United States Nuclear Regulatory Commission - Protecting People and the Environment

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

Page Last Reviewed/Updated Thursday, March 29, 2012