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DOE Sites Reporting a less than number



We recently got hit during a DOE audit for reporting a "less than" number on a survey form.  For example we have a smear-able release limit of 200 dpm/100cm-sq beta, if we see nothing, we use less than.  How do you do it at other sites?  Have you run into the same audit comments?  Any regulatory paragraph  references would be appreciated.

RADSAFE please respond directly to me at:

bielad@wv.doe.gov

Thanks
Dave Biela
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           
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