ML20205J512

Request for OMB Review & Supporting Statement Re NRC Form 277, Request for Visit or Access Approval. Estimated Respondent Burden Is 5 H

ML20205J512
Person / Time
Issue date:	02/18/1986
From:	Dopp R, Norry P NRC OFFICE OF ADMINISTRATION (ADM)
To:
References
OMB-3150-0051, OMB-3150-51, NUDOCS 8602260046
Download: ML20205J512 (9)

Text

)ESIGNATE;.b .OT@iNA S"d' """ s 3

. 3.-. i . Request for DMB Review Important l Read instructions before completing form. Do not use the same SF 83 Send three Copies of this form, the material to be reviewed, and for to request both an Executive Order 12291 review and approval under paperwor k-three copies of the supporting statement, to:

the Paperwork Reduction Act.

Answer all questens in Part I. If this request is for review under E.O. Of fice of Information and Regulato*y Affairs 12291, complete Part 11 and sign the regulatory certification. If this Office of Management and Budget request is for approvat under the Paperwork Reduction Act and 5 CF R Attention. Docket L.ibrary, Room 3201 1320. skip Part 11, complete Part lli and $sgn the paperwork certification. Washington, oC 20503 PART 1.-Complete This Part for All Hequests.

1. Department / agency and Dureau/of fece origmating request 2. Agencycode U.S. Nuclear Regulatory Commission Office of Administration Division of Security .L _1 L _0_

3. Name of person wno can best answer questiorts regarding this request Telephone number Richard Dopp

4. Title of mtormat.on collection or rulemakmg

( 301 ) 492-4124 Request for Visit or Access Approval S. Legal authovety for stdormat.on ccHettton or rule (cote (Jnsted $tates Code. Purvoc tas. or becutne Order) usc .orAentire3rAer IDE6

6. Affected pubhc(chec6 allthatapptr l 5 O r,oe,ai agencies or employees i O ind,v.duais or housenoids 3 0 ra,ms s O Non prof tinst,tutions i

> 2 O state or ic4ai eo,e,nmenti 4 G Bosmesses or eener to, prof.e i O smasibusmesses or organisations l

PART ll.-Complete This Part Only if the Request is for OMB Review Under Executive Order 12291

7. Regulat*on Identd er N.Jmber (RIN)

___~ _ _ _ _. or None ass-geed O j 8. Iype of subm ssuon (ctnk one on each category)

Type of reusew requested Classification Stage of development 1 Q stanoarc 1 O uator i O eroposedo,d, aft 2 O eend,ng 2 O nonma,or 2 O rin orint r mfinai,w,th pno,prupowe 3 0 tmergenc, 3 O Finalor inteam final, without prior propuwe 4 0 statutor, or tudiciaideadatse j 9. CF R section affected CFR

! ^

10. Does thes regulanen(cr<ta,n reportieg or recordkeeperst requirements that require oMB approvat under etw PapIrae4 Redu c tion Act

, and 5 CrR 1320'

. O ves O No

( l1, it a myor ru'e,is tN te a re6ulatory impact analysis attached >

I tt 'No,"did OMO a+ve itse ana ps' 2 O ves a O no 3 0 vei 4 0 no

{ C:rtiffection for Regulatory Submissions in submittmg pu.c, tn.s directaes have rewest t>een tot OMB camps,ed witn rev.ew, tre authonzed regulatory omtact and tt e program effeoa' cert <tv that the requ,rements of E o 12291 and l

$Thatufe Ot p'0 gram off4 141 Date t

$ht[rd aathorsterd rey story Lot) tact 8602260046 960219 . Da

PDR ORG EUBOMB '

PDR S 2. quMU use errty)

Pr.,u er e e onume r6Pe NO 00 t.14 4034 gj ggy stenae,a ie,m a a Wev 9 M O l

P+eurw %, (iWI SCFR 1120W t 0 IN91

- PART lil.-Comptt2 This P:rt Only if ths RIqu:st is f r Appr:v:1 cf e C:llicti:n dif InformrtiTn Under th2 Paperw:rk R ductirn Act cnd 5 CFR 1320.

13. Aestract-oescnbe neces. uses anc a"<cted pa.c in so.ords or iess "C1 assi fied Visi ts" NRC Form 277 data provides assurance that only properly cleared authorized individuals, who require access to classified information as part of their official employment duties, will have access during visits to NRC, other contractor or licensee facilities or Government agencies.

14. Type of information conect on tcheca oh one)

Information collections not contanned on rules 1 M Regular submission 2 O Emergency submiss'en(cert r cat >on art rched>

Information collections contained in rules 3 O Esisting regulation (nochangeproposed) ' 6 Final or intenm final without prior NPRM 7. Enter date of espected or actual Federal 4 0 Notice of proposed rutemakmg(NPRM) A Regu!ar submission Register pubhcation at this stage of rutemaking 5 O Finat. NPRM *as prev,Cusly pubbshed B Emergency submission (cert f, cation attuhed) ('nontn. d.ry. p ear):

15. Type of reven ressested(chech on4 or c) 1 O New conectiori 4 0 Remstatement of a previousry approved conection for wnicn approv6 2 O Rev,s on et a currenti, appreved co riect.cn "*"' P'*d 3 $ Entensson of the espiration da'e cf a currently approved codection 5 C Eusting collection en use witnout an ov8 controi number without ary chage m the m;tstance or in the method of colicctiort

16. Sgency report fctm number (s) g nctuae standardioptional form number (s)) 22. Purpo e of mformatnon coliection (check as trany as apply) 1 O Appbcai>on for benefits NRC Form 277 2 O Program evaluation

17. Annual reporterg or d sclosure tscen 3 0 ceneraipurpose stat'Siscs 1 Nureber of res.%rcerts 4 b Regulatory or comphance 2 Nurcer et responses per res.m~?e .t I _ 5 O Program planning or managerrent 3 Total anna rescomes(oce 1 tas one 2) 30. a 6 0 Res,a,cn 4 Hours per resporte .167 7 O Aud't 5 Tc*alnou s (we 3 t,mes sme 4) 5

18. Annual recordbee:Heg burden 23. F requency of recordkeepmg or reporteg (check all that apply)

! Number of recordmeepe,s 30 i E) p,ccrd eep ng 2 Annual hou rs per recorckeeper .0167 n ,portin ,

3 Total recordbeepmg hours (hne 1 tms hne 2) .5 2 K] onoccaon 4 Recordneepmg re'ert.on period 2 years 3 O 4,,ggy

19. Total annual burden 4 0 cont"y 1 Requester t(He 17 5 04s Ime 18 3) . 5,_5 5 0 ouarterv 2 in cu rrent CMG mientory 11 0 _

-164.5 q s O semi annuay 7 O Annuaoy 3 0iffvence thne hess l>ne 2) _

brplanation of(fference 8 0 Brennial19 4 Program change 9 0 ciner(desci,be) 5 Adjustm nt . - R4. 5

20. Current (most recent) oMB controt number or comment nur-ter 24. Respnnder ts' obhgat,on te comph icheck the strongest c0hgation that applies)

_3110-0.051 i O voiunmy

21. RIquested emp> rat.on date 2 O Require 1 to obtain or retain a benefit 3-31-89 3 X) me,to,y

25. Ara the responcents primanly enca' onal ar,encies or mstitutions or is the comary purpose of the cotection reisted to Federal education programs? O ves G No

26. Does the agency use sarnphrg to sMect re*pondents or does tne agenc y rer.ommend r>r prewribe the use of same'ing or statistical analysis by respondents

~

. O ves 3 no

21. Regulatory aJthcr ty for the informa'..on conet tion

_ l0 _ oR.25.35 , o, rR , or,otne,(spersy)

Paperwork Cirtihcation in sut,mdteg tha. rewest fnr OMB apperrral, the agency head, tee ser..nr off< ai or an autncnted repte ertat.ve, certifies that the requirements of 5 cF R 1320, tne Orsvacy Act statotiel standards r r dvet t vet, and any other appfcable mformat on pnI<v direttives have tir eri comphed w th s.gne m c,vn g % ]o,te Ri hard A. Doop, Chief, Policy and Operational suoport Branch, Division of / /J//86 Securi ty

~~

$lgn etsr e of ager.cy te.> t% vneor of f r.at or 40 authorred representatere "IIith i Patricia G. NI7 ecto 0 fNe/f Administration r

d //f/86 I

(' GP0 s 1% 4 0 - 4S b 776

n OMB SUPPORTING STATEMENT FOR NRC FORM 277 Request for. Visit or Access Approval Description of the Information Collection s The information collection associated with the NRC Form ?77, " Request for Visit' or Access Approval," affects any employee of approximately 22 licensees and 35 contractors who: (1) holds an NRC access authorization; and (2) needs to make a visit to NRC, other contractors / licensees or government agencies in which eccess to classified information will be involved or unescorted area access is desired. The completed NRC Form 277 contains a signature certification of the NRC access authorization and of an official need-to-know. Only a minimal amount of other identifying / pertinent information (e.g., date of birth, clearance type, dates of visit) are requested by the form.

A records retention period of two years following the expiration date of the visit by both the requesting and visited facility is required for the form.

Personal information contained on the completed form is handled and protected in accordance with NRC directives and the provisions of the Privacy Act of 1974. Other information containad on, or pertaining to the form (e.g.,

recordkeeping and reporting requirements) is available for public inspection in accordance with 10 CFR Part 9. /

/

The use of NRC Form 277 affords so,ne assurance that only properly cleared and authorized individuals, who require access as a part of their official duties, will have such access during visits to other facilities and agencies.

Therefore, the use of the NRC Form 277 benefits the NRC Security Program and public at large.

0 A. JUSTIFICATION

1. Need for Collection of Information Section 4.1 of Executive Order 12356 states: "A person is eligible for access to classified information provided that a determination ,

of trustworthiness has been made...and provided that such access is essential to the accomplishment of lawful and authorized Government  :

purposes." Further, Section 5.3 requires agencies to "... establish procedures to prevent unnecessary access to classified informa-tion...."

The use of the NRC Form 277 as cited in Section 25.35 of 10 CFR Part 25 (applicable to licensees) and in NRC Management Directive 2101, -

Part IX (applicable to contractors) is the method by which NRC can provide assurance of compliance with the above provisions of E.O.

12356. The NRC 277 provides the facility / agency to be visited with verification of the visitor's NRC access authorization and certifica-tion of their official need-to-know for the classified information or area access involved, as well as, other pertinent information regarding the visit. By requiring the information collection contained on the NRC Form 277 the facility / agency can assure that only properly cleared and authorized individuals will be permitted access during a visit. f

2. Agency Use of Information.

The NRC Form 277 is forwarded by the licensee / contractor through the appropriate NRC office exercising oversight, licensing or regulatory authority for certification of need-to-know to the NRC Olvision of l

OMB SUPPORTING STATEMENT NRC TORM 277

Security (SEC). After clearance verification, SEC forwards the completed form to the security office having cognizance over the facility to be visited. The security office of the facility being visited uses the information collected to confirm identity of the visitor and to permit the visitor access to the requested classified I

information/ area. Failure to use the NRC Form 277 by the licensee /

l contractor may result in denied access to classified information or areas which are necessary in the accomplishment of official duties.

3. Reduction of Burden Through Information Technology.

No reduction in the information collection burden can be realized through information technology with respect to the NRC Form 277.

The infomation contained /obtained on the form is visit specific.

Also, original signatures are necessary for access authorization verification and need-to-know certification.

( 4. Effort to Identify Duplication.

In order to safeguard classified information, other Government agencies and certain facilities collect information, of a nature similar to the NRC Form 277, to verify the access authorization and confirm the need-to-know of visitors. The information collection on a given NRC Form 277 does not duplicate or overlap other information collections made by the NRC or other Government agencies since each visit / access approval is unique. With respect to the actual form, l essentially identical forms are used throughout the U. S. Government, yet there is no standard form available. Instead, there is reciprocal' acceptance of the forms among facilities / agencies.

I OMB SUPPORTING STATEMENT NRC FORM 277

6 0

5. Effort to Use Similar Information.

There is no similar information collection made by NRC or any other Government agency which could be utilized, since each visit approval is unique and requires the establishment of specific permissible accesses for the visit.

6. Effort to Reduce Small Business Burden.

None of the licensees affected by the use nf the NRC Form 277 qualify as small business enterprises or entities. The burden associated with this form is so minimal that there would be no significant burden on a contractor, if they qualify as a small business enterprise or entity.

7. Consequences of less Frequent Collection.

The frequency of infonnation collection is dependent on the number l of visits an individual makes to Government agencies or facilities.

In most cases, a less frequent collection would mean eliminating the collection, as visits by contractor / licensees, for which the NRC Form 277 would be required, are infrequent. If the information is not collected, access by the visitor to classified information or  ;

areas, necessary in the accomplishment of official duties may be denied. Further, a reduction in the collection of the information required by the NRC Form 277 would reduce the assurance that only properly cleared and authorized individuals will be permitted access during a visit. Thus, less frequent collection may endanger the U. S.

common defense and national security.

OMO SUPPORTING STATEMENT NRC FORM 277

i.

f

8. Circumstances Which Justify Variation from OMB Guidelines.

l There is no variation from OMB Guidelines in the collection of information.

s

9. Consultation Outside the Agency.  ;

No consultations.

10. Confidentiality of Information.

] The information collected is used to establish the permissible

, access associated with a visit for an individual. The information is l

l protected from public disclosure under the Privacy Act of 1974 and is ,

i' j handled in accordance with routine uses specified in the Privacy Act I Statement contained on the form. l t

j

11. Justification for Sensitive Questions.

! i i For identification purposes the NRC Form 277 requests the date of

{ birth and social security number for the visitor. This information is essential to assure that the access authorization.(clearance)  !

l information is conveyed for the correct individual.

! i

12. Estimated Annualized Cost to Federal Government, f

l The estimated annual cost to Federal Government associated with the j NRC Form 277 is $263.06. This cost was computed as follows:  !

i l Note: Annual form usage 30-for NRC licensees / contractors I

]

4 I

OM8 SUPPORTING STATEMENT -5. NRC FORM 277

Costs:

Annual clerical effort =

$100.00 (30 X 10.00 minutes - 5.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> X $20/ hour)

Annual professional effort = 150.00 (30 X 5.00 minutes = 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> X $60/ hour)

• Annual record holding (2 yrs) = 13.06 (1/16 cu. ft. X $209/cu ft.)

Total estimated annual cost =

$263.06 In the current OMB clearance, the processing cost associated with the internal agency use of the form was inadvertently included, causing an inaccurately high cost to the Federal government. The above estimate is accurate.

13. Estimate of Burden.

(Sharedamong57 licensees / contractors)

The total estimated annual hours of burden to the public associated with the NRC Forn 277 is 5.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. The total estimated cost to the public for use of this form is $313.06. These totals were computed as follows:

'The NRC Form 277 must be retained for two years following the expiration date

• of the visit authorization to permit periodic ' survey.

OM8 SUPPORTING STATEMENT NRC FORM 277

m I=

l.

l l Costs:

30 annual respondents X 10.0 completion minutes i per response = 6.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> burden x $60.00/ hour $300.00 l

l l

• Annual record holding cost (2 years)

(1/16 cu. ft. X $209/cu ft.) 13.06 Total estimated dollar cost $313.06

14. Reasons for Change in Burden.

There has been no change in the burden on the public associated with the completion of NRC Form 277.

15. Publication for Statistical Use.

l There is no application of statistics on the infomation collection l related to NRC Form 136. There also is no publication of the infor-mation.

• The NRC Form 2/7 must be retained for two years following the expiration date of the visit authorization to permit periodic survey.

t l

l l

l l OMB SUPPORTING STATEMENT NRC FORM 277

.