Re[2]: Soc. Sec. # on Official Records

[julie_f_shafer@email.fpl.com]

     OK, after lurking on this discussion, I'll jump in.
     
     Chris said:  >>I believe that the NRC (and in my case Agreement State) 
     regulations require a SSN on dosimetry records.  I am attaching the 
     following reference to that effect from 10 CFR 19.  Our agreement 
     state regs have essentially the same statement.  Being from an 
     agreement state, I don't cite CFRs frequently, so please excuse any 
     syntax errors in the citation. << 
     
     
     We have been in a situation where an individual did not want to 
     provide their SSN.  Bottom line - the person did not have to disclose 
     it on the basis that we HAD to have it for the compliance with NRC 
     regulations.
     
     The individual contacted the NRC and was told, in writing, that the 
     use of the SSN is encouraged, but not mandatory.  We had no basis for 
     REQUIRING the SSN to be in compliance with NRC regulations (for 
     Radiation Protection purposes).
     
     
     There are provisions in the instructions for completing  both the NRC 
     forms 4 and 5 that allow licensees to identify what type of personnel 
     identifier is being used.  Read the instructions for completion of 
     these forms.  Both forms have a block next to the SSN where you have 
     to indicate what type of identifier has been used. They specify the 
     following:  (Reference Reg. Guide 8.7)
     
     Code:      ID TYPE:
     SSN        US SSN
     PPN        Passport number
     CSI        Canadian Social Insurance Number 
     WPN        Work Permit Number
     IND        INDEX identification number, which is now the same as PADS 
     OTH        OTHER
     
     
     Additionally, the last part of the instructions for completing NRC 4 & 
     5 is the Privacy Act Statement, which specifically states that:
     
     "It is voluntary that you furnish the requested information, including 
     social security number; however, the licensee must complete NRC Form 5 
     on each individual for whom monitoring is required under 10 CFR 
     20.2106.  Failure to do so may subject the licensee to enforcement 
     action in accordance with 10 CFR 20.2401.  The social security number 
     is used to assure that NRC has an accurate identifier not subject to 
     the coincidence of similar names or birth dates among the large number 
     of persons on whom data is maintained."
     
     
     As for requiring it for PADS, (i.e. no disclosure of SSN - no work) as 
     someone stated,  I am not sure that is legal either. (in regard to 
     exposure records - security requirements may be different)  If there 
     is a provision for personnel without SSNs, you can work with that 
     provision for personnel who do not want to disclose their SSN.  
     
     
     Further, the issue of establishing security clearances was also 
     addressed when this whole issue came up. 
     
     The following statement was made in reference to completion of Form 
     FD-258 Fingerprint Card.  (reference Federal Register 38480 (July 7, 
     1993) regarding the record system NRC-39 having to do with security 
     clearances)
     
     "Disclosure of your social security number is voluntary.  If you 
     choose not to supply it, your employment, your unescorted access or 
     your access to unclassified Safeguards Information may be delayed.  
     Disclosure of all other information is also voluntary; however, if it 
     is not supplied, your employment, your unescorted access or your 
     access to unclassified Safeguards Information may be delayed or your 
     fingerprint cared may not be processed".
     
     To me, that says that if you don't provide your SSN, you probably will 
     not obtain unescorted access.  Which also says to me that if a  worker 
     does not wish to disclose their SSN, it is not likely that they will 
     get in the gate.  It appears, (in my opinion) then that employment may 
     be able to be denied on THIS basis.  At that point, 
     establishing/maintaining exposure history is not an issue.  
     
     
     In another related situation, we did learn is that you absolutely 
     CANNOT allow that SSN to be posted in an open place.  For instance, 
     leaving an exposure printout containing the SSN at a location where it 
     is accessible to plant personnel.  OR having the SSN preprinted on TLD 
     labels or security badges, where it is in view of anyone.  That is NOT 
     protecting private information supplied to you by the employee. Every 
     printout that had the SSN on it that had any chance of being 
     distributed for exposure information was checked to ensure that it did 
     not include the SSN.  A few did, and the SSN was removed.  TLD SSN was 
     removed from TLD labels (was used as a secondary identifier), and 
     security badges no longer have the SSN printed on them.  We now also 
     have a paper shredder.
     
     
     We have "been there, done that" on the SSN issue!
     
     Julie Shafer
     Dosimetry Supervisor
     FPL/Turkey Point
     305-246-6117

        All statements made above are mine alone, and not that of my 
        employer's.