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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).