FINAL SUPPORTING STATEMENT FOR
NRC FORM 277
“Request for Visit or Access Authorization”
(3150-0051)
EXTENSION
Description of the Information Collection
The information collection associated with the NRC Form 277, “Request for Visit or Access
Approval,” affects any employee of 68 licensees and 7 NRC contractors who: (1) hold an NRC access authorization, and (2) need to make a visit to NRC, other contractors/licensees or government agencies in which access to classified information will be involved or unescorted area access is desired. The completed NRC Form 277 contains a signature certification of the NRC access authorization and of an official need-to-know. Only a minimal amount of other identifying or pertinent information (e.g., date of birth, clearance type, dates of visit) is requested by the form.
Personal information contained on the completed form is handled and protected in accordance with NRC directives and provisions of the Privacy Act of 1974.
Other information contained on, or pertaining to, the form (e.g., reporting requirements) is available for public inspection in accordance with 10 CFR Part 9.
The use of NRC Form 277 affords some assurance that only properly cleared and authorized individuals, who require access as a part of their official duties, will have such access during visits to other facilities and agencies. Therefore, the use of the NRC Form 277 benefits the NRC security program and public at large.
JUSTIFICATION
Need For and Practical Utility of the Collection of Information
Section 4.1 Executive Order (E.O.) 12958 states a person may have access to classified information provided that: (1) a favorable determination of eligibility for access has been made by an agency head or the agency head’s designee; (2) the person has signed an approved nondisclosure agreement; and (3) the person has a need-to-know the information. Further, Section 4.2 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.
The use of the NRC Form 277, as cited in NRC Management Directive 12.3 applicable to contractors and licensees, is the method by which NRC can provide assurance of compliance with the above provisions of E.O. 12958. The NRC Form 277 provides the facility/agency to be visited with verification of the visitor’s NRC access authorization and certification of their official need-to-know for the classified information regarding the visit. By requiring the information collection contained on the NRC Form 277, the facility/agency can assure that only properly cleared and authorized individuals will be permitted access during a visit.
Agency Use of Information
The NRC Form 277 is forwarded by the contractor/licensee through the appropriate NRC office exercising oversight authority for certification of need-to-know to the NRC’s Division of Facilities and Security (DFS). After clearance verification, DFS forwards the completed form to the security office having cognizance over the facility to be visited. The security office of the facility being visited uses the information collected to confirm identity of the visitor and to permit the visitor access to the requested classified information/area. Failure to use the NRC Form 277 by the contractor/licensee may result in denied access to classified information or areas which are necessary in the accomplishment of official duties.
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 98% of the potential responses are filed electronically.
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.
Effort to Reduce Small Business Burden
The burden associated with the occasional use of this form is so minimal that there would be no significant burden on a contractor/licensee, if they did qualify as a small business enterprise or entity.
Consequences to Federal Program or Policy Activities if the Collection Is Not Conducted or Is Conducted Less Frequently
The frequency of information collection is dependent on the number of visits an individual makes to Government agencies or facilities. In most cases, a less frequent collection would mean eliminating the collection, as visits by contractors, for which the NRC Form 277 would be required, are infrequent. If the information is not collected, access by the visitor to classified information or areas, necessary in the accomplishment of official duties, may be denied.
Further, a reduction in the collection of the information required by the NRC Form 277 would reduce the assurance that only properly cleared and authorized individuals will be permitted access during a visit. Thus, less frequent collection may endanger the U.S. common defense and national security.
Circumstances Which Justify Variation from OMB Guidelines
There is no variation from OMB Guidelines in the collection of information.
Consultations Outside the NRC
The opportunity for public comment on the information collections requirements was published in the Federal Register on April 16, 2010 (75 FR 20008). No comments were received.
Payment or Gift to Respondents
Not applicable.
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).
Justification for Sensitive Questions
NRC does request sensitive information on this form.
Estimated Burden and Burden Hour Cost
REPORTING
An estimated 10 minutes (based on staff experience) is required to complete each NRC Form 277, resulting in a total annual burden to the public of 10 hours
(60 responses X 10 minutes ÷ 60.) The estimated annual cost is $2,570.00 (10 hours X $257 per hour.)
RECORDKEEPING
N/A
Estimate of Other Additional Costs
None
Estimated Annualized Cost to the Federal Government
The estimated annual cost to the Federal Government associated with the NRC
Form 277 is $1,755.00. The cost was computed as follows:
NOTE: Annual form usage for NRC contractors/licensees is estimated as 60.
COST:
Annual clerical effort
(60 x 10 minutes ÷ 60 = 10 hrs. X $47/hr.) = $470
Annual professional effort
(60 x 5 minutes ÷ 60 = 5 hrs. X $257/hr.) = $1,285
This cost is fully recovered through fee assessment to NRC licensees pursuant to 10 CFR Parts 170 and/or 171.
Reasons for Change in Burden or Cost
There was a significant increase in burden from 1 hour to 10 hours because of an increase in the number of requests received during the past clearance cycle, which increased from 6 responses to 60 responses. Additionally, the cost for professional effort has increased in accordance with Part 170 from $214.00 to $257.00 per hour.
Publication for Statistical Use
There is no application of statistics in the information collection related to NRC
Form 277 and no publication of the information.
Reason for Not Displaying the Expiration Date
The expiration date is displayed
Exceptions to the Certification Statement
Not applicable.
COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Statistical methods are not used in this collection of information.
| File Type | application/msword |
| File Title | FINAL SUPPORTING STATEMENT |
| Author | keb1 |
| Last Modified By | TUD |
| File Modified | 2010-07-21 |
| File Created | 2010-07-21 |