ML23304A067

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Reactor Program System (RPS) Privacy Impact Assessment (Pia)
ML23304A067
Person / Time
Issue date: 10/05/2023
From:
NRC/OCIO/CISO
To:
Debnam C
References
Download: ML23304A067 (20)
v • d • e


Text

U.S. Nuclear Regulatory Commission Privacy Impact Assessment Reactor Program System (RPS)

Subsystem of Business Application Support System (BASS)

Office of the Chief Information Officer (OCIO)

Version 1.2 10/5/2023 Instruction Notes:

Please do not enter the PIA document into ADAMS. An ADAMS accession number will be assigned through the e-Concurrence system which will be handled by the Privacy Team Template Version 2.0 (03/2023)

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 Document Revision History Date Version PIA Name/Description Author 10/5/2023 1.2 PIA Updates OCIO Oasis Systems, LLC 09/15/2023 1.1 Finalized RPS PIA Jordon Alston, NRC Tech PM, AEGIS IV&V 08/23/2023 1.0 Reactor Program System (RPS) Initial OCIO Release Oasis Systems, LLC 08/03/2023 DRAFT Reactor Program System (RPS) - Draft OCIO Release Oasis Systems, LLC

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 Table of Contents 1 Description 1 2 Authorities and Other Requirements 3 3 Characterization of the Information 4 4 Data Security 5 5 Privacy Act Determination 8 6 Records and Information Management-Retention and Disposal 9 7 Paperwork Reduction Act 12 8 Privacy Act Determination 13 9 OMB Clearance Determination 14 10 Records Retention and Disposal Schedule Determination 15 11 Branch Chief Review and Concurrence 16

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 The agency is subject to the requirements of the E-Government Act and is committed to identifying and addressing privacy risks whenever it develops or makes changes to its information systems. The questions below help determine any privacy risks related to the E-Government Act or later guidance by the Office of Management and Budget (OMB) and the National Institute of Standards and Technology (NIST).

Name/System/Subsystem/Service Name: Reactor Program System (RPS).

Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform): OCIO ITI Azure Global Cloud Environment, ITI Azure Database Servers.

Date Submitted for review/approval: October 31, 2023.

1 Description 1.1 Provide the description of the system/subsystem, technology (i.e., Microsoft Products), program, or other data collections (hereinafter referred to as project).

Explain the reason the project is being created.

The NRCs Reactor Program System (RPS) is an enterprise workload management platform that supports the effective execution of business processes associated with the reactor inspections and licensing programs. RPS was designed to provide a planning, scheduling, reporting, and analysis tool for inspection activities at nuclear power reactor and fuel facilities in the United States (U.S.). This system is used to implement the policy and inspection guidance for programs assigned to the NRC regional offices and assesses the effectiveness and uniformity of the implementation of those programs through detailed reporting processes. The RPS is administered by the Office of Nuclear Reactor Regulation (NRR) and users include NRR, the Office of Nuclear Material Safety and Safeguards (NMSS), the Office of Nuclear Security and Incident Response (NSIR), the Office of Nuclear Regulatory Research (RES), the Office of Enforcement (OE), the Office of the Chief Information Officer (OCIO), and NRC Regional offices.

The modules of RPS are as follows:

- RPS - Inspection Scheduling and Tracking (Inspections) and Inspections Reporting tool (ISTAR) - Manages all the scheduling and tracking for inspection activities and findings; generates inspection reports.

- RPS - Licensing/Workload Management (LWM) - Manages and tracks reactor licenses, milestones, and workload review process; assigns reviewers to projects; generates LWM reports.

- RPS - Oversight - Manages and tracks safety and security performance assessments.

- RPS - Operator License (OL) - Manages and tracks updates for operator licensing activities and licenses.

- RPS - Reactor Oversight Process (ROP) - Manages data from all RPS modules and makes the appropriate information available for the public webpage.

- Read - only RPS - Allow limited access to Inspections and Licensing.

- Request for Additional Information (RAI) - Automates documentation and tracking associated with the reactor licensing RAI processes. License applicants are required to respond to gaps an address information with application submissions. RAI allows the NRC PIA Template (03-2023) 1

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 to request additional information during the review and approval process. If an applicant fails to respond to an RAI within a specified time frame, NRC can deny an application.

Please mark appropriate response below if your project/system will involve the following:

PowerApps Public Website**

Dashboard Internal Website SharePoint None Other - Virtual servers hosted in the NRC Azure tenant.

1.2 Does this privacy impact assessment (PIA) support a proposed new project, proposed modification to an existing project, or other situation? Select options that best apply in table below.

Mark appropriate response.

Status Options New system/project Modification to an existing system/project.

If modifying or making other updates to an existing system/project, provide the ADAMS ML of the existing PIA and describe the modification.

Annual Review If making minor edits to an existing system/project, briefly describe the changes below.

Applying the new PIA template.

Other (explain) 1.3 Points of

Contact:

System Business Technical Executiv Project Owner/Data ISSO Project Project e Manager Owner/Stewar Manager Manager Sponsor d

Victor Consuella Ikeda Jordon Andrea Name Gwen Hayden Kochuba Debnam Belts Alston Veil Office of Office of Office of Office of Office of Office of the Office the Chief the Chief Nuclear the Chief Nuclear Chief

/Division Informatio Informatio Reactor Informatio Reactor Information

/Branch n Officer n Officer Regulatio n Officer Regulatio Officer (OCIO)

(OCIO) (OCIO) n (NRR) (OCIO) n (NRR)

Telephon 301-415- 301-287- 301-415- 301-415- 301-415-301-287-0761 e 6270 0834 1959 4085 1270 PIA Template (03-2023) 2

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 2 Authorities and Other Requirements 2.1 What specific legal authorities and/or agreements permit the collection of information for the project?

Provide all statutory and regulatory authorities for operating the project, including the authority to collect the information; NRC internal policy is not a legal authority. Please mark appropriate response in table below.

Mark with an Authority Citation/Reference X on all that apply.

Statute United States Code, 2006 Edition, Supplement 4, Title 42 - THE PUBLIC HEALTH AND WELFARE - 42 U.S.C. 2201(d),

2201(p) (1996) and 42 U.S.C. 2137 and 2201(i) (1996).

Executive Order Federal Regulation Memorandum of Understanding/Agreement Other (summarize and provide a copy of relevant portion) 2.2 Explain how the information will be used under the authority listed above (i.e., enroll employees in a subsidies program to provide subsidy payment).

RPS includes inspection and licensing information, plant performance indicators, inspection follow-up items, safety issue data, NRC staff data, facility characteristics, request for additional information and other reactor regulatory data which is used to support the following functions:

- Manage all the scheduling and tracking for inspection activities and findings.

- Manage and track reactor licenses, milestones, and workload review process.

- Manage and track safety and security performance assessments.

- Manage and track updates for operator licensing activities and licenses.

- Generate events status reports.

- Issue requests for additional information If the project collects Social Security numbers, state why this is necessary and how it will be used.

N/A.

PIA Template (03-2023) 3

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 3 Characterization of the Information In the table below, mark the categories of individuals for whom information is collected.

Category of individual Federal employees Contractors Members of the Public (any individual other than a federal employee, consultant, or contractor)

Licensees Other: Reactor Operator Candidates and Operator Licensees.

In the table below, is a list of the most common types of PII collected. Mark all PII that is collected and stored by the project/system. If there is additional PII not defined in the table below, a comprehensive listing of PII is provided for further reference in ADAMS at the following link: PII Reference Table 2023.

Categories of Information Name Resume or curriculum vitae Date of Birth Driver's License Number Country of Birth License Plate Number Citizenship Passport number Nationality Relatives Information Race Taxpayer Identification Number Home Address Credit/Debit Card Number Social Security number (Truncated or Partial) Medical/health information Gender Alien Registration Number Ethnicity Professional/personal references Spouse Information Criminal History Biometric identifiers (facial images, Personal e-mail address fingerprints, iris scans)

Emergency contact e.g., a third party to Personal Bank Account Number contact in case of an emergency Personal Mobile Number Accommodation/disabilities information Marital Status Other: examination test scores, license type, fitness for duty and violations Children Information information.

Mother's Maiden Name PIA Template (03-2023) 4

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 3.1 Describe how the data is collected for the project. (i.e., NRC Form, survey, questionnaire, existing NRC files/ databases, response to a background check).

Information is provided by NRC Form 398 and NRC Form 396. The candidate/operator provides information to the NRC that has been certified by an authorized representative of the facility licensee as required, by 10 CFR Part 55 on NRC Form 398 (10 CFR Part 55.31(4) Personal Qualification Statement-Licensee, and NRC Form 396 (10 CFR 55.23) Certification of Medical Examination.

3.2 If using a form to collect the information, provide the form number, title and/or a link.

NRC Form 398, and NRC Form 396.

3.3 Who provides the information? Is it provided directly from the individual or a third party.

The facility and the employee together supply the requested information. The employee and the facility managers must certify as to the accuracy of the information.

3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.

Collected information is certified by facility management before it is submitted to NRC. NRC audits a sample of applications.

3.5 Will PII data be used in a test environment? If so, explain the rationale.

No.

3.6 What procedures are in place to allow the subject individual to correct inaccurate or erroneous information?

Collected information is certified by facility management before it is submitted. The information is verified during the business processes associated with the reactor inspections and licensing programs, which is conducted by the Office of Nuclear Reactor Regulation (NRR), the Office of Nuclear Material Safety and Safeguards (NMSS), the Office of Nuclear Security and Incident Response (NSIR), and NRC Regional offices.

4 Data Security 4.1 Describe who has access to the data in the project (i.e., internal NRC, system administrators, external agencies, contractors, public).

Access to specific information is restricted to only individuals and/or user groups who have a need to know and have authorized access.

4.2 If the project/system shares information with any other NRC systems, identify the system, what information is being shared and the method of sharing.

Master Data Management System (MDMS), Cost Activity Code System (CACS), Agencywide Document Access and Management System (ADAMS), Operator Digitized Dockets (ODD),

Headquarters Operations Officer Database (HOO), MDMS Enterprise Datawarehouse (EDW).

PIA Template (03-2023) 5

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 RPS pulls docket, employee, and organization data from MDMS via an Application Programming Interface (API). RPS pulls Enterprise Project Identifiers (EPID) and CAC/Staff Assignment data from CACS via API.

RPS pulls inspections and licensing accession numbers and meta data from ADAMS via database views. RPS pulls operator licensing data from ODD via API. The data is processed from the forms 396 and 398 provided by ODD and then saved within RPS OL module.

RPS pulls event notification (EN)/ license event reports (LER) data and part 21 creation data from HOO via a flat file drop.

The MDMS EDW connects to RPS via SQL server connection (TCP/IP port 1433) to pull operator licensing, licensing, inspections, and oversight data.

4.3 If the project/system connects, receives, or shares information with any external non-NRC partners or systems, identify what is being shared.

N/A.

Identify what agreements are in place with the external non-NRC partner or system in the table below.

Agreement Type Contract Provide Contract Number:

License Provide License Information:

Memorandum of Understanding Provide ADAMS ML number for MOU:

Other None 4.4 Describe how the data is accessed and describe the access control mechanisms that prevent misuse.

Access to specific information is restricted to only individuals and/or user groups who have a need to know and have authorized access. Application users are authenticated using Integrated Windows Authentication, in accordance with the NRC Identity, Credential, and Access Management (ICAM) Authentication Framework. The application provides a single sign-on experience that allows Active Directory to verify if a user should have access. This is coupled with a second layer of security that verifies that the user has an active role within the application granting permission to perform specific tasks.

4.5 Explain how the data is transmitted and how confidentiality is protected (i.e.,

encrypting the communication or by encrypting the information before it is transmitted).

The database uses TDE, transparent data encryption, to encrypt the data at rest.

Communication between the database and webserver uses SSL/TLS while communication between the web server and the client uses HTTPS which in turn uses SSL/TLS.

PIA Template (03-2023) 6

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).

ITI Azure Global Cloud environment.

4.7 Explain if the project can be accessed or operated at more than one location.

Yes, the system will be accessed by the NRC Program Office (HQ), Regional Offices, and through agency approved methods (e.g., VPN, mobility platforms). The system is hosted in the OCIO Information Technology Architecture (ITI) Microsoft (MS) Azure Global cloud environment in the East U.S. 2 region located in Southern Virginia.

4.8 Can the project be accessed by a contractor? If so, do they possess an NRC badge?

Yes, Teksynap/Centeva application administrators can access the RPS application and all its environments. RPS application administrators are NRC contractors, and they possess an NRC badge.

4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.

Access to specific information is restricted to only individuals and/or user groups who have a need to know and have authorized access.

4.10 Describe if the project has the capability to identify, locate, and monitor (i.e.,

trace/track/observe) individuals.

Yes, for operator license only.

4.11 Define which FISMA boundary this project is part of.

Business Application Support System (BASS).

4.12 Is there an Authority to Operate (ATO) associated with this project/system?

Authorization Status Unknown No If no, please note that the authorization status must be reported to the Chief Information Security Officer (CISO) and Computer Security Organization (CSOs)

Point of Contact (POC) via e-mail quarterly to ensure the authorization remains on track.

In Progress provide the estimated date to receive an ATO.

Estimated date:

Yes Indicate the data impact levels (Low, Moderate, High, Undefined) approved by the Chief Information Security Officer (CISO)

Confidentiality- MODERATE Integrity-MODERATE Availability-MODERATE PIA Template (03-2023) 7

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 4.13 Provide the NRC system Enterprise Architecture (EA)/Inventory number. If unknown, contact EA Service Desk to get the EA/Inventory number.

20150003.

5 Privacy Act Determination 5.1 Is the data collected retrieved by a personal identifier?

Mark the appropriate response.

Response

Yes, the PII is retrieved by a personal identifier (i.e., individuals name, address, SSN, etc.)

List the identifiers that will be used to retrieve the information on the individual.

For operator license records the data is retrieved by the docket number and name.

All other records are retrieved by docket number, name and report number.

No, the PII is not retrieved by a personal identifier.

If no, explain how the data is retrieved from the project.

The data is retrieved by the docket number and name.

5.2 For all collections where the information is retrieved by a personal identifier, the Privacy Act requires that the agency publish a System of Record Notice (SORN) in the Federal Register. As per the Privacy Act of 1974, "the term 'system of records' means a group of any records under the control of any agency from which information is retrieved by the name of the individual or by some other personal identifier assigned to the individual.

Mark the appropriate response in the table below.

Response

Yes, this system is covered by an existing SORN. (See existing SORNs:

https://www.nrc.gov/reading-rm/foia/privacy-systems.html )

Provide the SORN name, number, (List all SORNs that apply):

System NRC-16 Facility Operator Licensees Record Files (10 CFR Part 55),

SORN is in progress SORN needs to be created Unaware of an existing SORN No, this system is not a system of records and a SORN is not applicable.

PIA Template (03-2023) 8

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 5.3 When an individual is asked to provide personal data (i.e., form, webpage, survey), is a Privacy Act Statement (PAS) provided?

A Privacy Act Statement is a disclosure statement required to appear on documents used by agencies when an individual is asked to provide personal data. It is required for any forms, surveys, or other documents, including electronic forms, used to solicit personal information from individuals that will be maintained in a system of records.

Mark the appropriate response.

Options Privacy Act Statement NRC Form 398 has a Privacy Statement.

NRC Form 396 does not have a Privacy Act Statement.

Not Applicable Unknown 5.4 Is providing the PII mandatory or voluntary? What is the effect on the individual by not providing the information?

Mandatory.

6 Records and Information Management-Retention and Disposal The National Archives and Records Administration (NARA), in collaboration with federal agencies, approves whether records are Temporary (eligible at some point for destruction/deletion because they no longer have business value) or Permanent (eligible at some point to be transferred to the National Archives because of historical or evidential significance). Records/data and information with historical value, identified as having a permanent disposition, are transferred to the National Archives of the United States at the end of their retention period. All other records identified as having a temporary disposition are destroyed at the end of their retention period in accordance with the NARA Records Schedule or the General Records Schedule.

These determinations are made through records retention schedules and NARA statutes (44 United States Code (U.S.C.), 36 Code of Federation Regulations (CFR)). Under 36 CFR, agencies are required to establish procedures for addressing Records and Information Management (RIM) requirements. This includes strategies for establishing and managing recordkeeping requirements and disposition instructions before approving new electronic information systems or enhancements to existing systems.

The following questions are intended to determine whether the records/data and information in the system have approved records retention schedules and disposition instructions, whether the system incorporates RIM strategies including support for NARAs Universal Electronic Records Management (ERM) requirements, and if a mitigation strategy is needed to ensure compliance.

If the project/system:

  • Does not have an approved records retention schedule and/or
  • Does not have an automated RIM functionality, PIA Template (03-2023) 9

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023

  • Involves a cloud solution,
  • And/or if there are additional questions regarding Records and Information Management

- Retention and Disposal, please contact the NRC Records staff at ITIMPolicy.Resource@nrc.gov for further guidance.

If the project/system has a record retention schedule or an automated RIM functionality, please complete the questions below.

6.1 Does this project map to an applicable retention schedule in NRCs Comprehensive Records Disposition Schedule (NUREG-0910), or NARAs General Records Schedules?

NUREG-0910, NRC Comprehensive Records Disposition Schedule NARAs General Records Schedules Unscheduled 6.2 If so, cite the schedule number, approved disposition, and describe how this is accomplished.

System Name (include sub-systems, platforms, RPS or other locations where the same data resides)

Records Retention Schedule Number(s) RPS retention schedule, N1-431 18, ML092390130.

GRS 5.2: 020 Intermediary Records Approved Disposition Instructions GRS 5.2 item 020 - Intermediary Records (DAA-GRS-2017-0003-0002) - Temporary.

Destroy upon verification of successful creation of the final document or file, or when no longer needed for business use, whichever is later.

10 CFR Part 55 Docket Files -

NUREG 0910 2.18.6.a - Temporary.

Cut off files upon latest license expiration/revocation/termination, application denial or withdrawal, or issuance of denial letter. Destroy when 10 years old.

Examination Package - NUREG 0910 2.18.6.b - Temporary. Cut off file upon receipt of the facilitys next exam. Destroy 4 years after cutoff.

General Correspondence - NUREG 0910 2.18.6.c - Temporary. Cut off at close of fiscal year. Destroy when 10 years old.

PIA Template (03-2023) 10

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 If identified, any additional information/data/records kept in this system may need to be scheduled; therefore, NRC records personnel will need to work with staff to develop a records retention and disposition schedule for records created or maintained not otherwise noted. Until the approval of such schedule, these records and information are Permanent. Their willful disposal or concealment (and related offenses) is punishable by fine or imprisonment, according to 18 U.S.C., Chapter 101, and Section 2071. Implementation of retention schedules is mandatory under 44 U.S.

3303a (d), and although this does not prevent further development of the project, retention functionality or a manual process must be incorporated to meet this requirement.

Is there a current automated functionality or a TBD manual process to support RIM requirements? This includes the ability to apply records retention and RPS is hosted in the ITI ACS Cloud disposition policies in the system(s) to support IaaS environment, as such, relies on records accessibility, reliability, integrity, and ITI to support RIM requirements, and disposition. records accessibility, reliability, integrity, and disposition.

Disposition of Temporary Records TBD Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?

Disposition of Permanent Records TBD Will the records be exported to an approved format and transferred to the National Archives based on approved retention and disposition instructions?

If so, what formats will be used?

NRC Transfer Guidance (Information and Records Management Guideline

- IRMG)

PIA Template (03-2023) 11

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 7 Paperwork Reduction Act The Paperwork Reduction Act (PRA) of 1995 requires that agencies obtain an Office of Management and Budget (OMB) approval in the form of a "control number"before promulgating a paper form, website, surveys, questionnaires, or electronic submission from 10 or members of the public. If the data collection is from federal employees regarding work-related duties, then a PRA clearance is not necessary.

7.1 Will the project be collecting any information from 10 or more persons who are not Federal employees?

Yes.

7.2 Is there any collection of information addressed to all or a substantial majority of an industry (i.e., Fuel Fabrication Facilities or Fuel Cycle Facilities)?

No.

7.3 Is the collection of information required by a rule of general applicability?

Yes.

Note: For information collection (OMB clearances) questions: contact the NRCs Clearance Officer. Additional guidance can be found on the NRCs internal Information Collections Web page at: https://intranet.nrc.gov/ocio/33456.

PIA Template (03-2023) 12

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 8 Privacy Act Determination Project/System Name: Reactor Program System (RPS).

Submitting Office: Office of the Chief Information Officer (OCIO)

Privacy Officer Review Review Results Action Items This project/system does not contain PII. No further action is necessary for Privacy.

This project/system does contain PII; the Must be protected with restricted Privacy Act does NOT apply, since access to those with a valid need-to-information is NOT retrieved by a personal know.

identifier.

This project/system does contain PII; the SORN is required- Information is Privacy Act does apply. retrieved by a personal identifier.

Comments:

Covered by System of Records NRC 16 - Facility Operator Licensees Records Reviewers Name Title Signed by Hardy, Sally on 12/14/23 Privacy Officer PIA Template (03-2023) 13

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 9 OMB Clearance Determination NRC Clearance Officer Review Review Results No OMB clearance is needed.

OMB clearance is needed.

Currently has OMB Clearance. Clearance No. 3150-0024 (Form 396), 3150-0090 (Form 398), and 3150-0018 (Part 55)

Comments:

Reviewers Name Title Signed by Cullison, David on 11/30/23 Agency Clearance Officer PIA Template (03-2023) 14

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 10 Records Retention and Disposal Schedule Determination Records Information Management Review Review Results No record schedule required.

Additional information is needed to complete assessment.

Needs to be scheduled.

Existing records retention and disposition schedule covers the system - no modifications needed.

Comments:

Reviewers Name Title Signed by Dove, Marna on 12/07/23 Sr. Program Analyst, Electronic Records Manager PIA Template (03-2023) 15

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 11 Branch Chief Review and Concurrence Review Results This project/system does not collect, maintain, or disseminate information in identifiable form.

This project/system does collect, maintain, or disseminate information in identifiable form.

I concur with the Privacy Act, Information Collections, and Records Management reviews.

Signed by Feibus, Jonathan on 12/14/23 Chief Information Security Officer Chief Information Security Division Office of the Chief Information Officer PIA Template (03-2023) 16

Reactor Program System (RPS) Version 1.2 Privacy Impact Assessment 10/5/2023 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:

Reactor Program System (RPS).

Date CISD received PIA for review: Date CISD completed PIA review:

October 31, 2023 December 13, 2023 Action Items/Concerns:

Copies of this PIA will be provided to:

Caroline Carusone Director IT Services Development and Operations Division Office of the Chief Information Officer Garo Nalabandian Deputy Chief Information Security Officer (CISO)

Office of the Chief Information Officer PIA Template (03-2023) 17

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