ML20215G235

Provides Guidance on Statement in 10CFR20.102 Re Licensee Effort to Obtain Repts from Individuals of Previously Accumulated Occupational Dose

ML20215G235
Person / Time
Issue date:	06/30/1980
From:	Higginbotham L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
42, NUDOCS 8610200260
Download: ML20215G235 (2)

Text

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1. EMOMNDUM FOR:

A. B. Davis. Chief. FFMS Branch. Region III FRON:

Leo B. Higginbotham. Assistant Director. Division of i

Fuel Facility and Materials Safety Inspection. IE

SUBJECT:

10 CFR 20.102-DETERMIMTION OF PRIOR RADIATION DOSE l

Reference:

Memo Fisher to Higginbotham. 4/23/00 You asked for guidance en the statement in 20.10t(c)(1) that "..the licensee shall make a reasonable effort to obtain reports of the individual's previously i

accumulated occupational dose.*

i Who may (or must) the licensee obtain these reports from (i.e.. previous a.

employer er worker)?

If the worker has a copy of his record and attests that it is a complete record. I believe that it is reasonable for the licensee to accept that without further question. providing the licensee is satisfied it is a complete record. Aside from the requirement in NRC regulations the l

-" licensee should be mindful of protecting himself in matters that may arise l

later and perhaps request a certification from the worker that it is a complete record. The consideration here is, that if the worker (for some i

reason)dbeunreasonabletorequirethelicensestodoacompletebackg would want to conceal or be untruthful about prior work experience.

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or verification check en the employee.

If the worker does not have a complete record, the licensee should, from infomation supplied by worker, check with former employers to obtain the i

history of radiatten exposure.

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that tym ef. report is required (i.e. telephone call, hand-carried history, melled41 story,etc.)?

l I believe the

• hand-carried history' is covered te a.

above. A telephone call to former employers would suffice as an interim measure if there are time pressures for the licensee to put the guy to work, but a written record i

should be requested to confirm information obtained in a telephone call.

I believe the " malled history' question is answered by the above discussion, l

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8610200260 060630 PDR I&E

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A. B. Davis 2

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-1 If the licensee is unable to obtain a " complete" history from telephone er written inquiries (the nuder of which he determines may be reasonable. i.e. the effort involvedbyhtm),thenhisonlyalternativeistoassignpriorexposureaccording tothevaluesinthetablein20.102(c)(1).

Leo B. Higginbothan Assistant Director Olvisten of Fuel Facility and Materials safety Inspection. IE cc:

S. W. Smith. Region !

J. P. Stohr. REglon II S. D. Brown. Region III H. S. Book. Region V l

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