Lab Surveys & Documentation

[wpitch4d@IMAP2.ASU.EDU]

10 CFR Section 20.2103(a) requires record retention for results of 
surveys (and calibrations) required by Sections 20.1501 (and 20.1906(b)).

Section 20.1501(a) is very (almost unduly) broad... "Each licensee shall 
make or cause to be made, surveys that- (1) May be necessary for the 
licensee to comply with the regulations in this part; and (2) Are 
reasonable under the circumstances to evaluate- (i) The extent of 
radiation levels; and (ii) Concentrations or quantities of radioactive 
material; and (iii) The potential radiological hazards that could be present.

My unpopular point of view: If you want to say a survey was done, it has to 
be documented in such a manner that the record can be maintained. 

Even then the "may be necessary" and the "are reasonable" will be left to the
discretion of the unhappy regulators.

A sour note: Hindsight is usually the point of view of concern to the 
inspectors when making compliance determinations.

A suggestion: Make the regulators quit using "may" and "reasonable". 

Prudence and judgement seem to me a matter beyond the purview of 
administrative agencies, their inspectors and hearing officers.