United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Question 380: Nuclear power plant licensees are required

to meet the quality assurance criteria in 10 CFR Part 50

Appendix B. Regulatory Guide 1.33 describes a program

acceptable to the NRC staff to demonstrate compliance with

10 CFR 50 Appendix B requirements and includes guidance

regarding the documentation, use of procedures and periodic

review of radiation protection programs. Does commitment

to and conformance with 10 CFR Part 50 Appendix B and

Regulatory Guide 1.33 fully meet the requirements of 10 CFR

20.1101 (a) and (c)? Note: The answer to Question 118

provided previously did not clarify if additional

requirements are imposed on nuclear power plants by 10 CFR

20.1101 (a) and (c) that are new or different from the

previously applicable requirements.



Answer: No. See related question 134 and answer. 10 CFR

Part 50 Appendix B and 10 CFR 20.1101 (a) and (c) are

different requirements. 10 CFR Part 50 Appendix B

establishes quality assurance requirements for the

operations of nuclear power plant safety-related structures

systems and components. 10 CFR 20.1101 (a) requires each

license to develop, document, and implement a radiation

protection program commensurate with the scope and extent

of licensed activities and sufficient to ensure compliance

with the provisions of Part 20. 10 CFR 20.1101 (c)

requires periodic reviews of that radiation protection

program. Although for nuclear power plants, there is some

overlap between the requirements of 10 CFR 50 Appendix B

and the requirements of 10 CFR 20.1101 (a) and (c), they

clearly are different requirements. For example, some

aspects of the radiation protection program established

pursuant to 10 CFR 20.1101 (a) may not be considered

"safety related" within the meaning of this term in 10 CFR

50 Appendix B. The reference to 10 CFR Part 50 Appendix B

in the answer to Question 118 was provided in the context

of a discussion of quality assurance audits and was not an

indication that "commitment to and conformance with

Appendix B and Regulatory Guide 1.33 fully meet the

requirements of §20.1101 (a) and (c)." (References: 10

CFR 20.1101).









Page Last Reviewed/Updated Thursday, March 29, 2012