OMB SUPPORTING STATEMENT FOR
NRC FORM 136
ASecurity Termination Statement@
(3150-0049)
Extension Request with Burden Revision
Description of Information Collection
The reporting requirements associated with the NRC Form 136, "Security Termination Statement," affect NRC employees, licensees and contractors who have been granted an NRC access authorization (security clearance). When the NRC access authorization is no longer needed, the employee acknowledges and accepts his/her continuing security responsibilities, as stated on the NRC Form 136, by signing the form. Only a minimum amount of other pertinent information (e.g., contract number, if applicable; date of termination), none of which is personal in nature, is requested by the form. The form is countersigned by a division of Facilities and Security (DFS) employee, or representative of the licensee or contractor who administered the completion of the form by the employee.
There is no recordkeeping requirement for the NRC employee, licensee or contractor since the completed NRC Form 136 is to be forwarded to NRC Headquarters, Division of Facilities and Security (DFS), for retention in the individual's Personnel Security File (PSF). The established retention period of the PSF is: destruction upon notification of death or 5 years after termination of the last access authorization held. Although maintained in the PSF, the completed NRC Form 136 would not fall under the exemptions of the Privacy Act of 1974 and, upon request, would be made available for public inspection in accordance with 10 CFR Part 9.
The use of this form affords some assurance that classified information and knowledge gained by the respondent will be properly protected and, therefore, benefits the NRC security program and public at large.
A. JUSTIFICATION
1. Need for and Practical Utility of the Information Collection
Section 4.3 of Executive Order (E.O.) 12958 requires agencies to establish controls over the distribution of classified information to assure that it is distributed only to organizations or individuals eligible for access who also have a need-to-know the information. NRC's response to this requirement is termination of the access authorization when the circumstances cited in Section 25.33 of 10 CFR Part 25 (applicable to licensees) or in NRC Management Directive 12.3, (applicable to NRC employees and contractors) exist. The NRC Form 136, "Security Termination Statement," is an integral part of reminding individual of their continuing responsibilities after termination of service.
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2. Agency Use of Information.
As stated in NRC Management Directive 12.3 (for employees and contractors), and in 10 CFR 25.33 (for licensees), the completed NRC Form 136 is to be forwarded by the employee/licensee/contractor to NRC Headquarters Division of Facilities and Security (DFS), who uses the information in connection with the termination of the respondent=s employment with the NRC. In addition to providing assurance of NRC compliance with E.O. 12958, the NRC Form 136 is the vehicle used by DFS to apprize the individual of his/her continuing responsibilities for protecting classified information that he/she had access to in the course of performing official duties. The individual=s signature on this form indicates his acknowledgment/acceptance of these continuing responsibilities. Failure to use the NRC Form 136 by the licensee/contractor may result in: (1) failure to terminate the NRC access authorization when circumstances dictate and, therefore, continued access to classified information; and (2) the individual not being apprized of, or officially acknowledging (by signature) his/her continuing responsibilities for protecting classified information.
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 0% of the potential responses are filed electronically.
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.
None of the licensees affected by the use of the NRC Form 136 qualify as small business enterprises or entities. The burden associated with this form is so minimal that there is no significant burden on a contractor, if they qualify as a small business enterprise or entity.
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6. Consequences to Federal Program or Policy Activities if the Collection is Not
Conducted or is Conducted Less Frequently
The frequency of information collection is limited to circumstances when the respondent=s NRC service is to be terminated. In most cases, this is a one time event and less frequent collection would mean eliminating the collection altogether. If the information is not collected, the assurance that only appropriately cleared individuals have access to classified information is reduced; and it is likely that individuals will be unaware of their continuing responsibility to protect classified information. Thus, less frequent collection may endanger the U.S. common defense and national security.
7. Circumstances Which Justify Variation from OMB Guidelines
There is no variation from OMB Guidelines in the collection of information.
8. Consultations Outside the NRC
The opportunity for public comment on the information collection requirements was published in the Federal Register on April 16, 2010 (75 FR 20008). No comments were received.
9. Payment or Gift to Respondents
Not Applicable
10. Confidentiality of the Information
Confidential and proprietary information is protected in accordance with NRC regulations at 10 CFR 9.17(a) and 10 CFR 2.390(b).
11. Justification for Sensitive Questions.
There is no sensitive information requested on the NRC Form 136.
Estimated Burden and Burden Hour Cost
An estimated 10 minutes (based on staff experience) is required to complete each NRC form 136, resulting in a total of annual burden to the public of 50 hours (300 responses x 10 minutes / 60). Over half of the people are briefed in groups but everyone still has to fill out a form, so the clerical effort would still be 2 minutes per form. The estimated annual cost is $12,850.00 (50 hours x $257 per hour for professional effort).
NOTE: There is no record keeping requirement for contractors/licensees to maintain a copy of the NRC Form 136.
13. Estimate of Other Additional Costs
Not applicable.
Estimated Annualized Cost to the Federal Government
The estimated annual cost to the Federal Government associated with the NRC
Form 136 is $13,372.25. The cost was computed as follows:
NOTE: Annual form usage 300.
COST:
Annual clerical effort
(300 x 2 minutes = 600 /60 = 10 hrs. X $47.) = $470
Annual professional effort
(300 X 10 minutes = 3000/60 = 50 hrs. X $257/hr.) = $12,850
Annual record holding
(1/4 cu. ft. X $209/cu.ft.) = $ 52.25
Total estimated annual cost = $13,372.25
This cost is fully recovered through fee assessment to NRC licensees pursuant
to 10 CFR Parts 170 and/or 171.
15. Reasons for Changes in Burden or Cost
The overall burden increased by 27 hours from 23 to 50 hours because of an increase in the number of requests received during the past clearance cycle. However, the cost for professional effort has increased in accordance with Part 170 from $214/hr to $257/hr.
16. Publications for Statistical Use.
There is no application of statistics in the information collections related to NRC Form 136 and no publication of the information.
17. Reason for Not Displaying the Expiration Date
Not Applicable.
18. Exceptions to the Certification Statement
Not Applicable.
B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
Statistical methods are not used in this collection of information.
| File Type | application/msword |
| File Title | DRAFT OMB SUPPORTING STATEMENT FOR |
| Author | daf1 |
| Last Modified By | TUD |
| File Modified | 2010-07-21 |
| File Created | 2010-07-21 |