ML25343A276
| ML25343A276 | |
| Person / Time | |
|---|---|
| Issue date: | 01/29/2026 |
| From: | Carol Greenwood Office of Administration |
| To: | |
| Jarrell B | |
| References | |
| Download: ML25343A276 (0) | |
Text
U.S. Nuclear Regulatory Commission Privacy Impact Assessment (PIA)
Transit Subsidy Program Office of Administration (ADM)
Version 1.0 12/2/2025 Template Version 2.7 (09/2025)
Transit Subsidy Program Version 1.0 Privacy Impact Assessment 12/2/2025 Document Revision History Date Version PIA Name/Description Author 12/2/2025 1.0 Initial Release Carol Greenwood
Transit Subsidy Program Version 1.0 Privacy Impact Assessment 12/2/2025 Table of Contents 1
Description 1
2 Authorities and Other Requirements 4
3 Characterization of the Information 5
4 Data Security 6
5 Privacy Act Determination 9
6 Records and Information Management-Retention and Disposal 10 7
Paperwork Reduction Act 12 8
Privacy Act Determination 14 9
OMB Clearance Determination 15 10 Records Retention and Disposal Schedule Determination 16 11 Review and Concurrence 17
Transit Subsidy Program Version 1.0 Privacy Impact Assessment 12/2/2025 PIA Template (09-2025)-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: NRC Transit Subsidy Program.
Data Storage Location (i.e., Database Server, SharePoint, Cloud, Other Government Agency, Power Platform) Tracking spreadsheet is kept in a folder on the ADM shared drive under DFS/FLB/Parking and Subsidy; it is password protected, and 2 ADM staff have access.
Date Submitted for review/approval: December 2, 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 Describe the project, including the system, subsystem, technology (e.g., Microsoft products), program, or other data collection involved. Explain why this project is being developed and its intended purpose.
The transit subsidy program stems from federal law (the Federal Workforce Transportation Act /
previously the Federal Employees Clean Air Incentives Act) and a presidential directive (Executive Order 13150) to encourage federal employees to use mass transportation for their daily commute to and from work and to offset actual commuting costs.
The NRC Transit Subsidy Benefits program covers either Washington Metropolitan Area Transit Authority (WMATA) SmartBenefits, CommuteDirect, and/or other options, described in Nuclepedia at:
https://nuclepedia.usalearning.gov/index.php/Commuter_and_transportation_services#NRC_Tr ansit_Subsidy_Benefits_Program 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 NRC submits the application to WMATA for enrollment using the information from form 546.
NRC maintains a spreadsheet for tracking status on the NRC G drive. All NRC forms 546 are maintained in the transit subsidy resource mailbox and are deleted when the employee has provided an updated form or left the agency.
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1.2 Does this PIA pertain to a proposed new project, a planned modification to an existing project, or another type of situation?
Select options that are best applied in table below.
Status Options
New system/project
A change or update to an existing system or project that occurs outside of its scheduled annual review.
Provide the ADAMS ML of the existing PIA and describe the modifications made.
Annual Review - Briefly describe the changes that were made:
Other (explain) This subsidy program has been used for years at the NRC, but a PIA was never created.
1.3 Points of
Contact:
Role Contact Information Name Office/Division/Branch Phone Number Project Manager(s)
Carol Greenwood, ADM 301-415-1980 System Owner/Data Owner or Steward Eleni Jernell (acting Director) ADM 301-415-8725 ISSM Brenden Jarrell, OCIO 301-415-4074 Zanira Khan, OCIO 301-415-5248 Executive Sponsor Eleni Jernell (acting Director) ADM 301-415-8725 Other
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1.4 Does the project involve Artificial Intelligence (AI), if yes, please complete the table below:
No, the project does not involve AI.
Questions Explanation (if Yes/Applicable)
AI Model and Purpose What type of AI model is being used?
Large Language Model (LLM)
Generative AI Predictive/Analytical Model Other (specify)
Describe the purpose and function of the AI component. What specific role does it play (e.g., decision-making, recommendations, anomaly detection, document review, predictive modeling)?
N/A Data Inputs Does the AI use (PII) or sensitive data?
Yes No Does the AI use other data sources?
Publicly available data Third-party data Internal agency data List the types of data used and how data quality/accuracy is ensured.
N/A Outputs and Impact Does the AI generate outputs that affect individuals or operations?
Yes No If yes, describe the outputs (decisions, recommendations, predictions) and whether a process exists for human review or appeal.
N/A Risk Management Are safeguards in place to address risks (bias, inaccuracy, misuse, security)?
Yes No Is the AI model web-grounded (connected to the internet for real-time or periodic updates)?
Yes No Describe safeguards, monitoring, and controls in place to mitigate risks, including how web access is managed (if applicable).
N/A
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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 X on all that apply.
Authority Citation/Reference
Statute 5 U.S.C. 7905; 26 U.S.C. 132; 31 U.S.C.
3511; 41 CFR 102-74.210; 41 CFR Subtitle F; 41CFR 102-71.20
Executive Order Executive Order (E.O.) 9397, as amended by E.O. 13478; E.O. 13150.
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).
The information is used to enroll NRC employees in a transit subsidy program to provide subsidy payment through WMATA services. NRC employees need to complete NRC Form 546, Transit-Subsidy Benefits Program Application available in the NRC Forms Library.
2.2a If the project collects Social Security numbers, state why this is necessary and how it will be used.
SSNs are not collected.
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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 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
Education Information (i.e.,
Graduation Year, Test Scores)
Other
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3.1 Explain how the project collects its data. For example, is the data gathered through NRC forms, surveys, questionnaires, existing NRC files or databases, or responses to background checks?
Information is gathered by an NRC Form 546.
NRC employees need to complete NRC Form 546, Transit-Subsidy Benefits Program Application available in the NRC Forms Library.
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.
3.3 Who provides the information? Is it provided directly from the individual or a third party.
The individual completes and signs the form, which is then signed by their supervisor, then it is submitted to the subsidy benefits resource email inbox which is monitored by ADM/DFS staff.
3.4 Explain how the accuracy of the data collection is validated. If the project does not check for accuracy, please explain why.
The ADM/DFS staff validate the data/costs and contact the individual for any needed clarification.
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 test environment.
3.6 What procedures are in place to allow the subject individual to correct inaccurate or erroneous privacy information?
If there needs to be a correction, the employee can email the subsidy benefits resource email for any changes. If the employee moves they must complete a new NRC For 546 to calculate new computer costs.
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).
Currently there are two NRC ADM/DFS employees that monitor the subsidy benefit resource email and can make adjustments/corrections as needed.
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4.2 If this project or system shares information with other NRC systems, please identify:
- 1) the system(s) it shares data with, 2) the type of information shared, and 3) the method of sharing. Indicate whether Application Programming Interfaces (APIs) or other interconnectionssuch as direct database connections, file transfers, or web services are used.
There is no data sharing with other NRC systems.
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 If so, identify what agreements are in place with the external non-NRC partner or system in the table below.
Agreement Type
Contract 31310024C0013
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.
The Transit Subsidy Application (NRC Form 546) is transmitted via NRC email to the subsidy benefit resource email box where it is opened by ADM/DFS staff (2). The information is then used to enroll them into the transit subsidy program.
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).
NRC email is encrypted/protected by the Information Technology Infrastructure (ITI) system.
4.6 Describe where the data is being stored (e.g., NRC servers, cloud services, contractor sites, local desktops, network drives, SharePoint libraries, external databases, or other storage systems).
The forms and emails are in the NRC resource inbox.
4.7 Describe whether the project or system can be accessed or operated from multiple locations (e.g., Regional Offices, contractor sites) and explain how access is provided.
Since the Transit Subsidy Application (NRC Form 546) is transmitted via NRC email to the subsidy benefit resource email box, it can be operated in the regional offices.
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4.8 Is the project or system accessible by a contractor?
No. Contractors do not have access to the subsidy benefit resource email.
If yes, please indicate which of the following applies:
NRC IT II Investigation completed
Other Federal Background Investigation completed
Issued an NRC Badge
No background investigation conducted
Other 4.9 Explain the auditing measures and technical safeguards in place to prevent misuse of data.
The transit subsidy program relies on the NRC network administrators to provide technical safeguards.
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.
ITI.
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
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4.13 Provide the NRC system Enterprise Architecture (EA)/Inventory number. If unknown, contact EA Service Desk to get the EA/Inventory number.
ITI EA#-20090005.
5 Privacy Act Determination 5.1 Is the data collected retrieved using a personal identifier?
Mark the appropriate response.
Response
Yes - The information is retrieved using a personal identifier (e.g., individuals name, address, Social Security Number, employee ID, or other unique number).
List the identifiers that will be used to retrieve information on the individual.
Information is retrieved by the persons name
No - The PII is not retrieved by a personal identifier (e.g., Date of visit or service, Machine or equipment ID, Project or task ID)
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 SORN 26-Transit Subsidy Benefits Program 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.
Transit Subsidy Program Version 1.0 Privacy Impact Assessment 12/2/2025 PIA Template (09-2025)-ML050460335 10 5.3 When an individual is asked to provide personal data (e.g., via a form, webpage, or survey), is a Privacy Act Statement (PAS) provided?
A Privacy Act Statement is a disclosure that must appear on any document used by the agency to collect personal data that will be maintained in a system of records. This includes paper forms, electronic forms, surveys, or other documents.
Please mark the appropriate response:
Options
Privacy Act Statement The Privacy Act Statement is available/linked on NRC Form 546
Not Applicable
Unknown 5.4 Is providing the PII mandatory or voluntary? Explain the consequences for the individual if they choose not to provide the information (e.g., inability to receive services, delay in processing, or no impact).
The PII is mandatory if they want to receive the subsidy benefit.
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.
Transit Subsidy Program Version 1.0 Privacy Impact Assessment 12/2/2025 PIA Template (09-2025)-ML050460335 11 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)
Transit Subsidy Program Records Retention Schedule Number(s)
GRS 2.4, Item 130: Transportation subsidy program administrative record GRS 2.4, Item 131: Transportation subsidy program individual case files.
Approved Disposition Instructions GRS 2.4, Item 130: Temporary. Destroy when 3 years old, but longer retention is authorized if required for business use GRS 2.4, Item 131: Temporary. Destroy 2 years after employee participation concludes, but longer retention is authorized if required for business use.
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 accessibility, reliability, integrity, and disposition.
Transit Subsidy Program 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 Temporary Records Transit Subsidy Program will be assessed using the Records and Information (RIM) Certification
Transit Subsidy Program Version 1.0 Privacy Impact Assessment 12/2/2025 PIA Template (09-2025)-ML050460335 12 Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?
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)
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.
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?
No.
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?
No.
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.
Transit Subsidy Program Version 1.0 Privacy Impact Assessment 12/2/2025 PIA Template (09-2025)-ML050460335 13 STOP HERE - The remaining pages will be completed by the Privacy Officer, Records Management, and Information Collections Team.
Transit Subsidy Program Version 1.0 Privacy Impact Assessment 12/2/2025 PIA Template (09-2025)-ML050460335 14 8 Privacy Act Determination Project/System Name: Transit Subsidy Program Submitting Office: ADM 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:
This information is covered under NRC SORN 26-Transit Subsidy Benefits Program Records.
Reviewers Name Title Privacy Officer Signed by Hardy, Sally on 01/28/26
Transit Subsidy Program Version 1.0 Privacy Impact Assessment 12/2/2025 PIA Template (09-2025)-ML050460335 15 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:
The information collected from Federal employees meets the exemption from the requirements of the Paperwork Reduction Act in 5 CFR 1320.3(c)(4).
Reviewers Name Title Agency Clearance Officer Signed by Cullison, David on 12/12/25
Transit Subsidy Program Version 1.0 Privacy Impact Assessment 12/2/2025 PIA Template (09-2025)-ML050460335 16 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 01/26/26 Signed by Williams, Lisa on 01/15/26
Transit Subsidy Program Version 1.0 Privacy Impact Assessment 12/2/2025 PIA Template (09-2025)-ML050460335 17 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 01/29/26
Transit Subsidy Program Version 1.0 Privacy Impact Assessment 12/2/2025 PIA Template (09-2025)-ML050460335 18 ADDITIONAL ACTION ITEMS/CONCERNS Name of Project/System:
Transit Subsidy Program Date CISD received PIA for review:
December 8, 2025 Date CISD completed PIA review:
January 28, 2026 Action Items/Concerns: