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

HPPOS-128 PDR-9111210336

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