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