ML23144A240

OMB 3150-0033, Final Supporting Statement for NRC Form 212 Final Supporting Statement

ML23144A240
Person / Time
Issue date:	06/16/2023
From:	NRC/OCIO
To:
References
OMB 3150-0033
Download: ML23144A240 (4)

Text

SUPPORTING STATEMENT FOR NRC FORM 212, QUALIFICATIONS INVESTIGATION PROFESSIONAL, TECHNICAL, AND ADMINISTRATIVE POSITIONS 3150-0033 EXTENSION Description of the Information Collection The NRC Form 212 is sent to former employers, supervisors, and other references indicated on job applications as a part of the investigation for suitability of external candidates for appointment to professional, technical and administrative positions in the U.S. Nuclear Regulatory Commission (NRC). The information obtained on NRC Form 212 is reviewed and evaluated by personnel of the Office of the Chief Human Capital Officer (OCHCO) in determining the qualifications of applicants for employment.

The form provides questions that are designed to prompt the responder to engage in a meaningful discussion for all positions and reduces the number of references required to support a hiring decision.

A. JUSTIFICATION

1. Need for and Practical Utility of the Collection of Information Information requested on NRC Form 212 is used to determine the qualifications and suitability of applicants for employment in professional, technical, and administrative positions with the NRC. The completed form may be used to examine, rate and/or assess the prospective employees qualifications. The information regarding the qualifications of applicants for employment is reviewed by professional personnel in OCHCO, in conjunction with other information in the NRC files, to determine the qualifications of the applicant for appointment to the position under consideration.

2. Agency Use of Information The NRC Form 212, Qualifications Investigation, Professional, Technical, and Administrative Positions is used for investigating the qualifications of external candidates for appointment to professional, technical, and administrative positions in the NRC.

3. Reduction of Burden Through Information Technology There are no legal obstacles to reducing the burden associated with this information collection. The NRC encourages respondents to use information technology when it would be beneficial to them. The non-recurrence of each individual collection makes it difficult to reduce the burden using technology.

However, the NRC encourages the respondents to use any innovative technology which would reduce burden. It is estimated that approximately 100%

of the potential responses are filed electronically; the form is now fillable and may be sent directly to responders via email.

4. Effort to Identify Duplication and Use Similar Information No sources of similar information are available. There is no duplication of requirements.

5. Effort to Reduce Small Business Burden Information may be requested from individuals associated with small businesses; however, the amount of information requested is kept to a minimum while still allowing a full investigation.

6. Consequences to Federal Program or Policy Activities if the Collection Is Not Conducted or Is Conducted Less Frequently Without this information, the agencys ability to make sound decisions on employment eligibility is negatively impacted.

7. Circumstances Which Justify Variation from OMB Guidelines This request does not vary from OMB guidelines.

8. Consultations Outside the NRC Opportunity for public comment on the information collection requirements for this clearance package was published in the Federal Register on February 14, 2023 (88 FR 9541). No comments were received. As part of the consultation process, four NRC staff were contacted via telephone. No comments were received in responses to these consultations.

9. Payment or Gift to Respondents Not Applicable.

10. Confidentiality of Information Confidential and proprietary information is protected in accordance with NRC regulations in Title 10 of the Code of Federal Regulations (10CFR) 9.17(a) and 10 CFR 2.390(b).

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To maintain the privacy of applicants, completed NRC Form 212s are maintained in secured electronic files and destroyed within the Office of the Chief Human Capital Officer.

NRC Form 212 does not collect any personal identifiable information.

11. Justification for Sensitive Questions Not applicable.

12. Estimated Burden and Burden Hour Cost Based on staff experience, it is estimated that it takes about 30 minutes to complete a form. The total estimated burden for the approximately 1000 forms received annually is 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> (0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> x 1000 forms). The estimated annual cost is $144,00 (500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> x $288/hour).

The $288 hourly rate used in the burden estimates is based on the Nuclear Regulatory Commissions fee for hourly rates as noted in 10 CFR 170.20 Average cost per professional staff-hour. For more information on the basis of this rate, see the Revision of Fee Schedules; Fee Recovery for Fiscal Year 2021 (86 FR 32146, June 17, 2021).

13. Estimate of Other Additional Costs There are no additional costs.

14. Estimated Annualized Cost to the Federal Government The total estimated annual cost to the Federal Government for printing, handling, reviewing, and assessing the NRC Form 212 is $144,00 (1000 forms x .5/hours x 288/hour).

15. Reasons for Changes in Burden or Cost The estimated burden has increased from 250 to 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> annually. The number of forms that NRC staff anticipates receiving has increased from 500 to 1000 annually. This increase is due to the increase in external hiring since the last renewal of this information collection. The NRC Form 212 is only used as part of the suitability investigation of external candidates as part of the hiring process. An increase in external hires results in an increase in the number of NRC 212s that are completed.

In addition, the fee rate has increased from $278 per hour to $288 per hour.

16. Publication for Statistical Use 3

This information is not published for statistical use.

17. Reason for Not Displaying the Expiration Date The expiration date is displayed on the form.

18. Exceptions to the Certification Statement Not applicable.

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

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