ML20248C639

Request for OMB Review & Supporting Statement Re NRC Form 277, Request for Visit or Access Approval. Estimated Respondent Burden Is 1 H

ML20248C639
Person / Time
Issue date:	05/19/1998
From:	Shelton B NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
Shared Package
ML20248C644	List: ML20248C639 ML20248C649
References
OMB-3150-0051, OMB-3150-51, NUDOCS 9806020208
Download: ML20248C639 (8)

Text

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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 CDPection 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 101C2,72517th Street NW, Washington, DC 20503.

1. Agency / Subagency onginating request

2. OMB control number 3150-0051

b. None U.S. Nuclear Regulatory Commission g

a

3. Type of information collection (check one) 4 i ype of review requested (checA one)

a. New collection

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a. Regular

c. Delegated J

b. Revision of a currently approved collection b Emergency - Approval requested by (date)

5. Will this information collection have a a.Yes

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

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

g b.No collection for which approval has expired

e. Reinstatement, with change of a previously approved g

a. Three years from approval du collection for which approval has expired 6' ' Requested

f. Existing collection in use without an OMB control number

b. Other (Specify):

1. Title NRC Form 277. Request for Visit or Access Approval 8 Agency form number (s) (if apphcable)

NRC Form 277 9 Keywords Visits, Classified Information Access 10 Abstract The NRC Form 277 data provides assurance that only properly cleared authorized individuals, who reguire eccess to classified information as part of their official employment duties, will have access during visits to the NRC, contractors, licensee facilities, or government agencies.

1 11 Affected pubisc quare pnmary em v ew en cmers mar awy em 'x1

12. Obligation to respond (Man onmary em v om an omers mar awy em x=]

a. Voluntary

a. Individuals or hodseholds

d. Farms

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b Required to obtain or retain benefits f

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b. Dusiness or other for-profit

f. State. Local or Tnbal Governments c. Mandatory

e. Federal Government l

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c. Not-for-profit institutions

13. Annual reporting and recordkeeping hour burden

14. Annual reporting and recordkeeping cost burden (m mousaes ordonars;

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2

a. Total annualized capital /startup costs 0

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b. Totalannualresponses 6

b. Total annual costs (O&M)

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a. Number of respondents c Total annualized cost requested 0

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1. Percenta e of these responses collected electronically 0.0 %

d current OMB inventory 0

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c. Total annual hours requested I

e Difference 0

d. Current OMB inventory 5

f Explanation of difference

e. Difference (4) ogram change

f. Explanation of difference (4)

2. Adjustment l

1. Program change

2. Adjustment

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16 F requency of recordkeeping or reporting (check att that appI).

15 Purpose of information collection (Mark pnmary with "P" and all others that apply with "X*)

a Recordkeeping

b. Third-party disclosure

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l a Application for benefits e Program planning or management

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c. Reporting J 1. On occasion

2. Weekfy

3. Monthly

b. Program evaluation f Research

4. Quarterly

5. Semi-annually 6 Annually

c. General purpose statistics T g Regulatory or compliance

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7. Biennially 8 Other(desenbe)

d. Audit 18 Agency contact (person who can best answer guestions regarding the

17. Statistical methods content of this submossion)

Does this information collection employ statistical methods?

Susan E. Marshall Name-QNo 301-415-6545 Yes Phone 10'95 c,fM a 'o""a' "S*' ~o '""""

9806020208 980519

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PDR f r v g m r ~ p,.,u w m t. 4 (

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19. CirtificEticn fsr Pcperwork R: duction Act Submissions On behalf of this Federal agency, I certify that the collection of infxmansu encompassed by this request complies with 5 CFR 1320.9.

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

The following is a summary of the topics, regarding the proposed collection of information, 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; (c) Its implementation wil! 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 plarmed and a!!ocated resources for the efficient and effective manage-(i) EItsEs"ENe$'de"thicTShsSt$tka[ENEv'e#y nNEdNIog"y';Y (j) It makes appropriate use of information 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.

Date Sqnature of Authornea Agency Offcial

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Date Sgnature Senior Offcial or ces -- -

8k Iton. NR are. ~ Office of the Chief information Officer OyB3-4 10/95

4 o-OMB SUPPORTING STATEMENT FOR NRC FORM 277 (3150-0051)

Revision Request Request for V! sit or Access Approval Description of the information Collection The information collection associated with the NRC Form 277, " Request for Visit or Access Approval," affects any employee of two current NRC 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 access 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 or pertinent information (e.g., date of birth, clearance type, dates of visit) is requested by the form.

Personal information contained on the completed forrn is handled and protected in accordance with NRC directives and provisions of the Privacy Act of 1974.

Other information contained on, or pertaining to the form (e.g., reporting requirements), is available for public inspection in accordance with 10 CFR Part 9.

The use of NRC Form 277 affords some 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.

A.

JUSTIFICATION 1.

Need for and Practical Utility of the Collection of Information Section 4.2 Executive Order (E.O.) 12958 states a person may have access to classified information provided that: (1) a favorable determination of eligibihty for access has been made by an agency head or the agency head's designee.

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and the person has a need-to-know the information. Further, Section 4.3 requires agencies to ".. establish controls over the distribution of classified information to assure that it is distributed only to organizations or individuals eligible for access who also have a need-to-know the information.

The use of the NRC Form 277, as cited in NRC Management Directive 12.3 applicable to contractors, is the method by which NRC can provide assurance of compliance with the above provisions of E.O.12958. The NRC Form 277 provides the facility / agency to be visited with verification of the visitor's NRC access authorization and certification of their official need-to-know for the c!assified information regarding the visit. By requiring the information collection contained on the NRC Form 277, the facility / agency can assure that only properly c! eared and authorized individuals will be permitted access during a

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visit.

2.

Aaency Use of Information The NRC Form 277 is forwarded by the contractor through the appropriate NRC office exercising oversight authority for certification of need-to-know to the NRC Division of Facilities and Security (DFS). After clearance verification, DFS fonvards 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 information/ area. Failure to use the NRC Form 277 by the contractor may result in denied access to classified information or areas which are necessary in the accomplishment of official duties, l

3T Reduction of Burden throuah Information Techholoav No reduction in the information collection burden can be realized through l

information technology with respect to the NRC Form 277 The information contained and/or obtained on the form is visit specific. Also, original signatures are necessary for access authorization verification and need-to-know certification.

l 4.

Effort to identifv Duplication and Use Similar Information

,ln order to safeguard classified information, other Government agencies and 1certain facilities collect information of a nature similar tJ the NRC Form 277, to

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verify the access authorization and confirm the need-to-know of visitors. The information collection on a.given NRC Form 277 does not duplicate other information collections made by the NRC or other Government agencies since L

3 each visit / access approval is unique. With respect to the actual form, essentially em x'

identical forms are used throughout the U.S. Govemment, yet there is no standard form available. Instead, there is reciprocal acceptance of the formt ei among facilities / Agencies wh;ch is the closest approximation to use of similar 4

information possible under the circumstances.

The Information Requirements Control Automated System (IRCAS) was l

searched and no duplication was found.

5.

Effort to Reduce Smail Business Burden l

The burden associated with the occasional use of this form is so minimal that J

j there would be no significant burden on a contractor, if they did qualify as a small business enterprise or entity.

6.

Consequences to Federal Proaram or Policy Activiti.giff tbg_Qollection is Not Conducted or is Conducted Less Freauentiv The frequency of information collection is dependent on the number of visits an individual makes to Government agencies or facilities. In most cases, a less i

frequent collection would mean eliminating the collection, as visits by contractors, 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.

7.

Circumstances Which Justifv Variation from OMB Guidelines There is no variation from OMB Guidelines in the collection of information.

8.

Consultations Outside the Aaency 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 The information collected is used to establish the permissible access associated with a visit for an individual. The information is protected from public disclosure under the Privacy Act of 1974 and is handled in accordance with routine uses specified in the Privacy Act Statement contained on the form.

11.

Justification for Sensitive Questions

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NRC does not request sensitive information on this form.

12.

Estimated Burden and Burden Hour Cost An estimated ten minutes (based on staff experience) is required to complete each NRC Form 277, resulting in a total annual burden on the public of one hour.

The estimated annual cost shared between the two contractors is $125.00. This was computed as follows:

6 annual responses X 10 minutes completion time each = 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> X $125 per hour $125.00.

13.

Estimate of Other Additional Costs None 14.

Estimated Annualized Cost to the Federal Government l

The estimated annual cost to the Federal Government associated with the NRC Form 277 is $114.03. This cost was computed as follows:

NOTE: Annual form usage for NRC contractors is estimated as 6.

COSTS:

Annual clerical effort

= 45 (6 x 10 minutes = 1.0 hrs. X $45/hr.)

Annual professional effort

= 62.50 (6 x 5 minutes = 0.5 hrs. X $125/hr.)

Annual record holding (3 yrs.)

= 6.53 (1/32 cu. ft. X $209/cu. ft.)

15.

Reasons For Changes in Burden or Cost The burden estimates have been reduced because NRC licensees with NRC cleared personnel are no longer subject to NRC Form 277 requirements. The cost for professional effort has been reduced to $125 per hour.

16.

Publication for Statistical Use There is no application of statistics in the information collection related to NRC Form 277 and no publication of the information.

17.

Reason for Not Disolaving the Exoiration Date l

The expiration date is displayed.

18.

Exceotions to the Certification Statement Not applicable.

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS l

l Statistical methods are not used in this collection of information.

l l

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NRC FORM 277 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMS:NO. 31604041 EAPIRES. MM/DDnnfYY (M4YYYY)

NRCMD 12 4 Estimated burden pct risponse to comply with the mandatory nearmetion coaccton request 10 mmutes Forward comments regarding burden entsnote to the Records Management Branch (T4 F33). U S Nuclear Regulatory Commission. Washington, DC REQUEST FOR VISIT OR ACCESS APPROVAL

'JJ.'Ne@,n'e,"e,"li"J2' 25""E'&"l0 ntormation collection does not display a curraritty vend OMB control (Not to be used for temporary or permanent personnel assignments) number, the NRC may not conduct or sponsor, and a person a not requved to respond to. Ine mtormatan couectet PART A TO DATE PREPARED BY FROM SYMBOL TELEPHONE it is requested"ifiii~the f511owing person (s) be granted visit / access approval:

LAST NAME, FIRST E, MIDDLE INITIAL CHECK DATE TYPE CLEARANCE DATE OF SOCIAL SECURITY NUMBER Ni.

A N

ER CLEANCE AUEN BI H ZEN O

O O

NAME OF FACILITY (IES) TO BE VISITE' D:

FOR THE INCLUSIVE DATES SIGNATURE-NRC C RI FOR THE PURPOSE OF:

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TO CONFER WITH THE FOLLOWING PERSON (S):

SPIECIFIC lWORMATION TO WHICH ACCESS IS REQUISTED" ACCESS RET:lUESTED TO:

l YES l N

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RESTRICTED DATA O

O OTHER CLASSIFIED INFORMATION []

Pri:r arrangements ] have O have not been made as follows:

l CERTIFICATION FOR PERSONNEL HAVING DOD CLEARANCE The certWes t*at the person (s) names above need(s) this access m tne performance of duty and the permittog the above access wdl not endanger the common defense ord securey.

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REQUESTING DOD OFFICIAL AUTHORIZING. DOD OFFICIAL SIGNATURE, (SCE DOD D R TiVE 8210.2)

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CERTIFICATE fipOR PERSONNEL HAVING NRC CLEARANCE The certWes that the person (s) named above need(s) the access m the performance of duty.

TITLE SIGNATURE - REQUESTiWG NRC OR DOD OiplCIAL PART B App:vvalis granted with limitations indicated below*

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1. UTHOF12Ef0FFICIAL JfilNTEFOR TYPED NAME AN6flTLE SI EATURE NRC FORM 277 (MM YYYY)

PRINTED ON RECYCLEJ PAPER Inn form was posigneo using inf arms

PRIVACY ACT STATEMENT Pursuant TO 5 U.S.C. 552a(e)(3), enacted into law by Section 3 of the Privacy Act of 1974 (Public Law 93-579), the following statement is fumished to individuals who supply information to the U.S. Nuclear Regulatory Commission on NRC Form 277. This information is maintained in a system of records designated as NRC-39 and described at 55 Fed:ral Register 33991 (A or the most recent Federal Register publication of the Nuclear Regulatory Commission's Republicat,ugust 20,1990), ion of Systems of Records Notices" that is available at the N G;lman Building,2120 L Street NW, Washington, D.C.

Sections 145 and 161(i) of the Atomic Energy Act of 1954, as amended (42 U.S.C. 2165 and 2201(l),

1. AUTHORITY:

and Executive Order 12356. The authority for soliciting the social security number is Executive Order 9397, dated November 22,1943.

2. PRINCIPAL PURPOSE (S): The information is used by the NRC to verify an ir;dividual's security clearance and authorization for acceas during a classified visit.

The information is provided to the contractor, licensee or other organization or individual to be

3. ROUTINE USE(S):

visited. The information may also be disclosed to an appropriate Federal, State, or local agency in the event the information indicates a violation or potential violation of law and in the course of an administrative or judicial proceeding. In addition, this information. may be transferred to an appropriate Federal, State, and local agency to the Extent relevant and necessary for the NRC decision or to an appropnate Federal agency to the extent relevant and necessary for that agency's decision about you. The use of the social security numoer is necessary because of the l*rge number of individuals who have identical names and birth dates, and whose identities can only distinguished by the social security number.

4. WHETHER DISCLOSURE IS MANDATORY OR VOLUNTARY AND EFFECT ON INDIVIDUAL OF NOT PROVIDING INFORMATION: It is voluntary that you furnish the requested information. Failure to provide the requested information to the NRC may result in the denial of entrance and/or access to the agency or facility and the information to which access is requested. Failure to provide the social security number may delay processing.

5. SYSTEM MANAGER (S) AND ADDRESS:

1 Director, Division of Security Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20556-0001 l

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