ML20248B849

Request for OMB Review & Supporting Statement Re NRC Form 237, Request for Access Authorization. Estimated Respondent Burden Will Be 16 H

ML20248B849
Person / Time
Issue date:	05/19/1998
From:	Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
References
OMB-3150-0050, OMB-3150-50, NUDOCS 9806010402
Download: ML20248B849 (8)

Text

e PAPERWORK REDUCTION ACT SUBMISSION Please read the instructions before completing this form. For additional forms or assistance in completing this form, contact your agency's Paperwork Clearance Officer. Send two copies of this form, the (Dilection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102,72517th Street NW, Washington, DC 20503.

1. Agency / Subagency onginating request

2. OMB control number

~

3150-0050 b.None U.S. Nuclear Regulatory Commission y

a.

Type of information collection (check one) 4 1ype of review requested (check one) gl a Regular

c. Delegated

a. New collection

b. Revision of a currently approved collection

b. Emergency - Approval requested by (date).

5. Will this information collection have a a.Yes y

c. Extension of a currentty approved collection s@nificant economic impact on a

d. Reinstatement, without change, of a previously approved substantial number of small entites?

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b.No collection for which approval as expired

• ~ "*$'h'o'Tr"1nfch appTo"vhY M$r%* **

J ^hm****

lc Requestee

, expiration date

f. Exishng collection in use without an OMB control number

7. Title NRC Form 237, Request for Access Authorization

8. Agency form numberts) (if applicaD e) f i

NRC Form 237

9. Keywords Classified Information, Security Measures

10. Abstract NRC Form 237 is completed by licensees, NRC contractors, or other individuals who require a NRC access authorization.

11. Affected public cusa onmary em v oms en orners ther awy um v)

12. Obligation to respond cuem onme y am v mus en otnern met awy em v)

a. Individuals or households

d. Farms

a. Voluntary 1

Y

b. Business or other for-profit

e. Federal Govemment

b. Required to obtain or retain benefits

c. Not.for-profit institutions

f. State, Local or Tribal GovemmentT c. Mandatory

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13. Annual reporting and recorakeeping hour burden

14. Annual reporting and recordkeeping cost burden (m enousemss ordoners; 22 s Total annualized capital /startup costs O

p/

s. Number of respondents b Total annual responses 80

b. Total annual costs (O&M) 0

c. Total annualized cost requested 0

kh

1. Percentage of these responses collected electronically 0.0

d. Current OMB inventory

c. Total annual hours requested 16

e. Difference O

d. Current OMB inventory 16

f. Explanation of difference

e. Difference O

1. Program change

f. Explanation of difterence

2. Adjustment

1. Program change

2. Adjustment

16. F requency of recordkeeping or reporting fcheca att that appry) l

15. Purpose of information collection (Mark pnmary w#h "P" and a# others that apply wrth "X')

a. Recordkeeping

b. Third-party disclosure

a. Application for benefits

e. Program planning or management

c. Reporting

b. Program evaluation

f. Research

71. On occasion

2. Weekly 3 Monthly i

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c. General purpose statistics T g Regulatory or compliance

4. Quarterly

5. Semi-annually 6 Annually l

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7. Bennially

8. Other (desenbe)

d. Audit

18. Agency contact (person who can Dest answer questions regareng the

17. Statistical methods Does this information collection employ statistical methods?

Susn E. Marshall Name-Yes Q No i

301-415-6545 9006010402 980519 pnone:

PDR ORG EUSOMB

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.es oesigned usry informs

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19. Certification for Pcperwork RIducticn Act Submi2cicna On behalf of this Federal agency, I certify that the collection ofinformation encompassed by this request complies with 5 CFR 1320.9.

NOTE: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320.8 (b)(3), appear at the end of the instnsclions. The certification is to be made with reference to those regulatoryprovisions as setforth in the instructions.

The fcilowing is a sum' nary of the topics, regarding the proposed collection ofinformation, that the certification covers:

(a) It is necessary for the proper performance of agency functions; (b) It avoids unnecessary duplication; (c) It reduces burden on small entities; (d) It uses plain, coherent, and unambiguous terminology that is understandable to respondents; (e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices; (f) It indicates the retention periods for recordkeeping requirements; (g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3):

(i)

Why the information is being collected; (ii) Use ofinformation; (iii) Burden estimate; (iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature of extent of. confidentiality; and (vi) Need to display currently valid OMB control number; (h) It was developed by an office that has planned and allocated resources for the efficient and effective manage-iI I

19 f the instructions);

(i) ffi[ses*"el'f!EeYnh e"f0c'EEk'Efat'Ot!l'afS!ffNy nNb"8dfh"y;'E*IEd (j) It makes appropriate use ofinformation technology, if you are unable to certify coinpliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.

Date Sqnature of Authortzed Agency Official Signature neor Ofhc4 signee f,

Date k

on. RC r,

ce of t Chief Information Ofheer Olip434 N

N 10/95

OMB SUPPORTING STATEMENT FOR NRC FORM 237 Request for Access Authorization (3150-0050)

Extension Request Description of Information Collection Title 10, Code of Federal Regulations, Part 11 " Criteria and Procedures for Determining Eligibility for Access to or Control Over Special Nuclear Material" and Part 25," Access Authorization for Licensee Personnel" establish requirements that licensee personnel requiring access to either special nuclear material or classified information must have an investigation of their background and NRC Management Directive 12.3 " Personnel Security Program" establishes requirements that NRC contractors, subcontractors and other non-NRC individuals requiring access to classified information must have an investigation of their background. The reporting requirements associated with NRC Form 237 affect approximately 20 licensees and 2 contractors.

A.

JUSTIFICATION 1.

Need for and Practical Utility of the Collection of Information A completed NRC Form 237 is required to obtain or renew access to special nuclear material (10 CFR 11.15(a)(2)and(c)(1)) or classified information (10 CFR 25.17(c)and 25.21(c)(1)and(2)for licensee personnel, it is also used.to request NRC access authorizations for personnel of NRC contractors, subcontractors, or other individuals who are not applicants for employment with NRC. The signature of the authorizing official (the security officer) and the approval of the NRC sponsoring official must appear on the form. The information on the form will be reviewed by NRC Division of Facilities and Security personnel. Any questions about the validity or appropriateness of the request may be referred to the NRC office exercising contractual, licensing or regulatory authority over the requesters before processing the access authorization request.

In addition to the signatures mentioned above, the form contains the name of the applicant, the level of access authorization requested, the applicant's date of birth, other appropriate remarks (e.g., previous clearance history), and an identification of enclosures (e.g., completed personnel security packet). A personnel security packet received without this form or without the authorizing official's signature will result in no action being taken on the access authorization request. This information collection for access authorizations benefits NRC and the Federal government by affording a greater degree of control over who is granted access to special nuclear material or classified information.

2.

Acencv Use of Inform a

t The information on NRC Form 237 is forwarded to the Division of Facilities and Security (DFS) for administrative review and processing for access authorization.

If the individual for whom access is being sought currently has an active access authorization with another Federal agency, DFS may request certification of this access authorization from the agency concerned. Upon receipt of this certification, DFS will reply to the requester indicating that the requested access authorization has been granted. This process normally can be completed within 30 days. If the individual for whom access is being sought does not have an active access authorization with another Federal agency, DFS will take action to obtain the type of investigation necessary to support the level of access sought.

Upon favorable review of the completed investigation, DFS notifies the requester of the access authorization approval. If, after review of the investigation, DFS determines that there is a question of the individual's eligibility for NRC access 4

authorization, the "due process" provisions of 10 CFR Parts 10 and 11 may be l

invoked.

3.

Reduction of Burden throuah information Technology There is no information technology available which would reduce the burden and provide the documentation of identity and signature certification necessary to request an access authorization.

4.

Effort to identifv Duplication and Use Similar Information NRC Form 237 does duplicate certain identifying data (e.g., name, date of birth, and level of clearance) requested on other forms in order to assure positive identification of the individuals for whom access authorization is being sought.

The Department of Energy and some other government agencies use similar forms. However, since there is no standard form available for Govemment-wide use, the NRC Form 237 is needed to ensure that NRC has a standard procedure for receiving requests for access authorizations.

Since the form is only used when clearance for access to special nuclear material or classified information is being requested there is no other similar information available.

The information Requirements Control Automated System (IRCAS) was searched and no duplication was found.

5.

Effort to Reduce Small Business Burden None of the licensees affected by the use of the NRC Form 237 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 qualified as a small business enterprise or entity.

6.

Consequences to Federal Program or Policy Activities if the Collection is Not Conducted or is Conducted Less Freauentiv l

l

f Since the collection of information is only required when one applies for access to special nuclear material or classified information, there is no established frequency for collection. In most cases, this is a one time event and less frequent collection would mean eliminating the collection altogether. If the information is not collected, the assurance that only individuals who are properly authorized have access to classified information or special nuclear material is reduced. Thus, less frequent collection may endanger the U.S. common defense and national security.

7.

Circumstances Which Justifv Variation from OMB Guidelines No variation from OMB guidelines is required for the purpose of this collection process.

I 8.

Consultations Outside the NRC An invitation to comment on the information collections was published in the Federal Reaister on January 15,1998 (63 FR 2422). There were no comments.

9.

Pavment or Gift to Respondents Not applicable.

10.

Confidentiality of the Information NRC provides no pledge of confidentiality for this collection of information, however, as Social Security Numbers may be provided as a part of the information provided, they are protected by the Privacy Act and their confidentiality is maintained.

11.

Justification for Sensitive Questions NRC does not request any sensitive information on this form.

12.

Estimated Burden and Burden Hour Cost An estimated twelve minutes (based on staff experience) is required to complete each NRC Form 237, resulting in a total annual burden on the public of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.

The estimated annual financial burden shared among the 22 licensees / contractors is $2000. This was computed as follows: 80 applicants X 12 minutes per request X $125/hr.

13.

Estimate of Other Additional Costs Not applicable.

14.

Estimated Annualized Cost to the Federal Government.

The annual cost to NRC is estimated to be $1,666.67 This cost was computed as follows:

Annual professional effort

$1,666.67

=

(10 minutes [ processing, program review and approving requests for processing)

X 80 = 13.33 hrs. X $125 per hour).

This cost is fully recovered through fee assessment to NRC licensees pursuant to 10 CFR Parts 170 and/or 171.

15.

Reasons for Chances in Burden or Cost There is no reduction in the burden. However, the cost for professional effort has been reduced to $125 per hour.

16.

Publications for Statistical Use Data from this information collection are not published for statistical purposes.

Statistical methods cannot be used in the collection of information since each instance relates to an individual applying for access to special nuclear material or classified information.

17.

Reason for Not Disolavino the Exoiration Date The expiration date is displayed.

18.

Exceotions to the Certification Statement Not applicable.

B.

COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS Statistical methods are not used in this collection of information.

L

e NRC FORM 237 U.S. NUCLEAR REGULATORY COMMISSION APPROYED BY OMB: NO. 31504050 EAPIRE5: MM/DD/YYYY NRIuNs Na 5 mYs" suNnYsUsed bWyto de7er*ns r

" Tela " ;;?n"e'='aC".37l?.0"**"" 37'N Nudoar Regulatory Commason, Washngton. DC 20555 0001 are to the REQUEST FOR ACCESS AUTHORIZATION

"J,;3es"n"no",0""o!=3L5 J" J""eL"Es"*

o a currently vald oHB control number. the NRC may not corufuct or sponsor.

and a person is not required to respond to, the mformaton collecton.

1.DATE INSTRUCTIONS: Submit original only. Detailed instructions on the reverse.

3. FROM.

2. TO: CHIEF PERSONNEL SECURITY BRANCH DIVISION OF SECURITY U.S. NUCLEAR REGULATORY COMMISSION WASHINGTON, DC 20555-0001

4. SIGNATURE D

"Q" "U"

5. REQUEST THE BELOW NAMED APPLICANT (S), U.S. CITIZEN (S). BE PROCESSED FOR AN NRC ACCESS AUTHORIZATION AS INDICATED:

,,g,,

6. NAME OF APPLICANT (Last, First, Middle) or O SEE ATTACHED LIST OF APPLICANTS

7. DATE OF BIRTH

8. REMARKS

9. NRC SPONSORING OFFICE OR DIVISION (See instructions)

10. CONTRACT NUMBER, LICENSEE SECURITY PLAN REFERENCE OR OTHER IDENTIFYING NUMBER 4

11. ENCLOSURES Wit (DO NOT WRITE IN THIS SPACE)

O SF 88. QUESTIONNAIRE FOR SENSITIVE POSITIONS (For National SeCunty)

12. APPROVAL BY NRC SPONSORING OFFICIAL (Part 1)

SF 86, QUESTIONNAIRE FOR SENSITIVE POSITIONS (For National Security)

(Part 2). (Sealed in NRC Forrn E-1, Envelope for Part 2, SF 86).

FD 258, FINGERPRINT CARDS (Two copies)

O NRC FORM 176(A), SECURITY ACKNOWLEDGMENT (For *Q* and "L" Requests)

O NRC FORM 176(B), SPECIAL NUCLEAR MATERIAL ACCESS AUTHORIZATION ACKNOWLEDGMENT (For "U" and 'R' Requests).

OTHER (Specify)

NRC FORM 237 (MM YYYY)

PRINTED ON REGYCLEO PAPER Trus form was oesgneo usog r#orms L

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l INSTRUCTIONS A. PURPOSE OF FORM:

Tiiis form is to be used for requesting NRC access authorizations on personnel of NRC contractors, subcontractors, licensees, employees of other government agencies, or other individuals who are not applicants for employment with NRC.

B. MULTIPLE REQUEST:

A single NRC Farm 237 may be used to request access authorizations for soveralindividuals who all require the same type of access authorizations (e.g., all"Os" or all"Rs"). The individuals and their dates of birth may be listed in the remarks section or on a roster appended to the NRC Form 237.

C.WHO PREPARES THE FORM:

The agency or firm employing the individual (s) normally prepares this form (except in the case of a subcontractor, in which case the prime contractor would prepare this form). The NRC sponsoring office or division may prepare this form if it feels it would be more expedient, D. APPROVALS REQUIRED:

ltem 4 must be signed by the agency or firr" rity officer (or other authorized official). If this request is in connection with an NRC con!.. ;r anticipated contract (e.g. basic ordering agreement), items 9 and 10 must be cor, W and the request must be approved in item 12.

E. SUBMITTING THE REQUEST:

All requests may be submitted to the address in item 2; however, if approval in item 12 is required, it would avoid delay in processing if this request is submitted through the approving official. Security forms completed by the applicant are to be firmly attached to this form. (For certification of existing security clearance or federal access authorization, NRC license related activities should consult 10 CFR Parts 11 or 25, as appropriate, for requested forms and related procedures and fees.)

F. PRIOR INVESTIGATIONS AND SECURITY CLEARANCES:

To assist in the processing of this request, please list in item 8 or attached roster;

1. Any prior investigations on the applicant (s). Give date, type (i.e., background investigation or national agency checks), and investigating agency; and,

2. Any current or prior security clearances (i.e., access authorizations) held by the applicant (s) with NRC or any other agency. Give dates held, level (i.e., Top Secret, Secret, Confidential, "O,""L,"

"U," or "R"), and agency granting clearance.

_