Re: Review of Records by Inspectors

[RONALD GOODWIN <RONALD_GOODWIN@health.ohio.gov>]

I spent 25 years in Commercial Nuclear Power as Staff HP, EmerPlan, LLRW, and 
finally in Quality Assurance (those what can't, audit?).  In that time, and by 
working in more than 20 power plants (yep - had to stay one step ahead of my 
creditors) this rule as stated below was universally accepted by those being 
inspected/audited.  NEVER LET AN INSPECTOR/AUDITOR have originals!

As to the second statement, e.g., STYLE - Tell them to "{insert one's own 
preference here on what to do with obnoxius, ignorant, do-it-my-way or else 
idiots}"  Unless there is a regulation (i.e., Code of Federal Regulations) on 
what records to maintain, and how to maintain them, (hard copy vs. electronic 
media) these are your records.

Finally, (this relates to the above) I have never had an NRC inspector tell me 
HOW to FIX or MAINTAIN anything.  Mind you, they have told me that the way I was
doing things was not right (does the acronym NOV mean anything?) but they have 
never told me how to fix what was wrong.  This statement does not apply to EPA, 
DOT, (for a very short period of time - DOE), State and others, however, at 
power plants, we did not worry so much about the others, just the NRC.  (I will 
say that there was one state guy in Texas who caused me some hairloss, and 
because he is still there I won't mention his name, but we finally agreed on how
to do Emergency Planning and everything got better after that!)

Remember, the inspectors are to provide oversight!  They do not manage, nor do 
they fund your operations so that they can provide direction on how to do 
anything.  If what they want is not regulatory based, it is a Division 3 
response (nice to do, but they can not enforce!)

Hope all who read this have a great weekend.

Best regards, and peace

Ron Goodwin - Ohio

Ronald_Goodwin@health.ohio.gov

______________________________ Reply Separator _________________________________
Subject: Review of Records by Inspectors
Author:  radsafe@romulus.ehs.uiuc.edu at Internet
Date:    4/19/96 9:06 AM


RadSafers -- Kent Lambert mentioned the problems he has had with 
one inspector messing up his committee minutes and survey 
records.  I know of a licensee who is routinely inspected by NRC, 
DOT, DOD, DOE, FDA , the state and county equivalents, insurance 
carriers, customers, plus others. Literally, they are inspected 
by someone at a frequency that exceeds one per month.  Their 
first rule is -- DON'T EVER GIVE AN INSPECTOR AN ORIGINAL COPY OF 
ANYTHING!!! Their second rule is -- DON'T LET AN INSPECTOR TOUCH 
AN ORIGINAL COPY OF ANYTHING!!  Their third rule is -- DON'T 
ALLOW ORIGINAL RECORDS TO BE WITHIN THE REACH OF AN INSPECTOR!! 
Thier fourth rule is -- IF AN INSPECTOR WANTS A COPY OF 
SOMETHING, YOU MAKE A COPY OF IT AND GIVE THE COPY TO THE 
INSPECTOR.  It is very easy to screw up the record keeping 
requirements of this business; we don't need help from 
inspectors.
     
   In addition to the problem of losing records, this licensee 
also faces the problem of record keeping "STYLE." Each inspector 
believes that he/she can require that the records be maintained 
in a specific manner.  The fact that each inspector tries to 
require a different record keeping style is enough to drive a 
sane person crazy.
     
  Every time I read a message like Kent's I thank the Almighty 
that I no longer work for a licensee and ask Him/Her to give 
RadSafers the strength to deal with the nonsense, wastefulness, 
and stupidity that pervades radiation safety.
     
     
Sincerely,
     
Bill Schadt a.k.a. Mr. QUEST
Radiation Technology, Inc.
P.O. Box 10457
Silver Spring, MD 20914-0457
              (301) 622-9644 (voice)
              (301) 622-1582 (fax)
              info@chammp.com (email)