U.S. NUCLEAR REGULATORY COMMISSION

 PLAN TO ELIMINATE THE UNNECESSARY COLLECTION AND

USE OF SOCIAL SECURITY NUMBERS

INTRODUCTION

In response to the Office of Management and Budget (OMB) May 22, 2007,

memorandum (M-07-16), “Safeguarding Against and Responding to the Breach of Personally

Identifiable Information,” the U.S. Nuclear Regulatory Commission (NRC) has established a

plan in which the agency will eliminate the unnecessary collection and use of the Social Security

number (SSN) by November 22, 2008, in compliance with OMB’s eighteen month time frame.

The NRC’s mission is to license and regulate the Nation's civilian use of byproduct,

source, and special nuclear materials to ensure adequate protection of public health and safety,

promote the common defense and security, and protect the environment. The NRC is not an

agency whose primary purpose is to collect and maintain information about individuals. Of the

personally identifiable information (PII) that NRC does collect and use, a significant majority

relates to its personnel (employees and contractors).

The NRC has initiated improvements related to the protection of PII. These

improvements are based on the NRC’s Office of the Inspector General (OIG) June 30, 2006,

Audit (OIG-06-A-14), “Evaluation of Personal Privacy Information Found on NRC Network

Drives”, OMB’s June 23, 2006, memorandum (M-06-16), "Protection of Sensitive Agency

Information," and NRC Chairman Dale E. Klein’s July 26, 2006, memorandum, "Protection of

Personal Privacy Information." The increase in recent reporting of stolen/missing laptop

computers containing PII at various Government agencies was an additional incentive for

improving the NRC’s protection of PII.

In response to the OIG audit, which found PII on agency-shared network drives, the

NRC’s Office of the Executive Director for Operations directed agency staff to review data

generated or stored on the shared network drives for PII. As of April 18, 2007, the searches of

the shared network drives were completed and all PII that was identified was either removed

from the shared drives or access to the PII was restricted to individuals with a need-to-know. 

Agency staff have been instructed not to place PII on shared network drives unless access to

this information is restricted to individuals with a need-to-know. NRC has also developed

policies and procedures that include periodic (annual) reviews of agency network drives for the

presence of PII.

In an effort to identify how PII is used in the NRC and to develop policies and

procedures to protect PII, the NRC’s Senior Agency Official for Privacy established a task force

on September 29, 2006. The objectives of the task force, which consists of representatives

from each of the NRC program and support offices at its Headquarters and Regional locations,

are to identify current data sources containing PII, review the use of the SSN and other PII to

reduce its collection and storage, recommend modifications to business processes and

operations to protect PII, and increase staff awareness of PII issues, policies, and procedures.
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IDENTIFYING THE COLLECTION AND USE OF THE SSN

The NRC has identified the collections and uses of the SSN through multiple actions. 

The PII task force began its efforts in October 2006, coordinating with each of the agency’s

program and support offices, compiling details of the types of PII used throughout the agency,

the data sources that contain PII, the forms the agency uses that collect PII, the uses and

dissemination of PII, and the methods used to store and safeguard PII. In January 2007, the

NRC prepared its response to OMB’s December 5, 2006, request for Federal agencies to

complete a matrix identifying their processes where the SSN is used and collected. In May

2007, to assist in developing the agency plan to eliminate the unnecessary uses and collection

of the SSN, the PII task force began analyzing the information compiled on the agency’s PII use

and collection to determine how and where specific uses and collections of the SSN could be

reduced or eliminated.

ELIMINATING THE UNNECESSARY COLLECTION OF THE SSN

The NRC is in the process of reviewing all agency forms in an effort to reduce or

eliminate where possible the unnecessary collection of PII. Currently, the NRC maintains 425

forms in its inventory. As of August 3, 2007, the NRC determined that 68 of the 425 forms

collect PII. Of the 68 forms that collect PII, 42 have been identified as collecting the SSN.

To address the unnecessary collection of the SSN as required in OMB M-07-16, the

NRC began its review of all agency forms by first focusing on the 42 forms that collect the SSN. 

Each form is being reviewed in coordination with the owner of the form (sponsoring office) to

determine if the collection of PII, including the SSN, is necessary. If the collection of all or part

of the PII is determined to be necessary, the requirement to collect the PII, especially the SSN,

will be identified along with any process that will be modified to either reduce or visually mask

access. Although the collection of the SSN may be considered a required collection, the SSN

will be replaced when agencies are instructed to do so, with the Office of Personnel

Management (OPM) proposed unique employee identification number (UEID). If the NRC

determines that the collection of part or all of the PII is unnecessary, a decision will be made to

discontinue the collection or, in the case of the SSN, replace it with another unique identifier. 

The NRC plans to complete the review of the 42 forms that collect the SSN, including

incorporating all identified revisions, by November 30, 2007. The NRC expects to complete the

review of the remaining 26 forms identified as collecting PII, but do not collect the SSN, by

January 31, 2008. The NRC’s forms review process will be an ongoing effort to ensure that all

agency forms, current or proposed, that collect not only the SSN, but any PII, are reviewed to

prevent, reduce, or eliminate any unnecessary collections.

The majority of NRC forms that collect the SSN are owned by the NRC’s Office of

Human Resources, Office of the Chief Financial Officer (OCFO), and Office of Administration

(ADM) and are used for personnel, payroll/accounting, and security purposes. The NRC’s

elimination of the SSN or replacement of the SSN on these forms with the proposed OPM UEID

or other acceptable unique identifier can only be implemented based on guidance received from

the Federal agency requiring the collection (i.e. OPM, Internal Revenue Service (IRS), Federal

Bureau of Investigation (FBI), etc). The NRC will convert from the use of the SSN to the use of

the OPM UEID consistent with OPM and OMB guidance when such guidance is issued.
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ELIMINATING THE UNNECESSARY USES OF THE SSN

The majority of the NRC’s SSN uses are based on requirements placed upon the NRC

by other Federal agencies, for example the OPM’s requirement to use the SSN as a unique

identifier for maintaining official federal personnel records and the IRS’ requirement to use the

SSN as a unique identifier for reporting payroll earnings. Any action to eliminate an externally

driven required use will depend on guidance issued to NRC by that external entity. Therefore,

NRC’s review to eliminate unnecessary SSN uses focuses on internally driven uses.

The NRC’s review has identified a use of the SSN that is considered to be unnecessary

and will be eliminated. This is the use of the SSN to verify an employee’s identity for tracking

dosimeters used to measure exposure to radiation. The employee identification number will

replace the SSN in the ADM’s Dosimeter Tracking System for all existing and newly created

records. Employees will show their badge to verify their identity when they pick up and return a

dosimeter, but the bar code on their badge will no longer be scanned to collect the SSN. This

change will require a modification to the Dosimeter Tracking System which will be completed by

October 30, 2007.

The NRC’s review has also identified uses that, although necessary, involve processes

that can be modified to reduce access to the SSN. Below are the processes that have been

identified where access to PII, including the SSN, is being reduced.

One area the NRC has identified where access to and use of the SSN can be reduced is

within an organization’s administrative office files. Each program office maintains administrative

files on its employees, which include copies of travel, training, personnel, time and attendance,

and payroll records for administrative purposes. The Privacy Act systems of records managers

will be instructed to provide specific guidance to the custodians of these files by early January

2008, stating exactly what documents they are authorized to maintain copies of and how long

the copies should be retained. The system managers will then require confirmation from the

custodians by March 31, 2008, that the review of the administrative files for compliance with the

recordkeeping requirements has been completed. This recordkeeping guidance will then

become part of a system manager’s annual reminder to custodians of Privacy Act records on

the procedures, guidelines, and safeguards applicable to a system of records, and of the

responsibilities involved in protecting the records from unauthorized access. 

The NRC is also working on a project to identify all of its procurements for acquisition of

supplies and services (contract/simplified acquisitions) that receive, process, or maintain PII. 

To identify these procurements, the Statement of Work for each active contract/simplified

acquisition will be reviewed by the assigned project officer to determine if receiving, processing,

or maintaining PII is stated under the terms of the contract/simplified acquisition. The NRC

intends to have these procurements identified by November 30, 2007. Once identified, all

holdings will be reviewed to determine if the PII being received, processed, or maintained is

necessary, and if it is being handled in a manner to ensure security and integrity. This project

will be completed by November 22, 2008.

Although still considered to be a necessary use of PII, the NRC’s OCFO identified a

process to reduce access to the SSN and all PII by limiting its visibility in the agency’s Federal

Financial System (FFS). The OCFO created, tested, and loaded a new vendor table that
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masks all PII. Only system users requiring full access to PII as a requirement of their official

duties will be authorized to access the unmasked vendor table or any other tables containing

PII. All FFS user access profiles have been reviewed and revised as needed to ensure access

to PII is limited to those with a need-to-know. This system update was completed on June 6,

2007.

After performing a review to identify instances where the SSN is used, the NRC’s

Region IV staff determined that the use of the SSN in the Region IV Travel database was

unnecessary and could be eliminated. In order to immediately eliminate use of the SSN and at

the same time to minimize changes to the database, the system was modified to record the

SSN for each traveler to a common number of 000-00-0000, no longer allowing the SSN to be

included in the database. This change was implemented on August 1, 2007.

COMPLETION

The elimination of the collections and uses of the SSN that the NRC has determined to

be unnecessary will be completed by November 22, 2008, as required by OMB M-07-16. 

Where the collection and use of the SSN is considered to be necessary based on requirements

placed upon the NRC by outside sources, the completion of any further actions involving its

elimination or replacement will depend on the guidance and schedules issued to all Federal

agencies by those sources.
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masks all PII. Only system users requiring full access to PII as a requirement of their official

duties will be authorized to access the unmasked vendor table or any other tables containing

PII. All FFS user access profiles have been reviewed and revised as needed to ensure access

to PII is limited to those with a need-to-know. This system update was completed on June 6,

2007.

After performing a review to identify instances where the SSN is used, the NRC’s

Region IV staff determined that the use of the SSN in the Region IV Travel database was

unnecessary and could be eliminated. In order to immediately eliminate use of the SSN and at

the same time to minimize changes to the database, the system was modified to record the

SSN for each traveler to a common number of 000-00-0000, no longer allowing the SSN to be

included in the database. This change was implemented on August 1, 2007.

COMPLETION

The elimination of the collections and uses of the SSN that the NRC has determined to

be unnecessary will be completed by November 22, 2008, as required by OMB M-07-16. 

Where the collection and use of the SSN is considered to be necessary based on requirements

placed upon the NRC by outside sources, the completion of any further actions involving its

elimination or replacement will depend on the guidance and schedules issued to all Federal

agencies by those sources.

ADAMS Package No.: ML072140160

ADAMS Accession No: ML072270611

ADAMS Document Title: NRC Plan to Eliminate the Unnecessary Collection and Use of Social Security Numbers

Publicly Available Non-Sensitive

*E-mail concurrence

OFFICE OIS/FOIA-PA OIS/FOIA-PA Tech Editor OIS/RFPSB OIS/IRSD

NAME SSNorthern: SSN RANichols: RAN LACulp: LAC* MAJanney: MAJ JJLinehan: JJL

DATE 8/13/07 9/12/07 8/14/07 9/12/07 9/12/07

OFFICE OGC ADM OCFO HR DD/OIS

NAME JLSzabo: JLS* TFHagan: SJB* for RRRough: RRR* MEBeach: MEB* KOGreene:

KOG

DATE 8/15/07 9/12/07 9/11/07 9/11/07 9/12/07

OFFICE D/OIS DEDIS/CIO EDO

NAME ETBaker: ETB DBAsh W. Kane for: WFK

LAReyes

DATE 9/12 /07 9/19/07 9/19/07

OFFICIAL RECORD COPY