ML20197C542
| ML20197C542 | |
| Person / Time | |
|---|---|
| Issue date: | 11/08/1985 |
| From: | Besaw W, Scott R NRC |
| To: | Oconnell R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20197C372 | List: |
| References | |
| FRN-49FR30726, RULE-PR-50, RULE-PR-73 AA36-2-022, AA36-2-22, AB17-2-21, NUDOCS 8611060228 | |
| Download: ML20197C542 (21) | |
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senc posee ese U.s. NUCLE AM REGULAToMY COMh80ssioN steen ASSESSMENT oF PROPOSED INFORMATION COLLECTION i
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Robert O'Connell Final Insider Safeguards Rules IMC Package NMSS
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- 1. The requirement is needed. Ilt is the best means to achieve a necessary regulatcvy objective.) X
- 2. The requirement has practical utility, i.e., the NRC has the capabdity to use the information in a timely and useful fashion.
- 3. The schedule for imposing the requirement is reasonable. X
- 4. The requirement selected is the least burdensome method of achieving a necessary regulatory objective. X i
4 X
- 5. The requirement does not duplicate or overlap requirements imposed by the NRC. ,
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- 6. The requ;rement does not duplicate or overka requirements imposed by other Government agencies. X
- 7. The method used to estimate the burden er Llequate. X
- 8. The burden estimates are reasonable wher' compared with similar requirements previously submitted. X
- 9. The method proposed for collecting or keeping the information is consistent with sound records management practices. X
- 10. The records retention period is sufficiently definitive and reasonable. X
- 11. The requirement adequately identifies the records to be maintained and the information to be reported. X 4
- 12. NRC administrative support requirements are sufficient to manage the information collection. X
- 3. The information collection will not cause NRC to exceed its information Collection Budget.
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NCY 19 is SUPPORTING STATEMENT FOR 10 CFR PARTS 50 AND 73 INSIDER SAFEGUARDS RULES INTRODUCTION The Commission has published three related proposed rules concerning protection against the " insider" threat at nuclear power reactors. The corner-stone of the rule package is the Access Authorization Program which is designed to provide increased assurance of employee reliability and at the same time minimize the burden on the licensee by providing reciprocity of screening pro-grams among licensees. The second rule of the package is the Search Require-ments Rule which clarifies requirements for searches of individuals at power reactors. Present requirements for personnel searches have been interim for t
the past several years pending the codifi. cation this rule will provide. The remaining rule of the package is the Miscellaneous Amencments. The intent of this amendment is to provide a more safety-conscious safeguards system while l maintaining current levels of protection.
JUSTIFICATION Access Authorization Rule 4
History
, On March 17, 1977, the Commission published proposed amendments to Title 10 of the Code of Federal Regulations, 42 FR 14880, that sought to establish an unescorted access authorization program for individuals who have access to or control over special nuclear material. Written comments were invited and received. On December 28, 1977, the Commission issued a notice of 1
ss g
', I public hearing, 42 FR 64703, on the proposed regulations, and subsequently established a Hearing Board to gather additional testimony. As a result of information gathered at the public haaring and its own examination of the pro-posed access authorization program, the Hearing Board made recommendations to the Commission concerning future personnel screening requirements applicable to nuclear power reactors. The Hearing Board recommended that the NRC issue a screening rule based on the American National Standard Institute's Standard N18.17
" Industrial Security for Nuclear Power Plants" (ANSI N18.17), to ensure the trustworthiness and suitaoility of persons granted unescorted access to pro-l tected areas and vital areas at nuclear power plants. The Commission adopted
} this recommendation.
i l Need for Information Collection i .
The Commission's pursuit of an access authorization program is based upon the fact that the disoriented person and disgruntled employee, generic adversaries, are of primary safeguards concern because of their inside positions.
Commission study has shown that the goal-oriented, technically sophisticated disoriented person, particularly the psychotic, is perhaps one of the most dangerous of the generic adversaries.1 Both the disoriented person and disgruntled employee may have inside access to restricted areas, files and '
sensitive security information. They are also privy to shop and loose talk and often have knowledge of critical and vulnerable areas of facility operation.
l Further, NRC records show that in 1984 out of a total of 111 safeguards events )
reported by licensees, 43 involved insiders. These events included drug-related
" l incidents, vandalism, hoaxes, firearm incidents and other miscellaneous safe-guards events.
In line with ANSI N18.17, the proposed unescorted access authorization j rule consists of three major components: background investigation, psychological assessment, and continual behavioral observation. The proposed criteria have been designed to codify and make more uniform what many licensees LNUREG 0459, Generic Adversary Characteristics Summary Report, U.S. Nuclear Regulatory Commission, March, 1979.
4 2
.. c.
are doing either in part or in whole to meet industry standard ANSI N18.17. In the fall of 1978, the staff included in its closing statement to the Hearing Board the results of a survey on the personnel screening programs used by 39 power reactor facilities. The results of the survey clearly indicate that ANSI N18.17 did not result in a consistent and uniform program and that a mandatory, more consistent access authorization program was needed. The proposed rule i
l would provide a more consistent and uniform screening program as well as codify much of what the industry is already doing. This is of benefit to the n'uclear industry because standardized programs would permit reciprocity among licensees and eliminate the need for " rescreening" of previously screened transient workers as they move from plant to plant.
This information provides a clear need for the promulgation of an access authorization program designed to identify individuals who are untrustworthy or otherwise unsuitable for unescorted access to protected areas and vital areas at nuclear power reactors.
Practical Utility of Information Collection A 1982 article published in the periodical " Security World"2 resulting from a security survey of 2000 individuals indicated that virtually all large companies and organizations in the United States are using some form of screening of employees. Within the Federal government, the Department of Defense nuclear weapon personnel reliability program (PRP) uses background
! investigations as part of its program "..to ensure the highest possible standards in individual reliability..."3 Federal agencies such as the National
, Security Agency (NSA), Central Intelligence Ager.cy (CIA), Federal Aviation Administration (FAA), and Coast Guard use psychological testing as an initial screening tool to assess stability and reliability.4 Hence, the practical utility of such programs has been established by their wide-spread usage throughout industry and government.
2"What Companies are Doing About Employee Screening and Testing," Security World, pp. 29-40, April, 1985.
3 Enclosure 8, SECY84-72, Background Information on Proposed Insider Safeguards Rules, February 9,1984.
4 Ibid.
3
a.
I Experts in the field of employee screening generally agree that a three component program consisting of bac'kground investigations, psychological assess-ment, and continued behavioral observation is more effective than any one element used alone. This is reiterated by such industry standards as ANSI 18.17, and its update ANS 3.3, Security for Nuclear Power Plants, both of which contain *
) a three component screening program. Comments received from the National Institute of Mental Health (NIMH), Department of Health and Human Services noted that psychological assessment could provide some useful information about the emotional stability of persons given access to a nuclear power plant environment, however, such testing has questionable predictive value. The Commission agrees and for this specific reason has proposed a three component screening program. NIMH views on the NRC proposed rule were further solicited I
by NRC staff. This discussion yielded the agreement that while no screening program is 100 percent accurate the measures proposed by the NRC, when properly administered, appear to constitute the best approach presently available in detecting emotional instability in individuals. (See Enclosure 1).
Background investigations are used to determine undesirable elements in an individual's history which to a certain extent may be used to predict future
) behavior. Background investigations however do not give an indication as to an individual's current emotional stability. Current emotional stability is deter-mined through the use of psychological assessment. The utility of psychological assessment was tested in an analogous case to the NRC usage when the use of j psychological testing by the FAA was challenged in 1969 before the United States 4
District Court, Central District of California. The court remanded the issue to the Civil Service Commission for a formal hearing, and among other things, i directed the Commission to determine the validity of the 16-PF test. On the 1
basis of testimony of expert witnesses, the Commission found that the validity of the test was clearly established. Moreover, the-Commission also found that
, the FAA had acted within its authority by requiring a psychological evaluation of air traffic controllers as part of a " fitness for duty" examination, and that psychological testing is accepted as a legitimate adjunct of a medical examination particularly in areas involving the safety and security of the nation and its people. The Commission also found that psychological testing, and the 16-PF in particular, did not deprive the appellant of any Constitutional 4
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rights and that in the case of FAA procedures, adequate precautions were taken to protect the appellant's right of privacy. (Board of Appeals and Review, j U.S. Civil Service Commission; Decision in the matter of Duane E. Legget, Air Traffic Control Specialist (Tower), April 16, 1984.)
Psychological assessment further contributes to an employee screening
- program by functioning as an initial detector based upon professional judgment.
The third component of the access authorization program, behavioral observation, monitors individuals to assure continuing suitability within the nuclear environment. However, this monitoring is done by supervisors trained to observe, not assess. Hence, a continuum relationship exists between psychological assess-ment and behavioral observation with psychological assessment providing the professional judgment that allows behavioral observation to be effectively conducted by first-line supervisors.
a Reporting and Recordkeeping Requirements ,
- In the proposed rule, 10 CFR 50.34(h) and 73.56(a) require that the j applicant prepare an Access Authorization Plan in accordance with the criteria i
contained in 10 CFR 73.56 and submit it to the Commission for review and
- approval. This plan will delineate how the licensee intends to implement the
- various requirements of the Access Authorization Rule. A review and approval
!, of the plan by the Commission is needed to assure that a uniform screening pro-gram consistent with Commission regulations is implemented throughout the industry.
I
- a. Section 73.56(b) specifies the performance objective and requirements that must be met by the access authorization plan.
i
- b. Regulatory Guide 5.64, Standard Format and Content Guide for Access Authorization Plan for Nuclear Power Plants, was developed to explain the
) intent of the rule and content of the plan. This guide will assist applicants and licensees to prepare an access authorization plan.
1 l Certain records which are enumerated below need to be maintained by the
! licensee in order:
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- a. that the NRC, through inspection against the approved plan, can assure licensee compliance with the requirements of this rule; and
- b. to provide needed records in any review proceedings which may occur due to implementation of this rule.
The records, developed in the course of administering the Access Authoriza-tion Program and which the licensee is required to maintain, are as follows:
- a. Section 73.56(c) requires a background investigation for individuals seeking unescorted access to protected areas and vital areas, and specifies that licensees must require individuals subject to this program to report to the licensee any subsequent occurrence or circumstance that may have a bearing on continued access authorization. A record of background investigation, including any derogatory information obtained on an indi-vidual during the background investigation will be kept on file as well as any information related to subsequent occurrences that may have a bearing on an individual's access authorization.
- b. Section 73.56(d) requires that a written recommendation be provided to the licensee by the psychiatrist or psychologist as to the individual's behavioral suitability for unescorted access. This requires the establish-ment and maintenance of a psychological assessment program, and includes the need for the licensee to keep on file the recommendation of a qualified and, if applicable, State-licensed psychologist or psychiatrist on an individual's suitability for employment in a nuclear setting.
- c. Paragraph 73.56(e) requires the establishment and maintenance of a con-tinual behavioral observation program, which includes training supervisors, providing a supervisor's guide and a need for the licensee to keep on file I l
behavioral observation records made by the individual's immediate superior.
- d. Paragraph 73.56(f) indicates a need for the licensee to keep on file the unescorted access authorization certification received from another licensee on a temporary worker or transferring employee. The gaining licensee must request of the original granting licensee a photograph of 6
, - - i .
the individual or other unique personal data and a written verification of the individual's unescorted access authorization along with a statement which indicates last effective date of unescorted access authorization and reason authorization was suspended. The licensee will keep on file the unescorted access authorization certification received from another licensee on a transferring employee. A record of temporary workers granted access during major outages will be maintained by the licensee.
- e. Section 73.56(g) requires the establishment of an appeals grievance procedure for employees suspended from or denied access authorization to include; notification of suspension-denial, employee rebuttal, hearing and notification of final decision. The licensee will keep on file any
- records used as a basis for denying or revoking an individual's j unescorted access authorization and subsequen; c ,aal, hearing and decision records.
- f. Section 73.56(h) requires the licensee to establish and maintain protection measures for the individuals access authorization files, audit procedures to ensure compliance with requirements and that an individual's access authorization file be kept a minimum of 3 years after termination of the individual's access authorization.
Search Requirements Rule History l
The Commission was petitioned in 1977 to suspend a requirement for the use of " pat-down" searches as a matter of routine. Interim search requirements were established and action was deferred on the petition pending the development of
^
a rule specifying entry search requirements. A proposed rule on this subject was issued for public comment in 1980. The staff has now revised the rule con-cerning search requirements in light of the comments and in response to recom-mendations made by the Safety / Safeguards Review Committee. This Committee, which was formed in response to the Chairman's request of August 16, 1982, had the overal.1 task of studying power reactor safeguards requirements and practices to determine whether actual or potential conflicts exist with plant safety objectives.
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The Safety /Safeguarda Review Committee recommended that all persons enter-ing the protected areas of a nuclear power plant should be searched using metal detectors and explosive detectors. This recommendation, which the staff endorses, differs from the current interim procedures in that visitors would be subject to routine equipment searches rather than physical " pat-down" searches.
" Pat-down" searches would be required only when the licensee has cause to suspect that an individual is attempting to introduce contraband (firearms, explosives, or incendiaries), or when the detection equipment is out of service.
The staff has considered the use of random searches for screened individuals, but the Safety / Safeguards Review Committee found that most licensees have successfully adjusted to 100% equipment searches, and believed that changing to random searches would be disruptive. Due to their interrelationship with other provisions of the Insider Safeguards Rule Package, these revised search require-ments are again being published in proposed form. .
Need for and Practical Utility of Information Collection Licens'ees will be required under this rule to amend their facility's physical protection plan documenting how they will meet the requirements of the rule. This permits NRC approval of the licensee's proposal and, once approved, allows NRC inspection and enforcement. This amendment is anticipated I
to be of a minor nature because the majority of utilit!es presently conduct
, equipment searches of individuals ertering a protected area at nuclear reactors.
10 CFR 73.55(g) requires testing and maintenance of security-related equipment, e.g., search equipment, to assure proper operation of the equipment. Any new equipment purchased as a result of this amendment would be required to have documented operational testing. This recordkeeping is considered to be of minimal impact to the licensee because, as previously mentioned, the vast majority of licensees currently have the equipment in place.
Miscellaneous Safeguards Related Amendments History The Commission proposes to amend 10 CFR 73.55, " Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors Against Radiological 8
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Sabotage," to clarify and refine this policy for (1) vital area access controls, (2) authority to suspend safeguards measures during safety emergencies, (3) pro-tection of certain items of security equipment which significantly impact nuclear plant security, and (4) key and local controls. The requirements have been designed to accommodate recommendations of the previously mentioned Safety /
Safeguards Review Committee established in response to the Chairman's request of August 16, 1982.
The staff has proposed amendments to 10 CFR 73.55(d)(7) that address both non-emergency and emergency access controls to vital areas. These revisions assure adequate access for safety purposes while maintaining safeguards require-ments.
The staff has also proposed a revision to S 73.55(a) to clearly indicate the licensee's authority under S 50.54(x) and (y) to suspend safeguards measures if required to accommodate emergency response. These changes are I based upon recommendations made by the Safety / Safeguards Committee that power reactor licensees be given improved flexibility to facilitate response to site emergencies or " unusual events."
The Commission is considering requiring protection of specified onsite physical security equipment (e.g., secondary power supplies for intrusion alarms and nonportable communications equipment) which is required for the pro-per functioning of the security system: Usually. this equipment does not qualify as vital equipment but sabotage of such equipment could seriously impair the security of the plant. Such protection is necessary. to achieve the general
-l performance requirements of.10 CFR 73.55(a).
In a matter associated with access control,'the Commission is considering amending 6 73.55(d)(9) to reduce unnecessary costs associated with key and lock controls. The present requirements call for key, locks, and combination changes when any employee who has access to such devices is terminated.
Staff experience Indicates that adequate protection could be obtained by changing or rotating keys, locks, and combinations: (1) routinely on an annual basis, (2) whenever a person's access authorization is revoked for reasons of 9
l lack of trustworthiness, reliability or inadequate performance, and (3) when compromise of locks is suspected.
Need for and Practical Utility nf Information Collection Licensees will be required under this rule to amend their facility's physical protection plan documenting how they will meet the requirements of the rule. This permits NRC approval of the licensee's proposal and, once approved, allows NRC inspection and enforcement. The licensee will also be t
required to maintain current authorization access lists for each vital area
! (VA). These lists would be required to be updated at least every 31 days.
This action is necessary to ensure that only those individuals requiring VA access to perform their duties are allowed access to the most vital areas of nuclear reactors. Most licensees presently maintain such listings and the _
impact of this recordkeeping requirement is anticinated to be minimal ~
3 i DUPLICATION OF'0THER COLLECTIONS OF INFORMATION These reporting requirements do not duplicate or overlap other information i
collections.
CONSULTATIONS OUTSIDE THE NRC j Access Authorization Rule Both informal and formal consultations were made with some licensees, investigative agencies, psychiatrists, and psychologists to determine impact, receive guidance, and identify and help solve potential problems with the proposed rule.
The formal consultations were in the form of NRC contracts made to:
Personnel Decision, Inc. (PDI), Minneapolis, Minnesota for guidance con-cerning the behavioral observation program. In developing this guidance, PDI also convened a panel of experts from around the country to make recommenda-tions, including certain reactor licensees.
10
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also obtained from the Atomic Industrial Forum. Industry and academic experts in the field of psychological assessment were contacted to determine the utility of psychological assessment and behavioral-observation programs.
All suggestions and recommendations were taken under consideration in' I
developing the rule.
. Search Requirements Rule 4
The Safety / Safeguards Review Committee, during their task of studying i power reactor safeguards requirements and practices in order to determine whether actual or potential conflicts existed with plant safety objectives, visited several licensee sites to informally discuss search requirements. The suggestions and recommendations of the Committee have been taken into considera-l tion in the proposed revision of the rule.
! Miscellaneous Safeguards-Related Amendments j
The Safety / Safeguards Review Committee, during their task cf studying power reactor' safeguards requirements and practices in order to determine whether actual or potential conflicts existed with plant safety objectives, visited several licensee sites and observed plant operating conditions. The suggestions and recommendations of the Committee's findings have been t'aken into considera-tion in the proposed revision of the rule.
OTHER, SUPPORTING INFORMATION These proposed rule changes are presented together because of their marked interrelationship. Any major changes to the principal components of the pro-posed access authorization program could affect the proposal to relax require-ments for lock and key controls and other current requirements.
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DESCRIPTION OF THE INFORMATION COLLECTION Number and Type of Respondents Although the proposed rule applies to all existing and future nuclear j
power reactor operating licensees, the information collection requirements in the proposed rule will be applied on a reactor site basis and not on the basis of reactor units. Some sites have multiple units; thus, proposed information collection requirements will apply to 61 existing reactor sites, and approxi-mately 10 additional sites over a 3 year period, covered by the OMB clearance, for a total of 71 respondents.
Reasonableness of the Schedule for Collecting Information The license applicant whose application for an operating license was submitted prior to the publication date of the final rule in the Federal Register will be required to submit to the Commission his Access Authorization Plan and security plan for approval within 120 days of the effective date of the rule.
Based upon NRC staff experience in preparation of security and contingency plans and experience in implementing ANSI 18.17, the NRC believes that 120 days is a reasonable period of time for a licensee to compile and submit such a plan.
Under rules currently in effect, a licensee may 'equest an extension of time which is normally granted based upon good cause. Within 360 days after the rule becomes ef fective or 120 days after approval by the Corrmission, which ever is later, the licensee is required to implement the requirements of his approved plan. l The applicant whose application is st.bmitted after the final rule is published in the Federal Register shall include the Access Authoriza-tion Plan with the application submittal.
I METHOD OF COLLECTING INFORMATION Accass Authorization Plans and amendments to security plans submitted to the Commission will be reviewed, approved, and filed by the Commission.
Specific licensee Access Autho'ization Plans and amendments to security plans will not be published for public review or comment in accordance with 10 CFR 2.790(d).
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ADEQUACY OF THE DESCRIPTION OF THE INFORMATION It should be noted that the burden hours for following the guidance have been included in the estimate of burden hours found in the Estimate of Burden section.
Access Authorization Rule A draf t " Standard Format and Content Guide for the Nuclear Reactor Access Authorization Rule," being published with the proposed requirements, provides a detailed description of the recommended format for the plan. This standard format will be provided to each licensee as a guide for use in developing its plans. The information collection is designed to provide a uniform basis for determining an individual's trustworthiness and reliability through investiga-tion into an individual's past history and background, as well as through a psychological assessment of the individual's personality.
Search Requirements Rule Regulatory Guide 5.7 provides guidance to the licensee for conducting personnel searches. According to this guidance, the licensee will document the testing of the search eouipment before the beginning of each guard shift.
Such testing and documentation is necessary to assure that search by metal l
detectors and explosive detectors is meeting rule requirements.
{
l Miscellaneous Safeguards-Related Amendments A draf t " Miscellaneous Amendments Guide," being published with the proposed requirements, provides guidance to the licensee for meetin( the requirements )
of the Miscellaneous Amendments. The licensee is required to document any
, revisions to the licensee's physical security plan as a result of these amend-ments through submittal of revised portions of the licensee's security plan as appropriate.
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RECORD RETENTION PERIOD Access Authorization Rule Each litersee, contractor or supplier who collects personal information on an employee for the purpose of complying with this section is required to establish and maintain a system of files and procedures for the protection of the personal information. Such personal information collected and maintained will not be disclosed to persons other than the subject individual or those who have a need to have access to the information in performing assigned duties in the process of granting or denying access to protected areas and vital areas.
'The licensee will also confidentially maintain the records of those audits per-formed on contractor screening programs. Files of documents relied upon by the licensee will be available, at, the licensee's site, for examination by the NRC to determine the licensee's compliance in implementing its approved plan. The Commission requires that the licensee maintain the access authorization file of an individual for the period of access authorization and for an additional 3 year period subsequent to termination of the indiv.idual's unescorted access authorization for protected areas and vital areas.
i Search Requirement and Miscellaneous Safeguards Related Amendments Neither of these two reporting amendments contains a new record retention I requirement.
Records necessary to execute the new requirements are already being kept by the Licensee under OMB Clearance 3150-0002.
EFFORT TO REDUCE SMALL BUSINESS BURDEN
. The NRC has determined that the affected entities are not small entities of businesses as those terms are used in the Regulatory Flexibility Act.
CONFIDENTIALITY OF INFORMATION None, except for proprietary or safeguards information.
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u SENSITIVE QUESTIONS None.
REPORTING PERIOD Submittal of an Access Authorization plan and amendments to the security plan are required from each licensee 120 days after the effective rule is published in the Federal Register, in order to obtain NRC approval. The plans are then maintained by the licensee for the life of the plant and are avLilable for review by the NRC as needed.
COPIES REQUIRED TO BE SUBMITTED
, Access Authorization Plan Licensees are required to submit the original and two copies of each required submittal to the NRC for review and approval.
Amendments to Security Plans Licersees are required to submit five copies of each required submittal to the NRC for review and approval. One copy of each will be disturbed to:
o Regulatory Files (Docketing) o Office of Nuclear Material Safety and Safeguards o Regional Office o Advisory Committee on Reactor Safeguards (ACRS) o Office of Nuclear Reactor Regulation The security plans contain safeguards Jnformation and, therefore, cannot be duplicated by the Docketing Office where they are initially received and then distributed to the appropriate offices. Since the plans contain large blueprints and various photographs, it is more cost effective for the licensees to reproduce the five needed copies for submittal to the NRC for expedient review and approval as they are currently doing.
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. _ _ - - . . -. ~. _- . . - - - _ _ _ . _ _ _ , - , _ _ _ ._ -- - . .. . ._.
s.
P E 5 f lMAIF OF BUitO( N
's Cost to Industry =
+
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- a. Reporting Requirements Per Site Respondent Industry Respondents f requency Staff Hours Total Industry Burden Hours Total Annual Annual Burden Hours of Response Per 3 year Regulatory Section One time Site Burden Hours Number of histing future Annual Response One time Average Annual imisting Respondents future (61 sites) (10 sites)
- 1. 10 CTR 50.34(h) 1 800 800 267 267 10 Access Authorization 2.670
, Plan I 2. 10 CfR 73.56(a) 1 800 800 267 267 Access Authorization 61 16,287 Plan
- 3. 10 CFR 73.55(d)(1) 1 16 16 5 5 5 amend Physical Security 61 305 Plan (Search Requirements)
- 4. 10 CFR 5 73.55 1 24 24 8 8 amend Physical 61 488 i
Security Plan (Misc. Amendments)
Total Reporting: 280 267 17,080 2,670 Reporting Total Hours; 19,750 4
e 4
- b. Recordkeeping Requirements Per Site Respondent Industry Respondents
- Total Industry Frequency Staff Hours 8urden Hours lotal Annual Annual Burden Hours of Response Per 3 year Site Burden Hours Existing' Existing 3 Future , !
Rrgu17 tory Section One time Annual Response One time Average Annual Existing future (9 sites) 52 sites (10 sites)
^
Background Investigation 1500 75 5 7500 2500 375 375 2875 3,375 --
28,750 Review and Action 1500 75 4 6000 2000 300 300 2300 2,700 --
23,000 Employee reveals new 5 2 10 10 10 90 --
100 information and action
Psychological Assessment Tests 1500 75 3 4500 1500 225 225 1725 2,025 --
17,250 Interview 500 25 1 500 167 25 25 192 225 --
1,920 Review and Action 1500 100 .5 750 250 50 50 300 450 --
3,000
Continual Observation Program Deployee Evaluations 1500 .5 750 750 750 6,750 39,000 7,500 Referals 3 5 15 15 15 135 780 150 Supervisor Training Program 1 320 320 107 107 107 963 5,564 1,070 Maintain 1 12 12 12 12 108 624 120
Rrciprocity and Temporary Access Transfer & Reinstatement 225 .3 675 675 675 6,075 35,100 6,750 Temporary Access 1000 5 500 500 500 4,500 26,000 5,000
Appeal-Grievance .
Establish-amend procedures 1 80 80 27 27 27 243 --
270
~-
Inform Employees 1500 300 .1 150 50 30 80 80 720 800 Notice of Suspension 60 9 1 60 20 9 9 28 81 --
280 Rebuttal 60 9 1 60 20 .9 9 28 81 --
280 Hearing 60 9 64 3840 1280 576 576 1856 5.184 --
18,560 Decision Notification 60 9 16 960 320 144 144 464 1,2% --
4.640 Subtotals: 3889 11,944 35,001 107,068 '119,440 8 Denotes sites not subject to "grandfathering" 2 Denotes sites subject to "grandfathering" 3
- . .- . - . = - -_. . ~
's
- b. Rrcordkt4 ping Rrquirements (Continutd) ~
Per Site Respondent Industry Responr4nts ,
iotal Industry Frequency Staff Hours Burden Hours Total Annual Annual Burden Hours of Response Per 3 year Site Burden Hours Existing 3 Existing x Future Rrquirtery Section One time Annual Response, One time Average , Annual Existing Future (9 sites) (52 sites) (10 sites)
Pratection of Information Privacy Protection Program 1 80 80 27 27 27 243 1404 270 Inform Employees 1500 300 1 150 50 30 80 80 720 4160 800
' Audit 1 40 40 40 40 360 2080 400 Other burdens are included in previous sections.
Equipment test record 355 5 min 30 30 30 270 1560 30
- 8. 10 CFR 73.55 Access Authorization List 12 3 36 36 36 325 1872 360 Subtotal: 213 213 1918 11,076 1860 Total recordkeeping: 4,102 12,157 36,919 118,144 121,300 Recordkeeping Total Hours: 276,363 GRAND TOTAL Reporting Hours 19,750 Recordkeeping Hours 276,363 Total Annual Industry Burden:
- 296,113 3Denot'Is sites not subject to grandfathering 80enotts sites subject to grandfathering.
's.
- c. Estimate Cost Required to Respond to the Collection o future Site Industry
- Existing Site 16,800 $ 16,020 $ 1,185,000
- 1. Reporting Requirements $
246,120 729,420 16,581,780
- 2. RIcordkeeping Requirements
$ 745,440 $ 17,766.780 Total 5 262,920 mindustry cost consists of 61 existing sites and 10 future sites.
- d. Source of Burden Data and Method for Estimating Burden Number of burden hours x fully loaded salary at $60 per hour x site.
- e. Rrasonableness of Burden Estimates The burden estimates are derived from consultation with the regulated industry and staff experience.
Cest to the Federal Government
- a. Access Authorization Rule 10 CFR 50.34(h):
It is estimated that ten new sites will sut3mit plans for review and approval within three years which will cost the NRC about $67.2K (14 staf f-days /
pltn x 10 new plans x $480/ staff-day) to process and $53.6K (2 staff-days / plan x $480/ staff-day x 61 plans) to maintain.
10 CFR Part 73:
It is estimated that it will initially cost the NRC $409.9K (14 staf f-days / plan x 480/staf f-days) to review and approve all submitted Access Authorization Plans.and $187.2K additional inspection effort (preparation of revised inspection procedures (0.5 man-year) + additional inspection hours (1.0 man year).
It is estimated that the ten new sites will cost the NRC about $124.8K (1.0 man year ef forts @ 124,800/ man years) for additional inspection efforts.
s.
-a COSI SumARY IABlj
- e Subsequent NRC Initial Years Licensing Review $ 409.9K $ 125.8K Additional Inspection Effort $ 181.2K $ 124.8K Total 5 591.lK $ 250.6K ,
- b. Starch Requirements Rule It is estimated that it will cost the NRC $58.6K (2 staf f-days / plan x 61 plans x 480/staf f-days) to review and approve all submitted security plans.
It is estimated that ten new sites will submit plans for review and approval within three years which will cost the NRC about $9.6K to process (2 staff-days / plan x 10 plans x 480 staff-day).
- c. Miscellaneous Safeguards Related Amendments it is estimated that it will cost the NRC $234.2K (8 staff-days / plan x 61 plans x 480 staff-days) to review and approve all submitted revised sscurity plans.
It is estimated that ten new sites will submit plans for review and approval within three years which will cost the NRC about $38.4K to process (8 staff-days / plan x 10 plans x 480/ staff-day).
- d. Tctal Cost: $ 1.188.5K-I i
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