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Re: Annual Report to Workers
You only need to do the annual report (a Part 19
requirement) if monitoring IS REQUIRED. If, as in
your case, you assess that most 'are not likely to
exceed' then monitoring is not required (regardless
if you monitor anyway) and a report is not required.
This was explicitly discussed in the comments on
the revised 10CFR20.
Note that monitoring is also required under other
conditions, e.g., for those entering HRAs regardless
of their projected exposures.
A little risk adds spice to life.
Lester.Slaback@NIST.gov