Re: RWP Record Retention Requirements

[OFFTOWY@aol.com]

In a message dated 1/5/2001 11:17:25 AM Eastern Standard Time, 
RBauman@wssrap.com writes:

<< Does anybody know of a requirement to maintain records of Radiation Work
 Permits (or equivalent rad work authorizations) in either 10CFR20 or
 10CFR835?  I clearly see the requirement to maintain survey and individual
 monitoring records that may be associated with RWPs, but what about the RWPs
 themselves? >>

I would guess that RWPs are considered work authorizations required by 10 CFR 
835.501(d) and would fall into the general records category addressed by 10 
CFR 835.701(a) (records demonstrating compliance) and must be retained.  They 
could also be considered ALARA records under 835.704(b).  Note also that the 
Radiological Control Standard and IGs are both considered official 835 
guidance documents and address recordkeeping requirements.  I don't think DOE 
specifies retention periods anywhere, except maybe your contract.  A good 
guess is "turned over to DOE at the cessation of activities that may result 
in occupational exposures."

 Lew LaGarde
offtowy@aol.com
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