Burden spreadsheet for Enhanced Weapons Supplemental Proposed Rule

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Overview

Overall Rule Totals
Pt 73 1x reporting
Pt 73 reporting
Pt 73 3rd party
Pt 73 1x rkeeping
Pt 73 rkeeping
Part 73 total
Form 754 1x reporting
Form 754 reporting
Form 754 rkeeping
Form 754 Total
Government Costs

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Sheet 1: Overall Rule Totals

Calculations for the text: Sections 12 and 13.
One-Time
	Responses	Burden	Cost @$279/hr
Reporting (annualized)	1,687	12,950	3,613,050
recordkeeping	10	1333	372000
Overall Totals	1,697	14,283	3,985,050			# recordkeepers total		133
Annual						Recordkeeping Storage
Annual Reporting	2,196	24,312	6,783,076				Burden	Factor	Cost @$279/hr
recordkeeping	143	9,041	2,522,439			Part 73	10,034	0.0004	4.01373333333333
Third Party	60	270	75,330			Form 754	340	0.0004	0.136
Overall Totals	2,399	33,623	9,380,845
Combined
reporting	3,882	37,262	10,396,126
recordkeeping	153	10,374	2,894,439			Fraction of annual to overall costs
total*	4,085	47,906	13,365,895			0.701849368873909
*Note that 10 recordkeepers were counted only once in the total number of responses
	Total Burden for Enhanced Weapons Proposed Rule
	Responses	Hours	Cost at $279/hr
Reporting	3,882.5	37,262.1	$10,396,126
Recordkeeping	143.0	10,374.3	$2,894,439
3rd Party	60.0	270.0	$75,330
Total	4,085.5	47,906.4	$13,365,895

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Sheet 2: Pt 73 1x reporting

Requirement	Description	No. of Respondents	Responses per Respondent	Number of Responses	Burden Hours per Response	Total Annual Burden Hours	Cost at $279/hr
73.18(b)	Requirement to apply for Section 161A authorities	10	1	10	1,200	12000	$3,348,000
73.18(d)(2)	Preemption authority applications in writing	Burden shown under Section 73.18(b)
73.18(d)(4)	Notice of completion of firearms background checks for preemption authority application	Burden shown under Section 73.18(b)
73.18(e)(2)	Combined preemption and enhanced weapons authority applications in writing	10	1	10	400	4000	$1,116,000
73.18(e)(3)	Contents of combined preemption and enhanced weapons authority application	Burden shown under Section 73.18(e)(2)
73.18(e)(5)	Notice of completion of firearms background checks for combined preemption and enhanced weapons authority application	Burden shown under Section 73.18(e)(2)
73.18(e)(7)	Applications to change type, caliber, or quantity of enhanced weapons	Burden shown under Section 73.18(e)(2)
73.18(f)(1)	Updated physical security plans, training and qualification plans, safeguards contingency plans, and safety assessments	10	1	10	800	8000	$2,232,000
73.18(f)(2)(i)	Identify types of models, calibers, and numbers of enhanced weapons used	Burden shown under Section 73.18(f)(1)(i)
73.18(f)(2)(ii)	Updated training and qualification plan for use of enhanced weapons	Burden shown under Section 73.18(f)(1)(i)
73.18(f)(2)(iii)	Updated safeguards contingency plan for use of enhanced weapons	Burden shown under Section 73.18(f)(1)(i)
73.18(f)(2)(iv)	Updated safety assessment for use of enhanced weapons	Burden shown under Section 73.18(f)(1)(i)
73.18(f)(3)	Updated training and qualification plan on possessing, storing, maintaining, qualifying on, and using enhanced weapons	Burden shown under Section 73.18(f)(1)(i)
73.18(s)(4)	Notifying the NRC of completed transition from an order to the requirements of § 73.18	10	1	10	200	2000	$558,000
73.19(b)(1)	Develop Firearms Background Check Plan	10	250	2500	0.3	750	$209,250
73.19(d)(1)	Requirement for fingerprint checks	Burden shown under Section 73.19(b)(1)
73.19(d)(2)	Requirement for checks using the NICS system	Burden shown under Section 73.19(b)(1)
73.19(e)(1)	Firearms Background submittals in accordance with §73.4	Burden shown under Section 73.19(b)(1)
73.19(j)	Training on disqualifying events and status	10	1	10	310	3100	$864,900
73.19(k)(1)	Submission of standard fingerprint card	Burden shown under Section 73.19(b)(1)
73.19(k)(2)	Purpose of fingerprint check for firearms background check	Burden shown under Section 73.19(b)(1)
73.19(k)(3)	Procedures for quality finger print card submission	Burden shown under Section 73.19(i)
73.19(k)(4)	Resubmission of fingerprint cards that contain omissions or evident errors	Burden shown under Section 73.19(b)(1)
73.19(p)	Training on and process for delayed or denied NICS responses	Burden shown under Section 73.19(b)(1)
73.19(q)	System to protect the records and personal information	Burden shown under Section 73.19(i)
73.19(r)(1)	Update procedures, instructions, and training material to transition from orders to the final rule	10	1	10	400	4000	$1,116,000
73.19(r)(4)	Notify the NRC of complete transition from orders to the final rule	Burden shown under Section 73.18(s)(4)
TOTAL				2,560		33,850	$9,444,150
ANNUALIZED TOTAL				853.3		11,283.3	$3,148,050

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Sheet 3: Pt 73 reporting

Requirement	Description	No. of Respondents	Responses per Respondent	Number of Responses	Burden Hours per Response	Total Annual Burden Hours	Cost at $279/hr
73.18(k)	Notifications of adverse ATF findings or notices	Burden shown under Section 73.71(h)
73.18(p)	Notification of lost or stolen enhanced weapon	Burden shown under Section 73.71(g)
73.18(r)(1)	Applications to terminate Section 161A authorities	10	0.1	1	2	2	$558
73.18(r)(2)	Applications to modify combined preemption and enhanced weapons authority	Burden shown under Section 73.18(r)(1)
73.18(r)(4)	Re-applications for Section 161A authority after termination, suspension or revocation.	Burden shown under Section 73.18(r)(1)
73.19(b)(1)	Develop Firearms Background Check Plan	10	13	130	2	260	$72,540
73.19(b)(5-9)	Permission to initiate Firarms Background Checks	Burden shown under Section 73.19(b)(1)
73.19(b)(12)	Break-in-service Firearms Background Checks	Burden shown under Section 73.19(b)(1)
73.19(d)(1)	Requirement for fingerprint checks	Burden shown under Section 73.19(b)(1)
73.19(d)(2)	Requirement for checks using the NICS system	Burden shown under Section 73.19(b)(1)
73.19(g)	Notification of personnel removed from duties requiring access to covered weapons	Burden shown under Section 73.19(b)(1)
73.19(h)	Notification of disqualifying events or status	Burden shown under Section 73.19(b)(1)
73.19(j)	Tranining on disqualifying events and status	10	0.1	1	310	310	$86,490
73.19(k)(1)	Submission of standard fingerprint card	Burden shown under Section 73.19(b)(1)
73.19(k)(2)	Purpose of fingerprint check for firearms background check	Burden shown under Section 73.19(b)(1)
73.19(k)(4)	Resubmission of fingerprint cards that contain omissions or evident errors	Burden shown under Section 73.19(b)(1)
73.19(p)	Training on and process for delayed or denied NICS responses	Burden shown under Section 73.19(b)(1)
73.71(a)*	Notification of an imminent or actual physical threat	133	0.1	13.3	2	26.6	$7,421
73.71(b)*	Notification of an imminent or actual threat against a shipment of SNM fuel, HLW, or SSNM	Burden shown under Section 73.71(a)
73.71(c)*	Notification of a safeguards event	133	0.5	66.5	1	66.5	$18,554
73.71(d)*	Notification of a loss, actual or attempted sabotage, actual or attempted theft, or recovery or accounting of SNM during it’s shipment	Burden shown under Section 73.71(c)
73.71(e)*	Notification of events that indicate pre-operational surveillance, reconnaissance, or intelligence gathering activities	133	5	665	1	665	$185,535
73.71(f)*	Notification of unauthorized operation or tampering events	133	1	133	1	133	$37,107
73.71(g)	Notification of lost or stolen enhanced weapon	10	0.5	5	1	5	$1,395
73.71(h)	Notification after receipt of an advise inspection, enforcement action, or other adverse notice from the ATF	Burden shown under Section 73.71(g)
73.71(j)(1)*	Notification by telephone after receipt of an advise inspection, enforcement action, or other adverse notice from the ATF	Burden shown under Section 73.71(m)
73.71(j)(8)*	Notification by telephone to retract a security event report	Burden shown under Section 73.71(m)
73.71(m)(1)*	Submission of written report following security event notification	133	7	931	24	22344	$6,233,976
TOTAL				1,945.8		23,812.1	$6,643,576

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Sheet 4: Pt 73 3rd party

Requirement	Description	No. of Respondents	Responses per Respondent	Number of Responses	Burden Hours per Response	Total Annual Burden Hours	Cost at $279/hr
73.19(h)	Notification of disqualifying events or status	10	3	30	8	240	$66,960
73.19(p)	Training on and process for delayed or denied NICS responses	10	3	30	1	30	$8,370
TOTAL				60.0		270.0	$75,330

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Sheet 5: Pt 73 1x rkeeping

Requirement	Description	Number of Recordkeepers	Burden Hours Per Recordkeeper	Total Annual Burden Hours	Cost at $279/hr
73.18(s)(3)	Updating procedures, instructions, and training material to transition from requirements under the order to the requirements of § 73.18	10	400	4000	$1,116,000
Total		10		4000	$1,116,000
Annualized total		10		1333.3	$372,000

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Sheet 6: Pt 73 rkeeping

Requirement	Description	Number of Recordkeepers	Number of Records per Recordkeeper	Burden Hours Per Recordkeeper	Total Annual Burden Hours	Cost at $279/hr
73.18(o)	Periodic inventories of enhanced weapons	10	12	112	1120	$312,480
73.18(o)(2)	Maintain records of periodic inventories	Burden shown under Section 73.18(o)
73.18(o)(8)	Maintain log of tamper indicating devices	Burden shown under Section 73.18(o)
73.18(q) – (L)	Records of receipt, transfer, and transportation of enhanced weapons	Burden shown under Section 73.18(o)
73.71(k)*– (L)	Maintain a Safeguards Event Log	133	150	50	6650	$1,855,350
73.71(m)(1)*– (L)	Submission of written report following security event notification	133	7	7	931	$259,749
TOTAL		133			8,701.0	$2,427,579

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Sheet 7: Part 73 total

	Part 73 Enhanced Weapons Proposed Rule Totals
	Responses	Hours	Cost at $279/hr
Reporting	2,799.1	35,095.4	$9,791,626
Recordkeeping	133.0	10,034.3	$2,799,579		1119.8316
3rd Party	60.0	270.0	$75,330
Total	2,992.13	45,399.8	$12,666,535
					1224000
					89000
					22000
					1335000

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Sheet 8: Form 754 1x reporting

Section	Description	No. of Respondents	Responses per Respondent	Number of Responses	Burden Hours per Response	Total Burden Hours	Cost at $279/hr
73.19(e)(1)	Firearms Background submittals in accordance with § 73.4	10	250	2,500	2	5,000	$1,395,000
73.19(n)(2)	Forwarding NICS result to security personnel	Burden shown under Section 73.19(e)(1)
TOTAL				2,500		5,000	$1,395,000
ANNUALIZED TOTAL				833		1,666.7	$465,000

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Sheet 9: Form 754 reporting

Section	Description	No. of Respondents	Responses per Respondent	Number of Responses	Burden Hours per Response	Total Burden Hours	Cost at $279/hr
73.19(e)(1)	Firearms Background submittals in accordance with § 73.4	10	25	250	2	500	$139,500
73.19(n)(2)	Forwarding NICS result to security personnel	Burden shown under Section 73.19(e)(1)
TOTAL				250		500.0	$139,500

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Sheet 10: Form 754 rkeeping

Section	Description	No. of Recordkeepers	No. of Records per Recordkeeper	Burden Hours per Recordkeeper	Total Burden Hours	Cost at $279/hr
73.19(e)(4) – (CW+1)	Retain copies of Form 754 submittals	10	1	34	340	$94,860
TOTAL		10			340.0	$94,860

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Sheet 11: Form 754 Total

	NRC Form 754 Totals
	Responses	Hours	Cost at $279/hr
Reporting	1,083.3	2,166.7	$604,500
Recordkeeping	10.0	340.0	$94,860		37.944
Total	1,093.33	2,506.7	$699,360

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Sheet 12: Government Costs

	2011 proposed rule Supporting Statement		Burden scaled to 10 enhanced weapons respondents
	Burden	Cost @$279/hr	Burden	Cost @$279/hr
review the required reports and records, and perform onsite inventory inspections	2,624	$732,096	320	$89,280
annual cost to perform 752 onsite inventory inspections	656	$183,024	80	$22,320
Total	3,280	$915,120	400	$111,600
	2032624.6459144
	$2,947,745