Question 12: How will the revised Regulatory Guides be
used in determining acceptability of a licensee's
implementation of the revised Part 20?
Answer: In determining the acceptability of a licensee's
implementation of the revised Part 20, new regulatory
guides will be used in the same way existing guides have
been used in determining acceptability of a licensee's
implementation of the old Part 20 in cases in which there
is no licensee commitment to the guide in a license
application. As stated in virtually every guide,
Regulatory Guides are not regulations and compliance with
them is not required, unless the guide has been made a
specific condition of a license (a common practice for
materials licensees who are licensed by NRC's Office of
Nuclear Material Safety and Safeguards). Also, as
indicated in every guide, alternatives to methods described
in the guide may be acceptable. (Reference: Regulatory
Guides)