ML25219A216

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Allegations Resolution Investigation and Enforcement System (Aries) Pia
ML25219A216
Person / Time
Issue date: 08/04/2025
From: Harris N, Thomas A
NRC/OCIO, NRC/OE, NRC/OI
To:
Hardy S
References
PIA
Download: ML25219A216 (0)


Text

U.S. Nuclear Regulatory Commission Privacy Impact Assessment Allegations, Resolution, Investigation and Enforcement System (ARIES)

Subsystem of Business Application Support System (BASS)

Office of the Chief Information Officer (OCIO)

Version 1.3 08/04/2025 Template Version 2.5 (03/2025)

Allegations, Resolution, Investigation and Enforcement System (ARIES)

Version 1.3 Privacy Impact Assessment 08/04/2025 Document Revision History Date Version PIA Name/Description Author 8/4/2025 1.3 FY25 update to include the Individual Action Tracking System (IATS) information and converted to the new template Natasha Harris - OI Audrey Thomas - OE 11/9/2023 1.2 Updated ARIES PIA Final Draft OCIO/Bill Nightingale 10/25/2023 1.1 ARIES PIA Final Draft Release OCIO/Bill Nightingale 10/13/2023 1.0 ARIES PIA Initial Draft Release Bill Nightingale

Allegations, Resolution, Investigation and Enforcement System (ARIES)

Version 1.3 Privacy Impact Assessment 08/04/2025 Table of Contents 1

Description 1

2 Authorities and Other Requirements 3

3 Characterization of the Information 4

4 Data Security 7

5 Privacy Act Determination 10 6

Records and Information Management-Retention and Disposal 11 7

Paperwork Reduction Act 15 8

Privacy Act Determination 17 9

OMB Clearance Determination 18 10 Records Retention and Disposal Schedule Determination 19 11 Review and Concurrence 20

Allegations, Resolution, Investigation and Enforcement System (ARIES)

Version 1.3 Privacy Impact Assessment 08/04/2025 PIA Template 2.5 (03-2025)-ML050460335 1

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: Allegation, Resolution, Investigation and Enforcement System (ARIES) - Formerly Case Management System Web (CMS-W).

Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform) Power Platform.

Date Submitted for review/approval: Aug 4, 2025.

Note: When completing this PIA do not include any information that would raise security concerns or prevent this document from being made publicly available.

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 Allegations, Resolution, Investigation and Enforcement System (ARIES) is an overarching subsystem hosted within the Microsoft Power Platform that provides an integrated methodology for planning, scheduling, conducting, reposting, and analyzing allegation and enforcement programs for the U.S. Nuclear Regulatory Commission (NRC). ARIES is the umbrella title given to separate processes (listed below) and one SharePoint database. It includes legacy functionality from the following legacy functionality. In addition to legacy functionality, improvements have been made to reflect current business owner needs.

Allegation Process - Allows authorized users to store and retrieve key information on allegations related to NRC-regulated facilities.

Investigation Process - Designed to assist the Office of Investigations (OI) meet their objectives by tracking all the different entities required for NRC investigations.

Enforcement Process - Allows authorized users to enter new or updated case information, query enforcement case information and report on enforcement case information.

Individual Action Tracking System - Allows authorized users to track cases of individuals involved in NRC-licensed activities who have been subject to NRC enforcement actions.

Allegations, Resolution, Investigation and Enforcement System (ARIES)

Version 1.3 Privacy Impact Assessment 08/04/2025 PIA Template 2.5 (03-2025)-ML050460335 2

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

PowerApps Artificial Intelligence (AI)

Dashboard Public Website SharePoint Internal Website Cloud Service Provider Server/Database Design Other 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 the 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.

ML23244A043 Added IATS information to the ARIES PIA

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

Other (explain) 1.3 Points of

Contact:

Role Contact Information Name Office/Division/Branch Phone Number Project Manager(s)

Arathi Dommeti OCIO/ITS DOD/ADS B/CCAT 301-415-4003 System Owner/Data Owner or Steward Jonathan Feibus OCIO/CISD 301-415-0717 Business Project Manager Sandra Mendez - Allegations David Hsia - Investigations Gerald Gulla - Enforcement OE, OI 301-287-9426 301-415-3486 301-287-9143

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Role Contact Information Name Office/Division/Branch Phone Number ISSM Consuella Debnam OCIO 301-287-0834 Executive Sponsor Bo Pham OCIO-OI-OE 301-415-1261 Technical Project Manager Bill Nightingale OCIO 703-973-3265 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 the appropriate response in the table below.

Mark with an X on all that apply.

Authority Citation/Reference

Statute Privacy Act of 1974, as amended, 5 U.S.C.

§552a Paperwork Reduction Act, as amended, 44 U.S.C. § 3501 et seq E-Government Act of 2002, Section 208 (Public Law 107-347)

Records Management by Federal Agencies, 44 U.S.C. Chapter 31 Atomic Energy Act of 1954 Also 42 U.S.C 2113, 2114, 2231; 42 U.S.C. 2167, as amended; 42 U.S.C. 2201(I), as amended; and 42 U.S.C. 2282, as amended; 10 CFR 30.10, 40.10, 50.5, 60.11, 61.9b, 70.10, 72.12, and 110.7b.

Executive Order

Federal Regulation

Memorandum of Understanding/Agreement

Other (summarize and provide a copy of relevant

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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).

ARIES contains sensitive allegation, enforcement action, and investigation data involving actual or alleged criminal and civil/regulatory violations. ARIES may include witness and subject names and personal identifiers as well as personal background information with address and phone numbers. These systems may contain detailed information on current and completed allegations, enforcement actions, and investigations with pre-decisional information for enforcement actions.

If the project collects Social Security numbers, state why this is necessary and how it will be used.

ARIES does not collect SSNs, but they may appear in the investigative data.

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)

General Pubic who work at/for an NRC licensee - vendors, certificate holders, and/or applicants including contractors.

Licensees

Other

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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.

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

Sex (Male or Female)

Alien Registration Number

Ethnicity

Professional/personal references

Spouse Information

Criminal History

Personal e-mail address

Biometric identifiers (facial images, fingerprints, iris scans)

Personal Bank Account Number

Emergency contact e.g., a third party to contact in case of an emergency

Personal Mobile Number/Home Number

Accommodation/disabilities information

Marital Status

Children Information

Mother's Maiden Name

Other 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 initially provided in the form of a third-party contact in the form of emails, phone calls or in person contact regarding possible issues at facilities. Subsequent interviews will gather additional information regarding an Allegation, (e.g., personal information, additional witness information, facility information, etc.). Information may also be provided by an NRC licensed facility.

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

N/A.

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

Information is initially provided in the form of a third-party contact in the form of emails, phone calls or in person contact regarding possible issues at facilities. Subsequent interviews will gather additional information regarding an Allegation/investigation, (e.g., personal information, additional witness information, facility information, etc.). Information may also be provided by an NRC licensed facility.

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

The ARIES approach to data integrity, including accuracy, is multi-faceted and incorporates all the following elements:

There is no external portal or interface. The data are entered into ARIES by cleared NRC personnel.

We have worked with Stakeholders and User Groups to ensure that only data elements that deliver real business value are captured within the system. All extraneous data elements from the four legacy systems have not been incorporated into the future system.

All requests for additional data elements are scrutinized to ensure there are legitimate value propositions for inclusion.

Each data element incorporated in ARIES is assessed and categorized. This exercise includes:

o A determination on whether each element is mandatory or optional. If Optional, we perform an additional exercise to ensure relevance.

o A determination of field characteristics. This includes establishing attributes such as field length, field type, and field business logic. Every effort is made to tighten the parameters for each field to restrict what can be entered and improve the validity and accuracy of the value.

o The data element business logic will check across fields where associations exist. It will also automate the display of tier-two data elements that should only be presented based on the value selected on another related data element.

o An additional determination is made as to the potential for incorporating lookup tables and/or drop-down lists for each data element. This is done to further restrict what can be entered/selected and improve data integrity. A significant percentage of data elements captured within ARIES are tied to formal lookup tables with predetermined value sets.

We have invested significantly in the sharing of data elements across the domains of Allegations, Investigations, and Enforcement. Moreover, we have focused on the movement of data across records and phases to ensure that each data value entered will not require reentry at a later point in the lifecycle.

We have worked diligently to organize and group data elements in a manner that is logical to users. This gives much needed context for users and allows for quick population of multiple fields related to a single purpose.

We are incorporating alt text for almost every data element to ensure users

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have the ability to received additional context about the purpose and requirements for data population.

We will be developing data integrity report(s) that will track data entry patterns and raise awareness of issues related to the integrity of system data, including accuracy, completeness, and timeliness of data.

3.5 Will PII data be used in a test environment? If so, explain the rationale for this and how the PII information is protected.

No, PII will not be used in the test environment; however, production data from the legacy databases will be migrated in small data sets to both Dev and Test environments to facilitate development and testing. While a small subset of production data is needed to support testing by the team and product owners, the data is scrubbed for PII using migration scripts.

Stakeholders performing testing may also include additional dummy data to facilitate the testing process. Dummy data will not be migrated forward to Staging or Production following testing.

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

Information is initially provided in the form of a third-party contact in the form of emails, phone calls or in person contact regarding possible issues at facilities. Subsequent interviews will gather additional information regarding an Allegation/investigation, (e.g., personal information, additional witness information, facility information, etc.). Through later interactions the data can be updated by NRC personnel if necessary. Also, docketed information may be submitted by an NRC licensed facility.

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).

Internal NRC (program office enforcement specialists), Administrators, Badged Contractors.

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.

N/A.

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

NA.

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If so, 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.

Badged system administrators can access the data directly through the raw data tables in Dataverse. All other data access occurs exclusively through the ARIES application and is limited to cleared NRC personnel and contractors. This access is governed by a role-based access control (RBAC) model, ensuring users can only view or interact with data on a need-to-know basis. Access roles are defined according to business rules established by the Product Owners representing the core functional areas: Allegations, Investigations, Tracking and Enforcement.

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).

Data are encrypted at rest and in motion. Access to data from within ARIES is restricted to those with need to know via RBAC 4.6 Describe where the data is being stored (i.e., NRC, Cloud, Contractor Site).

Power Platform Dataverse.

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

ARIES is a cloud based internal system accessible via Intranet URL at the location where they work. The system employees Single Sign-On (SSO) and two factor authentication using PIV credentials and PIN to ensure secure access.

4.8 Can the project be accessed by a contractor? Have the contractors completed an IT-II investigation? Do they possess an NRC badge?

Yes, all team members are badged.

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

Auditing can be enabled for any table or field, capturing a complete change history including who made changes and whenfor any field with auditing turned on. To prevent data misuse, authorization-based permissions are applied to all users. These permissions restrict access to records unless the user is either the owner or has been explicitly granted access. For PII, field-level security provides an additional layer of protection: users must not only have access to the record itself but also be assigned a PII-specific security role in order to view sensitive data.

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

trace/track/observe) individuals.

No.

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 4.13 Provide the NRC system Enterprise Architecture (EA)/Inventory number. If unknown, contact EA Service Desk to get the EA/Inventory number.

BASS EA# is 20070047.

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Mark the appropriate response.

Response

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

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

Name, Organization, Date of Birth, Home or Cellular Number, Mailing Address, Professional Training, Social Security Number, Witness and Subject Names, Gender, Experience, Ethnicity, License Type, Education, Email Address, Biometric identifiers (Height, Weight, Hair Color, Eye Color, Scars, Tattoos, etc.), Title, Certifications

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

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

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):

NRC 23, Case Management System - Indices, Files, and Associated Records

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.

Allegations, Resolution, Investigation and Enforcement System (ARIES)

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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

Not Applicable

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

Voluntary, system allows for anonymous contact if desired. Information is initially provided in the form of a third-party contact in the form of emails, phone calls or in person contact regarding possible issues at facilities. Subsequent interviews will gather additional information regarding an Allegation, (e.g., personal information, additional witness information, facility information, etc.).

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

Allegations, Resolution, Investigation and Enforcement System (ARIES)

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If the project/system:

Does not have an approved records retention schedule and/or Does not have an automated RIM functionality, 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, or other locations where the same data resides)

ARIES See table below for Records Retention Schedules/ Dispositions for ARIES which is based on the former Case Management System Web (CMS-W).

Records Retention Schedule Number(s)

See table below Approved Disposition Instructions See table below Is there a current automated functionality or a manual process to support RIM requirements? This includes the ability to apply records retention and disposition policies in the system(s) to support records Manual

1. When files are uploaded to the system, they will always be associated with a single record in the system. Record types include Contact, Case, Allegation, Investigation, Enforcement,

Allegations, Resolution, Investigation and Enforcement System (ARIES)

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Alternative Dispute Resolution, Concern, Entity, and Action.

2. In order to upload a file, a user must first be granted permission to access and edit a respective record. Most users who are granted permissions to edit a respective record will only be permitted to upload and edit files but not delete them.
3. In order to delete a file, a user must be given elevated permissions to the associated record.

This permission will only be granted to a restricted number of users. (Elevated Roles include Admins, Supervisors, and Record Owners)

4. As authorized users will have the capability of deleting files, we intend to display a notification at the time of deletion informing users of NRCs retention policy and if it is appropriate to delete the respective document(s). Accompanying this notification, a user will be presented a secondary delete button requiring they confirm that the deletion of this file does not violate NRC policy.
5. As files are uploaded, they will be automatically tagged in accordance with the associated record they belong to.
6. Additionally, users will be given the opportunity to manually add metatags to assist them (and other users) with dispositioning.
7. Shortly after go-live, we intend to develop a report(s) to track the status of each record (and associated files), and notify users when milestones are reached requiring disposal. This report will serve as an interim means for supporting retention and disposal requirements.
8. After a series of priority enhancements are completed after go-live, we intend to develop a system component that will introduce semi-automated mechanisms supporting disposal.

Although the exact nature of this envisioned component is not yet designed, it will serve as a mechanism for monitoring all closed records,

Allegations, Resolution, Investigation and Enforcement System (ARIES)

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

ARIES will be assessed using the Records and Information (RIM) Certification process. The structured process will provide criteria aligned with the Suggested Rating to accurately reflect the system's ability to support records management requirements.

Disposition of Permanent Records 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)

ARIES will be assessed using the Records and Information (RIM) Certification process. The structured process will provide criteria aligned with the Suggested Rating to accurately reflect the system's ability to support records management requirements.

Schedule Number Schedule Title Disposition NUREG 0910-2.10.2(a)(1)

(page 2.10.5)

Enforcement Action Case Files. Significant Enforcement Actions Permanent. Cut off files when case is closed. Transfer to NARA with indexes when 20 years.

(Regions have the same retention)

NUREG 0910-2.10.2(b)(1)

(page 2.10.5)

Enforcement Action Case Files. All other Enforcement Actions and Violations Temporary. Cut off files when case is closed. Hold 2 years.

Destroy 10 years after enforcement actions are cut off.

(Regions have the same retention)

NUREG 0910- 2.16.1 (page 2.16.1)

Allegation and Inquiry Files Temporary. Hold closed allegation case files in office 2 years. Destroy 10 years after cases are closed.

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Investigation Case Files (Significant)

Permanent. Cut off files when case is closed. Hold in field 6 months then forward to HQ. Hold for 2 years, Transfer in 10-year blocks which will be transferred at 10-year intervals.

NUREG 0910-2.16.4.b (page 2.16.70)

Investigation Case Files (Other case files that do not meet the criteria for permanent retention)

Temporary. Temporary. Cut off files when case is closed. Hold in field office for 6 months then forwarded to HQ. Hold for 2 years.

Destroy 20 years after cases are closed.

NUREG 0910- 2.17.1 (page 2.17.1)

NUREG 0910- 2.18.1 (page 2.18.1)

Allegation Case Files Temporary. Cut off files upon final resolution of allegation.

Retain in office for 2 years or until no longer needed for current activities. Destroy 10 years after cutoff.

NUREG 0910- 2.18.1 (page 2.18.1)

Allegation Case Files Temporary. Cut off files upon final resolution of allegation.

Retain in office for 2 years or until no longer needed for current activities. Destroy 10 years after cutoff.

GRS 3.1 Item 011 System Development Records Temporary. Destroy 5 years after system is superseded by a new iteration, or is terminated, defunded, or no longer needed for agency/IT administrative purposes, but longer retention is authorized if required for business use.

GRS 5.2 item 020 Intermediary records This schedule is generally used to dispose of those records which are used to create a subsequent record, such as those manually input into a system.

Temporary. Destroy upon creation or update of the final record, or when no longer needed for business use, whichever is later.

Note: Information in Section 6, Records and Information Management-Retention and Disposal does not need to be fully resolved for final approval of the privacy impact assessment.

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Version 1.3 Privacy Impact Assessment 08/04/2025 PIA Template 2.5 (03-2025)-ML050460335 16 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 more 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, OMB approval is not required for information collections during a Federal criminal investigation or prosecution, during a civil action to which the United States is a party, or during the conduct of intelligence activities.

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?

OMB approval is not needed for information collections made:

During the conduct of a federal criminal investigation or prosecution, or during the disposition of a particular criminal matter.

During the conduct of a civil action to which the United States or any official or agency thereof is a party, or during the conduct of an administrative action, investigation, or audit involving an agency against specific individuals or entities.

However, the requirements of the Paperwork Reduction would apply during the conduct of general investigations or audits undertaken with reference to a category of individuals or entities such as a class of licensees or an entire industry.

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.

STOP HERE - The remaining pages will be completed by the Privacy Officer, Records Management, and Information Collections Team.

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Submitting Office: 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 Privacy Act does NOT apply, since information is NOT retrieved by a personal identifier.

Must be protected with restricted access to those with a valid need-to-know.

This project/system does contain PII; the Privacy Act does apply.

SORN is required-Information is retrieved by a personal identifier.

Comments:

Covered by NRC 23, Case Management System - Indices, Files, and Associated Records.

Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 09/24/25

Allegations, Resolution, Investigation and Enforcement System (ARIES)

Version 1.3 Privacy Impact Assessment 08/04/2025 PIA Template 2.5 (03-2025)-ML050460335 18 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.

Comments:

ARIES is not used to collect information directly from covered entities. Any collections of information that is used to populate ARIES and do not fall under the exception in 5 CFR 1320.4 may be subject to the requirements of the Paperwork Reduction Act.

Reviewers Name Title Agency Clearance Officer Signed by Cullison, David on 08/25/25

Allegations, Resolution, Investigation and Enforcement System (ARIES)

Version 1.3 Privacy Impact Assessment 08/04/2025 PIA Template 2.5 (03-2025)-ML050460335 19 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 Sr. Program Analyst, Electronic Records Manager Records and Information Management Specialist Signed by Dove, Marna on 09/11/25 Signed by Williams, Lisa on 09/04/25

Allegations, Resolution, Investigation and Enforcement System (ARIES)

Version 1.3 Privacy Impact Assessment 08/04/2025 PIA Template 2.5 (03-2025)-ML050460335 20 11 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.

Director Chief Information Security Officer Cyber Information Security Division Office of the Chief Information Officer Signed by Nalabandian, Garo on 11/25/25

Allegations, Resolution, Investigation and Enforcement System (ARIES)

Version 1.3 Privacy Impact Assessment 08/04/2025 PIA Template 2.5 (03-2025)-ML050460335 21 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:

Allegations, Resolution, Investigation and Enforcement System (ARIES)

Date CISD received PIA for review:

August 6, 2025 Date CISD completed PIA review:

September 16, 2025 Action Items/Concerns: