Interpretation - RG 1.33, Meaning of "Procedure Implementation ...," STS Se ction 6.8.1
HPPOS-128 PDR-9111210336
Title: Interpretation - RG 1.33, Meaning of "Procedure
Implementation ...," STS Section 6.8.1
See the Interpretive Guide in the IE Manual on Regulatory
Guide 1.33 dated April 1, 1977. Technical Specifications
Section 6.8.1 states that written procedures shall be
established, implemented, and maintained for activities
listed in Appendix A of RG 1.33. "Implementation" means
the actions prescribed by the procedures must be
accomplished.
Region V had reviewed the TS requirements for the Radiation
Protection Program at Humboldt Bay. While the Region
recognized that the requirements were unartfully drafted
and that other TS and STS requirements use the words
"prepared, maintained, and adhered to", Region V thought
that the appropriate interpretation of the word
"maintained", in the context of the TS requirements, was
that procedures not only be kept up-to-date but that they
be followed. Given the age of Humboldt Bay, these
procedures were probably among the first written; well
before the more precise language of the STS were developed.
In summary, Region V thought a broader interpretation of
the word "maintain" included "adherence to" and that this
interpretation is consistent with the intent of the TS
requirements that licensees have a radiation protection
program to meet 10 CFR Part 20.
The Administration Control Section of STS Section 6.8.1
states that written procedures shall be established,
implemented, and maintained for activities that include
applicable procedures recommended in Appendix A of RG 1.33.
NRR and IE interpret the term "implemented," as used in
Section 6.8.1, to mean "adhered to." It is interesting to
note that ANSI N19.7-1976, Section 5.2.2, "Procedure
Adherence," states that procedures shall be followed and
that the requirements for use of procedures shall be
prescribed in writing. Hence, the term "adhered to" means
that the actions prescribed by the procedure must be
accomplished, it does not mean that the operator,
technician, or engineer must have a copy of the procedure
in hand and sign off each step as the function is performed.
Regulatory references: Regulatory Guide 1.33, Technical
Specifications
Subject codes: 1.7
Applicability: Reactors