United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

U.S. Nuclear Regulatory Commission

Question 395: If an individual is monitored several times

during a year by the same licensee (e.g., during two

monitoring periods separated in time), how should the

monitoring period (s) be designated in the annual

individual monitoring report required by 10 CFR 20.2206

(i.e., on the NRC Form 5 or equivalent)? Due to the

possible limitations in the format and structure in

licensee's computerized occupational dose recordkeeping

systems, it seems that there should be flexibility in

meeting the intent of the requirements. Alternatives might

include the following:



a. Issue one NRC Form 5 or equivalent with a single

monitoring period that begins on the first day of the year

and ends on the last day of the year.



b. Issue one NRC Form 5 or equivalent with single

monitoring period that begins on the first day of the first

monitoring period and ends on the last day of the last

monitoring period.



c. Issue a separate NRC Form 5 or equivalent for each

individual monitoring period (i.e., issue two or more NRC

Form 5s for the same individual in the same year).



Would any or all of these approaches be acceptable in

meeting the intent of the regulatory requirements? Would

other approaches be acceptable? If so, please describe.



Answer: All three options are acceptable (option B is

preferable) provided that the separate "monitoring period

(s)" in the question fall within the year used to

demonstrate compliance. 10 CFR 20.2206 requires an annual

report of monitoring for individuals for whom monitoring

was required by 10 CFR 20.1502 during that year (emphasis

added). 10 CFR 20.1502 requires monitoring sufficient to

demonstrate compliance with the limits. The year as

defined in 10 CFR 20.1003 is the period of time used to

demonstrate compliance. Thus, the time period for

reporting under 10 CFR 20.2206 must be the year as defined

in 10 CFR 20.1003 that is used to demonstrate compliance.

(Reference: 10 CFR 20.2206).









Page Last Reviewed/Updated Thursday, March 29, 2012