ML20207T079

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Advises That Resource Implications of Implementing FBI Criminal History Rule Examined.Proposed Approach for Handling FBI Fingerprint Cards & Anticipated Sequence of Activities for Processing FBI Fingerprint Encl
ML20207T079
Person / Time
Issue date: 10/03/1986
From: Norry P
NRC OFFICE OF ADMINISTRATION (ADM)
To: Roe J
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML19310E127 List:
References
FRN-51FR40438, RULE-PR-73 AC27-2-17, NUDOCS 8703230166
Download: ML20207T079 (7)
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.p g OCT 03 1986 MEMORANDUM FOR: Jack W. Roe, Deputy Executive Director for Operations Office of the Executive Director for Operations FROM: Patricia G. Norry, Director Office of Administration

SUBJECT:

RESOURCE IMPLICATIONS OF THE FBI CRIMINAL HISTORY RULE As requested at your meeting of August 13, 1986, we have examined the resource implications of implementing the FBI Criminal History Rule. Overall, the agency FTE requirements of implementing this rule are estimated at a minimum of 1.52 staff years the first year (i.e.,1 SEC FTE, .32 inspection effort FTE, and .2 RM FTE). Thereafter,1.22 staff years would be required (i.e.,1 SEC FTE, .2 inspection effort FTE, and .02 RM FTE). I have detailed these NRC FTE costs as well as contractor supplied effort in the enclosures, together with the coor-dinated RM, NMSS, and ADM proposal / assumptions for handling FBI fingerprint checks (see Enclosures 1, 2, and 3). Two key assumptions underlie our resource estimates and proposals for processing the fingerprints in a timely manner.

First, RM must develop, test, and have operational by January 1987 an efficient automated system for inputting and tracking fingerprint data; and, second, only those records necessary for administering and auditing this program will be maintained by the tracking system.

As you may be aware, the Edison Electric Institute (EEI) estimates an initial volume of 240,000 fingerprint cards (200,000 original submittals and 40,000 retake submittals) will be submitted to NRC over the 6-month schedule allowed by the rule. Thereafte , NRC should expect 24,000 fingerprint cards (20,000 original submittals and 4,000 retake submittals) annually. Based on data from the National Association of Securities Dealers, which operates a similar auto-mated fingerprint program, we estimate that 9 data entry and administrative /

supervisory personnel would be needed to process the 240,000 fingerprint cards

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expected under this program. These fingerprint cards will be processed by the NRC and FBI over a nine month period, beginning on the effective date of the rule. After this initial implementation stage, .5 FTE data entry staff would be required for the ongoing program.

The Division of Contracts, SEC, and RM are going to contract out for the necessary support services and personnel for this program, and have already taken action in this regard. The contract would provide for such matters as opening request packages, fee accounting activities, data entry, preparing packages for the FBI, returning packages to each licensee, coordinating work-flow, and supervision. The contract would also provide a daily courier service 8703230166 870318

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Jack W. Roe to deliver cards to the FBI and return completed ones to NRC. In addition to this contractor effort, ADM/SEC should be authorized 1 FTE for the initial management and ongoing control and administration of this program. With this

. 1 FTE, ADM/SEC would establish and maintain quality control standards, oversee the processing of the fingerprint cards and fees from the licensee, and ensure both the updating and safeguarding of the NRC tracking data and the timely .

return of the fingerprint cards /results to the licensee. ADM/SEC would also interact with the licensees concerning all processing issues and questions.

Please note that this program is in addition to present ADM/SEC personnel security initiatives and heavy work load requirements, including SEC's ongoing processing of 4,000 licensee employees for material access authorizations under 10 CFR Part 11.

Sevt.ral time sensitive factors should be highlighted. Under the provisions of the enabling legislation which the President signed into law on August 27, 1986, NRC must publish the Criminal History Rule as an effective rule in February 1987.

NRC must therefore be geared up and staffed by February 1987 to receive and process the fingerprint cards. Accordingly, RM must have the data entry and tracking system developed, tested, and operational by January 1987. Additionally, ADM/RM must have the data entry contract in place and trained personnel must be available by February 1987. ADM will work with RM to ensure that the contract ,

for maintaining this system and accounting for the data has the necessary -

language to ensure compliance with the Privacy Act. ADM has also initiated steps to make a minor. amendment to the NRC System of Records 39, Personnel Security Files and Associated Records - NRC, to include the receipt and pro-cessing of Privacy Act information under the Criminal History Rule. Space to accommodate the RM contractor personnel is under review. While space with or near SEC appears to be preferred from an administrative point of view, the decision is dependent on the capabilities of the automated system RM selects, as well as spaca availability in NRC buildings. ADM is pursuing this matter.

With respect to the information collection requirement of this rule, it will be t submitted to OMB for approval under the Paperwork Reduction Act. This process should not impact on the implementation of the rule.

There is one factor that may also impact on the implementation of this rule which requires close attention. NRC's FY 87 proposed Appropriations Act needs to be amended in order to use and disburse funds received from licensees under this program. If the Appropriations Act with this amended language is not passed or a continuing resolution does not contain the amending language, it could then cost the NRC up to $3,000,000, based on the latest work load

estimates provided by EEI, to implement this program in FY 1987. As currently proposed, the licensee would pay NRC a $15.00 fee for each original finge 3rint card submitted. NRC would pay $13.00 of this fee to the FBI and would rei.aln

$2.00 for each fingerprint card received, for an initial reimbursement of

$400,000 and a yearly reimbursement thereafter of $40,000. These funds would remain available for salaries and related expenses until expended.

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Jack W. Roe I am available to discuss the matter with you at your convenience.

ortsinaisigned by Patricia Nori7 Patricia G. Norry, Director Office of Administration

Enclosures:

1. Proposed Approach for Handling FBI Fingerprint Cards
2. Anticipated Sequence of Activities for Processing FBI Fingerprint Check of Licensee Employees
3. Assumptions / Constraints cc w/encis: J. G. Davis, NMSS H. R. Denton, NRR W. G. Mcdonald, EDO W. C. Parler, OGC R. M. Scroggins, RM J. M. Taylor, IE bec w/encls: R. F. Burnett, SG bec w/o encls: SCF A0P 1.01.07 L. L. Bush, IE SCF A0P 3.03.07-5 J. H. Corley, F0S D/SEC R/F R. A. Dopp, FSOSB PERSEC R/F J. M. Felton, TIDC D. H. Grimsley, DRR E. L. Halman, DC T. B. Kellam, TB I. A. Kirk, RM/D M. J. Mattia, DC E. W. McPeek, NRR P. G. Norry, ADM J. G. Partlow, IE P. Rowe, PSS E. C. Shomaker, 0GC R. P. Shumway, RM/B J. Yardumian, SG SCF PER 3.00.11 g,
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  • Enclosure 1 Proposed Approach for Handling FBI Fingerprint Cards -

Initial Submission and Subsequent Annual " Steady State" Condition Initial Submission

1. Shortly before rule is published, licensee will be sent a package con-taining fingerprint cards, a sample forwarding letter, and information on availability of an FBI Video Training Tape describing the correct way to take fingerprints.
2. The rule will allow licensees up to 180 days to submit cards on their "

current employees with unescorted access and/or access to Safeguards Information(SGI).

3. EEI estimates an industry volume of approximately 200,000 cards initially, with 20,000 annually thereafter.
4. The NRC processing load would amount to 200,000 incoming cards, 200,000 responses from the FBI, and reprocessing of rejected cards. Based on the FBI estimated rejection rate of 20% for illegible fingerprint cards, an additional 80,000 cards would be processed (40,000 incoming cards and a.

40,000 card response from the FBI). Thus, the total initial processing volume would be 480,000 cards.

5. Based on National Association of Securities Dealers experience, each experienced data entry person can process between 75 and 100 cards per hour. It would be unreasonable to assume this level of efficiency in a new operation. Accordingly, a rate of 50 cards / hour per person is assumed for NRC.
6. At a rate of 50 cards / hour / person, the 480,000 cards could be processed in 9 months with 7 data entry personnel, 1 administrative, and 1 supervisory personnel. On average, 2,800 cards would be processed each working day and at the end of each day all PC entries would be merged onto a dedicated PC/AT or the MV 8000, if appropriate.
7. As the volume of cards after the " bow wave" would drop dramatically to a low level of 20,000/ year, it would be unrealistic for NRC to hire 9 data entry and administrative / supervisory personnel for this purpose.
8. The Division of Contracts, SEC, and RM are going to contract out for the necessary support services and personnel for this program, and have already taken action in this regard. The contract would provide for such matters as data entry, preparing packages for the FBI, returning packages to each licensee, handling fees, and supervision. If appropriate, the contract should also provide a daily courier service once a day to deliver cards to the FBI and return completed ones.
9. ADM/SEC have stated that they must be allocated 1 FTE for the initial management and ongoing control / administration of this program; to establish and maintain quality control standards, oversee the processing of the fingerprint cards and fees from the licensee, and ensure both the updating and safeguarding of the NRC tracking data and the timely return of the fingerprint cards /results to the licensee.
10. Estimated contract or NRC purchase costs for this operation would be:

I system development effort for 2 months *........................$ 20,000 7 data entry personnel for 9 months. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .$ 157,500 1 admini strative indi vidual for 9 months. . . . . . . . . . . . . . . . . . . . . . . . .$ 18,000 1 s upe rvi s or fo r 9 mon th s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 30,000 1 PC/AT purchased with associated hardware and software *.........$ 6,000 7 leased PC's for 9 months *......................................$ 12,500 Courier Service for 9 months.....................................$ 6,000 Total 5 250,000

11. Initial NRC FTE:

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1 SEC staff project monitor / administrative officer (1 FTE).......$ 30,000

.32 inspection staff initial effort (.32 existing FTE)...........$ 11,500

.2 RM staff for task order development and administration

.2 existing FTE)..............................................$ 8,600 Total 5 50,100

12. The NRC would receive $2/ card for reimbursement..................$ 400,000 {

Less initial contract and FTE costs..............................$ 300,100 Amount available until expended to offset steady state operating costs................................................$ 99,900 Steady State Operation

a. Card receipts are estimated at 20,000/ year. Processing 20,000 cards from licensees and 20,000 returns from the FBI results in handling 40,000 cards / year. (Rejects will result in handling an additional 8,000 cards.)

At a handling rate of 50/ hour, 960 hours0.0111 days <br />0.267 hours <br />0.00159 weeks <br />3.6528e-4 months <br /> would be required to process the cards. Allowing for opening boxes, sorting fees, and supervision / overhead, approximately 1.5 staff years (1 FTE for SEC and .5 staff year for contractor) would be expended annually on this effort.

b. Total cost would amount to (.5 contractor staff).................$ 15,200 Courier cost for daily runs to FBI ($30/ day x 250 days)..........$ 7,500 PC/AT for data entry / tracking (previously purchased)............. NC
c. 1 SEC staff project monitor / administrative officer (1 FTE).......$ 30,000

.2 inspection sta f f ef fort ( .2 exis ting FTE) . . . . . . . . . . . . . . . . . . . . .$ 7,200

.02 RM staff for task order administration ( 02 existing FTE)....$ 900 T 22 Total 5 60,800

d. Annual receipts: 20,000 cards x $2/ card = $40,000/ year.

Ccmbined Cost During the first nine months of operation, the initial submission and the steady state submission would overlap. After 9 months, cost should stabilize at approximately $60,800/ year.

  • Note: The approach described above is based on information available at this time which is preliminary in nature and subject to change as better or more complete information becomes available. In particular, further analysis by IRM may indicate that microcomputer technology would be inadequate and pro-cessing may need to be accomplished on a miniccmputer mainframe such as the NRC MV 8000.

, Enclosure 2 ANTICIPATED SEQUENCE OF ACTIVITIES FOR PROCESSING FBI FINGERPRINT CHECK OF LICENSEE EMPLOYEES

1. Licensee takes fingerprints of existing and prospective employees that will have unescorted access to nuclear power plant or access to SGI and completes information (preferably typed) on fingerprint card. Docket number will be entered on each card for tracking purposes.
2. Fingerprint card (s) are mailed to NRC SEC by standard forwarding letter along with a check for the $15.00 fee for the first time fingerprint cards submitted.
3. Fingerprint card (s) and fee are received by NRC and preliminary reviews are made for required data and to ensure that the proper dollar amount was included for first time requests for an FBI record check. Fees are forwarded to RM/A upon receipt by SEC.
4. Record is created in an NRC tracking system to track the status (audit trail) of the card. (Additional IRM analysis is necessary to determine l whether this can best be accomplished by microcomputer or minicomputer l technology.)

I 5. Fingerprint card (s) are sent to FBI daily via special messenger.

6. Fingerprint card (s) are returned from FBI on a daily basis via special messenger with one of the following dispositions:

No record.

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Arrest record indicated with RAP (arrest) sheet attached.

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Illegible prints; retake prints and return card.

Turnaround time at FBI is on the order of 13 to 21 days.

t 7. Update NRC tracking system with date received from FBI and disposition (i.e., no record, arrest record indicated, or illegible prints).

Note: No specific arrest information will be maintained in the tracking system.

8. NRC sends the fingerprint cards and RAP sheets (if applicable) received from the FBI back to the licensee.
9. Only those records necessary for administering this program will be kept in the NRC tracking system.
10. Form letter is used as a means for the licensee to transmit the finger-print cards to NRC. The form would indicate the number of first time cards submitted and the dollar amount enclosed as well as the name and number of the person to contact in case of questions.

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. -r 1 Enclosure 3 l

ASSUMPTIONS / CONSTRAINTS

1. No fingerprint cards or arrest records would be retained by NRC. All such information would be returned to the licensee for handling-and retention.
2. Depending on the volume of cards to be processed in the initial submission, either a PC/AT with a 30 MB hard disk and a printer or the MV 8000, as appropriate, appear necessary for the NRC tracking of the status of the fingerprint check requests from the licensees.
3. To handle the initial surge of licensee fingerprint checks, a contract would be utilized to provide the data entry and support personnel for processing the initial surge of data. .
4. ADM/SEC have stated that they must be allocated 1 FTE for the initial management and ongoing control / administration of this program; to establish and maintain quality control standards, oversee the processing of the fingerprint cards and fees from the licensee, and ensure both the updating and safeguarding of the NRC tracking data and the timely return of the fingerprint cards /results to the licensee.  ;
5. Licensee would submit a check for the proper dollar amount for the first time submission of fingerprint cards. NRC would have an account with the FBI for monthly billing and cost reimbursement. NRC would prefer not having accounts set up with the licensees to avoid a complicated procedure for cost accounting.

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j#.. ....%g UNITED STATES PbR-O ^

NUCLEAR REGULATORY COMMISSION 3

a i WASHINGTON, D. C. 20$55 e

%. / OCT 3 1986 MEMORANDUM FOR: Victor Stello, Jr. .

Executive Director for Operations FROM: James H. Sniezek, Chairman Comittee to Review Generic Requirements

SUBJECT:

MINUTES OF CRGR MEETING NUMBER 96 The Committee to Review Generic Requirements (CRGR) met on Wednesday, September 17, 1986, from 1-5 p.m. A list of attendees for this meeting is enclosed (Enclosure 1).

1. R. Burnett and K. Jamgochian (NMSS) presented for CRGR review a legislatively mandated proposed rule entitled, " Criminal History Checks."

This matter is discussed in Enclosure 2.

2. L. Shao and J. O'Brien (RES) presented for CPGR review a proposed revision to SRP 3.6.2, " Determination of Rupture Locations and Dynamic Effects Associated with the Postulated Rupture of Piping " This matter is discussed in Enclosure 3.

,3. W. Houston and J. Ridgely (NRR) presented for CRGR review a proposed generic letter that would transmit to BWR licensees the technical findings in NUREG-1169 entitled, " Boiling Water Reactor Main Steam Isolation Valve Leakage and Leakage Treatment Methods." This matter is discussed in Enclosure 4.

The Enclosures contain predecisional information and, therefore, will not be released to the Public Document Room until the NRC has considered (in a public forum) or decided the matter addressed by the information.

In accordance with the ED0's July 18, 1983 directive concerning " Feedback and Closure on CRGR Reviews," items 1, 2 and 3 above require written responses from the cognizant office to report agreement or disagreement with CPGR recommenda-tions in these minutes. The responses, which are required within 5 working days after receipt of these meeting minutes, are to be forwarded to the CPGR Chairman and if there is disagreement with the CRGR recommendations, to the ED0 for decisionmakin -

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OCT 3 1986 Questions concerning these meeting minutes should be referred to Walt Schwink (492-8639). /

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f) e.s H. Sniezek, Chaiman ittee to Review Generic equirements

Enclosures:

As Stated .

cc: Commission (5)

SECY Office Directors Regional Administrators CRGR Members p W. Parker 1 R. Burnett l K. Jamgochian L. Shao J. O'Brien W. Houston J. Ridgely

Enclosure 1 LIST OF ATTENDEES CRGR MEETING NO. 96 September 17, 1986 CRGR MEMBERS J.H. Sniezek R. Bernero E. Jordan (for R. Starostecki)

J. Scinto F. Hebdon (for C. Heltemes)

R. Burnett (for R. Cunningham)

D. Ross OTHERS i

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Walter Schwink R. L. Fonner Kris Jamgochian Ralph Avery George McCorkle Bill Shields John Zerbe Larry Shao Joseph Yardumian J.E. Richardson Gene McPeek A. Murphy Liz Ten Eyck E. Igne Ronald Villafranco F. Cnerny Pat Norry I.D. Jamison Don Mausshardt A. Tse Loren Bush Jim Clifford David Diehl Jerry Hulman Jim Dunleavy John Ridgely Sarah Wigginton Ali Tabatabai Tom Cox Mat Taylor Jim Conran W. Minners Bill Brach Jerry Mazetis Ronald Bellamy Trip Rothschild

Enclosure 2 to the Minutes of CRGR Meeting No. 96 Review of Proposed Rule Entitled, " Criminal History Checksu R. Burnett and K. Jamgochian (NMSS) presented for CRGR review a legislatively mandated proposed rule entitled, " Criminal History Checks." A copy of their presentation is attached.

The proposed rule essentially repeats Section 606 of Public Law 99-399, "The Omnibus Diplomat . Security and Anti-Terrorism Act of 1986." The Act adds a new section (149) to the Atomic Energy Act cf 1954, entitled " Fingerprinting for Criminal History Checks" and requires the NRC to administer the Act through regulation (s). In this regard, the proposed rule would amend 10 CFR Part 73 to \

require that each power reactor licensee or applicant for license:

1. fingerprint each individual who is permitted unescorted access to the protected or vital areas of the reactor facility or access to Safeguards Information concerning access to those areas,
2. submit the fingerprints through the NRC to the Attorney General of the United States for r.ational criminal history ~ checks,
3. use the results of criminal history checks solely for the purpose of determining an individual's suitability for access, and
4. process and use fingerprints / criminal history information in a manner that assures the rights of individuals are not infringed upon and facilitates receipt of information.

In determining whether to grant a person unescorted access to certain areas of a power reactor facility or access to Safeguards Infomation concerning those areas, licensees and applicants currently make judgments concerning a person's identity and criminal history. These judgments and others are considered in determining the person's trustworthiness (not likely to commit or facilitate sabotage). Currently, licensees and applicants have limited or no access to only local criminal history information. The Act and the proposed rule would grant access through the NRC to FBI national criminal history information.

Access to such information would significantly reduce the uncertainty concern-ing a person's identity and criminal history. While substantial safety im-provement will not be readily evident from implementation of the rule, it is both prudent and consistent with the Comission's defense in depth policy to minimize uncertainty associated with determining the trustworthiness of a per-son needing the aforementioned access. This is particularly important from the safety perspective because a person granted such access would have access to or information concerning access to equipment and structures that prevent and mitigate radiological releases to the environment. Sabotage of such equipment and/or structures could threaten public health and safety. NRC has emphasized human trustworthiness rather than additional equipment and/or structures be-cause of the number of insiders granted such access; the balancing of security l

concerns and impediments to safe facility operation; and the unpredictability of which equipment and/or structure (s) would be degraded or failed as a result of sabotage.

The CRGR review focussed on the proposed rule's implementation of the Act rather than the need for the rule since the rule is mandated by the Act and the

  • Committee strongly supports the emphasis on human trustworthiness. The CRGR raised the following issues concerning the proposed rule:
1. The term " facility" in the Act is interpreted in the proposed rule to mean both protected and vital areas. Since by definition the means for radio--

logical release does not exist in protected areas, there does not appear to be a safety rational for interpreting " facility" to mean protected areas. Mr. Burnett remarked that protected areas were included at indus-try request rather than for safety reasons. The CRGR recommended that the rule not include requirements for protected areas.

2. Although the Act permits the Commission to relieve persons from the act under certain circumstances, the rule is silent on this matter. The CRGR recommended that this matter be explicitly addressed in the rule. While it was agreed that "grandfathering" should not be permitted, it was agreed that reciprocity between NRC and other licensees and applicants should be addressed in the rule to preclude unnecessary and redundant fingerprinting and criminal history checks by each licensee. When they were done, whether they should be repeated, and how often they should be repeated should be taken into account. Also, the rule should address the matter of emergency access without fingerprinting and/or criminal history checks.
3. The Act implicitly requires that fingerprints be taken correctly and that criminal history information be used along with other information to de-termine whether an individual shall be permitted unescorted access to the facility or access to Safeguards Information concerning the facility. The CRGR recommended that the proposed rule be explicit in these matters.
4. Both the Act and the proposed rule address the matter of individual rights. The CRGR reccamended that the rule be more aggressive and expli-cit concerning the disclosure of criminal history information in various situations, e.g., withdrawal of application for access, disclosure to others who have a need to know, etc.
5. Upon the rule becoming effective, licensees and applicants will have six months to submit fingerprint cards for their employees and contractors who have unescorted access and/or access to Safeguards Information. It is estimated that during that period 240,000 people will be fingerprinted (includes replacement of rejected fingerprints) and roughly 480,000 docu-ments (includes replacement of rejected fingerprints) will be processed through the NRC to the FBI for criminal history checks. After this ini-tial effort, roughly 28,000 documents will be processed annually. A 13 to 21 day FBI turnaround time has been assumed. Depending upon whether

licensees grant access before or after criminal history information is considered, there could be significant impacts on operating plants if criminal history information is not promptly forwarded to licensees. Out of concern for the capability to accommodate such a work load, the CRGR recommended that the staff confirm industry's ability to accomplish their effort, obtain firm commitments from the FBI concerning their effort and assure that NRC resources are available and committed to accomplish their effort.

6. An NRC automated system is planned to track the handling of documents pro-cessed by the NRC in connection with the proposed rule. There were dif-fering staff views about whether the NRC should maintain any information (summary or detailed) about the criminal histories of individuals proces-sed under the rule. The CRGR recommended that no such information in any form be maintained by the NRC.
7. A backfit analysis in response to the 10 CFR 50.109 requirement for such an analysis accompanied the proposed rule. The CRGR recommended that the staff review its finding that "...the proposed rule will result in a sub-stantial increase in the overall protection of the public health and safety..." to assure that the finding is correct and supportable.
8. The staff intends that'the proposed rule and final rule be issued by EDO signature without Commissinn involvement. The CPGR recommended that is-suance of the rule in this manner be discussed with the EDO before proceeding.

In summary, the CRGR recommended that after the Committee's recommendattor.s in 1 through 8 above have been adopted, the proposal has been modified accordingly and the modified proposal has been reviewed by the DEDROGR staff, the proposed rule should be forwarded for ED0 approval.

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9/17/365, 9

teon neems *'M b-'7- 80 PROPOSED' RULE 10 CFR 73.57

" REQUIREMENTS FOR CRIMINAL HISTORY CHECKS" l

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0 ilRC CONCERN - IO ASSURE THAT INDIVIDUALS HAVING UNESCORTED ACCESS TO

'/ ITAL AREAS D0 fl0T HAVE A CRIMINAL HISTORY BEARING UPON THEIR PERSONAL I TRUSTWORTHlf1ESS AND RELIABILITY. (SECY 33-517 - NRC PROPOSED LEGISLATION).

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0 CONGRESS HAD SIMILIAR CONCERil - LEGISLATION PASSED ALLOWING LICENSEES  ;

ACCESS TO f8I CRIMINAL HISTORY DATA FOR ALL HAVING UNESCORTED ACCESS.

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l 0 8Y REDUCING THE UNCERTAINTY OF TRUSTWORTHINESS OF INDIVIDUALS HAVING l

UNESCORTED ACCESS, INCREASEi> ASSURANCE IS PROVIDED AGAINST l

RAD'10 LOGICAL SABOTAGE BY AN It1 SIDER WHICH REDUCES THE LIKELIHOOD 0F OFFSITE RELEASE OF RADIOACTIVE MATERIAL.

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i Puntic LAW 99-399 "THE OMainUS DIPLOPMATIC SECURITY AND $NTI-IERRORISM ACT OF 1986" o PR$SIDENT SIGNED INTo LAW AUGUST 27, 1986 o

REQUIRES EACH'lHDIVIDUAL-GRANTED, ACCESS TO SAFFGUARDS INFORMATION OR UNESCORTED ACCESS TO A NUCLEAR POWER PLANT TO DE FINGERPRINTED 0

l DATA FORWARDED To FBI THROUGH NRC o

NRC RULE REQUIRED FOR CONTROL /USE OF FBI DATA 4

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NRC To ESTABLISH AND COLLECT FEES FOR PROCESSING FINGERPRINTS i o Six MONTH SCHEDULE l .

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PROPOSED RULE - 10 CFR 73.57 0 PROVISIONS PARALLEL LEGISLATION - (PUBLIC law 99-399, SECTION 606)

- CONTROL DATA TO PREVENT MISUSE

- LIMIT REDISSEMINATION OF DATA ,

- LIMITS ON USE OF CERTAIN ARREST DATA REGARDING FINAL DETERMINATION

- PROTECT RIGHTS OF INDIVIDUAL TO COMPLETE / CORRECT DATA O ANTICIPATE PUBLICATION 10/86, 30 DAY COMMENT PERIOD O EFFECTIVE ON FINAL ISSUANCE DATE O  !!O SECURITY PLAN AMENDMENTS REQUIRED 0 180 DAYS TO SUBMIT FINGERPRINTS OF INDIVIDUALS CURRENTLY IIAVING UNESCORTED ACCESS O 115 FEE ($13 TO FBI, $2 FOR ilRC) i i

4 PROCESSING SYSTEM OPERATION O LICENSEE SENDS CARDS PLuS FEE TO NRC SECURITY 0 CARDS REVIEWED FOR COMPLETENESS, FEE SENT TO RM 0 TRACKING DATA ENTERED IN COMPUTER O CARDS SENT AND RETURNED FROM FBI DAILY BY COURIER 0 TRACKING SYSTEM UPDATED, CARDS AND DATA SENT TO LICENSEES O d

'a CARDS OR ARREST RECORDS RETAINED BY NRC 0 ACCOUNT WITH FBI FcR MONTHLY BILLING O

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hjPACT Off AGENCY siHD FBI .

hl]TIAL IMPACT: (200.00J FINGERPRINT CARDS) 1 SYSTEM DEVELOPMENT EFFORT 2 M0NTHS..........................................$ 20,000

/ DATA ENTRY PERSONNEL FOR 9 M0rmiS...........................................$ 157,500 1 ADMINISTRATIVE INDIVIDUAL FOR 9 M0rmiS......................................$ 18,000 1 SueERviSOR FOR 9 M0NTHS..................................~...................$ 30,000 1 PC/AT PURCHASED WITH ASSOCIATED HARDWARE AND SOFTWARE.......................$ 6,000 7 LEASED PCS FOR 9 M0NTHS.....................................................$ 12,500 COURIER SERVICE FOR 9 M0NTHS...................................................$ 6.000 TOTAL $ 250,000 1 SEC PR0a. MONITOR /ADM!rilSTRATOR.............................................$ 30,000

.32 IE HODULE DEVELOPMENT S INSPECTION........................................$ 11,500

.2 RM TASK ORDER DEVELOPMENT &

ADMIN..........................................$ 8,600 TOTAL $ 50,100 NRC WOulD RECEIVE $2/ CARD = $1100,000-INITI AL Ar1HUAL IMPACT: (20,000' CARDS)

.5 CONTRACTOR STAFF...........................................................$ 15,200 COURIER COST FOR DAILY RUNS TO FBI ($30/ DAY x 250 DAYS).......................$ 7,500 PC FOR DATA ENTRY / TRACKING (PREVIOUSLY PURCHASED).............................$ NC 1 SEC PROJ. MONITOR / ADMINISTRATOR.............................................$ 30,000

.2 INSPECT 10N.................................................................$ 7,200

.02 RM FOR TASK ADMIN. (42 HRS)...............................................$ 900 TOTAL. $ 60,800 ANNUAL RECEIPTS, 20,000 CARDS, $2/ CARD =$40,000/YR.

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