ML20248C633

Request for OMB Review & Supporting Statement Re NRC Form 136, Security Termination Statement. Estimated Respondent Burden Is 400 H

ML20248C633
Person / Time
Issue date:	05/19/1998
From:	Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
References
OMB-3150-0049, OMB-3150-49, NUDOCS 9806020206
Download: ML20248C633 (7)

Text

{{#Wiki_filter:*, PAPERWORK REDUCTION ACT SUBMISSION Please read the instructions before completing this form. For additional forms or assstance in completing this form, contact your agency's Paperwork Clearar:ce Officer. Send two copies of this form, the collection instrumertt to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Eudgst, Docket Library, Room 10102,72517th Street NW, Washington, DC 20503.

1. Agency / Subagency onginating request

2. OMB contro: numoer 3150-0049 b None U.S. Nuclear Regulatory Commission g

a.

3. Type of information collection (cneck one)

4. Type of review requested (check one)

a. New collection g

a Regular

c. Delegated

b. Revision of a currently approved collection

b. Emergency - Approval requested by (date):

5. Will ths information collection have a a y,s y

c. Extenssor of a currently approved collection significant economic impact on a

d. Reinstatement, without change, of a previousty approved substantial number of small entities?

Y D NO collection for which approval has expired gl a. Three years from approval date "hh hangs ,v usly approved

e. R*

a col ap expiration date

f. Existing collection in use without an OMB control number

b. Other (Specify):

7. fitle

~ NRC Form 136, Security Termination Statement

8. Agency form number (s) pf apphcaole)

NRC Form 136

9. Keywords Security Classified Records Access Authorization Termination l

10. Abstract The NRC Form 136 affects employees oflicensees and contractors w ho have been granted on NRC access authorization. When the access authoriz.ation is no longer needed, the completion of the form apprises the

-{ l respondent of their continuing security responsibilities and is used to initiate termination of the access authorization. i

11. Atfacted pubhc run onmary em vandanotrers thatappty em 'x=>

12. Obligation to respYd iMar*.v, mary am y ans an amers ener appoy utn =x=>

a. Individuals or households

d. Farms

a. Voluntary T

b. Business or other for-profit

e. Federal Government

b. Required to obtain or retain benefits

c. Not-for-profit institutions

f. State. Local or Tribal GovemmentT c. Mar.datory

~ ~

13. Annual reporting and recordxeeping hour burden 14 Annual reporting and recordkeeping cost burden (m mousands or amtlars) 22

a. Total annualized capital /startup costs 0

g l

a. Number of respondents D. Totalannualresponses 400

b. Total araual costs (O&M) 0

1. Percentage of these responses 0

c. Tp?al annualized cost reouested

,3 collected electronically 0.0 d Cunent OMB inventory

c. Total annual hours requested 400 e Difference o

f. Explanation of difference e Difference 0

t gram change

f. Explanation of difference

2. Adjustment

1. Program change

2. Adjustment 11 Purpose of information collection

16. Frequency of recordkeeping or reporting (check an snar appfy)

(Mark pnmary with "P" and a# o*hers that app!y with 'X") a Recordkeeping

b. Third-party disclosure l

a. Apphcation for benefits

e. Program planning or management 7

c. Reporting

~

b. Program evaluatiun

f. Research

71. On occasion

2. Weekly

3. Monthly l

~ ~ ~ ~

c. General purpose statistics T g Regulatory or compliance

4. Quarterly

5. Semi-annually

6. Annually

~

7. Biennially

8. Other (desenbe)

d. Audit

17. Statistical methods 18 Agency contact (person who can cesr answer questions regaramp rne Does this information collection employ statistical methods?

Susan E. Marshall Name: ]Ves y No ( 301-415-6545 Phone. 9906020206 980519 I~ 10/95 ,,,,,,,,a,,,,,,w o,m, C g PDR ORG EUSOMBT 20ElU?SEBIEBBSPxl,,N. 4&nA

19.CIrtificrti:n f:r P:perw rk Reductisn Act Submlaciona On behalf of this Federal agency, I certify that the collection ofinformation encompassed by this request complies with 5 CFR 1320.9, NOTE: ne text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320.8 (b)(3), appear at the end of the instructions. The certification is to be made with reference to those regulatory provisions as setforth in he instructions. The following is a summary 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 avokb unnecessary duplication; (c) It reduces burden on small entities; (d) It uses plain, coherent, and unambiguous tenninology that is understandable to respondents; (c) Its implementation will be consistent and compatible with current reporting and recordkeeping practices; (f) It indicates the retention periods for recordkeeping requirerr.,; (g) It informs respondents of the information called for under ;> CFR 1320.8 (b)(3): (i) Why the information is being collected; (ii) Use ofinformation; (iii) Burden estimate; (iv) Nature of response (volurn.ary, required for a benefit, or mandatory); (v) Nature of extrat 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-(i) E!Ees"Sh$ftNn*de"b$ciekSfat$tkaiSnhi$E8ofoO;Nd (j) It makes appropriate use ofinformation technology. If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement. Signature of Authonzed Agency Official Date _ 4 Signatur of Sendr Offcal or desonad / J I/. Oate WY / -- ?7_ lton. ' Officer. Omce of the Chief information Officer GMBsu N Nw 10/95

r I OMB SUPPORTING STATEMENT FOR l NRC FORM 136 i Security Termination Statement (3150-0049) Extension Request Description of information Collection The reporting requirements associated with the NRC Form 136, " Security Termination Stctement," affect the employees of approximately 20 licensees and 2 contractors who have been granted an NRC access authorization (security clearance). When the NRC access authorization is no longer needed, the employee acknowledges and accepts his/her continuing security responsibilities, as stated on the NRC Form 136, by signing the form. Only a minimu'i amount of other pertinent information (e.g., contract number, if applicable; date of termination), none of which is personal in nature, is requested by the form. The form is countersigned by a representative of the licensee or contractor who administered the completion of the form by the employee. l There is no recordkeeping requirement for the licensee or contractor since the completed NRC l Form 136 is to be forwarded to NRC Headquarters, Division of Facilities and Security (DFS), for retention in the individual's Personnel Security File (PSF). The established retention period of the PSF is: destruction upon notification of death or 5 years after termination of the last access authorization held. Although maintained in the PSF, the completed NRC Form 136 would not fall under the exemptions of the Privacy Act of 1974 and, upon request, would be made available for public inspection in accordance with 10 CFR Part 9. l The use of this form affords some assurance that classified information and knowledge gained by the respondent will be properly protected and, therefore, benefits the NRC security program l and public at large. A. JUSTIFICATION 1. Need for Practical Utility of the Collection of InformatiQD i l Section 4.3 of Executive Order 12958 requires agencies to establish controls l over the distribution of classified information to assure that it is distributed only to organiz;tions or individuals eligible for access who also have a need-to-know the information. NRC's response to this requirement is termination of the access l authorization when the circumstances cited in Section 25.33 of 10 CFR Part 25 (applicable to licensees) or in NRC Management Directive 12.3, (applicable to contractors) exist. The NPO Form 136, " Security Termination Statement," is an integral part of these termination of access authorization procedures. 2. Aaencv Use of Information As stated in NRC Management Directive 12.3 (for contractors), and in 10 CFR

l 25.33 (for licensees), the completed NRC Form 136 is to be forwarded by the licensee / contractor to NRC Headquarters Division of Facilities and Security (DFS), who uses the information in connection with the termination of the respondent's access authorization. In addition to providing assurance of NRC compliance with E.O.12958, the NRC Form 136 is the vehicle used by DFS to apprise the individual of his/her continuing responsibilities for protecting classified information that he/she had access to in the course of performing official duties. The individual's signature on this form indicates his acknowledgment / acceptance of these continuing responsibilities. Failure to use the NRC Form 136 by the licensee / contractor may result in: (1) failure to terminate the NRC access authorization when circumstances dictate and, therefore, continued access to classified information; and (2) the individual not being apprised of, or officially acknowledging (by signature) his/her continuing responsibilities for protecting classified information. 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 136. The inforrnation contained /obtained on the form must be personally signed / reviewed /provided by the individual affected. 4. Effort to identifv Duplication and Use Similar Information The information collection requirement does not duplicate information the affected licensee, organization, or person must submit for other purposes since the nature of the information requested / collected is unique to NRC's activity at the facility. Since the information collected by the NRC Form 136 is specifically and solely related to the termination of an individual's NRC access authorization, there is no similar information collection made by any other government agency which could be utilized. 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 136 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 Frecuentiv The frequency of information collection is limited to circumstances when the ( respondent's NRC access authorization is to be terminated. In most cases, this I

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 appropriately cleared individuals have access to classified information is reduced; and it is likely that individuals will be unaware of their continuing responsibility to protect classified information. Thus, less frequent collection may endanger the U.S. common defense and national security. 7. Circumstances Which Justifv Variation from OMB Guidelines There is no variation from OMB Guidelines in the collection of information. 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. Payment or Gift to Respondents Not applicable. 10. Confidentiality of the Information The information collected is used to terminate a respondent's NRC cccess authorization. The completed NRC From 136 contains no information of a confidential or personal nature and would not fall under the exempticns of the Privacy Act of 1974. Upon specific request, the form would be made available for public ir'spection in accordance with 10 CFR Part 9. 11. Justification for Sensitive Questions There is no sensitive information requested on the NRC Form 136. 12. Estimated Burden and Burden Hour Cos1 A n estimated six minutes (based on staff experience) is required to complete aach NRC Form 136, resulting in a total annual burden on the pubi:c of 40 hours. The estimated annual cost shared among the 22 licensees / contractors is 55000. This was computed as follows: 400 annual responses (10% of the approximately 4,000 access authorizations held by licensees / contractors X 6 minutes completion time each = 40 hours X $125 per hour = $5000. NOTE: There is no recordkeeping requirement for contractors / licensees to maintain a copy of the NRC Form 136. 13. Estimate of Other Additional Costs Not applicable. i

t 14. Estimated Annualized Cost to the Federal Govemment The estimated annual cost to the Federal Govemment associated with the NRC Form 136 is $1419.25. The cost was computed as follows: NOTE: Annual form usage 400 (10% of the approximately 4,000 access authorizations held by licensees / contractors). COST: Annual clerical effort = $1200 (400 x 4 minutes = 26.67 hrs. X $45/hr.) l Annual professional effort = $167 (400 X.2 minutes = 1.33 hrs. X $125/hr.) J Annual record holding = 52.25 (1/4 cu. ft. X $209/cu. ft.) Total estimated annual cost = $1419.25 This cost is fully recovered through fee assessment to NRC licensees pursuant to 10 CFR Parts 170 and/or 171. l l 15. Reasons for Chances in Burden or Cost There is no change in the burden estimate. However, the cost for professional effort has been reduced to $125 per hour. 16. Publications for Statistical Use There is no application of statistics in the information collection related to the NRC Form 136 and no publication of the information. 17. Reason for Not Disolavina the Exoiration Date Not Applicable. j 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 I l l 1 _______ ____ A

a NRC FORM 136 U.S. NUCLEAR REGULATORY CoMMisslON APPROVEDDfOasS:NO. 3M0404. EAPtRES L JDC/YYYY N CM 3 h" t6m m i nC _, nc..t., - .F-to th. R

e. M-.n.,.wu SECURITY TERMINATION STATEMENT ES?xxk "."4*f t. K'%in*.'"t#L*."Mhif wS*nE"n %"5"o*n"L""7.*IE/, *.7. nit Y,. Ou's m,n-th. NRC m., - o f.quir.d to r.spond to, th. Worm. hon cop.Clioft NAME (Pnnt tuM name, actu00 ad Other n.mes usedj

'lEMYLOY..H U.S. Nuclear Regulatory Comraission MC iicss~IU6iOEisiiOifitiEUueEhinJoa ~ ~ --' ErFECTivE DATE OF TERMINATION ~- l make the following statement in conne. tion with the termination of my access authorization granteel by, or pending with, the U.S. Nuclear Regulatory Commission (NRC): m en r-1. I shall not unlawfully reveal to any person any National $ecurity information, Restricted Data, or other classified information, o,r, unclassified'd' Safeguards'ir'for41alion,of which I may have gained i knowledge except as authorized by law, regulations of the NRCrorin, writing by officials of the NRC empowered to grant p,ermission for such disclosure. /1 h h. 2. I am aware that the Atomic Energy Act of 1954, as amended, and U.S. Code, Tide 18," Crimes and Crirniral Procedures))rescribe penalties for unauthorized disclosure of Restricted Data, Formerly Restricted Data, Safeguards Information, and other informatforIreiating to ' he national defense. t [% N'yk CED [kk( O 3. I am aware that, unless and until t am teleased in writing by an authorized representative of the U.S. Government 7au conditions fmd o^ li' atiohs iridosed dpon me by virtue'ofiny having executed bg SF 189, "Classifisd h1 formation Nondisclosiir' Xfe~ ivsnt SF 312 of the'sa'me title, remain in e d full force and effeh*) I' 4. I am aware that I be liabIe for Bamages if I reveaf to any unauthorized person sensitive unclassified inform' (e g.ihisidy,informdi$rkprUtidtarf thformation)##of1which I have gained knowledge as a resu Iny eripI6pment, affiliasbn Witii RRCP y LG.)i y y hiQ 3 M 5. I have destroyed, in accordance with NRC security regulations or transferred to persens j i designated by the NRC, alf'ch!Issified and/or sensitive unclassifiedhf8rmation which I may have l I had in my possession. gT 6,k @ "9P 6. I am aware that i may be subject to criminal penaltiesif I liave made any statement of material J facts knovcing that such statement is false or if I willfully conceal any material fact (Title 18, U.S. j Code, Section 1001). 7. I understand that the NRC desires to be informed when persons who have been granted an NRC j access authorization propose to travel to designated countries within 2 years from erecution of this form. This does not apply to individuals who obtain an NRC access authorization and receive i access to NRC classified information solely as employees of other Gover. ment agencies or their contractors. MGNATURE - PERSON CONDUCTING BRIEFING SKINATURE - PERSON EXECUTtNG THIS FORM EMPLOYER OF PERSON C NDI STING BRIEFING AND TITt.E"OF' POSITION NELO~ DATE AND P(ACE WHERt SIGNED ~ ^ ~ U.S. Nuclear Regulatory Commission NRC FORM 136 (MM-YYYY) PRINTED ON RECYCLED PAPER Thi. form we. c.negn.d v.ing inF orms ______.________.______s}}