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