Re: Error Condition Re: Re: Review Of Internal Audits

["Bruce Dicey" <Bruce_Dicey@guardian.brooks.af.mil>]

     IF I'M NOT SUBSCRIBED TO RADSAFE, HOW COME I GET ALL THESE MESSAGES 
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     SOMEBODY PLEASE GIVE THE COMPUTER A KICK - THIS IS THE 3rd TIME THIS 
     HAS HAPPENED!
     
     (Just to cover things, I've also re-re-re submitted a "subscribe 
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______________________________ Reply Separator _________________________________
Subject: Error Condition Re: Re: Review Of Internal Audits
Author:  radsafe@romulus.ehs.uiuc.edu at guardian
Date:    4/18/96 3:31 PM


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     Relaying an experience I had at a former institution. We had a broad 
     scope byproduct materials license and were doing primarily 
     environmental level radiochemistry. Our agency headquarters had 
     conducted a comprehensive internal review of workplace safety that 
     included evaluations of general safety hazards, chemical, toxic, 
     employee health issues, etc. The whole report was intended as a 
     limited distribution "self-assessment" Local management review had not 
     been completed and the report had not been put in final form.  
     Included in the rather large report were 1 or 2 pages regarding the 
     facility radiation safety program.
     
     Two NRC inspectors arrived and, in the course of their visit, learned 
     of the existence of the report and demanded to be provided with a copy 
     of the entire document.
     
     After a flurry of phone calls from our management to the agency's 
     office of general counsel it was decided that only those pages 
     directly related to the radiation safety program were to be shown  to 
     the inspectors.  The inspectors were'nt pleased with the situation and 
     muttered all sorts of comments under their breaths that were probably 
     intended for our ears.  Several days after the on-site inspection had 
     concluded one of the inspectors called back and noted that regional 
     office management had "decided (they) could evaluate the program with 
     the material they had" and were withdrawing their request for the 
     entire document.
     
     Bottom line - as others have noted, if the NRC inspector learns of the 
     existence of a document that even appears to be relevant, they may 
     well request to see it.  When the propriety of the request comes into 
     question, it can easily come down to a judgement call on the part of 
     higher management.
     
     B.T.W. - one commenter in this thread noted problems resulting from 
     letting an inspector take records back to the hotel.  10 CFR and the 
     license will require that the facility (and by extension records) be 
     available for inspection "at reasonable times."  Again, a judgement 
     call, but it seems like facility records are the property of the 
     facility being inspected, not the inspector.  If an inspector 
     requested to take records off site as a matter of personal 
     convenience, you might give a counter-proposal to either stay after 
     hours with the inspector or provide the inspector with photocopies -- 
     the first commenter learned the hard way to never give up original 
     records!
     
     An interesting thread - interested in experiences others may have had 
     in this area.
     
     Bruce Dicey
     Dosimetry QC Manager - USAF
     
     Bruce_Dicey@guardian.brooks.af.mil
     
     >>>>> "Usual disclaimer" <<<<<
     
     
______________________________ Reply Separator _________________________________
Subject: Review Of Internal Audits
Author:  radsafe@romulus.ehs.uiuc.edu at guardian 
Date:    4/18/96 12:48 PM
     
     
Radsafers:
     
I received a few responses to my earlier question on:
 Can a NRC or an Agreement State Inspector DEMAND to see you Internal
Radiation
 Safety AUDITS conducted by your company staff?
     
Appreciate everyone's time in responding to this question.
     
There is a related question that I did not deliberately ask yesterday.  That 
is: 
 If an audit is required for regulatory reasons or for compliance with your
license conditions,
 Are you required to show the inspector the whole audit report or can you
show 
 documentation that the audit was done without showing the full report and
the audit 
 results?
This documentation could be through a log book or some other mechanism.  The 
idea is NOT 
TO HIDE any thing, but, to have a consistent policy, regardless of the 
results of an audit.
     
I would appreciate your thoughts and experiences.
     
 Ashok Dhar
 AKDHAR@MKG.COM