Health Physics Questions and Answers - Question 395

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:

1. 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.
2. 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.
3. 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)