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Question 118: 10 CFR 20.1101 (c) requires that each
licensee "periodically (at least annually) review the
radiation program content and implementation." A nuclear
power plant has many reviews and audits (including quality
assurance audits) of various aspects of their radiation
protection programs during a year and reviews are on a
schedule that covers all phases of the program on a
2-3-year review cycle. Is this acceptable to the NRC?
Answer: Yes, provided that the combination of these
reviews and audits covers program content and
implementation. Reviews and audits at nuclear power plants
should incorporate the following features to assess
procedural compliance, technical performance,
implementation, and effectiveness of the facility radiation
protection program.
Radiation protection supervisory reviews
Onsite radiation protection supervisors should periodically
perform and document reviews of the effectiveness of the
radiation protection staff in such areas as radiological
work practices, work monitoring, procedural compliance, and
survey adequacy.
Quality assurance audits
Quality assurance audits should be performed by the onsite
auditing group. Personnel in the auditing group should have
sufficient radiation protection training or experience so
they can determine whether radiation protection functions
are being performed as required. The quality assurance
program audits should meet the requirements of Appendix B
to 10 CFR Part 50.
Corporate or contract audits
Offsite (corporate or contract) audits and evaluations
should be performed to determine whether the radiation
protection program complies with the regulations and other
requirements and whether plant-wide objectives are being
met as well as to identify needed program improvements.
(Reference: 10 CFR 20.1101)