ML20206F277

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Request for OMB Review & Supporting Statement Re 10CFR25, Access Authorization for Licensee Personnel. Estimated Respondent Burden Is 14 H
ML20206F277
Person / Time
Issue date: 11/08/1988
From: Mcdonald W
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
To:
References
OMB-3150-0046, OMB-3150-46, NUDOCS 8811210075
Download: ML20206F277 (9)


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WIGli1TD ORICCH, staed;,d r,<h 83 Reeuest for'OMBiidhTeSi

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important Read enstruct;ons before completir form. Do not use the same SF 83 Send three copies of this form, the mitt nal to be reviewed, and for to request both an Executive Order.2291 review and approval under paperwork-three copies of the suppor*r "atement, to:

the Paperwork Reducten Act Ar.swer all queshons in Part 1. If this request is for reiew under E.O.

Office of Information and Regulatory A rs 12291, ccmpiete Part it and sign the regulatory certittcation. If this Offwe of Mar.agement ard Budget I

reovest is for approval under the Paperwork Reducteon Act and 5 CFR Attention: Docket Ubrary, Room 3201 1320, slup Part II, complete Part til and s'go the papererork certificaticn.

Washirgton, DC 20503 PART l.-Cornplete This Part for All Requests.

1. Deprt+ent/ agency a-o Bureau 'of hce or g nat.ng request
2. Agency coce 3

1 5

0 U. S. Nuclear Regulatory Commission U.orre of person ano can best answer cuest.ons ruard as this recuest Teteps.ie numoer Cynthia G. Hart,augh f 301 > 492-4128

4. Iltle of iriforff ation CC4 ectCO Cr rVemaking I

10 CFR 25, Access Authorization for Licensee Personnel

5. Legal aut'or;ty for inforcrat on co ect.on or rule cc:te vruted States Ccce, Puohc Lan. or becutar order) 42__usc 2165,2201 E.O.12356; Atomic Energy Act of 1954
6. Attected gubhc(cre.a attthaf aco))

5 C Federalagencies or empicyees i

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! C :ndmosa s or housencos 3 O rarns s C Non prof t irst,to. '.ns 2 C State orlocalgosernrnents 4 D Bus.resse< or otner for pro,t 7 C Sma'l buwesses or orgamesters r

PART ll.-Complete This Part Onlyif the Requestis for OMB Review Under Executive Order 12291 I

7. Regu'aton Idert Aer Number (Rit4)

_ ~-" _ _ _ _. Or, None ass goed C

8. Type of sur u4n (chea ere tr' e.rch categc0)

Type or rerle ur requested CUssirication stago of esvelopment g O $ranc4ra 1 O Ma9 1 C Proposed or draft 2 C Pendmg

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2 C o.onma o, 2 C Finat or.et er,m f.-nai. nit'i pncr propod 3 C Emergency 3 C Final or <4erm hnal. vrthei.t pra prxosat 4 C Stat.1orr or jud.c.# deapre

9. CF R Secten attected

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CFR

10. Doea tNs regutat cn centa.n rete t rg er rec vdb ears requiremeets trat reswee CMB atproval under the Paperwork Redaten Act t

a6d 5 CF M 1320?

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11,it a rt atee ruie. e r

s poi.cy d.rectnes have been ccepFed a th

$taat.re of program officia!

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Date 8J11210075 001100 PDR ogg EUSOPIB 5.gnature of a.,tNwee reg hton conta:t PNU D*t*

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C PART lli.-Complete This Part Only if the Regt.ast is for Approval of a Collection of information Under the Paperwork Reduction Act and 5 CFR 1320.

13. Abstrar* -Describe needs ses and affected pope in 50 "Access, security" Licensees and other organizations Ddsorless.g., fuel cycle facilities, licensee contractors) are required to provide infonnation to ensure that an adequate level of protection is provided for NRC classified information and material.
14. Type of infortnation cvocton (check en/y one)

Intnrmation ceMeetlese not contained kt rutee 10 Regutar suom ss on 2 O tmersency submission (cert,r, cat.oriattached>

Infortrwtien conectione contained hs rules 3 @ Emsting regulate (nochangeprcrosed) 6 Final or intenm fmal mthout pnor NPRM

7. Enter date of espected or actual Federal 4 O Notice of proposed rulemaking(NPRM)

A O Reguiar subm ssion Reg ster pubscation at this stage of ruiem k,ng s O rinar, sen M.a. previous 1y puboshed s O tmergency submission (certer cat +> setxh.4)

(rnanth. aar. rear >:

15. Type of review requested (check ovy one) 10 new ewecte 4 O Remitatement of a previously appre red conect.on eor wh.cn approvai has expwed 2 O Revis.cn of a currentF approved cWecte

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3 @ Estensen of the empirate date of a currently approved conectson s O tustingconectoninuw-thoutanoMecontroinumber without any enarse in the substance or in the method of collection

16. Agexy report iorm number (s)(#ncOde standartf/optonal form number (s))
22. Purpose of informat.on cc"ection (check as many as appty) 1 O Apphcat.on for benevits 2 O erogramevsivaten
17. Annual reportmg or disclosure burden 3 0 cenersi purpow statist cs 1 Number of respondents.

4 @ Re:utatoryorcompliance b'9 5 O Program planning or management 2 Number of responses per respondent N

6 O Research 3 Total annual responses (kne I times hne 2) 7 7 O Audit 4 Hours per response 6l 5 Totat hours (tme 3 ters line 41

18. Annual recorckeep.ng burceu
23. Freqancy of recordkeepng or reportmg (checa ## that appry) 14 1 @ Recordkeepeg 1 Nember of recordkeeperb 2

n,,,, tin,

  • 2 Annual hours per recordkeeper.

20 2 @ onoccasion 3 Total recordkeepmg hour 9(Ice I times one 2; 4 Recordkeeprg retenton period 3

years 3 g w,,g,y I

13. Total annuat burden 4 0 uonthly 90 S O Quarterfy 1 Requested (kne 17 5 plus Irne 18 3).

109 s O se mi.annuaity 2 In current CMB mventory -

  • Ek 7 0 Annuany 3 Difference (ImellessimeE).

gsplanation of d tterenee S Q 8,ennaafty

-l4 9 O otser(descno ).

4 pregram chant;e

$ Adgstment

20. current (most recent) OMS cortroi nurrbef or comment number
24. Respondents' obogst;on to compy(chec4 the strorgest o66satot thaf spptees) 3150-0046 1 O voeuntry
21. R;4.ested espiratton date 2 O Required to obtain or retain a benefit 1/31/92_

3 0 Mandcon-

25. Are the respondents pnmarity educational agencies or institutons or es the pnmary purpose of the c$ect.on related to fedraf educaton programst O
26. Doss tre agenef use samphes to a ect responder as or does the agency recommend or prescr.de the us* of samphns or

.. O ves 0 no by r*6pondents e

H.Regut.t 50 crR Part 25 authority for the informaton conecton

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e,,ou,r (spofy)

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Paperwerk CeWifkatloa fn subm.ttirg this request for oMB approsal, the agency P. 4. the sen.or off<ial or an authortred representatree, certifies that the requirements of 5 CFR 1320. the Ftri cy Act, stat.stical standards or d.rectrees, a'"4 any other apphcable information pohey dweetnes have been comphed wth.

Dste Swture of preg +am ettcial m

Date pg s gwo ot a u

Wf liam G.. Mcdonald. Director. Office of AdministraHnn hennrene ll/l /88 4

Mariagemento cro, i o. 4s3. m

O OkBSUPPORTINGSTATEMENTFOR 10 CFR PART 25 Access Authorization for Licensee Personnel Description of the Information Collection The re)orting requirements of 10 CFR Part 25 affect approximately 14 licentees and ot1er organizations (e.g., fuel cycle facilities, licensee contractors).

The licensees or other organizations 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 temination, cancellation or reinstatement, 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 res)onse to the application, recordkeeping and reporting requirements is availasle for public inspection in accordance with 10 CFR Part 9.

A.

JUSTIFICATION 1.

Need for Collection of Infomation.

10 CFR Part 25 contains numerous reporting, recordkeeping 1.nd application requirements, including requirements for submittal of personnel security access authorization requests, snurity 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. connon defense and national security. Escentially, all of the reporting, recordkeeping and application requirements are necessary for one or more of the reasons listed below, a.

To obtain the essential data from individuals necessary to determine their eligibility for an NRC access authorization for access to classified infonnation. These infomation requirements are derived from pertinent statutet, and Execative Orders which authorize background investigations on an l

individual's character, associations and loyalty.

t, To obtain essential data describing normal operating hrocedures pertinent to personnel security and visitor control 1.ctivities to ensure that regulatory requirements are being met by licensees and other organizations.

cc To'obtain essential data which serves as the batis for deter-mining continued eligibility of an individual fo an NRC access authorization when occurrences cr developments onse which may affect the initial determination.

The currently effective infomation collection requirements of 10 LFR Prrs 25 are identified and explained below:

25.11 Exemption Requests. The information and justification i

required by this section are used to detemine 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.

I 25.17(b) NRC Access Authorization Request Form.

(NRC Forn 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) 4 that the licensee or other organization endorses the request.

i 25.17(c) Personnel Security (Access Authorization) Packet. The l

information requii'ed by this section provides the pertinent data necessary to conduct an initial or u > dating investigation used to l

f determine the respondent's trustwortiiness and his/her eligibility for access to National Security Infomation or Restricted Data. The information submitted on the SF 86, Parts 1 and 2 (cleared under I

3206-0007) is reviewed by SEC staff and forwarded to the appropriate investigating agency.

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

1 i

25.21(b) Reporting Personnel Security Data. The reports and i

information required by this section ensure that personnel security i

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 I

1 NRC classified information.

"Data Report on Spouse;" NRC Form 354, j

is cleared under 3150-0026.

f 25.23 Notification of Access Authorization Approval. The maintenance l

of access authorization grant letters permits review and confimation l

during prescribed NRC surveys that only properly authorized employees i

havt had access to classified information. This recordkeepi requirement ensures these records are available for review b NRC inspectors and that they can be compared against records hel by the l

)

NRC Division of Security. The records under this section must be i

kept for three years following the access authorization termination 1

date.

i i

1 l

OMB SUPPORTIhG STATEMENT 10 CFR PART 25 I

I

25;25 Access Authorization 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 teminate its processing of the individual and to notify the investigating agency that the investigation may also be cancelled. This action saves the l'. S. Government specific processing costs and curta11s unnecessary invettigations and invasions of privacy.

25.27(a)&(b) Reopening Cancelled Requests. These sections identify the personnel security infomation 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. These procedurer, are required in order i

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 tominated) to reinstate or reactivate the access authorization.

i 25.31(a)&(b) Extension or Transfer of the Individual's Access 1

Authorization. The procedures and requirements provide the necessary infomation to properly identify and process an individual for an extension or transfer of their access authorization.

25.33(b)24 (c) Reporting Access Authorization Teminations. 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 been found ineligible for a i

continuing access authorization.

25.35 Classified Visits.

These procedures and the use of NRC Form 3150 0051) ensure that only properly authorized 277 (cleared under individuals who require access to classified matter as a part of i

their official duties will have such access during visits to other j

facilities and agencies. The recordkeeping requirement f three years following the expiration riate of the visit authorization) for this section permits the review and inspection of documents related to classified visits. This review, completed during periodic surveys, j

will insure that only properly cleared individuals have been granted access to classified infomation during visits in accordance with the provisions of this Part.

e Except as noted for 25.17 (c), there is no duplication with any other Federal agency reporting requirements for all of the above. For each of the reporting requirements the respondent is not required to submit more than two copies of any response.

2.

Agency Use of Information.

Personal history infomation which is sutetuted by applicants for access authorizations is reviewed, eval-i usted by Division of Security personnel and provioed to OPM which conducts background investigations. The NRC reviews the data from l

l OM8 SUPPORTING STATEMENT 10 CFR PART 25 1

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

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

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

3.

Reduction of Burden Through Information Technology. There is no significant impact upon the information collection requiremerit through the application of information technology. Only a small portion of other agency information [e.g., 425.17(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 i

government agencies. Whenever possible, NRC uses these alternative sources of information.

5.

Effort to Use Similar Information. These requirements and procedurts do permit NRC to use information already collected by other Federal agencies for similar access authorization programs. However, personal h' story infonnation 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 si,all business enterorises or entities.

7.

Consequences of Less Frequent Collection.

If the information is i

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. cosmon defense and national security.

8.

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

9.

Consultation Outside the Agency. The currently effective a> plication, recordkeeping and reporting requirements in 10 CFR Part 25 iave been

.the subject of fonnal rulemaking stoceedings. Any new proposed information collection and recordcoeping requirements will be published as part of a proposed rule, subject to public coseent.

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

I

10. Confidentiality of Information. The information collected is used to determine an applicant's eligibility for access authorization. The information is )rotected from public disclosure under the Privacy Act of 1974 and is iandled in accordance with routine uses specified in the Privacy Act Statement provided with or on each form.

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OM8 SUPPORTING STATEMENT 10 CFR PART 25

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11. Justification fo'r Sensitive. Questions. Sensitive information collected under this program has been authorized under DM8 Clearsnce Nos. 3206-0007, 3150-0050 and 3050-0051.

12.

Estimated Annual Ccst to the Federal Government. The estimated cost to the Federal Government in administering the program and procedures contained in these requirements is:

Annual cost - professional effort

$33,900 (565 hrs. X $60/hr.)

=

Annual cost - clerical effort

$15,400 (770 hrs. X $20/hr.)

=

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

209

=

$49,509 Total annual cost

=

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 Chance in Burden. Burden estimates have changed, in part to reflect the acdition of Two new licensees which are subject to the requirements of 10 CFR Part 25; and to reflect reductions in sections 25.11 (Exemption Request) and 25.31 (Exemption or Transfer of Access Authorization) for which previously projected estimater, have proven to be to high.

15.

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

I i

OM8 SUPPORTING STATEMENT 10 CFR PART 25

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ATTACMENT A t

10 CFR 25 BURDEN ESTIMATE

)

Total No. of Annual Total Hours per Burden Cost to Section Requirement Respondents Responses Responses

Response

Hours Respondent Reporting 25.11 Exemption Request 1

1 1

.5

.5 30 25.17(b) NRC Access Authorization Request -

Form cleared under OMB control number 3150-0050.

NRC Form 237 25.17(c) Personnel Security Packet Form cleared under OMB control number 3206-0007.

SF 86 25.21(b) Reporting Personnel Security Data Form cleared under OM8 control number 3150-0026.

NRC Form 354 25.25 Access Authorization Cancellation 14 5

70

.25 17.5 1,050 25.27 Reopening Cancelled Requests 6

2 12 2.0 24.0 1,440 (a) & (b) 25.29 Access Authorization Reinstatement 4

3 12 2.0 24.0 1,440 25.31 Extension or Transfer of Access 1

1 1

.5

.5 30 (a) & (b) Authorization 25.33 Reporting Access Authorization Form cleared under OMB control number 3150-0049.

(a) & (c) Terminations - NRC Form 136 25.35 Classified Visits Forn cleared under OMB control number 3150-0051.

NRC Form 277 66.5

$3,990 Totals

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O ATTAOSENT A 10 CFR 25 BURDEN ESTIMATE Annual Total No. of Hours per Rcrdkpng Cost to Section Requirement / Record Retentior Rcrdkprs Rcrdkpr Hours Respondent Recordkeeping 25.11 Exemption Request (3 yrs) 1

.1

.1 6

25.23 Notification of Access Authorization 14 2.0 28.0 1,680 Approval (3 yr) 25.35 Classified Visits (3 yrs)

Fom cleared under OMB e ntrol number 3150-0051.

NRC Fom 277 28.1

$1,686 Totals