Re: Review of Internal Company(Licensee)Audits by A Regulatory

["James G. Barnes" <mail15077@pop.net>]

Ms. Hamrick's reply reflects my understanding of the regulations.  It should be 
noted, however, that NRC and Agreement State regulations are supportive of 
"self-identified" violations, so one is encouraged to root out any programmatic 
faults, note them in an audit process, and address them in a timely manner.  By 
doing so, one reduces the severity of a potential violation.

Other regulatory agencies (such as EPA) do not take this approach, thus 
self-identifying a violation is tantamount to putting one's head in a noose and 
inviting the agency to kick the ladder out.  This creates a problem, as it is 
tantamount to self-incrimination.  I believe that this issue is being 
adjudicated at the present in several court cases(???).

I have generally opened any file an NRC or State Radiological Regulator wants 
to see, as long as the inspector could demonstrate that his agency had 
jurisdiction in the subject matter of the file material.


Jim Barnes, CHP
RSO
Rocketdyne Divison; Rockwell Aerospace

=========================================
> In a message dated 96-04-17 12:13:35 EDT, Ashok Dhar wrote:
> 
> > 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.
> 
> Check 10 CFR 19.14(a):  Each licensee shall afford to the Commission at all
> reasonable times opportunity to inspect materials, activities, facilities,
> premises, and records pursuant to the regulations in this chapter.
> 
> Most Agreement States will have similar language somewhere in their
> regulations.  If the record, of survey, audit, recordable incident, etc. is
> required by regulation and/or license condition to be maintained, the
> inspector shall be given the opportunity to inspect it.
> 
> That's my understanding of the matter.
> 
> Barbara L. Hamrick
> Los Angeles County - Radiation Management
> BLHamrick@aol.com
>