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

[lambert@HAL.HAHNEMANN.EDU]

On Wed, 17 Apr 1996, Brewer, Ronald K.(RBREWER) wrote:
> 
> An NRC inspector has the right to see ANY record, required by 
> regulation/license or not, which has a bearing on licensed activities. 

Staff performance clearly have a bearing on licensed activities.  Does 
this mean that the NRC has the right to see personnel performance 
appraisals?  Somehow I don't think so.  (I am speaking from an 
academic/medical licensee perspective, I do not know about at nuclear 
power plants where fitness for duty is a regulatory issue.)  Radiation 
safety office budgets clearly have a bearing on licensed activities.  
Does this mean that the NRC has the right to review these records?  
Again, I think not.

So, if therse examples are not inspectable, then where is the line?  If I 
choose to monitor the radiation exposure of housekeeping personnel 
to protect my institution from litigation in the future even though 
monitoring is not required by 10 CFR 20, does the NRC have a right to see 
these records?  My OPINION is no, they do not have a RIGHT to see these 
records.  Would I show these records to the NRC?  Yes, I have nothing to 
lose, and I only gain by being cooperative.

Program audits are required by 10 CFR; therefore, they are inspectable.  
Also note that the definition of survey can be broadly interpreted; 
therefore, a host of activities can be considered surveys and are 
inspectable.


Kent Lambert
LAMBERT@hal.hahnemann.edu

These are my thoughts.  If they are wrong
I accidentally pressed the send instead of
the delete key.  My employer makes no claim
to endorse my opinions.