Lab Surveys & Documentation

["Sue M. Dupre" <DUPRE%PUCC.bitnet@vmd.cso.uiuc.edu>]

Good morning!  Several weeks ago, I posted a question about the documentation
of surveys by lab personnel; I made the inquiry because an auditor had sug-
gested that we could discontinue our practice of requiring that all personal
and work area surveys by lab personnel be recorded in a survey log.  I think
a summary of the responses to my question will be of general interest.

I heard from 16 universities, 1 VA med center, 3 biomed/pharmaceutical-type
places, an agreement state regulator, and a few power plant and DOE people.
A consensus?  NONE!  There were instead a wide variety of responses, some of
which expressed disdain for our auditors and some that expressed support for
our auditors' position.  Some people said "The NRC makes us record all those
surveys" and others said "The NRC doesn't make us record all those surveys".

At any rate, I found out that most of my respondents do NOT require that
every work area survey performed by lab personnel (remember, I am not referring
to surveys by health physics personnel) be recorded.  It is the common prac-
tice to require that periodic surveys (daily, weekly or monthly) of work areas
be recorded.  The periodicity of the recorded surveys is often determined by
the amount of activity being used.  It appears to me that periodic documented
surveys by lab personnel are required because Health Physics personnel at many
institutions do their surveys on a quarterly basis so weekly or monthly recor-
ded surveys by lab personnel are needed to fill in the gaps.

Not everyone responded to my question about documentation of personal surveys
i.e., surveys of lab coats, hands, etc. but most of those that did either did
not require a record of personal surveys or required that a record be made only
when contamination was found.

The arguments advanced in favor of requiring documentation of all surveys were:
1) regulatory compliance:  the NRC requires documentation or the NRC requires
surveys and takes the position that "no record = no survey", 2) survey records
provide information to HP personnel about lab conditions, 3) as RSO, how can
you be sure that required surveys are being done unless the surveys are re-
corded, and 4) records provide evidence in the event of litigation.

The arguments to support a policy which does not require documentation of all
surveys by lab personnel were: 1) the NRC accepts such a policy (in those
cases compliance with NRC survey requirements is determined by NRC inspectors
who question lab personnel about survey practices), 2) requiring documentation
is a disincentive to actually performing the survey, and 3) requiring documen-
tation is regulatorily unnecessary and therefore unnecessarily burdensome to
researchers.

Finally, a summary of my summary:  It appears that the most common survey
practices have the following components:

1)  Very frequent surveys by lab personnel are required.

2)  Documentation of every survey is not required.  Documentation requirements
    are commonly based on a specified frequency, a trigger level (using certain
    quantities of radioactivity) or the detection of contamination.

3)  Surveys by HP staff are not performed more often than once a month and
    more usually are performed on a quarterly basis.

4)  Greater emphasis is placed on recording work area surveys than package and
    personal surveys.

I hope you'll find this summary clear and useful.  Please e-mail me if you have
further questions or need anything clarified.

Sue Dupre/Health Physicist/Princeton University
dupre@princeton.edu
(609) 258-6252