Re: Lab Surveys & Documentation

[BRZGV@ccmail.ceco.com]

     It is very difficult to prove you performed something without hard 
     copy documentation.  We use both specific survey sheets with room 
     layouts and one-liner log type sheets for other specific surveys to 
     show that they were completed.  
     
     We also use a section on our surey to put the initials and date/time 
     the instruments were source checked.
     
     You need a good means of tracking all of your surveys with a good 
     numbering methodology to go back and retrieve them at a later date
     
     
     Just a few thoughts...


______________________________ Reply Separator _________________________________
Subject: Lab Surveys & Documentation
Author:  radsafe@romulus.ehs.uiuc.edu at INTERNET
Date:    6/25/96 1:41 PM


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.