United States Nuclear Regulatory Commission - Protecting People and the Environment

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).

Page Last Reviewed/Updated Thursday, March 29, 2012