Health Physics Questions and Answers - Question 380

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)