMINING ELIGIBILITY FOR ACCESS TO OR CONTROL OVER SPECIAL NUCLEAR MATERIAL Description of the Information Collection 10 CFR Part 11 established a program of special nuclear material access authorizations (similar to personnel clearances) which required investigation of individuals based upon information supplied upon uniquely NRC forms. This amendment to 10 CFR Part 11 would allow use of forms from other Federal agencies. The result of this is that considerable administrative and investigative effort is avoided by licensees and the Federal government.
A.
JUSTIFICATION 1.
Need for the Collection of Information 10 CFR Part 11 prescribes that two levels of special nuclear material access authorizations shall be established for individuals filling certain jobs at licensees using or possessing a formula quantity of special nuclear material.
Information must be collected for individuals regarding their personal history in order to determine their eligibility for these jobs.
10 CFR 11.15(a). Licensees may request certification of existing clearances of individuals from the NRC or other Federal agencies if the investigative data is equivalent to that required for NRC-U or NRC-R special nuclear material access authorization.
Information upon which to base certifications is submitted on Security Acknowledgements (Form 176) and Requests for Access Authorizations (NRC Form 237). The information is needed to determine the investigative basis and level of the clearance.
The NRC grants the requested special nuclear material access authorization if the relevant criteria are met.
I
i 10 CFR 11.15(b). For individuals other than those qualified under Section 11.15(a) above, licensees must submit applications for NRC special nuclear material access authorizations for individuals employed in jobs identified in Section 11.11. Applications contain personal history infor-mation which is provided to the Office of Personnel Management (OPM).
That agency conducts either a National Agency Check or a full-field back-ground investigation, depending upon the level of access authorization sought. The NRC then determines whether the individual should be granted the level of special nuclear access authorization which was requested.
)
10 CFR 11.16. Licensees wishing to withdraw or cancel a request for an individual to be granted a material access authorization do so by supplying the identifying infomation on the individual and the level of authorization requested. This information is provided telephonically and confirmed in writing. A portion of the fee for a "U" access authorization may be refunded depending upon the status of the full field investigation.
2.
Agency Use of Information Personal history information which is submitted on applicants for the relevant jobs is provided to OPM which conducts investigations. The NRC reviews the data from these investigations and makes determinations of the eligibility of the applicants.
If the information is not provided, these determinations cannot be made.
3.
Reduction of Burden Through Information Technology There is no impact upon the information requirement througt, the application of technology.
4 Effort to Identify Duplication This amendment of 10 CFR Part 11 eliminates duplicating the collection of information already collected under similar Federal programs.
NRC will 2
I accept for its special nuclear material access authorization program infonnation already collected by other Federal agencies for incumbents in appropriate jobs. NRC will also accept for its renewal program part of the information collected by DOE for its renewal program.
5.
Effort to Use Similar Information This proposed amendment will permit NRC to use information already collected by other Federal agencies for similar access authorization programs.
6.
Effort to Reduce Small Business Burden None of the licensees affected qualify as Small Business enterprises.
7.
Consequences of Less Frequent Collection If the requested infonnation is collected less frequently, licensees will be in violation of regulatory requirements for submitting applications for renewal of material access authorizations.
NRC will not be able to evaluate personal history data to establish continuing eligibility for the affected jobs.
8.
Circumstances Which Justify Variation From OMB Guidelines Proposed Section 11.16 would vary from the OMB guidlines specifying a minimum of 30 days to respond to an infonnation collection requirement.
Section 11.16 would require that NRC be notified inanediately by telephone, with prompt confinnation by letter, of the withdrawal or cancellation of any request for access authorization. This requirement is reasonable in order to allow the government to promptly terminate investigations which may be underway so as to prevent the further expenditure of extremely scarce government investigative resources on a clearance that will not be needed.
9.
Consultations Outside the NRC The proposed amendment to the reporting requirement was developed in response to a licensee suggestion to eliminate duplication of information 3
collection under DOE and NRC programs. Each of the affected licensees has been contacted and views have been solicited.
- 10. Confidentiality of I'nformation The information collected is used to determine an individual's eligi-bility for access to or control over special nuclear material. The infor-mation is protected from public disclosure under the Privacy Act of 1974 and is handled in accordance with routine uses specified in the Privacy Act Statement on NRC Fom 254.
- 11. Justification for Sensitive Questions Sensitive information collected under this program has been authorized previously under OMB clearance No. 3150-0048.
- 12. Estimated Annualized Cost to the Federal Government Annual costs to the government related to reporting requirements controlled by OMB are those for processing NRC Form 1.
The only costs under regulations are those for processing withdrawals and cancellations as provided for under 911.16. The current total number of NRC Form 1s to be processed annually in response to all regulations is 1511, of which 700 have been estimated to arise from Part 11 regulatory requirements. The remainder arise under 10 CFR Part 25, and are not discussed here. On the basis of recent infomation it is estimated that a total of 5075 individuals will require NRC special nuclear material access authorizations. Under the current Part 11 requirements each one of these individuals would have to complete a copy of NRC Form 1.
They would also have to complete the form when applying for renewal of the access authorization 5 years after initial issuance.
The total number of NRC Fom 1s to be submitted during the first 5 years, assuming there will be 4
an annual attrition rate of 10% requiring new applications.for replacement employees, would be as follows.
initial applications 5075 second year new 508 third year new 508 fourth year new 508 fifth year new 508 total 7107 annualized rate 1421 Under the proposed revision to Part 11, information filed with the Federal government under other investigative programs can be used as a basis for
' issuing NRC material access authorizations.
It is, therefore, expected that 3200 of the initial 5075 applications will not need to contain the NRC Fonn 1.
Also, an estimated 880 renewals will, instead of the NRC Form 1, use copies of an equivalent DOE form which is sent simultaneously to DOE at the time of the NRC renewal application.
It is ' expected that the percentage of individuals subject to both NRC and DOE programs will remain fairly constant. Therefore, the DOE form will be used for roughly the same proportion of NRC renewals in the future. The rate of submission of NRC Form 1s under the revised Part 11 requirements would therefore be as follows.
l initial applications 5075-3200 1875 second year new 188 third year new 188 fourth year new 188 fifth year new
.188 total 2627 annualized rate 525 i
Processing an NRC Form I requires about 9 minutes of NRC staff time.
l l
Therefore, processing the 1421 annual submissions under the current Part 11 would, at $60 per staff hour, cost $12,780. Under the revised i
l 5
1
Part 11 the reduced cost for proccessing only 525 forms per year would be
$4,725.
The total annual rate of submissions of NRC Form 1s under all regula-tions is 1511, of which 700 were forecast to result from Part 11.
On the basis of later information it is now estimated that 1421 applications would result from Part 11 alone each year. A corrected estimate of the total annual rate of NRC Fonn 1 submissions from all sources would therefore be 2232 instead of 1511.
However, since the proposed revisions to Part 11 would reduce Part 11 submissions of the form to 525 per year, overall use of NRC Form 1 under all regulations would thereby be reduced to 1336 annually.
Under the revisions to Part 11 each of the six licensees is expected to utilize NRC Form 237 for a total of 6 submissions.
Processing time for this form based upon its usage under other regulations is 0.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The cost to the government for the use of this fonn is therefore 0.2 x 6 = 1.2 hrs x 60 per hour equals $72.
On the basis of experience with the personnel clearance program under -
Part 25, it is expected that there will be a small number of withdrawals and cancellations of requests for access authorization.
Processing the estimated one percent of applications requires about 15 minutes each (0.25 hr). The costs to the government of providing for withdrawals and cancellations under the revised regulations are as follows:
(525 applications X 0.01 cancellation rate X 0.25 hrs X $60 = $75.)
i i
13.
Estimate of Burden i
The primary burden affected by the revision of Part 11 is the reporting burden for completing NRC Form 1 and, under certain circumstances, replacing that burden by completing NRC Fonn 237. The only burden under Part 11 regulation would be related to withdrawal or cancellation of requests for access authorizations under proposed Section 11.16. The total burden for completing NRC Form I including requirements under 10 CFR Parts 10 and 25 is currently shown as 2267 hours0.0262 days <br />0.63 hours <br />0.00375 weeks <br />8.625935e-4 months <br />. This is based on 1511 respondents requiring one and one half hours to complete the 6
form once per year. Of the 1511 respondents, 700 were estimated to be based upon the requirements of Part 11.
The more recent infomation indicates that the current (unrevised) Part 11 requirements would affect 1421 respondents.
(See previous section.) The proposed revisions to Part 11 would reduce the number of respondents to 525.
Each respondent would submit the NRC Fom 1 once annually and preparation of the fom requires i
one and one half hours. Therefore, the burden associated with Part 11 under the current version of the regulation would be 2132 hours0.0247 days <br />0.592 hours <br />0.00353 weeks <br />8.11226e-4 months <br /> (1421 x 1.5) rather than 1050 (700 x 1.5).
Under the revised Part 11, the burden would decrease to 788 hours0.00912 days <br />0.219 hours <br />0.0013 weeks <br />2.99834e-4 months <br /> (525 x 1.5).
The total number of respondents submitting NRC Fom 1s under all regulations would decrease to 1336 (525 Part 11 and 811 other). The total burden for forms under all regulations would therefore decrease from 2267 hours0.0262 days <br />0.63 hours <br />0.00375 weeks <br />8.625935e-4 months <br /> (1511 x 1.5) to 2004 (1336 x 1.5) rather than increase to 3348 (2232 x 1.5). At $60 per staff hour, costs would decrease proportionally, i.e., from $136,020 (2267 x $60) to
$120,240 (2004 x $60) rather than $200,880 (3348 x $60).
In addition, fees for 880 NRC "U" access auth'orizations and 2320 NRC "R" access authorizations will be avoided. At $1580 and $15 respectively, the fee savings are $1,425,200. The total of fee and respondent time savings is
$80,640 respondent time plus $1,425,200 fees equals $1,505,040.
The revision to Part 11 providing for withdrawal or cancellation of requests leads to a burden of about 0.25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> for each such licensee action. Since the current Part 11 does not provide for withdrawals or cancellations, no burden is assigned.
Therefore, there is a new license l
burden on the basis of the regulatory change. At an anticipated rate of 1% of all applications this amounts to a total burden as follows:
(525 applications X 0.01 rate X 0.25 hr X $60 = $75.)
14.
Reasons for Change in Burden Part of the reduction in burden results from certifying the eligibility of an estimated 3200 individuals on the basis of current l
l 7
t equivalent clearances rather than through reinvestigation for the NRC using complete applications.
An additional reduction in burden is caused by the fact that information for the DOE "Q" leval personnel security clearance renewal program is used for the. NRC "U" level material access renewal program.
- 15. Publication for Statistical Use There is no application of statistics in the information collected.
There is no publication of the infonnation.
t 8'
JED Estimated Burden Table Burden Total-Number of Annual Total Hours Per Total Cost to under Burden Section
' Form Respondents Responses Responses Responses Burden Respondent Part 25* For Forms
- 11.15(b) NRC Form 1 525 1
525 1.5 788
$47,280 1217.
2004 11.15(a) NRC Form 237 6
1 6
0.2 1.2 72 158 159 11.16 5
1 5
0.25 1.25
$ 75 Total 536 790.45
$47,427
- For information only. Not part of this Part 11 clearance application.
9