United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Interpretation - RG 1.33, Meaning of "Procedure Implementation ...," STS Se ction 6.8.1

HPPOS-128 PDR-9111210336

Title: Interpretation - RG 1.33, Meaning of "Procedure

Implementation ...," STS Section 6.8.1

See the Interpretive Guide in the IE Manual on Regulatory

Guide 1.33 dated April 1, 1977. Technical Specifications

Section 6.8.1 states that written procedures shall be

established, implemented, and maintained for activities

listed in Appendix A of RG 1.33. "Implementation" means

the actions prescribed by the procedures must be

accomplished.

Region V had reviewed the TS requirements for the Radiation

Protection Program at Humboldt Bay. While the Region

recognized that the requirements were unartfully drafted

and that other TS and STS requirements use the words

"prepared, maintained, and adhered to", Region V thought

that the appropriate interpretation of the word

"maintained", in the context of the TS requirements, was

that procedures not only be kept up-to-date but that they

be followed. Given the age of Humboldt Bay, these

procedures were probably among the first written; well

before the more precise language of the STS were developed.

In summary, Region V thought a broader interpretation of

the word "maintain" included "adherence to" and that this

interpretation is consistent with the intent of the TS

requirements that licensees have a radiation protection

program to meet 10 CFR Part 20.

The Administration Control Section of STS Section 6.8.1

states that written procedures shall be established,

implemented, and maintained for activities that include

applicable procedures recommended in Appendix A of RG 1.33.

NRR and IE interpret the term "implemented," as used in

Section 6.8.1, to mean "adhered to." It is interesting to

note that ANSI N19.7-1976, Section 5.2.2, "Procedure

Adherence," states that procedures shall be followed and

that the requirements for use of procedures shall be

prescribed in writing. Hence, the term "adhered to" means

that the actions prescribed by the procedure must be

accomplished, it does not mean that the operator,

technician, or engineer must have a copy of the procedure

in hand and sign off each step as the function is performed.

Regulatory references: Regulatory Guide 1.33, Technical

Specifications

Subject codes: 1.7

Applicability: Reactors

Page Last Reviewed/Updated Thursday, March 29, 2012