Health Physics Questions and Answers - Question 134
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?
(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)