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audits
The following is in response to query on conduct of audits.
REF: Draft Reg Guide DG-0005
(2d proposed Revision to to Reg Guide 10.5)
"Applications for licenses of Broad Scope)
Section 10.4 (p.23) "Audits and Appraisals" states
The regulations in 10CFR20.1101(c) require the licensee
to periodically (at least annually) review the radiation program
content and implementation. The radiation safety program
review and audits are the responsibility of management. Management
may fulfill this responsibility either by having this audit conducted
by the RSC or by contracting with an independent auditor to review
the program. This auditor should be accompanied by management,
the RSO, and available representatives of the RSC. The auditor's
results of the program review should be submitted to the RSC for
formal documented committee review and action. Licensees are
required by 10 CFR20.2102 to maintain records of the radiation
protection program, including (1) the provisions of the program
and (2) audits and other reviews of the program contents and
implementation.
[end of quote from Reg Guide]
NOTE: there are additional guidance words after the above par.
on Audits and Appraisals.
OUR METHOD:
We use appendix E to the inspectors Guide (obtained from the
NRC Regional Office after our recent inspection) which has 13
sections and is the guide the inspector uses for license visits.
I divided the Appendix in appropriate sections and the RSC
assigned them to the various members of the committee to use
as the guideline for the audit. The Appendix is pretty much
self explanatory and the auditing member of the RSC met with me
and it was my job to provide the info/documentation to answer
the points in the form, just as if it were the NRC inspector.
Even if we weren't deficient, it was a good exercise in reviewing
our procedures etc. and seeing if there might not be a better
way, or a need to update something. After the audits, each
RSC member wrote a summary memo with results, any deficiencies
noted, and any suggestions for improval/update etc. The audit
sheets (sections of Appendix E) were attached to the report. I will now respond at the next quarterly RSC meeting to the results
of the audit.
BY THE WAY, the REG GUIDE is issued for comment - comments
due to NRC NLT 1-25-95. I'd like to ask your support
for at least 2 items
p. 15 para 2. "The RSC chairperson should be named on the license
application. A license amendment is required if the RSC chair
person changes.
THIS one would cause a lot of extra paperwork and potentially
(if not fee exempt) a significant cost for a minor amendment. I
am proposing to NRC that we be sure the RSC meets the criteria -
this would be an inspection item - but that we not have to tell
them who specifically is chair as it usually changes every
year. They need to realize we know the criteria and won't put
an emeritus english professor in the slot.
p. 19 par 2. The radiation detection and monitoring equipment
available to both the radiation safety office and all users should
be described, and the type and "numberof instruments available"
(e.g. ino-chambers, G-Ms, air samplers, liquid scintillation
counters) should be listed. AGAIN - to give a specific number in
an application would make it a license condition. To commit to
types and availability for designated users is o.k., but a speci-
fic number is unnecessary minutia and could cause problems for
compliance.
these are some of my inputs to the question of the audit and also
what i notice about the proposed reg. guide. i welcome your
response.
paul skierkowski, RSO, University of Oklahoma - Norman
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