NRC regulations in 10 CFR Part 73
prescribe requirements to establish and maintain a physical
protection system and security organization with capabilities for
protection of 1) special nuclear material (SNM) at fixed sites, 2)
SNM in transit, and 3) plants in which SNM is used. The objective
is to ensure that activities involving special nuclear material are
consistent with interests of common defense and security and that
these activities do not constitute an unreasonable risk to public
health and safety. The information in the reports and records
submitted by licensees is used by the NRC staff to ensure that the
health and safety of the public and the environment are protected,
and licensee possession and use of special nuclear material is in
compliance with license and regulatory requirements.
The increase in burden is due
to the addition of two Commission Orders dated 9/29/06 and 4/30/07,
and the revision of burden associated with two previous Orders.
Changes are as follows: New orders Commission Order (Fingerprints
for Access to Safeguards Information), dated 8/21/06, requires
fingerprinting and background checks for access to safeguards
information for non-power reactors. The NRC estimates that it will
receive 250 fingerprints and background checks per year under this
order, which will cover new employees initially undergoing these
checks. Some licensees will submit multiple fingerprint and
background checks, whereas others may have no new employees in a
given year. NRC estimates a half hour of reporting burden for
fingerprinting, and 4 hrs of burden to complete background
information. As a result, this order adds 1,125 hrs of reporting
burden (250 fingerprints and background checks x 4.5 hrs per check
= 1,125 hrs). In addition, NRC estimates 2.397 hrs of recordkeeping
per fingerprint and background check, for a total of 600 hrs of
recordkeeping (250 fingerprints and background checks x 2.297 hrs =
600 hrs). Commission Order (Fingerprinting Orders for Access to
Research and Test Reactors [RTRs]), dated 4/30/07, requires the
submittal of fingerprints of individuals who seek or currently have
unescorted access to Research and Test Reactors. The NRC estimates
that it will receive 100 fingerprints and background checks per
year under this order from the 36 RTRs, which will cover new
employees initially undergoing these checks. (Current employees
underwent these checks previously, at the time the order was
issued). Some RTRs will submit multiple fingerprint and background
checks, whereas others may have no new employees in a given year.
NRC estimates a half hour of reporting burden for fingerprinting,
and 4 hrs of burden to complete background information. As a
result, this order adds 450 hrs of reporting burden (100
fingerprints and background checks x 4.5 hrs per check = 450 hrs).
In addition, NRC estimates 2.397 hrs of recordkeeping per
fingerprint and background check, for a total of 240 hrs of
recordkeeping (100 fingerprints and background checks x 2.397 hrs =
240 hrs). Burden revisions to previously issued orders Commission
Order (Training) dated 4/29/03, required power reactor licensees to
revise their training and qualification program to implement
revised training requirements. The previous supporting statement
included a total of 4 hrs of recordkeeping burden for CAT I
licensees under this order. This order does not apply to CAT I
licensees; therefore, these 4 hrs have been removed from the total
burden. The NRC reviewed fingerprint submissions processed during
the past 3 yrs and based on a review of these NRC estimates that
licensees submit 7,500 fingerprint cards and background checks per
year under Commission Order (Access Authorization Power Reactors)
dated 1/7/03, which requires nuclear power reactor licensees to
reinvestigate selected personnel at a predetermined frequency, and
to collect, verify, maintain, and protect additional background
information not previously considered. This previous estimate
included 1.5 hrs for the 64 power reactor licensees to determine
the number of reinvestigations required, totaling 96 hrs. Upon
further review, the NRC re estimated the burden for this order from
1.5 hrs per licensee to 4.5 hrs per investigation to implement this
order. NRC currently estimates a half hour of reporting burden for
fingerprinting, and 4 hrs of burden to complete background
information. This order currently totals 33,750 hrs of reporting
burden (7,500 fingerprints and background checks x 4.5 hrs per
check = 33,750 hrs), an increase of 33,654 hrs. In addition, these
fingerprints increased the current recordkeeping burden for this
order by 17,978 hrs (7,500 records x 2.397 hrs recordkeeping per
record), from 153,408 hrs to 171,386 hrs.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
10CFR73FinalSS2008.doc
10 CFR 73, Physical Protection of Plants and Materials