RE: Conundrum

["LANNI, MARC" <MLANNI@entergy.com>]

	To all that are pondering the practices of releasing
records to other facilities..I suggest reading the 
ANSI/HPS N13.6 released in 1999. Although not a 
regulatory requirement, it is the guideline that
both states and the NRC use to look at programs.
The standard has been around for a long time, and
has just recently been revised, however section 4.2
has not changed much with the exception of adding
the requirements that "The transmitting facility 
operator should only release the information with
the subject individual's written authorization."
10CFR19.13 requires "at the request of a worker" 
the licensee will provide records to the "worker"
The final statement we are guided by is the
10CFR20.2106 privacy protection section that
basically defers to the state's privacy laws.

Just my thoughts

   Marc

> Marc Lanni  <mailto: mlanni@entergy.com>
> Grand Gulf Nuclear Station - Health Physicist
> Entergy Operations
> mlanni@entergy.com
> Office:	(601) 437-6572
> Fax:         (601) 437-6573 
> Pager:	(601) 930-8904
> 


-----Original Message-----
From: Sandy Perle [mailto:sandyfl@earthlink.net]
Sent: Tuesday, April 25, 2000 5:21 PM
To: Multiple recipients of list
Subject: Re: Conundrum


> if you have subcontractors on
> your site their employer is entitled (and most likely, required) to know
> what doses they are receiving because they are ultimately responsible. 

Liz,

While I am not sure what DOE requires, I do know that under NRC, 
as well as state regulations which are based on 10CFR20, the 
employer only needs to know (for monitoring purposes) whether or 
not the individual will exceed the 10% rule at THEIR facility. If the 
decision made is that they do nor, then the employer need not 
provide dosimetry, nor, are they required to complete a Form 4 on 
the individual. 

Personally. I had a problem with this when as a member of the AIF 
Committee that met with Bob baker and Walt Cool to discuss this, 
that the NRC didn't not require dose from all facilities be 
documented when making the decision as to whether or not 
monitoring was required, as was the case with the previous Part 
20. The comments were that the employer only needed to make a 
proactive decision based on their won doses to be concerned with.

As far as the requirement to obtain signatures, I require an 
employee signature when one facility requests doses from other 
facilities where their employees may also be badged (assuming we 
provide the dosimetry to the other facility). However, you would be 
surprised how many of these customers, when told of our 
requirement, stated that this was not required by other commercial 
processors. My comment has been, and is still the case, that if 
they want the doses from other facilities, not only do I require an 
employee signature, but also from the other employer as well, 
since it is THEY who provide for and pay for the dosimeters. This 
has not been a problem once they are informed of the requirements.
----------------------------------------------------------------------------
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Sandy Perle					Tel:(714) 545-0100 / (800)
548-5100   				    	
Director, Technical				Extension 2306

ICN Worldwide Dosimetry Division		Fax:(714) 668-3149

ICN Biomedicals, Inc.				E-Mail:
sandyfl@earthlink.net 				                           
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Costa Mesa, CA 92626

Personal Website:  http://www.geocities.com/capecanaveral/1205
ICN Worldwide Dosimetry Website: http://www.dosimetry.com
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