RE: Review of Internal Audits

[VERNIG.PETER@FORUM.VA.GOV]

{Original Msg: 'Review of Internal Company(Licensee)Audits by A Regulatory Inspector' from <radsafe@romulus.ehs.uiuc.edu>
{
{I'm interested in hearing from any one on OFFICIAL company positions
{regarding:
{
{	Can a NRC or an Agreement State Inspector DEMAND to see your internal 
{	Radiation Safety AUDITS conducted by your Company Staff ?
{
{Some of these audits may be conducted for Annual Rad Safety audits for Part
{20 compliance
{and others for compliance with license conditions (e.g.; Quarterly Audits)
{and/or company SOPs.
{
{I have not seen any guidance on this issue in NRC Regulatory Guides or any
{where else.
{
{We have both Broad Scope and Specific Licenses, and we are interested in
{developing 
{a Company Policy on this issue, instead of debating it with inspectors- who
{may be themselves
{used to handling this issue differently  with different licensees.  Our
{facilities are subject to 
{inspections by different NRC regions.  Also, How would other
{agencies(e.g;DOT) react to a
{company policy which is established for NRC/Agreement State licenses?
{
{Thank You
{
{	Ashok Dhar
{	
{	AKDHAR@MKG.COM     0r (314) 895-2088
{
{
{
 
 
My opinion would be that as a MINIMUM any audit or review required by
either a regulation [10 CFR 20 or 35 etc.] or by license conditions
would have to be shown to an inspector upon request.  Else how could they
confirm your compliance?  I don't know and am less sure but I would
suspect that ANY internal auditaddressing radiation safety or regulatory
compliance issues might also be fair game.
 
Just my opinions
Peter G. Vernig, VA Medical Center, Denver vernig.peter@forum.va.gov
 
 
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VA Medical Center, 1055 Clermont St. MS 115 - DISCLAIMER
Denver, CO 80220; 303-399-8020 x2447 FAX 393-4656 Opinions = Mine
FAX 303-393-4656, vernig.peter@forum.va.gov Opinions =/ VA or USA
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