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).