U.S. Nuclear Regulatory Commission
Question 134: 10 CFR 20.1101 (c) requires a periodic (at
least annual) review of the radiation protection program as
defined in 20.1101 (a). 10 CFR 20.1101 (a) refers to 10
CFR 20.2102 for recordkeeping requirements. (a) Does the
use of the word "audit" in 10 CFR 20.2102 (a) require
records for all audits that are performed in addition to
the periodic review? (b) Are the reviews required by 10
CFR 20.1101 (c) also considered to be audits that are
subject to the quality assurance criteria specified in 10
CFR Part 50, Appendix B, XVIII?
Answer: (a) No. The recordkeeping requirements of 10 CFR
20.2102 (a) (2) apply only to audits and reviews performed
by the licensee to comply with 10 CFR 20.1101. If the
review is performed annually, then only the records of that
review are required.
(b) No. The requirements of Parts 20 and 50 are separate
requirements. However, quality assurance audits of aspects
of the radiation protection program at nuclear power plants
pursuant to the requirements of 10 CFR Part 50, Appendix B,
XVIII, may partially satisfy the requirements of 10 CFR
20.1101 (c). (Reference: 10 CFR 20.1101, 10 CFR 20.2102).