U.S. Nuclear Regulatory Commission
Personnel Monitoring Requirements for an NRC / Agreement State Licensed Contractor Working at a Part 50-Licensed Facility
HPPOS-047 PDR-9111210207
Title: Personnel Monitoring Requirements for an
NRC / Agreement State Licensed Contractor Working at a Part
50-Licensed Facility
See the letter from L. B. Higginbotham to D. Romine (Chem
Nuclear Systems, Inc.) dated October 3, 1978. When a
contractor licensed by the NRC or an Agreement State
performs work under its license at a Part 50 facility, only
one party need provide personnel monitoring if the other
party assures that dosimetry and records are adequate to
meet regulatory requirements. The health physics position
was written in the context of 10 CFR 20.202 and 20.401, but
it also applies to the "new" 10 CFR Part 20, Sections
20.1501, 20.1502, and 20.2106.
NRC was asked to provide an explanation on whether a
contractor's records of personnel radiation exposure
satisfied regulatory requirements or whether the contractor
must obtain radiation exposure records from Part
50-licensed facilities after employees performed work at
these facilities. The answer to this question is in
several parts, since the responsible party must be
identified and, in some cases, the responsibility may fall
to more than one party.
If contractor-employees perform work at a Part 50-licensed
facility and the work is performed under the Part 50
license, the responsibility to provide appropriate
personnel monitoring and maintain exposure records falls to
the Part 50 licensee. However, if contractor-employees
perform work at a Part 50-licensed facility, but the work
is performed under the contractor's NRC or Agreement State
license, the responsibility falls to the contractor to
provide appropriate personnel monitoring and maintenance of
exposure records.
In the case where the two licensees (Part 50 and
contractor) are subject to this responsibility, it is not
necessary for both to provide personnel monitoring
equipment. One licensee may accept the dosimetry program
and records of the second licensee provided that the
dosimetry program and records are adequate to comply with
NRC requirements and its license conditions. In a similar
manner, a licensee may accept the dosimetry program and
records of a non-licensee (contractor) provided the
conditions are as described above.
In the situation in question, most of the work was
performed under the Part 50 license of the power reactor
facility. It was acceptable for the contractor to use its
own monitoring equipment and maintain its own records,
provided the Part 50 licensee was willing to accept this
arrangement. In this situation, the responsibility for
compliance with NRC requirements was with the Part 50
licensee and it would have to perform such evaluations as
necessary for it to be satisfied that the regulatory
obligation was being met by the contractor's equipment.
The decision belongs to the Part 50 licensee and it could
provide additional monitoring equipment for contractor
personnel, if it so desired, to meet its own obligations.
Regulatory references: 10 CFR 20.202, 10 CFR 20.401, 10
CFR 20.1501, 10 CFR 20.1502, 10 CFR 20.2106
Subject codes: 2.1, 8.1, 12.2
Applicability: All
