10CFR73FinalSS2008

FINAL SUPPORTING STATEMENT

FOR

10 CFR PART 73

PHYSICAL PROTECTION OF PLANTS AND MATERIALS

(3150-0002)

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REVISION WITH BURDEN UPDATE

Description of the Information Collection

The U.S. Nuclear Regulatory Commission (NRC) regulations in 10 CFR Part 73 prescribe requirements for the establishment and maintenance of a system for physical protection of special nuclear material (SNM) at fixed sites, SNM in transit and of plants in which SNM is utilized. The regulations are issued pursuant to the Atomic Energy Act of 1954, as amended, and Title II of the Energy Reorganization Act of 1974, as amended. Part 73 contains reporting and recordkeeping requirements which are necessary to help ensure that an adequate level of protection is provided for nuclear facilities and nuclear material. This clearance revision incorporates changes in information collections contained in Commission Orders issued August 21, 2006, (Fingerprints for Access to Safeguards Information), and April 30, 2007 (Fingerprinting Orders for Unescorted Access to Research and Test Reactors). The Orders were issued to enhance security programs in response to the threat environment following the attacks of September 11, 2001.

A. Justification

1. Need for and Practical Utility of the Information

In general, the reports and records are necessary for one or more of the following reasons:

• Information describing the content and planned operation of the licensee's physical protection system (e.g., Security Plan, Contingency Plan, or Training and Qualification Plan). This information is essential to enable the NRC to make a determination about the adequacy of the licensee's planned system in meeting regulatory requirements.

• Information describing the normal operation of the physical protection system (e.g., access authorizations, equipment performance logs). This information is needed to permit the NRC to make a determination as to reasonable assurance that the physical protection system operates in accordance with the regulatory requirements.

• Information notifying the NRC of the occurrence of and circumstances surrounding abnormal events (e.g., report of theft, sabotage, or overdue shipment). This information is needed to enable the NRC to fulfill its responsibilities to respond to, investigate, and correct situations which adversely affect public health and safety or the common defense and security.

Requirements in Part 73

Specific requirements for reports and records in Part 73 are as follows.

Section 73.5 provides that the Commission may grant exemptions from the requirements of the regulations in Part 73 under specified conditions, upon the application of any interested person or on its own initiative. Applications under this section are examined by the NRC staff to determine whether the requested exemption is authorized by law and whether it will not endanger life or property or the common defense and security, and to determine if it is otherwise in the public interest.

Section 73.20(c) requires that each affected licensee shall establish, maintain, and follow NRC approved safeguards physical protection, contingency, and if appropriate, transportation protection plans. The required plans are used to review the adequacy of a licensee's intended security system for compliance and enforcement purposes.

Section 73.21(a) requires that licensees who possess a formula quantity of SSNM, operate a nuclear power reactor or transports a formula quantity of SSNM establish and maintain an information protection system that protects Safeguards Information. This is a one time requirement and would have been completed by all licensees. There is no burden to keep this information on file.

The proposed rule change for Section 73.21(a) would require additional types of information to be marked, controlled, and protected as Safeguards Information. This increased volume of Safeguards Information will increase the recordkeeping effort associated with marking, control and protection of Safeguards Information.

Section 73.24(b)(1) requires that licensees maintain a log of the arrival at the final destination of each shipment. The record is necessary to ensure that there are not two or more shipments of SNM in transit at the same time which together would constitute a formula quantity, and to ensure verification of the arrival of the shipment.

Section 73.25(b) requires procedures to restrict access to and activity in the vicinity of transports and strategic special nuclear material (SSNM).

Section 73.25(c) requires procedures to prevent or delay unauthorized entry or introduction of unauthorized materials into, and unauthorized removal of, SSNM from transports.

Section 73.25(d) requires procedures for responding to safeguards contingencies and emergencies in order to engage and impede adversary forces until local law enforcement forces arrive. These procedures are necessary to protect the material while in transit.

Section 73.26(b)(3) requires that, prior to each shipment, licensees provide information to NRC concerning the identity of the shipper, consignee, carriers, transfer points, modes of shipment, and security arrangements for the shipment. The information is needed to permit NRC to ensure that adequate measures will be taken to protect the material in transit.

Section 73.26(b)(4) requires that hand to hand receipts be completed at origin, destination, and all points en-route where there is a transfer of custody. These receipts are needed to provide a record of custody to verify that accountability for the shipment has been maintained.

Section 73.26(c) provides that required records of exports or imports must be maintained for 3 years after the licensee possesses the SNM, and that superseded material must be retained for 3 years after the change. The records are reviewed by NRC inspectors to ensure compliance with transportation protection requirements.

Section 73.26(d)(3) requires that licensees maintain a written management system to provide for the development, revision, implementation, and enforcement of transportation physical protection procedures. The system must include (1) written security procedures which document the structure of the transportation security organization and duties of personnel, and (2) provisions for written approval of procedures and revisions by the individual with overall responsibility for the security function. The information is needed to ensure compliance with, and oversight of, the transportation protection plan.

Section 73.26(d)(4) requires that licensees maintain documentation of qualification and re-qualification of members of the security organization. The record of initial qualification must be maintained for the term of employment and the record of re-qualification must be retained for three years. The information is reviewed by NRC inspectors to ensure that security organization members are properly qualified in accordance with the safeguards transportation protection plan.

Section 73.26(e)(1) requires licensees to maintain a written safeguards contingency plan for dealing with threats, thefts, and radiological sabotage related to SSNM in transit. The plan must be retained for 3 years after the possession of the SSNM and superseded material must be retained for three years after the change. The records are used by NRC inspectors to ensure that the licensee is adequately prepared to respond to different safeguards contingencies.

Section 73.26(f)(2) requires licensees to (1) call remote location at least every 30 minutes to report status of shipment; (2) if call is not received, licensee commander shall request assistance from local law enforcement agencies (LLEA) and notify shipment movement control center and initiate appropriate contingency plan; (3) upon departure from transfer point, escorts shall notify the licensee of the latest status immediately thereafter departure. Calling the remote location every 30 minutes is a part of the security staffs normal duties and is not reported as part of the burden.

Section 73.26(g)(1) requires a numbered picture badge identification procedure to be used to identify all individuals who will have custody of a shipment of nuclear material. All security officers assigned to duties involving shipments of nuclear material are required as a normal part of their duties to wear numbered picture badges and as such this is not reported as part of the burden.

Section 73.26(h)(6) requires that licensees document the results of an annual audit of the transportation security program, along with recommendations for improvements, and that the documentation be retained as a record for 3 years. The records are reviewed by the NRC inspectors to ensure that the effectiveness of the physical security system is evaluated by licensee personnel independent of security management and supervision.

Section 73.26(i)(1) requires that licensees prepare a detailed route plan showing the routes to be taken, refueling and rest stops, and call-in times to the movement control center. This document is used to plan the movement of the shipment so that it is made on primary highways with minimum use of secondary roads, and to ensure that adequate measures for support and communications are available to protect the shipment.

Sections 73.26(i)(6) and 73.26(k)(4) require that, in the event that no communication is received from the shipment or escort personnel at a designated call-in time, the licensee must notify law enforcement authorities and the NRC Regional Office immediately and initiate appropriate contingency plans. This notification is necessary so that the NRC can ensure that timely response or investigation actions may be undertaken.

Section 73.27(a)(1) requires that a licensee who delivers formula quantities of SSNM to a carrier for transport must immediately notify the consignee by telephone, telegraph, or teletype, of the time of departure of the shipment and method of transportation, including names of carriers, and the estimated time of arrival at destination. This information is needed to ensure that the consignee is aware that the shipment is en route so the consignee can carry out the safeguards transportation protection plan.

Section 73.27(a)(2) requires that, in the case of a free on board shipment, the licensee shipper must obtain written certification from the consignee who is to take delivery at the f.o.b. point that the required physical protection arrangements have been made. This information is needed to ensure that the safeguards transportation protection plan will be carried out.

Section 73.27(a)(3) requires that a shipper make arrangements to obtain immediate notification from the consignee of the arrival of a shipment at its destination or of any shipment that is lost or unaccounted for after the estimated time of arrival at its destination. This information is required so that the licensee can promptly notify the NRC of any missing material so that a trace investigation may be initiated.

Section 73.27(b) requires a licensee who receives a shipment of formula quantities of SSNM to immediately notify the shipper and the NRC of the arrival of the shipment at its destination, or of the failure of a shipment to arrive at its destination at the estimated time. In the latter event, the shipper must also notify the NRC of the actions being taken to trace the shipment. This information is needed to ensure that accountability is maintained for SSNM in transit, so that appropriate measures may be taken to initiate a trace and undertake recovery action if necessary.

Section 73.27(c) requires that in the case of a lost or unaccounted for shipment, the licensee who made the physical protection arrangements must conduct a trace investigation and file with the NRC a report of the investigation as specified in §73.71. This information is needed to permit the NRC to determine whether all appropriate measures have been taken to trace and recover the material.

Section 73.37(a) requires licensees who ship irradiated reactor fuel to establish and maintain a physical protection system that includes provisions for notification to the appropriate response forces of any spent fuel shipment sabotage attempts. This notification is needed to ensure that appropriate action is taken in accordance with the safeguards transportation protection plan.

Section 73.37(b) requires that the physical protection system include a number of provisions, including: § 73.37(b)(1) advance notice to the NRC of each shipment in accordance with § 73.72; § 73.37(b)(2) a copy of current procedures for coping with circumstances that threaten deliberate damage to a spent fuel shipment and with other emergencies; § 73.37(b)(3) a copy of instructions for each escort which require that, upon the detection of certain threats, the escort must inform LLEA of the threat and request assistance; § 73.37(b)(5) a written log by the escorts and communications center personnel which describes significant events during the shipment; § 73.37(b)(7) advance approval by the NRC of routes used for road and rail shipments of spent fuel, and for any U.S. ports where vessels carrying spent fuel shipments are scheduled to stop; § 73.37(b)(11) calls by the escort to the communications center at least every 2 hours. These procedures are needed to ensure that appropriate measures are in place to protect the material during transport and that an adequate response can be taken to emergencies affecting the shipment.

Section 73.37(f) requires that the licensee notify the governor of a State in writing prior to a shipment of spent fuel within or through a State. The notification must include information on the shipper, carrier, and receiver, the shipment, routes to be used within the State, and the schedule to be followed. The licensee must also notify a designated state official by telephone or other means of any schedule change that differs by more than 6 hours from the previous schedule. The notifications are necessary to ensure that the governor of the state is provided with advance information, not otherwise available to the governor, related to spent fuel transportation in the governor's State.

Section 73.40 requires that the licensees shall establish and maintain physical security in accordance with security plans approved by the NRC.

Section 73.45 requires that the licensee's fixed site physical protection system contain certain provisions, including the following:

§ 73.45(b)(2)(i),(ii) Access authorization control procedures;

§ 73.45(c)(1)(i),(iii) Detection and surveillance procedures to detect unauthorized activity;

§ 73.45(d)(i)-(iv) Procedures to detect unauthorized placement and movement of SSNM within material access areas;

§ 73.45(e)(1)(ii) Procedures for the detection, assessment and communication of any attempts at unauthorized removal of SSNM from material access areas;

§ 73.45(e)(2)(i)-(iii) Procedures to confirm the identity and quantity of SSNM presented for removal and the identity of persons making the removal;

§ 73.45(f)(1)(ii) Procedures to detect, assess, and communicate any unauthorized access or penetrations of the protected area;

§ 73.45(f)(2)(i)(ii) Procedures to verify the identity of persons, materials, and vehicles and assess such identity against current authorization schedules and to initiate response measures to deny unauthorized access;

§ 73.45(g)(2) Response plan for safeguards contingency events.

These plans and procedures are required in order to ensure that measures are in place to control movement of persons, vehicles, and materials into or out of material access or vital areas and to detect, assess, and initiate appropriate response to any unauthorized penetration or access attempts.

Section 73.46(b)(1) requires that, if a contract guard force is utilized, the licensee have a written agreement with the contractor that contains provisions showing that the licensee is responsible to NRC for maintaining safeguards in accordance with NRC regulations and the licensee's security plan, that NRC may inspect, copy, and remove copies of required reports and documents, and that the licensee must demonstrate the capability of the security force, including contractor personnel, to perform their assigned duties. This requirement is necessary to ensure that the licensee makes the security force contractor aware of its responsibilities.

Section 73.46(b)(3) requires that the licensee have written security procedures which document the structure of the security organization and which detail the duties of the Tactical Response Team, guards, watchmen, and other individuals responsible for security. The licensee must also have provisions for written approval of such procedures and any revisions thereto by the individual with overall responsibility for the security function. These procedures are necessary to ensure that a management system is in place, that responsibilities and duties are set forth clearly, and that the security organization is adequate to provide protection in accordance with the security plan.

Section 73.46(b)(4) requires that the licensee document the results of each weapons qualification and re-qualification, the annual physical fitness performance test or the quarterly administered site specific content-based test. These records verify that qualification and re-qualification have occurred and provide a record of individual performances.

Section 73.46(b)(7) requires that licensees document the qualification and re‑qualification of Tactical Response Team members, armed response personnel, and guards in day and night firing. These records verify that qualification and re-qualification have occurred and provide a record of individual performances.

Section 73.46(b)(8) requires that licensees document the training of Tactical Response Team members in response tactics. These records verify that training has occurred and provide a record of individual performances.

Section 73.46(b)(9) requires that the licensee notify NRC at least 60 days in advance of a scheduled training exercise for the security force which is required to be observed by NRC. The licensee must also document the results of all exercises. The notification requirement allows the NRC to arrange for NRC inspectors to observe the exercise. The documentation verifies that the exercise was conducted and provides a record of security force performance.

Section 73.46(b)(10)(iii) requires that the licensee obtain a written certification by an examining physician that there are no contraindications to individual's participation in the physical fitness training program.

Section 73.46(b)(11)(i) requires that the licensee retain a record of each security force member's attempt to qualify or re-qualify by meeting or exceeding the applicable qualification criteria. This is a repetition of the requirement in 10 CFR 73.46(b)(4).

Section 73.46(b)(11)(iii) requires that prior to participation in the physical performance testing each security force member must obtain a medical clearance from a licensed practitioner stating that there are no medical contraindications to the individual's participation in such testing.

Section 73.46(b)(12) and 73.46(b)(12)(i) when taken together require the submission of the site specific content-based tests for NRC's approval. This information is incorporated into the Licensee's Physical Protection Plan and may be used by NRC to inspect the physical performance testing programs to ensure that they are adequate to protect the health and safety of the public.

Section 73.46(b)(12)(ii) requires that, prior to the administration of the site specific content-based physical fitness tests and annually thereafter, a physical examination be conducted and a written certification, that there are no medical contraindications to participation in the tests, be obtained from a licensed physician.

Section 73.46(d)(3) requires the licensee to maintain written procedures that permit access control personnel to identify those vehicles that are authorized and those materials that are not authorized entry to protected, material access, and vital areas. These procedures are necessary to ensure compliance with access control provisions of the security plan.

Section 73.46(d)(10) requires that the licensee must maintain records of the findings of teams conducting drum scanning and tamper sealing of containers of contaminated waste. These records verify that the scanning was conducted and document the scan readings for later use in review of the waste shipments if needed.

Section 73.46(d)(11) requires that licensee teams must verify and certify the contents of containers of SSNM being prepared for shipment offsite. These records verify the weight, assay, and tamper seal integrity of the containers.

Section 73.46(d)(13) specifies that licensees must require that individuals provided escorted access to protected areas register their name, date, time, purpose of visit and employment affiliation, citizenship, and name of the individual to be visited in a log. The log serves as a record of visitors permitted access, serves as an document that may be inspected to verify that access control requirements are being followed, and facilitates any subsequent investigation of irregular events.

Section 73.46(g)(5) requires that the licensee maintain corrective action procedures for use in the event of failure or other contingencies affecting the operation of security related equipment or structures. The security organization must be notified before and after service is performed on such equipment. These procedures are needed to ensure that compensatory measures will be employed in the event of failure of the function of physical protection related systems.

Section 73.46(g)(6) requires the documentation and reporting to management of the results of an annual independent review and audit of the security program. The records are reviewed by NRC inspectors to ensure that the effectiveness of the security program is evaluated by licensee personnel independent of security management and supervision and that the results of the review are reported to higher management. These records must be retained for 3 years.

Section 73.46(h)(1) requires that licensees maintain a safeguards contingency plan for dealing with threats, thefts, and radiological sabotage related to SSNM and nuclear facilities. This document is used by the licensee to set forth plans for dealing with contingencies as outlined in Appendix C to Part 73. The plan is used by NRC in the licensing approval process to ensure sufficient scope and depth in the contingency planning area and also serves as a compliance benchmark during the inspection process.

Section 73.46(h)(2) requires that licensees establish and document a response agreement with local law enforcement authorities. The agreement is used to verify law enforcement response capabilities and to ensure a clear understanding by both parties of what is expected and what law enforcement assistance will be provided in case of an emergency.

Section 73.46(h)(3) requires that licensees include in the physical protection plans submitted to NRC the basis for the determination of the size and availability of an additional force of guards or armed response personnel. This information permits NRC to ensure that the licensee has made appropriate provision for an onsite response force to engage and impede an adversary force until offsite assistance arrives.

Section 73.46(h)(4) requires that licensees inform local law enforcement agencies of any detected threat and request assistance. This notification requirement is necessary to ensure that law enforcement assistance is obtained to help neutralize any threat to vital areas or material access areas.

Section 73.46(h)(5) requires that licensees instruct all guards and armed response personnel regarding the use of force, including deadly force when necessary for self-defense or defense of others, to prevent or impede acts of radiological sabotage or theft of SSNM.

Section 73.46(i)(1) requires that licensees submit a revised fixed site physical protection plan to NRC for approval. This requirement is necessary to conform licensee plans to current NRC regulations. The NRC regulations concerning physical protection, security personnel performance, and design basis threat for certain fuel facilities provide requirements for guard weaponry, training, and tactical response exercises, as well as certain physical security measures.

Section 73.50(a)(3) requires that certain licensees who possess, use, or store formula quantities of SSNM must maintain written security procedures that document the structure of the security organization and detail the duties of guards, watchmen, and other individuals responsible for security. These procedures are necessary to ensure that responsibilities and duties are set forth clearly, and that the security organization is adequate to provide protection in accordance with the security plan.

Section 73.50(a)(4) requires that licensees document the qualification and re‑qualification of guards, watchmen, and other members of the security organization. These records verify that qualification and re-qualification have occurred and provide a record of individual performances.

Section 73.50(c)(5) specifies that licensees must require that individuals provided escorted access to protected areas register their name, date, time, purpose of visit and employment affiliation, citizenship, name and badge number of the escort, and name of the individual to be visited in a log. The log serves as a record of visitors permitted access, serves as a document that may be inspected to verify that access control requirements are being followed, and facilitates any subsequent investigation of irregular events.

Section 73.50(g)(1) requires that licensees maintain an NRC‑approved safeguards contingency plan for dealing with threats, thefts, and radiological sabotage related to SSNM and nuclear facilities. This document is used by the licensee to set forth plans for dealing with contingencies as outlined in Appendix C to Part 73. The plan is used by NRC in the licensing approval process to ensure sufficient scope and depth in the contingency planning area and also serves as a compliance benchmark during the inspection process.

Section 73.50(g)(2) requires that licensees establish and document a response agreement with local law enforcement authorities. The agreement is used to verify law enforcement response capabilities and to ensure a clear understanding by both parties of what is expected and what law enforcement assistance will be provided in case of an emergency.

Section 73.50(g)(3) requires that licensees inform local law enforcement agencies of any detected threat and request assistance. This notification requirement is necessary to ensure that law enforcement assistance is obtained to help neutralize any threat to vital areas or material access areas.

Section 73.50(g)(4) requires that licensees instruct all guards and armed response personnel regarding the use of force, including deadly force when necessary for self-defense or defense of others, to prevent or impede acts of radiological sabotage or theft of SSNM.

Section 73.50(h) requires that licensees establish, maintain, and follow an NRC‑approved training and qualifications plan outlining the processes by which guards, watchmen, armed response persons, and other members of the security organization will be selected, trained, equipped, tested, and qualified. This section required preparation of a plan for spent fuel storage facility security forces training and qualification. It serves as a basis for NRC assessments of licensee adequacy in security force training and qualification and serves as an inspection reference in verifying licensee performance.

Section 73.51(b)(1) requires the licensee to establish and maintain a physical protection system to provide high assurance that activities involving spent nuclear fuel and high level radioactive waste do not constitute an unreasonable risk to public health and safety.

Section 73.51(b)(2) requires the licensee to store spent fuel in a secured area, to grant access only to authorized individuals, detect and assess unauthorized penetrations, provide timely communication to a response force and manage the system to ensure that it remains effective.

Section 73.51(c) requires the licensee to retain a copy of the effective physical protection plan as a record for 3 years or until termination of the license for which procedures were developed.

Section 73.51(d) describes the physical protection systems, components, and procedures acceptable to the NRC for meeting the performance capabilities in 73.52(b)(2).

Section 73.51(d)(5) requires that a security organization must include sufficient personnel per shift to provide monitoring of detection systems and the conduct of surveillance, assessment, access control and communication to assure adequate response. Members of the security organization must be trained, equipped, qualified, and re-qualified to perform assigned job duties in accordance with Appendix B.

Section 73.51(d)(6) requires a licensee to establish a documented liaison with local law enforcement or designated response force. (This documentation is updated as needed. In most cases this occurs at intervals of 5-8 years.)

Section 73.51(d)(7) requires the licensee to establish and maintain a personnel identification system and a controlled lock system to limit access to authorized individuals.

Section 73.51(d)(10) requires the licensee to establish and maintain written response procedures to address unauthorized penetrations into the protected area. Once the procedures are completed there is no ongoing burden to maintain the procedures. These procedures are incorporated into the physical protection plan.

Section 73.51(d)(12) requires the licensee to review the physical protection program every 24 months by individuals independent of both physical protection program management and personnel who have direct responsibility for implementation of the physical protection program. The review must include an evaluation of the effectiveness of the physical protection system and verification of the liaison established with the designated response force or LLEA.

Section 73.51(d)(13)(i)(ii)(iii)(iv)(v) requires the licensee to retain the following records for 3 years after the record is made or until termination of the license: A log of individuals granted access to the protected area. Screening records of members of the security organization. A log of all patrols. A record of each alarm received identifying the type of alarm, location, date and time when received, and disposition of the alarm and the physical protection program review reports.

Section 73.55 requires that licensees submit proposed amendments to their security plans which show how the regulations regarding physical protection against radiological sabotage will be met. The plans were required in order to allow NRC to determine that licensees had made adequate provisions to protect against the design basis threat of radiological sabotage. All such amendments under this section have been previously submitted and no new burden is anticipated.

Section 73.55(b)(1) requires that, if a contract guard force is utilized, the licensee have a written agreement with the contractor that contains provisions showing that the licensee is responsible to the NRC for maintaining safeguards in accordance with NRC regulations and the licensee's security plan, that the NRC may inspect, copy, and remove copies of required reports and documents, and that the licensee must demonstrate the capability of the security force, including contractor personnel, to perform their assigned duties. This requirement is necessary to ensure that the licensee makes the security force contractor aware of its responsibilities.

Section 73.55(b)(3) requires that the licensee have written security procedures which document the structure of the security organization and which detail the duties of guards, watchmen, and other individuals responsible for security. The licensee must also have provisions for written approval of such procedures and any revisions thereto by the individual with overall responsibility for the security function. These procedures are

necessary to ensure that a management system is in place, that responsibilities and duties are set forth clearly, and that the security organization is adequate to provide protection in accordance with the security plan.

Section 73.55(b)(4)(i) requires that licensees document the qualification and re-qualification of guards, watchmen, armed response persons, and other members of the security organization. These records verify that qualification and re-qualification have occurred and provide a record of individual performances.

Section 73.55(b)(4)(ii) requires that licensees submit a training and qualifications plan to NRC for approval setting forth the process and schedule by which guards, watchmen, armed response persons, and other members of the security organization will be selected, trained, equipped, tested, and qualified. This section requires preparation of a plan for power reactor security forces training and qualification. It serves as a basis for NRC assessments of licensee adequacy in security force training and qualification and serves as an inspection reference in verifying licensee performance.

Section 73.55(c)(7) requires applicable licensees to establish vehicle control measures and to design and install a vehicle barrier system. This requirement is necessary to protect against the use of a land vehicle to gain unauthorized proximity to vital areas.

Section 73.55(c)(8) requires licensee to compare the vehicle control measures established in accordance with 10 CFR 73.55(c)(7) to the Commission's design goals and criteria for protection against a land vehicle bomb; and either confirm to the Commission that the vehicle control measures meet the design goals and criteria specified, or propose alternative measures that, in addition to the measures established in accordance with 10 CFR 73.55(c)(7), describe the level of protection that these measures would provide against a land vehicle bomb, and compare the costs of the alternative measures with the cost of measures necessary to fully meet the design goals and criteria. This requirement is needed to give the NRC confirmation that the licensee has met the Commission's design goal.

Section 73.55(c)(9)(i) requires licensees to submit to the Commission a summary description of the proposed vehicle control measures as required by 10 CFR 73.55(c)(7) and the results of the vehicle bomb comparison as required by 10 CFR 73.55(c)(8). For licensees proposing alternative measures as provided for in 10 CFR 73.55(c)(8), the submittal must include the analysis and justification for the proposed alternatives. This submittal will ensure the NRC that the licensee is meeting the intent of the rule.

Section 73.55(c)(9)(iv) requires licensees to retain, in accordance with 10 CFR 73.70, all comparisons and analyses prepared pursuant to 10 CFR 73.55(c)(7) and (8). The requirement will ensure that the licensee remains in compliance with the rule.

Section 73.55(c)(10) requires applicants for a license to operate a nuclear power reactor to incorporate the vehicle control program into the site physical security plan. This information is incorporated into the Licensee's Physical Protection Plan and may be used by NRC to inspect the measures that have been put into place to protect against a land vehicle bomb.

Section 73.55(d) requires that each licensee define how the final search requirements of this section will be met. This requirement is necessary to permit NRC to determine that the licensee has made adequate provisions to detect and prevent access of firearms, explosives, and incendiary devices.

Section 73.55(d)(6) specifies that licensees must require that individuals provided escorted access to protected areas register their name, date, time, purpose of visit and employment affiliation, citizenship, and name of the individual to be visited in a log. The log serves as a record of visitors permitted access, serves as a document that may be inspected to verify that access control requirements are being followed, and facilitates any subsequent investigation of irregular events.

Section 73.55(d)(7) requires the licensee to establish, maintain, and update an access authorization list for each vital area. This requirement is used to limit unescorted access to vital areas during non-emergency conditions to individuals who require access in order to perform their duties.

Section 73.55(g)(1) requires that the licensee maintain compensatory measures and procedures for use in the event of failure or other contingencies affecting the operation of security related equipment or structures. These procedures are needed to ensure that the effectiveness of the security system is not reduced.

Section 73.55(g)(4) requires the documentation and reporting to management of the results of an annual independent review and audit of the security program or a 24‑month review of the entire security program. The records are reviewed by NRC inspectors to ensure that the effectiveness of the security program is evaluated by licensee personnel independent of security management and supervision and that the results of the review are reported to higher management.

Section 73.55(h)(1) requires that licensees execute a safeguards contingency plan for dealing with threats, thefts, and radiological sabotage related to the nuclear facilities. This document is used by the licensee to set forth plans for dealing with contingencies as outlined in Appendix C to Part 73. The plan is used by NRC in the licensing approval process to ensure sufficient scope and depth in the contingency planning area and also serves as a compliance benchmark during the inspection process.

Section 73.55(h)(2) requires that licensees establish and document liaison with local law enforcement authorities. The agreement is used to verify law enforcement response capabilities and to ensure a clear understanding by both parties of what is expected and what law enforcement assistance will be provided in case of an emergency.

Section 73.55(h)(4) requires that licensees inform local law enforcement agencies of any detected threat and request assistance. This notification requirement is necessary to ensure that law enforcement assistance is obtained to help neutralize any threat to vital areas or material access areas.

Section 73.55(h)(5) requires that licensees instruct all guards and armed response personnel regarding the use of force, including deadly force when necessary for self-defense or defense of others, to prevent or impede acts of radiological sabotage or theft of SSNM.

Section 73.56 provides personnel access authorization requirements for nuclear power plants. All licensees authorized to operate a nuclear power reactor pursuant to 10 CFR 50.22 are required to establish an access authorization program consisting of a background investigation, psychological assessment, and behavioral observation, and to submit the program to NRC to be included in their physical security plan. The specific requirements are described below.

Section 73.56(a)(1), (2), and (3) requires that the licensee or applicant incorporate the access authorization program into its physical security plan within a year of the enactment of the rule and certify its implementation. This one-time submittal is necessary to inform NRC that the access authorization programs have been added to the physical security plans and are being implemented. The change in burden was reported in a previous supporting statement.

Section 73.56(b)(1) requires that the licensee establish and maintain an access authorization program that provides high assurance that individuals granted unescorted access to protected and vital areas are trustworthy and reliable, and do not constitute an unreasonable risk to the health and safety of the public including a potential to commit radiological sabotage.

Section 73.56(b)(2) establishes the three elements necessary to meet the performance objectives: a background investigation, a psychological assessment, and behavioral observation.

Section 73.56(c) establishes provisions for existing, reinstated, transferred, and temporary access authorization.

Section 73.56(d) establishes the conditions under which unescorted access authorization may be granted during cold shutdown. The licensee must incorporate measures to ensure functional capability of equipment into its physical security plan and submit those plan changes to the NRC under 10 CFR 50.90.

Section 73.56(e) requires that licensees establish a procedure for a review process for an employee when a denial of unescorted access has an adverse effect on employment.

Section 73.56(f)(1) requires the establishment of a system of files and procedures designed to protect personal information.

Section 73.56(f)(2) requires licensees, contractors, and vendors to make personal information available to other requesting licensees, contractors, and vendors provided that the request is accompanied by a signed release from the individual.

Section 73.56(g)(1) requires that licensees audit their access authorization programs within 12 months of implementation of the rule and at least every 24 months thereafter to ensure that the requirements of the rule are satisfied.

Section 73.56(g)(2) requires each licensee who accepts the access authorization program of a contractor or vendor to perform an audit every 12 months to ensure that the requirements of the rule are satisfied.

Section 73.56(h)(1) requires that the licensee retain records on which unescorted access authorization is based for the duration of unescorted access authorization and 5 years following its termination, and retain records of denial for 5 years. The records are reviewed by NRC inspectors to verify that the requirements of the access authorization program are being met.

Section 73.56(h)(2) requires that licensees retain records of the results of audits, resolution of the audit findings, and corrective actions, for 3 years. The records are reviewed by NRC inspectors to verify that the requirements of the access authorization program are being met.

Sections 73.57(a) requires that each applicant for a license to operate a nuclear power reactor shall submit a fingerprint card for individuals who have access to Safeguards Information and nuclear power plant licensees shall fingerprint each individual who has or will have access to Safeguards Information or who will require unescorted access to the nuclear power facility.

Section 73.57(b)(3) requires that each nuclear power plant licensee notify fingerprinted individuals that the fingerprints will be used to secure a review of his/her criminal history record, and inform the individual of proper procedures for revising the record or including explanation in the record.

Section 73.57(d) requires that licensees submit the fingerprint cards to NRC, which will forward them to the Federal Bureau of Investigation (FBI) for criminal history checks.

Section 73.57(e) requires that, prior to any adverse action, the licensee must make available to the individual the contents of records obtained from the FBI for the purpose of assuring correct and complete information, and must retain a record of receipt by the individual of this notification for 1 year from the date of the notification.

Section 73.57(f) requires that the licensee establish and maintain a system of files and procedures to retain and protect criminal history data and other personal information from disclosure for one year after termination or denial of access.

Section 73.60(e) requires the licensee to establish, maintain, and follow an NRC‑approved safeguards contingency plan, as outlined in Appendix C to Part 73.

Section 73.67(a)(1) requires the licensee to establish and maintain a physical protection system that will minimize the possibilities for unauthorized removal, and to facilitate the location and recovery of missing special nuclear material.

Section 73.67(a)(2) requires licensees to establish and maintain a physical protection system that provides (I) early detection and assessment of unauthorized access or activities by an external adversary within the controlled access area containing SNM; (ii) early detection of removal of SNM by an external adversary from a controlled access area; (iii) assure proper placement and transfer of custody of SNM; and (iv) respond to indications of an unauthorized removal of SNM and then notify the appropriate response forces of its removal in order to facilitate its recovery.

Section 73.67(c)(1) requires the licensee to submit a security plan or amended security plan describing how the licensee will comply with the physical protection requirements of the regulations. The licensee must also retain the effective security plan as a record. This information is needed to permit the NRC to determine the adequacy and completeness of the licensee's safeguards system and to provide documentation of a satisfactory safeguards system which can be inspected by NRC.

Section 73.67(d)(11) requires licensees to establish and maintain written response procedures for dealing with thefts or threats of thefts of SNM of moderate strategic significance at fixed sites. The licensee must retain a copy of the procedures as a record. The information is used by the licensee to provide instructions to employees for dealing with contingencies and is inspected by NRC to ensure that the licensee has developed adequate procedures for dealing with thefts or threats of thefts.

Section 73.67(e)(1) requires that a licensee shipping SNM of moderate strategic significance provide advance notification to the receiver of any planned shipments specifying the mode of transport, estimated time of arrival, location of the nuclear material transfer point, name of the carrier, and transport identification. The licensee must also receive confirmation from the receiver prior to commencement of the shipment that the receiver will be ready to accept the shipment at the planned time and location and acknowledges the specified mode of transport. This information alerts the intended receiver of an impending shipment. The required notification and confirmation ensure that the shipper has preplanned the transportation of the material and that the receiver is ready to accept the material. It also helps ensure positive control of the material during transport and helps ensure traceability of any missing material.

Section 73.67(e)(2)(ii) requires the licensee to notify the shipper of receipt of material as required in 70.54.

Section 73.67(e)(3)(iv) requires that a licensee who arranges for the in-transit physical protection of SNM of moderate strategic significance, or who takes delivery of the material free on board the point at which it is delivered to a carrier for transport, must establish and maintain written response procedures for dealing with thefts or threats of thefts of the material. The licensee must retain a copy of the procedures as a record. The information is used by the licensee to provide instructions to employees for dealing with contingencies and is inspected by NRC to ensure that the licensee has developed adequate procedures for dealing with thefts or threats of thefts.

Section 73.67(e)(3)(v) requires that a licensee who arranges for the in-transit physical protection of SNM of moderate strategic significance, or who takes delivery of the material free on board to the point at which it is delivered to a carrier for transport, must make arrangements to be notified immediately of the arrival of the shipment at its destination, or of any such shipment that is lost or unaccounted for after the estimated time of arrival at its destination. This information is used by the licensee to determine that a shipment either arrived safely or is missing. Such notification gives the licensee a basis for initiating a trace investigation in the event a shipment becomes delayed or lost.

Section 73.67(e)(3)(vii) requires that a licensee notify the NRC Operations Center within 1 hour after the discovery of the loss of the shipment and within 1 hour after recovery of or accounting for such lost shipment, in accordance with Section 73.71. This notification permits NRC to initiate or terminate a trace investigation if necessary.

Section 73.67(e)(4) requires that a licensee who arranges for the in-transit physical protection of SNM of moderate strategic significance, or who takes delivery of the material f.o.b. the point at which it is delivered to a carrier for transport, must comply with the requirements of § 73.67(e)(1), (2), (3), and (4)(i) and (ii) and retain required records for 3 years. The records are inspected by NRC in order to ensure compliance with the requirements.

Section 73.67(e)(5) requires that a licensee who exports SNM of moderate strategic significance must comply with the requirements of § 73.67(c) and (e)(1), (3), and (4) and retain required records for 3 years. The requirement is similar to that of § 73.67(e)(4), above, but the shipper is exporting material. The records are inspected by NRC in order to ensure compliance with the requirements.

Section 73.67(e)(6)(i) requires that a licensee who imports SNM of moderate strategic significance must comply with the requirements of § 73.67(c) and (e)(2), (3), and (4) and retain required records for 3 years. The requirement is similar to that of § 73.67(e)(5), above, but the shipper is importing material. The records are inspected by NRC in order to ensure compliance with the requirements.

Section 73.67(e)(6)(ii) requires that a licensee notify the exporter who delivered the material to a carrier for transport of the arrival of such material. This information is used by the licensee to determine that a shipment either arrived safely or is missing. Such notification gives the licensee a basis for initiating a trace investigation in the event a shipment becomes delayed or lost.

Section 73.67(e)(7)(i) requires that, upon request by the NRC, a shipper provide additional information regarding a planned shipment. This information, if requested, is used by the NRC to determine whether it is necessary to issue Orders to licensees in the event that it appears to the NRC that two or more shipments of SNM of moderate strategic significance, constituting in the aggregate an amount equal to or greater than a formula quantity of SSNM, may be en route at the same time.

Section 73.67(e)(7)(ii) requires that the receiver, or the shipper if the receiver is not a licensee, notify the NRC Regional Office by telephone within 24 hours after the arrival of the shipment at its final destination, or after the shipment has left the United States as an export. This notification permits the NRC to confirm the integrity of the shipment at the time of receipt or exit from the United States.

Section 73.67(f)(4) requires that a licensee who possesses or uses SNM of low strategic significance at fixed sites, except nuclear power reactor licensees, must establish and maintain written response procedures for dealing with thefts or threats of thefts of the material. The licensee must retain a copy of the procedures as a record. The information is used by the licensee to provide instructions to employees for dealing with contingencies and is inspected by the NRC to ensure that the licensee has developed adequate procedures for dealing with thefts or threats of thefts.

Section 73.67(g)(1) and (2) requires that a licensee shipping SNM of low strategic significance provide advance notification to the receiver of any planned shipments specifying the mode of transport, estimated time of arrival, location of the nuclear material transfer point, name of the carrier, and transport identification. The licensee must also receive confirmation from the receiver prior to commencement of the shipment that the receiver will be ready to accept the shipment at the planned time and location and acknowledges the specified mode of transport. The receiving licensee must notify the shipper of the receipt of the material in accordance with § 70.54. The required notifications and confirmation ensure that the shipper has preplanned the transportation of the material and that the receiver is ready to accept the material. It also helps ensure positive control of the material during transport and helps ensure traceability of any missing material.

Section 73.67(g)(3)(i) requires that a licensee shipping SNM of low strategic significance must establish and maintain written response procedures for dealing with thefts or threats of thefts of the material. The licensee must retain a copy of the procedures as a record. The information is used by the licensee to provide instructions to employees for dealing with contingencies and is inspected by the NRC to ensure that the licensee has developed adequate procedures for dealing with thefts or threats of thefts.

Section 73.67(g)(3)(ii) requires that a shipper of SNM of low strategic significance must make arrangements to be notified immediately of the arrival of the shipment at its destination, or of any such shipment that is lost or unaccounted for after the estimated time of arrival at its destination. This information is used by the licensee to determine that a shipment either arrived safely or is missing. Such notification gives the licensee a basis for initiating a trace investigation in the event a shipment becomes delayed or lost.

Section 73.67(g)(3)(iii) requires that a licensee notify the NRC Operations Center within 1 hour after the discovery of the loss of the shipment and within 1 hour after recovery of or accounting for such lost shipment, in accordance with § 73.71. This notification permits the NRC to initiate or terminate a trace investigation if necessary.

Section 73.67(g)(4) requires that a licensee who exports SNM of low strategic significance must comply with the requirements of § 73.67(c) and (g)(1), and (3) and retain required records for 3 years. The records are inspected by NRC in order to ensure compliance with the requirements.

Section 73.67(g)(5)(i) requires that a licensee who imports SNM of low strategic significance must comply with the requirements of § 73.67(c) and (g)(2), and (3) and retain required records for 3 years. The requirement is similar to that of § 73.67(g)(4), above, but the shipper is exporting material. The records are inspected by NRC in order to ensure compliance with the requirements.

Section 73.67(g)(5)(ii) requires that a licensee notify the person who delivered the material to a carrier for transport of the arrival of such material. This information is used by the licensee to determine that a shipment either arrived safely or is missing. Such notification gives the licensee a basis for initiating a trace investigation in the event a shipment becomes delayed or lost.

Section 73.70(a) requires that the licensee keep a record of the names and addresses of all authorized individuals. This information serves as a means of identifying those who have responsibility for surveillance of SNM, and of limiting the number of individuals with such responsibility. It identifies persons who had access in the event an investigation proves necessary and serves as a means of verification for inspection purposes to ensure that designation and access control procedures are being properly conducted.

Section 73.70(b) requires that the licensee keep a record of the names, addresses, and badge numbers of all individuals authorized to have access to vital equipment or SNM, and the vital areas and material access areas to which authorization is granted. This record provides formal access authorization control. It provides verification that access control requirements are being met and serves to limit the number of individuals with such access.

Section 73.70(c) requires that the licensee keep a register of visitors, vendors, and other individuals not employed by the licensee pursuant to 73.46(d)(1)(13), 73.55(d)(6), or 73.60. The register serves as a record of visitors permitted access, serves as a document that may be inspected to verify that access control requirements are being followed, and facilitates any subsequent investigation of irregular events.

Section 73.70(d) requires that the licensee keep a log of all individuals granted access to a vital area except those individuals entering or exiting the reactor control room. This record provides a means of determining who had access to vital areas. It is inspected to assess licensee performance in minimizing unnecessary access. It also can provide data to aid an investigation of an irregular event.

Section 73.70(e) requires that the licensee keep documentation of all routine security tours and inspections, and of all tests, inspections, and maintenance performed on physical barriers, intrusion alarms, communications equipment, and other security related equipment. This requirement provides a record of security tours, tests and maintenance and is used to ensure that the frequency of tests and prompt maintenance of failures is verifiable by inspection. It also provides a maintenance history of equipment useful in evaluating operating performance.

Section 73.70(f) requires that the licensee keep a record at each onsite alarm annunciation location of each alarm, false alarm, alarm check, and tamper indication. In addition, details of response by facility guards and watchmen to each alarm, intrusion, or other security incident must be recorded. This record provides verification that alarms are operating properly, that licensees respond properly, and that operational checks are conducted in accordance with the regulations. It also provides a means of evaluating the long term reliability of the alarm system. This includes all types of signals sent to the alarm systems main computer which incorporates authorized door openings and closings.

Section 73.70(g) requires that the licensee keep a record of shipments of SNM subject to the requirements of Part 73, including names of carriers, major roads to be used, flight numbers for air shipments, dates and expected times of departure and arrival of shipments, verification of communications equipment on board the transfer vehicle, names of individuals who are to communicate with the transport vehicle, container seal descriptions and identification, and other details to confirm compliance with protection requirements. Information obtained during the course of the shipment such as reports of all communications, change of shipping plan, including monitor changes, trace investigations, and others, must also be recorded. These records serve as a part of the material control system by providing a record of bulk inventory change at any given plant. They also provide an audit trail and experience base for evaluating the transportation process at a later time.

Section 73.70(h) requires that the licensee maintain written procedures for controlling access to protected areas and for controlling access to keys for locks used to protect SNM. This record serves to aid access control and lock

and key control. It also serves as a record that may be inspected, of the licensee's performance in minimizing access and providing adequate control of key and lock operations.

Section 73.71(a)(1) requires that each licensee subject to the provisions of 73.25, 73.26, 73.27(c), 73.37, 73.67(e), or 73.67(g) notify the NRC Operations Center within 1 hour after the discovery of the loss of any shipment of SNM or spent fuel and within one 1 hour after recovery of or accounting for such lost shipment. This notification permits NRC to initiate or terminate a trace investigation if necessary.

Section 73.71(a)(4) requires that each such licensee follow the initial telephonic notification with a written report to the NRC within 60 days. This report permits NRC to analyze and evaluate the event and subsequent recovery efforts.

Section 73.71(a)(5) requires that each such licensee follow the initial telephonic notification and written report with a follow-up telephonic notification and written report to NRC if any significant supplemental information is discovered or if corrections to previous reports are necessary. Copies of the written reports must be retained as a record for 3 years.

Section 73.71(b) requires that each licensee subject to the provisions of 73.20, 73.37, 73.50, 73.55, 73.60, or 73.67 notify the NRC Operations Center within 1 hour after the discovery of the theft or attempted theft or unlawful diversion of SNM.

Each licensee subject to the provisions of 73.20, 73.37, 73.50, 73.55, 73.60, 73.51 or possessing SSNM and subject to 73.67 must notify the NRC Operations Center within one hour after the discovery of the following:

(a) an event involving actual or attempted significant physical damage to a power reactor or any facility possessing SSNM or its equipment or carrier equipment transporting nuclear fuel or spent nuclear fuel, or to the nuclear fuel or spent nuclear fuel a facility or carrier possesses;

(b) an event involving actual or attempted interruption of normal operation of a licensed nuclear power reactor through the unauthorized use of or tampering with its machinery, components, or controls including the security system;

(c) an actual entry of an unauthorized person into a protected area, material access area, controlled access area, vital area, or transport; or an event involving any failure, degradation, or the discovered vulnerability in a safeguard system that could allow unauthorized or undetected access to one of the above areas for which compensatory measures have not been employed.

Each licensee subject to the provisions of 73.20, 73.37, 73.50, 73.55, or 73.60, must notify the NRC Operations Center within 1 hour after the discovery of an event involving actual or attempted introduction of contraband into one of the above areas. The Commission requires the reports made pursuant to 73.71 so that the Commission may be aware of events in order to determine their significance, whether a change in a licensee's safeguards plan is needed, and whether a report to Congress is necessary in accordance with Section 208 of the Energy Reorganization Act of 1974, as amended. The safeguards event reports are also needed for the development of a database whereby generic problems can be identified and feedback given to licensees for improving their safeguards systems.

Section 73.71(c) requires that each licensee subject to the provisions of 73.20, 73.37, 73.50, 73.51, 73.55, 73.60, or possessing SSNM and subject to 73.67(d) must maintain a current log and record the safeguards events described in paragraphs II(a) and (b) of Appendix G to Part 73 within 24 hours of discovery by a licensee employee or member of the licensee's contract security organization.

Section 73.71(d) provides guidance for the submission of 60-day reports required under the forgoing provisions of 73.71. It provides that power reactor licensees should submit the written report using NRC Form 366, "Licensee Event Report." Other licensees must submit the written report in letter format. NRC Form 366 has previously been cleared under OMB No. 315O-0104, which should be referred to for additional supporting information, burden and cost data.

Section 73.71(e) provides that duplicate reports are not required for events that are reportable in accordance with 50.72 and 50.73.

It is necessary for both the licensee and the NRC to maintain copies of the reports for the following reasons. The licensee must maintain copies to perform the yearly security audit required by 73.46(g)(6) for fuel facilities and 73.55(g)(4) for power reactors. This audit evaluates the effectiveness of the security system at these facilities. Also, in order to maintain the level of security deemed adequate by NRC, the licensee must observe and analyze the operational aspects of its security system. This can only be done through the maintenance and analysis of such records as those for security events. The NRC maintains copies of security event records to conduct analyses to identify and characterize generic and facility-specific precursors to certain safeguards events. Improving the ability of the NRC to identify generic precursors or defects provides the agency with a capability to initiate corrective action, if needed, prior to a vulnerability having a detrimental effect on public health and safety.

Section 73.72 requires that licensees shipping a formula quantity of SSNM, SNM of moderate strategic significance, or irradiated reactor fuel required to be protected pursuant to 73.37, must provide advance written notification to NRC at least 10 days prior to shipment, along with shipment details and itinerary, and must notify NRC by telephone of the transmittal of the advance notice and of any changes to the shipment itinerary. This requirement is necessary to allow the NRC to review shipment details and schedule appropriate monitoring of the shipment. It also serves as a means to verify shipment details during the inspection process.

Section 73.73 requires that licensees exporting SNM of low strategic significance to provide advance written notification to the NRC at least 10 days prior to shipment, along with shipment details and itinerary, and may notify the NRC by telephone of any changes to the shipment details or itinerary. This requirement is necessary to allow the NRC to review shipment details and schedule appropriate monitoring of the shipment. It also serves as a means to verify shipment details during the inspection process.

Section 73.74 requires that licensees importing SNM of low strategic significance from a country not a party to the Convention on the Physical Protection of Nuclear Material must provide advance written notification to NRC at least 10 days prior to shipment, along with shipment details and itinerary, and may notify the NRC by telephone of any changes to the shipment details or itinerary. This requirement is necessary to allow the NRC to review shipment details and schedule appropriate monitoring of the shipment. It also serves as a means to verify shipment details during the inspection process.

Appendix B sets the minimum training and qualification criteria for security personnel.

Appendix B Section I.C. requires the licensee to document and maintain for 3 years a record of the physical qualification of each guard, armed response person, armed escort, and other security force members.

Appendix B Section I.E. requires the licensee to document and maintain a record for 3 years of the physical re-qualification of each central alarm station operator, guard, armed response personnel, and armed escort.

Appendix B Section I.F. requires the licensee to document and maintain a record for 3 years of the results of suitability, physical and mental qualifications data, and test results.

Appendix B Section II.A. requires the licensee to maintain documentation of the current training and qualifications plan as a record for 3 years after possession of the material.

Appendix B Section II.B. requires the licensee to document and maintain a record of the results of qualifications of each individual in a security-related job for 3 years after the employment ends or 3 years after possession of the material.

Appendix B Section II.C. requires the licensee to document and maintain a record of the results of qualifications of contract personnel in security-related duties for 3 years after the employment ends or 3 years after possession of the material.

Appendix B Section II.E. requires that licensees document and maintain a record of the results of annual re-qualification of security personnel in security-related duties for both normal and contingency operations for 3 years after the re-qualification.

Appendix B Section IV requires that licensees document and maintain a record of the results of qualification and annual re-qualification of security personnel in weapons firing for 3 years after the qualification or re-qualification.

The requirements of Appendix B serve as a basis to assure adequacy of licensee security force training and qualification and also serve as an inspection reference in verifying licensee performance.

Appendix C sets the minimum requirements for licensee safeguards contingency plans. The safeguards contingency plan must include plans for dealing with threats, thefts, and radiological sabotage. Each licensee safeguards contingency plan must contain five categories of information, as listed below. The licensee must submit to the NRC for approval the first four categories of information contained in the plan‑‑Background, Generic Planning Base, Licensee Planning Base, and Responsibility Matrix. The fifth category, Procedures, does not have to be submitted for approval. This document serves as a written record for the licensee, setting forth plans for dealing with contingencies. The plan is used by NRC in the licensing approval process to ensure that there is sufficient scope and depth in the contingency planning area and also serves as a compliance benchmark during the inspection process.

Licensees must provide for the implementation, revision and maintenance of the safeguards contingency plan. To this end, licensees must provide for an annual independent review and audit of the plan, procedures and practices. The results must be documented, reported to the licensee's management, and kept available at the plant for inspection for 3 years. This requirement is needed to ensure that the licensee's contingency plans are up to date and effective. The plan is required to be retained as a record until termination of the license, and superseded material is required to be retained for 3 years after the change is made.

1. Background. This category of information must identify and define the perceived dangers and incidents with which the plan will deal and the general way it will handle them.

2. Generic Planning Base. This category of information must define the criteria for initiation and termination of responses to safeguards contingencies together with the specific decisions, actions, and supporting information needed to bring about such responses.

3. Licensee Planning Base. This category of information must include the factors affecting contingency planning that are specific for each facility or means of transportation. To the extent that the topics are treated in adequate detail in the licensee's approved physical security plan, they may be incorporated by cross-reference to that plan.

4. Responsibility Matrix. This category of information consists of detailed identification of the organizational entities responsible for each decision and action associated with specific responses to safeguards contingencies.

5. Procedures. This category of information must detail the actions to be taken and decisions to be made by each member or unit of the organization as planned in the Responsibility Matrix. The procedures entail operating details subject to frequent change. They need not be submitted to NRC for approval, but will be inspected by NRC staff on a periodic basis.

Appendix G provides clarification of the requirements for reporting safeguards events. Safeguards experience is a vehicle for providing licensees with feedback about the effectiveness of safeguards systems. Some safeguards events require immediate response by the NRC. Under §73.71, these events are required to be reported within 1 hour of detection of their occurrence to assure timely response by NRC regional and headquarters staff, followed by a written report within 60 days. Other safeguards events, while of less significance, must be reported in order to determine trends in deficiencies in safeguards systems. NRC has established a program for the collection and analysis of all pertinent safeguards data. This data is immediately entered into the NRC data base and analysis is begun as soon as the data is entered. Upon completion of the analysis, appropriate action and response are initiated. In order to achieve program objectives, a standardized level of detail is required for the evaluation of safeguards events. The results of the analyses are used to improve regulations for these facilities, for preparing for inspections, and to give feedback to licensees for improving their safeguards systems.

Commission Orders

In addition to requirements in Part 73, the NRC has issued a number of orders related to the physical security of plants and materials. Unless otherwise specified, specific requirements of these Commission Orders are Safeguards Information and are prohibited

from public disclosure in accordance with the provisions of the Atomic Energy Act of 1954, as amended, Chapter 12, Section 147. These orders are as follows, in order of the date issued:

Commission Order (Compensatory Measures – Power Reactors), dated February 25, 2002, required nuclear power reactor licensees to implement additional security measures to protect against the current threat environment. There are no ongoing reporting or recordkeeping requirements associated with this Order.

Commission Order (Compensatory Measures - CAT I), dated August 21, 2002, required CAT I fuel facilities licensees to implement additional security measures to protect against the current threat environment. There are no ongoing reporting or recordkeeping requirements associated with this Order.

Commission Order (Access Authorization – Power Reactors) dated January 7, 2003, 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. The initial investigations for this Order have been completed, but reinvestigations continue at a predetermined frequency.

Commission Order (Revised Design Basis Threat for CAT I licensees), dated April 29, 2003, required CAT I licensees to protect against the revised design basis threat. In addition, this order required CAT I licensees to revise their site security plans and to submit the revised plans for NRC review and approval no later than April 29, 2004, and to implement the revised plans no later than October 29, 2004. Specific requirements of this order are CNSI and are prohibited from public disclosure in accordance with Executive Order 12958. There are no ongoing reporting or recordkeeping requirements associated with this Order.

Commission Order (Revised Design Basis Threat for Power Reactors), dated April 29, 2003, required nuclear power reactor licensees to protect against the revised design basis threat. In addition, this order required nuclear power reactor licensees to revise their site safeguards contingency plans and to submit the revised plans for NRC review and approval no later than April 29, 2004, and to implement the revised plans no later than October 29, 2004. This order included a one-time burden to revise site safeguards contingency plans. There are no ongoing reporting or recordkeeping requirements associated with this Order. Burden for maintaining site safeguards contingency plans is included in Part 73 requirements.

Commission Order (Training) dated April 29, 2003, required power reactor licensees to revise their training and qualification program to implement revised training requirements. This Commission Order also required licensee Training and Qualification Plans to be marked and protected as Safeguards Information in accordance with the provisions of the Atomic Energy Act of 1954, as amended, Chapter 12, Section 147. This order included a one-time burden to implement the revised training requirements, as well as an ongoing requirement to maintain a record of the revised training plan.

Confirmatory Action Letter (CAL), dated October 28, 2002, requires research and test reactors (RTRs) to establish a physical security and access authorization program. Requirements also include the collection, verification, maintenance, and protection of information not previously considered. This Confirmatory Action Letter includes ongoing requirements to report information and maintain records.

Commission Orders (Site Specific Dry Independent Spent Fuel Storage Installations [ISFSIs]), dated October 26, 2005; May 5, 2005; and June 15, 2006, required six different licensees to address the current threat environment for dry independent spent fuel storage installations within 20 days. This one-time response has been completed; there are no ongoing reporting or recordkeeping requirements.

Commission Order (Licenses for Operating Power Reactors), dated June 20, 2006, required 104 commercial nuclear power plants to immediately implement interim compensatory security measures. This one-time response has been completed; there are no ongoing reporting or recordkeeping requirements.

Commission Order (Updated Adversary Characteristic), dated March 20, 2006, required 104 commercial nuclear power plants to immediately implement interim compensatory security measures based on an updated adversary characteristic. This one-time response has been completed; there are no ongoing reporting or recordkeeping requirements.

Commission Order (Fingerprints for Access to Safeguards Information), dated August 21, 2006, requires fingerprinting and background checks for access to safeguards information for non-power reactors as part of the implementation of Section 652 of the Energy Policy Act of 2005 (EPAct) which was signed on August 8, 2005. The reporting and recordkeeping requirements under this Order are ongoing.

Commission Order (Fingerprinting Orders for Access to Research and Test Reactors), dated April 30, 2007. This requires fingerprinting and background checks of individuals who seek or currently have unescorted access. The reporting and recordkeeping requirements under this Order are ongoing.

2. Agency Use of the Information

The information included in the applications, reports, and records is reviewed by the NRC staff to assess the adequacy of the applicant's physical plant, equipment, organization, training, experience, procedures, and plans for protection of public health and safety and the common defense and security. The NRC review and the findings form the basis for NRC licensing decisions related to special nuclear material.

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. NRC issued a regulation on October 10, 2003 (68 FR 58791), consistent with the Government Paperwork Elimination Act, which allows its licensees, vendors, applicants, and members of the public the option to make submissions electronically via CD-ROM, e-mail, special Web-based interface, or other means. It is estimated that approximately 2% of the potential responses are submitted electronically. However, all (100%) of fingerprint submissions from the 64 power reactor licensees are submitted electronically. Other licensees continue to submit fingerprints through non‑electronic means.

4. Effort to Identify Duplication and Use Similar Information

No sources of similar information are available. There is no duplication of requirements. NRC has in place an ongoing program to examine all information collections with the goal of eliminating all duplication and/or unnecessary information collections.

5. Effort to Reduce Small Business Burden

Some of the licensees who use special nuclear material are small businesses. Since the consequences to the common defense and security or to the health and safety of the public of inadequate safeguards for special nuclear material are the same for large and small entities, it is not possible to reduce the burden on small businesses by less frequent or less complete reports, records, plans, and procedures.

6. Consequences to Federal Program or Policy Activities if the Collection is Not Conducted or is Conducted Less Frequently

If the information collection was not conducted or was conducted less frequently, the NRC would not be notified in time to provide rapid response and quick assistance in achieving timely resolution of safeguards events. Reports are submitted and evaluated as events occur. Applications for new licenses and amendments may be submitted at any time. License renewal of fuel cycle facility licenses can be for terms up to 10 years. Information submitted in previous applications may be referenced without being resubmitted.

7. Circumstances Which Justify Variation from OMB Guidelines

Certain sections of Part 73 vary from the OMB Guidelines by requiring that licensees submit reports to the NRC in less than 30 days. Sections 73.26, 73.27, 73.37, 73.67, and 73.71 require immediate notifications to response forces, NRC, and local law enforcement authorities, communications between convoys and movement control centers, and immediate notifications of consignees and shippers. These notification requirements are needed to permit response forces, NRC, law enforcement authorities, shippers, and consignees to confirm the integrity of shipments or to determine whether there has been a loss or diversion of special nuclear material and to initiate prompt action for recovery of such material.

Certain other sections of Part 73 vary from the OMB Guidelines by requiring that licensees retain records for more than 3 years. Various sections require retention of records for 5 years, or for extended periods such as duration of possession of the material, duration of employment, or 5 years after termination of access authorization. These requirements are necessary to ensure that procedures for handling and safeguarding nuclear materials are available throughout the period in which the licensee possesses the material or operates the facility. Other records are required for inspection or for reconstruction of events in the event of a safeguards incident.

8. Consultations Outside the NRC

The opportunity for public comment on the information collection requirements was published in the Federal Register on January 2, 2008 (73 FR 214). No comments were received.

Since the publication of the Federal Register Notice, the NRC has revised the burden estimate for this collection to reflect burden for the two most recent Commission Orders (Fingerprints for Access to Safeguards Information, dated August 21, 2006 and Fingerprinting Orders for Access to Research and Test Reactors, dated April 30, 2007). In addition, the NRC conducted a review of the actual number of fingerprints annually submitted to NRC security by licensees. In order to make the burden estimate more accurately reflect the number of fingerprints submitted, the NRC increased the burden associated with the Commission Order for Access Authorization – Power Reactors, dated January 7, 2003.

Commission Orders contain Safeguards Information or classified National Security Information and therefore no opportunity for public comment was published when the Orders were issued.

9. Payment or Gift to Respondents

Not applicable.

10. Confidentiality of Information

Confidential and proprietary information is protected in accordance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b).

Certain information designated as Safeguards Information is prohibited from public disclosure in accordance with the provisions of the Atomic Energy Act of 1954, as amended, Chapter 12, Section 147, or designated as classified National Security Information, in accordance with Executive Order 12958.

11. Justification for Sensitive Questions

The information required by Part 73 to be reported, collected and maintained consists of sensitive information which could be used by unauthorized personnel to gain unauthorized access to a site which could constitute an unreasonable risk to the public health and safety. The NRC needs this information to assess the adequacy of the licensee's planned system in meeting regulatory requirements, determine with reasonable assurance that the physical

protection system operates in accordance with the regulatory requirements, and to respond to, investigate, and correct situations which adversely affect public health and safety or the common defense and security.

12. Estimated Burden and Burden Hour Cost

The estimated burden is based on:

• 2 Category I fuel facilities,

• 20 Category II and III facilities,

• 64 power reactor facilities,

• 36 research and test reactors, and

• 262 other nuclear materials licensees.

Category I licensees possess formula quantities of strategic SSNM and Category II and III are licensees that possess moderate and low formula quantities of SSNM, respectively. The estimated number of annual respondents is 384.

The overall estimated annual burden is 578,863 hours at an estimated annual cost of $149,346,654 (578,863 hrs x $258/hr). This includes 85,441 hours for reporting and 493,422 hours for recordkeeping. See burden tables for estimated burden for Part 73 requirements and Commission Orders related to Part 73.

13. Estimate of Other Additional Costs

The NRC has determined that the records storage cost is roughly proportional to the recordkeeping burden cost. Based on a typical clearance, the records storage cost has been determined to be equal to .0004% of the recordkeeping burden cost. Therefore, the records storage cost for this clearance is estimated to be $50,921 (493,422 recordkeeping hours x $258 x .0004).

14. Estimated Annualized Cost to Federal Government

The estimated cost to the government for review of required reports and records is approximately $1,161,000 (4,500 hours at $258/hr) and is based on the materials fee recovery rate. The cost is fully recovered by license fee assessments to NRC licensees pursuant to 10 CFR Parts 170 and/or 171.

15. Reason for Change in Burden or Cost

The estimated burden has increased from 524,820 (50,212 reporting and 474,608 recordkeeping) to 578,863 hours (85,441 reporting and 493,422 recordkeeping), for a total increase of 54,043 hours. The estimated reporting burden increased by 35,229 hours from 50,212 to 85,441 hours and the estimated recordkeeping burden increased by 18,814 hours from 474,608 to 493,422 hours.

The reporting and recordkeeping requirements under Part 73 have not changed. The increase in burden is due to the addition of two Commission Orders dated September 29, 2006 and April 30, 2007, 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 August 21, 2006, requires fingerprinting and background checks for access to safeguards information for non-power reactors. This includes all 320 licensees that are not 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. (Current employees underwent these checks previously, at the time the order was issued). 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 hours of burden to complete background information. As a result, this order adds 1,125 hours of reporting burden (250 fingerprints and background checks x 4.5 hours per check = 1,125 hours). In addition, NRC estimates 2.397 hours of recordkeeping per fingerprint and background check, for a total of 600 hours of recordkeeping (250 fingerprints and background checks x 2.297 hours = 600 hours).

• Commission Order (Fingerprinting Orders for Access to Research and Test Reactors [RTRs]), dated April 30, 2007, 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 hours of burden to complete background information. As a result, this order adds 450 hours of reporting burden (100 fingerprints and background checks x 4.5 hours per check = 450 hours). In addition, NRC estimates 2.397 hours of recordkeeping per fingerprint and background check, for a total of 240 hours of recordkeeping (100 fingerprints and background checks x 2.397 hours = 240 hours).

Burden revisions to previously issued orders

• Commission Order (Training) dated April 29, 2003, 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 hours of recordkeeping burden for CAT I licensees under this order. This order does not apply to CAT I licensees; therefore, these 4 hours have been removed from the total burden.

• The NRC reviewed fingerprint submissions processed during the past three years. Based on a review of these fingerprint submissions, the NRC estimates that licensees submit 7,500 fingerprint cards and background checks per year under Commission Order (Access Authorization – Power Reactors) dated January 7, 2003, 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 hours for the 64 power reactor licensees to determine the number of reinvestigations required, totaling 96 hours. Upon further review, the NRC re‑estimated the burden for this order from 1.5 hours per licensee to 4.5 hours per investigation to implement this order. NRC currently estimates a half hour of reporting burden for fingerprinting, and 4 hours of burden to complete background information. This order currently totals 33,750 hours of reporting burden (7,500 fingerprints and background checks x 4.5 hours per check = 33,750 hours), an increase of 33,654 hours. In addition, these fingerprints increased the current recordkeeping burden for this order by 17,978 hours (7,500 records x 2.397 hours recordkeeping per record), from 153,408 hours to 171,386 hours.

Also, there is a change in cost because the hourly rate increased from $157/hour to $258/hour.

16. Publication for Statistical Use

None.

17. Reasons for Not Displaying the Expiration Date

The requirements are contained in a regulation. Amending the Code of Federal Regulations to display information that, in an annual publication, could become obsolete would be unduly burdensome and too difficult to keep current.

18. Exceptions to the Certification Statement

None.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

Not applicable.

10 CFR Part 73 Estimated Reporting Burden

Section	No. of Respondents	Responses per Respondent	Number of Responses	Burden Hours per Response	Total Annual Burden Hours
73.5	2	.5	1	8	8
73.20(c)		0			0
73.26(b)(3)		0	0	5	0
73.26(f)(2)	2	1	2	4	8
73.26(i)(6) and (k)(4)		0		1	0
73.27(a)(1)		0		0.1	0
73.27(a)(2)		0		0.5	0
73.27(a)(3)		0		0.5	0
73.27(b)		0		0.5	0
73.27(c)(None anticipated in the next 3 years)					0
73.37(a)		0		0.1	0
73.37(b)(1) (Included in 73.72)					0
73.37(b)(11)	2	20	40	.3	12
73.37(f)	2	21	42	3.5	147
73.46(b)(9)	2	1	2	1	2
73.46(h)(4)		0		0.1	0
73.46(h)(5)	4	50	200	1	200
73.46(i)(1) (Requirement completed)					0
73.50(g)(3) (Emergency notification - never used)		0		0.1	0
73.50(g)(4) (Included in 73.20(c))					0
73.50(h) (Included in 73.20)					0
73.55 (Requirement, completed)					0
73.55(b)(4)(ii)	75	1	75	16	1,200
73.55(c)(8)(i)&(ii) (Burden included in 73.70(e))					0
73.55 (c)(9)(i) (Requirement completed)					0
73.55 (c)(9)(ii) (Requirement completed)					0
73.55 (c)(9)(iii) (Requirement completed)					0
73.55(d) (Requirement, completed)					0
73.55(h)(4)	75	1	75	.26	20
73.55(h)(5)	75	92.4	6,930	1	6,930
73.56(a)(1) (Requirement completed)					0
73.56(a)(2),(3) (None until advanced reactors start application process)					0
73.56(b)(1),(2) (Included in 73.56(a)(1), (2), & (3))					0
73.56(c) (Included in 73.56(a)(1), (2), & (3))					0
73.56(d)(None anticipated during clearance per.		0		89	0
73.56(e) (Included in 73.56(a)(1), (2), & (3))					0
73.57(a) & (d)	75	426.7	32,002	.5	16,001
73.57(b)(3)	75	426.7	32,002	.5	16,001
73.57(e)	75	68	5,100	.5	2,550
73.67(c)(1) (Requirement, completed)					0
73.67(e)(1)	20	18.5	370	2	740
73.67(e)(3)(v)	20	18.5	370	.5	185
73.67(e)(3)(vii) (no reports anticipated)					0
73.67(e)(6)(ii)		0		.5	0
73.67(e)(7)(i)		0		2	0
73.67(e)(7)(ii)	20	1.1	22	1	22
73.67(g)(1),(2)	20	3.5	70	4	280
73.67(g)(3)(ii)	20	3.5	70	1	70
73.67(g)(3)(iii) (Included in 73.71(a) (1) (No reports anticipated in the next 3 years)					0
73.67(g)(5)(ii)	20	1.75	35	1	35
73.71(a)(1)		0		1.5	0
73.71(a)(4) & (5)		0		40	0
73.71(b)	20	2	40	6	240
73.71(d)	20	2	40	6	240
73.72	20	1.5	30	.2	6
73.73	20	4.5	90	8	720
73.74	20	1.4	28	8	224
Appendix B - Included in previous sections					0
Appendix C - Included in previous sections					0
Appendix G -	286	1	286	14.887	4,258
Commission Order (Power Reactor –Compensatory Measures) (Requirement Completed)					0
Commission Order (CAT-I –Compensatory Measures) (Requirement Completed)					0
Commission Order (Power Reactor - Access)	64	117.19	7,500	4.5	33,750
Commission Order (CAT-I – Design Basis Threat) (Requirement Completed)					0
Commission Order (Power Reactor – Design Basis Threat) (Requirement Completed)					0
Commission Order (Power Reactor - Training) (Requirement Completed)					0
Confirmatory Action Letter (Research and Test Reactors - Access)	36	3	108	0.16	17
Commission Orders (Dry Independent Spent Fuel Storage Installations) (Requirement Completed)					0
Commission Order (Licenses for Operating Power Reactors) (Requirement Completed)					0
Commission Order (Updated Adversary Characteristic) (Requirement Completed)					0
Commission Order (Fingerprinting for Safeguards Information)	320	0.78	250	4.5	1,125
Commission Order (Fingerprinting – Research and Test Reactors)	36	2.78	100	4.5	450
Total	384		85,880		85,441

10 CFR Part 73 Estimated Recordkeeping Burden

Section (including Record Retention Period)1	No. of Recordkeepers	No. of Records per Recordkeeper	Hours per Record	Total Annual Burden
73.20(c) - (L)1	2	1	10	20
73.21 (Proposed Rule)	262	1	3.155	827
73.21(a) (Included in 73.20(c))				0
73.24(b)(1) - (3)	2	135	.2	54
73.25(b),(c),(d) - (Included in 73.20(c)) (P+3)				0
73.26(b)(4) - (S+3)		0	1	0
73.26(c) - (P+3)		0	8	0
73.26(d)(3) - (P+3)		0	1.5	0
73.26(d)(4) - (E,Q,R+3)		0	40	0
73.26(e)(1) - (P+3)		0	100	0
73.26(g)(1)	2	20	10	400
73.26(h)(6) - (3)	2	1	5	10
73.26(i)(1) - (S)		0	18	0
73.37(b)(2) - (P+3)	2	20	.3	12
73.37(b)(3) - (P+3)	2	20	.2	8
73.37(b)(5) - (S+3)	2	20	.2	8
73.37(b)(7) - (Included in 73.67(e)(4))				0
73.40 (included in 73.20(c)) - (P)				0
73.45 - (Included in 73.20(c)) - (P)				0
73.46(b)(1) - (Requirement completed and included on 73.46(b)(3)) - (L)				0
73.46(b)(3) - (L)	2	1	160	320
73.46(b)(4),(7),(8) - (Q/R+3)	2	1	32.8	66
73.46(b)(9) - (3)	2	1	1	2
73.46(b)(10)(iii) - (3)	2	1	8	16
73.46(b)(11)(i) - (Included in 73.46(b)(4))				0
73.46(b)(11)(iii) - (3)	2	1	8	16
73.46(b)(12)&(b)(12)(i) - (Included in 73.46(b)(4))				0
73.46(b)(12)(ii) - (3)	2	1	8	16
73.46(d)(3) - (Included in 73.20(c)) - (L)				0
73.46(d)(10) 255 - (3)	2	127.5	.5	128
73.46(d)(11) 170 - (3)	2	85	.5	85
73.46(d)(13) - (3)	2	510	.1	102
73.46(g)(5) (Included in 73.20(c)) - (P)				0
73.46(g)(6) - (3)	2	1	8	16
73.46(h)(1) - (L)	2	7.5	10	150
73.46(h)(2) - (L/3)	2	1	.5	1
73.46(h)(3) (Included in 73.20(c)) - (L)				0
73.50(a)(3) - (L)	75	0.04	100	300
73.50(a)(4) - (Q/R+3)	75	0.04	16	48
73.50(c)(5) - (3)	75	8	.2	120
73.50(g)(1) - (L)	75	0.04	100	300
73.50(g)(2) - (L)	75	0.04	.5	2
73.51(b)(1) (Included in 73.20(c))				0
73.51(b)(2) (Included in 73.20(c))				0
73.51(c) (included in 73.20(c))				0
73.51(d) (Included in 73.20(c))				0
73.51(d)(5) (Included in 73.67(e)(4))				0
73.51(d)(6) (included in 73.67(e)(4))				0
73.51(d)(7) (Included in 73.20(c))				0
73.51(d)(10) (Included in 73.20(c))				0
73.51(d)(12)	2	1	8	16
73.51(d)(13)(i)(ii)(iii)(iv)(v) (Requirement included in 73.20(c))				0
73.55(b)(1) - (C)	75	1	10	750
73.55(b)(3) - (L/3)	75	1	1	75
73.55(b)(4)(i) - (Q/R/3)	75	80	.5	3,000
73.55(b)(4)(ii) - (L/3)	75	1	1	75
73.55(c)(7) - (Included in 73.55(c)(8))				0
73.55(c)(8) - (3) (Requirement included in 73.20(c))		0	0	0
73.55(c)(8)(i) - (3) (Requirement included in 73.20(c))		0	0	0
73.55(c)(8)(ii) - (3) (Requirement included in 73.20(c))		0	0	0
73.55(c)(9)(iv) - (3)	75	0.09	20	135
73.55(c)(10) (Requirement completed) - (3)		0	0	0
73.55(d)(6) - (3)	75	333	.5	12,488
73.55(d)(7) - (L)	75	12.3	4	3,690
73.55(g)(1)&(4) - (L)				0
- Reviews	75	337	4	101,100
- Focused audits	75	.27	50	1,013
73.55(g)(4) - (5)	75	1	8	600
73.55(h)(1) - (L)	75	1	10	750
73.55(h)(2) - (L)	75	1	1	75
73.56(b)(1) - (L)	75	1	5	375
73.56(f)(1),(2) - (Included in 73.56(h)(1) - (A+5)				0
73.56(g)(1),(2) - (Included in 73.50(c)) - (3)				0
73.56(h)(1) Credit checks - (A+5)	75	1952	0.22	32,208
73.56(h)(1) Military checks - (A+5)	75	195.2	0.56	8,198
73.56(h)(1) Education records check - (A+5)	75	813.3	.56	34,159
73.56(h)(1) Psychological evaluation - (A+5)	75	813.3	.22	13,420
73.56(h)(1) Transfers - (A+5)	75	48.8	3	10,980
73.56(h)(1) Appeal reviews - (5)	75	4.88	49	17,934
73.56(h)(2) - (Included in 73.50(c)) - (3)				0
73.57(e),(f) - (A)	75	800	.25	15,000
73.60(e) - (Included in Appendix C) - (L)				0
73.67(a)(1) (included in 73.20(c))				0
73.67(a)(2) (included in 73.20(c))				0
73.67(c)(1) - (P+3)	4	1	20	80
73.67(d)(11) - included in 73.20 (c)		0	20	0
73.67(e)(2)(ii) (included in 70.54 and 74.15)				0
73.67(e)(3)(iv) - (P+3)	20	2.5	1	50
73.67(e)(4) - (P+3) ***	20	14.8	1.5	444
73.67(e)(5) - (P+3)	20	9.25	2	370
73.67(e)(6)(i) - (P+3)	20	3.5	4	280
73.67(f)(4) -(Included in 73.50(g)(1)) - (P+3)				0
73.67(g)(3)(i) - (P+3)	20	3.5	2	140
73.67(g)(4) - (P+3)	20	2.8	1.5	84
73.67(g)(5)(i) - (P+3)	20	1.75	1	35
73.70(a) - (P+3)	20	14	.5	140
73.70(b) - (P+3)	20	20	.5	200
73.70(c) - (3)	20	75	.2	300
73.70(d) - (3)	20	2,835	.03	1,701
73.70(e) - (3)	20	126	.5	1,260
73.70(f) - (3)	20	38,325	.02	15,330
73.70(g) - (3)	20	2	2	80
73.70(h) - (L/3)	20	4.2	24	2,016
73.71(a)(4),(5) - (3)		0	1	0
73.71(c) - (3)	20	1,699.5	1	33,990
73.71(e) -(Included in 73.46(g)(4)&(g)(6)) - (3)				0
Appendix B - Included in above rqmts - (3/L)				0
Appendix C - (L/3)				0
- Biannual reports	20	2	100	4,000
- Focused audits	20	1	30	600
Commission Order (Power Reactor - Access) (E+5)	64	1,117.2	2.397	171,386
Commission Order (Power Reactor - Training)	64	1	2	128
Confirmatory Action Letter (Research and Test Reactors - Access)	36	10	2.5	900
Commission Order (Fingerprinting for Safeguards Information) (E+5)	320	0.78	2.397	600
Commission Order (Fingerprinting – Research and Test Reactors) (E+5)	36	2.78	2.397	240
Total	384			493,422

*** Third Party (6)

Total number of record keepers: 384

(64 power reactor; 36 Research & Test Reactors; 2 CAT I Facilities; 20 CAT II & III Facilities; 262 Materials Licensees)

Total Number of Responses:	86,264 (85,880 plus 384 recordkeepers)
Total Recordkeeping Burden:	493,422 hours ($127,302,876)
Total Reporting Burden:	85,441 hours ($22,043,778)
Total Annual Burden Hours:	578,863 hours ($149,346,654)

1 Notes on maintenance period for records:

P = Duration of Possession of Material C = Duration of Contract

L = Duration of License Q = Qualification

E = Duration of Employment R = Requalification

S = Duration of Shipment A = Duration of Access Auth.

5