ML26005A163

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Privacy Threshold Analysis Docketscope
ML26005A163
Person / Time
Issue date: 01/28/2026
From:
Office of Nuclear Material Safety and Safeguards, NRC/OCIO/CISD
To:
Butler J
References
Download: ML26005A163 (0)


Text

U.S. Nuclear Regulatory Commission Privacy Threshold Analysis DocketScope Office of Nuclear Material Safety and Safeguards (NMSS)/

Office of the Chief Information Officer (OCIO)

Version 1.0 12/04/2025 Template Version 2.6 (09/2025)-ML091970114

DocketScope Version 1.0 Privacy Threshold Analysis 12/04/2025 Document Revision History Date Version PTA Name/Description Author 12/04/2025 1.0 DocketScope Final Release - PTA was recently approved under ITI boundary-Moved to TPS Boundary, transferred to the latest template and updated POC list NMSS/OCIO Oasis Systems, LLC 11/18/2025 DRAFT DocketScope Draft Release - PTA was recently approved under ITI boundary-Moved to TPS Boundary, transferred to the latest template and updated POC list NMSS/OCIO Oasis Systems, LLC

DocketScope Version 1.0 Privacy Threshold Analysis 12/04/2025 Table of Contents 1

Description 1

2 Characterization of the Information 4

3 Records and Information Management-Retention and Disposal 7

4 Privacy Act Determination 11

DocketScope Version 1.0 Privacy Threshold Analysis 12/04/2025 PTA Template (09/2025)-ML091970114 1

System/Project Name: DocketScope.

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

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

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.

DocketScope (https://www.docketscope.com/) is a web-based platform that the U.S. Nuclear Regulatory Commission (NRC) Division of Rulemaking, Environmental, and Financial Support procured in order to assist with the review and analysis of public comments on rulemaking documents published in the Federal Register.

DocketScope is used by the Office of Nuclear Material Safety and Safeguards (NMSS) office and operates within the Office of the Chief Information Officer (OCIO) TPS boundary at the NRC. Comments are submitted by members of the public to the Federal Docket Management System (FDMS) (and its public-facing analog, Regulations.gov). Before submitting a comment, all commenters are requested not to include personally identifiable information (PII) in their comment and informed that their comment will be made public on Regulations.gov. The NRC reviews submitted comments for three main purposes:

Detecting duplicate comments (i.e., comments that contain identical or nearly identical text, commonly seen in form letter submissions);

Labeling comments by issue area; and Detecting sensitive unclassified non-safeguards information included within the comments.

These functions are required for the NRC to be able to post comments to Regulations.gov for public viewing, to review the comments, and to begin the process of drafting final regulations.

The NRC uses DocketScope to review and label comments by issue area only, and not for the drafting process of the final rule.

The NRC requests access to the public comments from FDMS. After access has been provided, DocketScope downloads the public comments from Regulations.gov, which NRC users review through DocketScopes website. DocketScope groups comments together as duplicates or near duplicates by detecting similarities between comments, and NRC users would view these groups as a redline comparison to show differences between comments to expedite their review. The ability to review duplicate documents in groups facilitates compliance with the requirements of the Administrative Procedure Act, which requires that final regulations respond to all substantive issues raised in public comments on proposed regulations.

DocketScope Version 1.0 Privacy Threshold Analysis 12/04/2025 PTA Template (09/2025)-ML091970114 2

All comments are also labeled by issue area. Once comments are labeled by issue area, the text of the comments are compiled into reports for each issue area, which NRC users will request and download from DocketScope. These reports will be used by the NRC to draft summaries of the comments relevant to a particular issue area for the preamble to the final regulations. The summarization of the comments does not occur within DocketScope. The NRC only uses DocketScope to review and label comments by issue area, and not for the drafting process for the final regulations.

Once the final rule has been drafted, comments will be retained internally within the NRC in accordance with the Records Retention schedule. While providing the service to the NRC, DocketScope may have access to data as part of the administration for the system.

Please indicate if your project/system will involve the following:

PowerApps Server/Database Design Dashboard Public Website SharePoint Internal Website Cloud Service Provider Artificial Intelligence (AI)

External Sharing Other 1.2 Does this PTA 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 PTA and describe the modifications made.

Annual Review - Briefly describe the changes that were made

Other (explain)

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1.3 Points of

Contact:

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

Daniel Doyle Nuclear Material Safety and Safeguards(NMSS) /

Rulemaking, Environmental, and Financial Support (REFS) 301-415-3748 System Owner/Data Owner or Steward Andrea Kock Nuclear Material Safety and Safeguards(NMSS) 610-337-5299 ISSM Jonathan Butler Office of the Chief Information Officer (OCIO) / Cyber and Infrastructure Security Division (CISD) / Information Assurance and Oversight Branch (IAOB) 301-415-2560 Executive Sponsor Jake Zimmerman Nuclear Material Safety and Safeguards Nuclear Material Safety and Safeguards(NMSS)

/ Rulemaking, Environmental, and Financial Support (REFS) 610-337-5318 Other 1.4 Does the project involve Artificial Intelligence (AI), if yes, please complete the table below:

No, this project does not involve Artificial Intelligence (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)?

Data Inputs Does the AI use (PII) or sensitive data?

Yes No Does the AI use other data sources?

List the types of data used and how data quality/accuracy is ensured.

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Questions Explanation (if Yes/Applicable)

Publicly available data Third-party data Internal agency data 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.

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).

2 Characterization of the Information Does this project collect, process, or retain information on: (Check all that apply)

Category of individual

NRC Federal employees

Other Federal employees

Contractors working on behalf of NRC

Members of the Public (non-licensee workers, applicants before they are licenses etc.)

Project/system does not collect any personally identifiable information

Other

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2.1 Please list the data fields/information being collected in the system. For example (name, billing/financial information, conference registration information, medical information, education information, license numbers, business information, contact information, etc.)

Note: Response is required-not applicable is not an option.

Although the NRC does not request this information, the public comments may include the following: personal email address, home address, and personal mobile or home phone number.

2.2 Is the project/system collecting information about an individual? If yes, provide a description of the information being collected.

No, DocketScope organizes the public comments submitted to Regulations.gov. DocketScope itself does not collect any data from individuals.

2.3 Does this project use or collect Social Security Numbers (SSNs)? (This includes truncated SSNs, such as the last four.)

No.

2.4 Describe how the data is collected for the project. For example, is the data gathered through NRC forms, surveys, questionnaires, existing NRC files or databases, or electronic responses).

Public comments are submitted via Regulations.gov (https://www.regulations.gov/).

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

Public comments are submitted via Regulations.gov (https://www.regulations.gov/).

2.6 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.

No, DocketScope does not share information with other NRC systems.

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

No.

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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 2.8 Describe how the data is accessed (NRC network/remotely) and the access control mechanisms that prevent misuse.

The data is accessed through a web browser.

2.9 Define the FISMA boundary this project/system is part of.

DocketScope is a subsystem of TPS.

2.10 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)

CISO Short Term Authorization until 7/31/2026 ML25261A353 Confidentiality-Low Integrity-Low Availability-Low

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

The TPS EA Number is 20180002.

3 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 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.

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

3.1 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 3.2 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)

DocketScope Not owned by NRC.

Comments (with labels) from DocketScope are not put into ADAMS but are used for the Rulemaking cases. Can be considered working files - see input source records which are Intermediary Records in GRS 5-2 020.

Regulations.gov Not owned by NRC. These are going into:

ADAMS Public comments on NRC rulemaking activities are stored in ADAMS, and the NRCs final rule documents including responses to comments are also stored in ADAMS.

DocketScope generates reports, but those reports are not stored in ADAMS. DocketScope reports are used internally by the NRC staff for efficiency and convenience to see which portions of comments are related to each issue area in the final rule.

The schedule numbers and disposition instructions below are for the public comments stored in ADAMS.

Records Retention Schedule Number(s)

Working Files: GRS 5.2 item 020:

Intermediary Records Regulatory History Files for Proposed and Final Rulemaking:

N1-431-00-4 Item 6.a(4)

(see page 2.1.20 in NUREG-0910)

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Rulemaking Docket Files:

N1-431-01-2 Item 6.d (see page 2.22.21 in NUREG-0910)

Approved Disposition Instructions Intermediary Records:

GRS 5.2 item 020: Intermediary Records.

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

Regulatory History Files for Proposed and Final Rulemaking:

N1-431-00-4 Item 6.a(4):

Permanent.

Cut off electronic files when regulation is issued through notice in the Federal Register. Transfer to the National Archives 2 years after cut off. At the time of transfer, NARA and NRC will determine medium and format in which records will be transferred as well as their arrangement. Every effort will be made to transfer records electronically in accordance with the standards for permanent electronic records contained in 36 CFR 1228.270 or standards applicable at the time. If transfer in an electronic medium is not feasible, prior to transfer, with NARA concurrence, records will be converted to paper or to microform. Destroy NRC copy 8 years after transferring record to NARA.

Rulemaking Docket Files N1-431-01-2 Item 6.d: Temporary. Cut off electronic files after the completion (through adoption or withdrawal) or rulemaking proceedings noticed in the Federal Register. Destroy 10 years after cutoff.

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.

Manual automation TBD DocketScope is not owned by NRC.

Regulations.gov not owned by NRC.

DocketScope 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.

DocketScope Version 1.0 Privacy Threshold Analysis 12/04/2025 PTA Template (09/2025)-ML091970114 10 Disposition of Temporary Records Will the records/data or a composite be automatically or manually deleted once they reach their approved retention?

Manual (automation TBD)

DocketScope 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)

Yes. Hard drive or FTP submittal or CD submittal.

DocketScope 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.

DocketScope Version 1.0 Privacy Threshold Analysis 12/04/2025 PTA Template (09/2025)-ML091970114 11 4 Privacy Act Determination Review Results Action Items

This project/system does not contain PII.

No further action is necessary for Privacy.

This project/system does contain PII A privacy impact assessment is required

Other See comments section below for further details.

Comments:

Reviewers Name Title Privacy Officer I concur with this analysis.

Director Chief Information Security Officer Cyber Information Security Division Office of the Chief Information Officer Signed by Hardy, Sally on 01/28/26 Signed by Nalabandian, Garo on 01/28/26