ML20138K456

From kanterella
Jump to navigation Jump to search
Request for OMB Review & Supporting Statement Re 10CFR25 Concerning Occess Authorization for Licensee Personnel. Estimated Respondent Burden Is 87.6 H
ML20138K456
Person / Time
Issue date: 12/12/1985
From: Norry P
NRC OFFICE OF ADMINISTRATION (ADM)
To:
References
OMB-3150-0046, OMB-3150-46, NUDOCS 8512180455
Download: ML20138K456 (9)


Text

'

$d O

r2 mcw

.' 3 Recuest for OMB Re.i.a W "u.

CAA A" view v-

~

.1 Important h:.so.n +,ur t o s tw w e 1 omc. etq terro De r <,1

-MH3

'.. no t h r.. < i p.es o' tv, f onn the m. iter si

.u a Jh to re4.+st both o, [ acu.* ve Un ter I ?.'91 r epev.

  • 1:

o un te' p.werwerk three op.es of the s.yombrg st.i:. q e, *

ne N.erwork 9ewt x et Ar,swer as quest.cns.n Part t i+ fnm regoc st e, f a sec. e. m-rer I o OtNe # In'ormaton out hegulatory At%rs 12291 Comp'ete P.irt 11.;nd syn the rep 'a tor, c o. ! b r.,t e, H th.

mfn.e of Man.ye rent arri fiu: fret rewe3: s for arcreva! uder the F'averwar Eco x i A i.m S U H Attention Doc wt 1.t rarv. Room 3201 1320 Sp D II. i omp.ete Par + m and s gn tne par cr o <. tk.u en Washingt(" Dc 20503 PART l.-Complete This Part for All Requests.

1. Dewrt,ent/a,;. nc, are weausott.t e ong e ter'.v.nt

~

~

~ ~ ~ ~ ~ ~~

~ T2Ae&Mie ~ - ~ ' ~~

f i

U.S. Nuclear Regulatory Commission l 3 1 5 0

3. tu e et rescn w= can dest am er w ss,ecre..On.s revs-n.cor..., m.,

Richard A. Dopp_ _ _

301 )492-4124 i

4. let e c't enmernat-on conect en or rWmo.irg 10 CFR 25, Access Authorization For Licensee Personnel
5. Lepi a an, v to rr*c-anon rocecocn o<,u.e (.-re ore a r cue. nt.f,c taw. o, necurme orden 42_ust220_lloL

_ or

6. wec.< rs. meo a me.eM

$ C v<t..,% enc 1ew, e,,,.m.or.s

. u re..dua4 c>r no-se wc3

.im 6 C r.on pru' t mst tt.t.ons 2 O state c,.vaw.ernme ts 4 [X b

. -s or ete r for-piot.t 7 0 smaa bus.nesses en o,praiatuo e

PART li.-Complete This Part Only if the Reque.st is for OMB Review Under Executive Order 12291

7. beuf at on M a~ *. N. e e n. !N i l

l

, e u

& l' n.

,av

. rA s v.~e es yype og resie w requegger Crassdkation Sta e sidesetepment D yzarag,a U Ma.cr 1

'-rc%se d or c'att 2 C Pendmg 4

en 2 y hottera;or 2 2 f <r a or in'er.m f.o#. w:tn p<:or propow i 3 U [mergency 3 a, i vs or.ntenm te.at w thout pnor proposai 4 [, Statutory or judicial ceachne J

9. Cf 9 sect.on atfected CFR 3 0. Oces this regulation corta n report:r g or re..n d.eep", v.an rreris that reauere OMB at pmvai unce the Paperworm Peduction Act snf 5 CFR 13207

[

v.-

] Na

11. If a rNgor rule. is there a res;ul ate.ry impact anatys 1 at'.+ + @

I i

Ve<

,7 e l rJa l*' th " dw OMB waive tr e araps?

3 Yes 4 U tm C: rtifiction for ReFulatory submissions in subtr.iting this request fur OMB review the autboniec re,wate y r ert.xt arid the pros; ram cthcial certif y that the requirernents of E O 12291 ar.d an, apphcase pobr y direct:ves nave t<en corrptiej weh E.r #ture of program of f.c a.

['Date I

e I

se ats e a uteovice.e u. w e ment i n.ee 8512180455 851212 l

124ous use only)

PDR ORG EUSOMB PDR ne.<

c um. e.-

.N

-40 08 6 M 4034 D3 A*

M *""d I " * " 3 ' ' ' ' S h 3 3

& " o rd e ! t < DUl!

h (. O is 1 Uf> '.d l */ i 7."J I

PART lil.-Cetnplate This Part Only if tha Request is for Apprsv:1 cf a Ccllection of Information Under the Paperwork Reduction Act and 5 CFR 1320.

13. Adstract-Descrece needs uses and atfntni pubhc in 50 mords or less

" Nuclear facility security, access, personnel".

Licensees and other organizations are required to provide information to ensure that an adequate level of protection is provided NRC classified information and material.

14. T ype of informa*ain c 04ection (rhet i on!F one) d Informatoon co*tectoons not contained in rules 1

Rett'lar submiss on 2 O tme gency submissioa(cert,hcat,onattached) laformation collections contarnedin rules 3 @ Existirg regulation (no change proposed) 6 Final or entenm final without pnor NPRM

7. Enter date of espected or actual Federat 4 O Notice of proposed rulemakirg(NPRM)

A O Reguiar submission Register pubhcation at this itase of ruiemaning 5 0 bnal. NPRM was previously pubbshed B

Emergency submission (cert,6 cat,on attached)

(month, day, year)-

15. Type of rev.e. recuested (chece only one) 1 O ne. coitect on 4 0 Reinstatement of a previously approved collecte for which approval 2 @ Revrsion of a currently approved coliecten h* ' '"P' 3 0 catens.on of tne..piration date of a current >y approved cotiecten 5 0 taisting cosiecten in use without an oue control number without any charte in the substance or in the method of coHecten
16. Agency teport form number (s}(snclude standardtoptoonal form trumber(s))
22. Purpost of information coilecten (check as many as apply)

NA 1 O Application for benefits 2 O erogram evaivation

17. Annual repoecg or o scicsure burden 3 0 ceneraipurpose stat,stics 1 Number of respondents.

l2 4 @ Regulatory or comphance 2 Numoer of rewporses per respondent I

5 Prograrn planning or management 3 Tctal annual responses (tire I t,mes hne 2) 13 s O Research 4 Hours per response 6.7

/

Audit 5 inta' <eu>s Mac 3 t.mes one 4) 87.6

18. Annuas recordteep ng burden
23. Frequency of recorcheeping or reporting (chec8i all that apply) 1 Nu nber of recordkeepers I2 1 @ Recordbeeping 2 Annualhours periecordkeeper.

2 Reporting 31otal recordbeeping hours (!.re I times line 2) 24,4 2 [x1 on occasion 4 Fuorceeep.ng retent.on pencd 2 years 3 ] w,,,,y

19. Tctai amai beoan 4 O Mcntniy 1 Requested (hne 17 5 pus one 18 3).

II2 5 0 ouarteriy 2 in csrent CP/B ir.ertory 2J 58 e O semi-annuany 3 DMeter ce (kne ) Jess hne 2)

~l $$0 7

Arnuany Esplination oidatterence 8 O Bsenniatiy 4 Program change 9 0 other(desenbe>-

5 Adjustment.

-l.946

20. currrnt (most recent) oM B control number or comment number
24. Respondents
  • obhgation to comply (check the strongest obigation that apples) 3l50-0046 1 O votontary
21. Requzsted empiration date 2

Required to obtain or retain a benefit 1/3l/89 3 Kl uandatory

25. Ara the respondents primarify educational agencies or mst:tutions or is tne prirnary purpose of the collection related to Federal education programs? O Yes G No
26. Does the agency use samphng to select respondents or does the agency recommend or presenbe the use of samphng or statistical analysis by resportents.

YeshNo

27. Regui tory notsty f r he informaten collection l

CFR

or FR
or,other(specsfy)

Paperwork Certification in submetting this request for oMB approval, the agency head, the semor officias or an autnoriied eepresentative, certifies that the requirements of 5 CFR 1320. the Privac y Act, statistical standards or direct'ves. and any other apphcable information pohcy directives have been comphed with, signstureof programothcial Date

. s gnature of agenc y head. the senior o*ficial or an authonred representative Date Patricia G. Norry, Director

~

/.1_ - a _ g

  • i Office of Administration JM C GPO : 1904 0 - 453-776 l

t

OMB SUPPORTING STATEMENT FOR 10 CFR PART 25 Access Authorization for Licensee Personnel Description of the Infomation Collection The reporting requirements of 10 CFR Part 25 affect approximately 12 licensees and other organizations (5 fuel cycle facilities, 3 transportation companies, I power reactor and 3 other organizations). The licensees or other organiza-tions make the reports available at their place of business or send the reports to NRC at its Headquarters or Regional Offices. Reports or applications are only required as occasioned by the occurrence of specific events such as the request for an access authorization, a termination, cancellation or reinstate-ment, or by a request for exemption from the Part. Other requirements for recordkeeping are necessary for checking the licensees' and other organizations' procedures for maintaining an acceptable personnel security and visitor control program.

Information submitted in connection with applications for access authorizations includes personal data which is handled and protected in accordance with NRC directives and the provisions of the Privacy Act of 1974.

Other information submitted to NRC in response to the application, recordkeeping and reporting requirements is available for public inspection in accordance with 10 CFR Part 9.

A.

JUSTIFICATION 1.

Need for Collection of Information.

10 CFR Part 25 contains numerous reporting, recordkeeping and application requirements, including requirements for submittal of personnel security access authorization requests, security recordkeeping requirements and security reporting and notification procedures relative to access authorizations.

In all cases, the requirements are necessary to help ensure that granting individuals, covered by this Part, access to classified information will not en-danger the U. S. common defense and national security.

Essentially, all of the reporting, recordkeeping and application requirements are necessary for one or more of the reasons listed below, To obtain the essential data from individuals necessary to a.

determine their eligibility for an NRC access authorization for access to classified information. These information require-ments are derived from pertinent statutes and Executive Orders which authorize background investigations on an individual's character, associations and loyalty.

b.

To obtain essential data describing normal operating procedures pertinent to personnel security and visitor control activities to ensure that regulatory requirements are being met by licensees and other organizations.

c.

To obtain essential data which serves as the basis for deter-mining continued eligibility of an individual for an NRC access authorization when occurrences or developments arise which may affect the initial determination.

The currently effective information collection requirements of 10 CFR Part 25 are identified and explained below:

25.11 Exemption Requests. The information and justification required by this section are used to determine whether an exemption can be granted. The submittal is necessary from any licensee which possesses nonself-protecting formula quantities of strategic special nuclear material (SSNM) seeking exemption from the requirements of Part 25.

25.17(b) NRC Access Authorization-Request Form.

(NRC Form 237 cleared under 3150-0050). The information and signature required by this section are used to verify the identity of the employee for whom access authorization is requested and ensures (through the signature of a licensee, licensee contractor or other organization official) that the licensee or other organization endorses the request.

25.17(c) Personnel Security (Access Authorization) Packet. The infomation required by this section provides the pertinent data necessary to conduct an initial or updating investigation used to detemine the respondent's trustworthiness and his/her eligibility for access to National Security Information or Restricted Data. The information submitted on NRC Form 1 Parts I and II (cleared under 3150-0048) is reviewed by SEC staff and forwarded to the appropriate investigating agency.

In those cases where the respondent already has a security clearance granted by another Federal agency, alterna-tive sources (other agency records) may be used to obtain this information.

25.21(b) Reporting Personnel Security Data. The reports and information required by this section ensure that personnel security records are kept up-to-date and that any developments or circumstances which may have an impact on an individual's continued access authori-zation eligibility are properly and accurately evaluated. This eval-uation enables NRC to carry out the regulatory intent to safeguard NRC classified information. " Data Report on Spouse," NRC Form 354, is cleared under 3150-0026, 25.23 Notification of Access Authorization Approval. The maintenance of access authorization grant letters permits review and confirmation during prescribed NRC surveys that only properly authorized employees have had access to classified information. This recordkeeping requirement ensures these records are available for review by NRC inspectors and that they can be compared against records held by the NRC Division of Security. The records under this section must be j

kept for one year following the access authorization termination date.

l OMB SUPPORTING STATEMENT 10 CFR PART 25

f

=

's

~

7

?

"25 25 Access Authorizat$on Cancellations. The information required by this section is necessary each time a licensee or other organiza-tion wishes to withdraw or cancel an access authorization they have requested. The information is used by NRC to terminate its processing of the individual and to notify the investigating agency s

that the investigation may also.be cancelled. This action saves the U. S. Government specific procesing costs and curtails unnecessary s

investigations and invasions of privacy.

25.27(a) & (b) Reopening Cancelled Reinests. These sections identify the personnel security infonnation which is necessary from licensees and other organizations in order to reopen a cancelled request. The information is used by NRC to complete the access authorization processing. The'se procedures are required in order for NRC to determine the respondent's trustworthiness and his/her eligibility for an access authorization.

25.29 Access Authorization Reinstatement. The purpose of this requirement is to: provide that information which may be necessary (depending upon when the access authorization was terminated)-to reinstate or reactivate the access authorization.

25.31(a) & (b) F tension or Transfer of:the Individual's Access Authorization. The procedures and requirements provide the necessary information to properly identify and process an individual for an extension or transfer of their access authorization.

25.33(b) & (c) Reporting Access Authorization Terminations. These procedures are required in order to ensure that an individual's access authorization is properly terminated whenever his/her need for access has expired or the individual has teen found ineligible for a continuing access authorization.

25.35 Classified Visits. These procedures and the use of NRC Form 277 (cleared under 3150-0051) ensure that only properly authorized individuals who require access to classified matter as a part of their official duties will have such access during visits to other facilities and agencies. The recordkeeping requirement for this section permits the review and inspection of documents related to classified visits. This review, completed during periodic surveys, will insure that only properly cleared individuals have been granted access to classified information during visits in accordance with the provisions of this Part.

Except as noted for 25.17 (c), there is no duplicaticn with any other Federal agency reporting requirements for all of the above.

For each of the reporting requirements, except for the carbon set (supplied by i

NRC) Form 1, Ports I and II,'the respondent is not required to submit more than three copies of any response.

~

2.

Agency Use of Information.' Personal history information which is submitted on applicants for access authorizations is reviewed, eval-uated.by Division of Set.urity personnel and provided to OPM which conducts background investigations. The NRC reviews the data from OMB SUPPORTING STATEMENT

- 10 CFR PART 25

.. (

these investigations and makes determinations regarding the eligibility of applicants for access to classified information.

Classified visit information is also processed and verified by Division of Security personnel.

If the information collection was not conducted, individuals' would not be permitted access to NRC classified information or be permitted to make visits involving NRC classified information.

3.

Reduction of Burden Through Information Technology. There is no significant impact upon the information collection requirement through the application of information technology. Only a small portion of other agency infomation [e.g., 925.17(c)] is available through information technology means. Most of the information is obtained directly from the individual affected.

4.

Effort to Identify Duplication. These requirements and procedures have been used by the Department of Energy to collect similar infor-mation. Similar requirements and procedures are used by other government agencies. Whenever possible, NRC uses these alternative sources of information.

5.

Effort to Use Similar Infomation. These requirements and procedures do permit NRC to use informatior already collected by other Federal agencies for similar access authorization programs. However, personal history information is time perishable and may need to be supplemented and updated.

6.

Effort to Reduce Small Business Burden.

None of the licensees affected qualify as small business enterprises or entities.

7.

Consequences of Less Frequent Collection.

If the information is collected less frequently, the assurance that only appropriately cleared individuals have access to NRC classified information is reduced. Less frequent collection may endanger the U. S. common defense and national security.

8.

Circumstances Which Justify Variation from OMB Guidelines. There is no variation from OMB Guidelines in this collection of information.

9.

Consultation Outside the Agency. The currently effective application, recordkeeping and reporting requirements in 10 CFR Part 25 have been the subject of formal rulemaking proceedings. -Public comments were received and rule changes were made where appropriate. Any new pro-posed information collection and recordkeeping requirements will also be published as part of a proposed rule, subject to public conenent.

These same requirements and procedures have been used by the Depart-ment of Energy. Similar requirements and procedures are used by other government agencies involved with programs requiring access to National Security Information.

10. Confidentiality of Information. The information collected is used to determine an applicant's eligibility for access authorization.

The information 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 each form.

l OMB SUPPORTING STATEMENT 10 CFR PART 25

9 I

}.

\\

x

11. Justification for Sensitive Questions.

Sensitive information collected under this program has been authorized under OMB Clearance Nos. 3150-0048, 3150-0050 and 3050-0051.

12. Estimated Annual Cost to the Federal Government..The estimated cost to the Federal Government in administering the program and procedures contained in these requireme'ntstis:

Annual cost - professional effort (485 hrs. X $60/hr.)

$29,100

=

Annual cost - clerical effort (660 hrs.X$20/hr.),r

$13,200

=

Annual cost - record holding, requirement for ongoing program (1 cubic ft. X $209/ cubic ft.)

209

=

Total annual cost

$42,509

=

s The annual cost to the respondents is reflected on Attachment A.

The cost of $60.00/hr. was used.

)

13.

Estimate of Burden. See Attachment A for a breakdown of burden estimates by Section.

14 Reasons for Change in Burden. The burden estimated in Section/25.35-represents a decrease of 585 hours0.00677 days <br />0.163 hours <br />9.672619e-4 weeks <br />2.225925e-4 months <br /> and $35,100 over the annual cost to respondents estimated under the= current OMB clearance. The previous estimate for Section 25.35 was a good faith estimate of the amount / frequency of classified visits that would need to be accomplished by,the licensees under 10 CFR Part 25. 0perational experience, however, has shown that the number of visits are far less than previously estimated. The burden estimate is even further reduced since previously, some burden was counted twice, once for the form itself and again as part of the requirements for Part 25. This new estimate is now shown on Attachment A.

15. Publication for Statistical Use. There is no application of statistics on the information collected. There is no publication of the information.

5 1

l r

b.

b I

9 OMB SUPPORTING STATEMENT 10 CFR PART 25-t i

. - - -.,. l

4 ATTACHMENT A 10 CFR 25 BURDEN ESTIMATE Total No. of Annual Total Hours Per Burden Cost to S:ction

. Requirement Respondents Responses Responses Responses Hours Respondent Rip.rting 25.11 Exemption Request 2

1 2

1.8 3.6 216 25.17(b)

NRC Access Authorization Request -

Form cleared under OMB control number 3150-0050.

NRC Fonn 237 25.17(c)

Personnel Security Packet Form cleared under OMB control number 3150-0048.

NRC Form 1 25.21(b)

Reporting Personnel Security Data Form cleared under OMB control number 3150-0026.

NRC Form 354 25.25 Access Authorization Cancellation 12 6

72

.25 18.0 1,080 25.27(a) & (b) Reopening Cancelled Requests 6

2 12 2.0 24.0 1,440 25.29 Access Authorization Reinstatement 4

3 12 2.0 24.0 1,440 25.31(a) & (b) Extension or Transfer of Access 12 1

12 1.5 18.0 1,080 Authorization 25.33(a) & (c) Reporting Access Authorization Form cleared under DMB control number 3150-0049.

Terminations - NRC Form 136 25.35 Classified Visits Form cleared under 0MB control number 3150-0031.

NRC Form 277 87.6

$ 5,256 Totals

ATTACHMENT A 10 CFR 25 BURDEN ESTIMATE Annual Total No. of Hours Per Rcrdkpng Cost to Section Requirement Rcrfkprs Rcrdkprs Hours Respondent R c'.rdkeeping

'25.11 Exemption Request (2 yrs) 2

.2

.4 24 25.23 Notification of Access Authorization 12 2.0 24.0 1,440 Approval (1 yr)

-25.35 Classified Visits (2 yrs)

Form cleared under OMB control number 3150-0031.

NRC Fonn 277

. Totals 24.4

$ 1,464

%