Review of Internal Company(Licensee)Audits by A Regulatory

[Keith Brown <KDB1@nrc.gov>]

	         Inspector -Reply

>>>>>>>>>>>>>>>
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.

<<<<<<<<<<<<<<<

It seems to me the question is asked incorrectly.  Perhaps it would be
better to ask: do the records need to be kept and do they need to be made
available to an inspector who asks to see them?  10 CFR 20.2102 gives the
requirements for retention of these records.  10 CFR 19.14 and 10 CFR
30.52 (40.62 and 70.55 for source and special nuclear material
respectively) give requirements for making records available to the NRC. 
This is probably not an exhaustive list of applicable NRC regulations.

While the views here are solely mine and not my employers, my employer
should agree with the content of the regulations cited.

Keith Brown