Re: Lab Surveys & Documentation

[sandy_perle@email.fpl.com]

     This is my interpretation:
     
     10 CFR 20.2103(a) states that records must be maintained for surveys 
     and calibrations that ARE required. The determination of what surveys 
     are required, as written in 10 CFR 20.1501(a) NEEDS to be written as 
     such, otherwise the licensee must continually survey areas where there 
     is no radiological need to do so. In other words, IF the survey is 
     done, as deemed required by the licensee, then it shall be 
     docunmented. The record need only be retained for a period of 3 years, 
     which in itself is not a very prudent thing to do, to discard it after 
     the finite period is passed. ANI on the other hand requires that ALL 
     records generated be maintained by the facility for the Life of Plant 
     + 10 years. The reason, future litigation.
     
     The NRC is unable to direct a facility to continually conduct surveys. 
     If the requirement were written as SHALL, then to what end must the 
     Licensee survey? How many survey points in an area is deemed adequate? 
     How many rooms, how many sq. ft. of floor space, etc? The wording 
     currently contained in 10 CFR 20 is the semantics the utility HPs have 
     been clamoring for. The burden is on HP to identify areas where 
     surveys need to be taken, and if so, they document the results. If it 
     happens where an inspector questions the facilities reasoning as to 
     why a survey wasn't done, then HP is bound to respond. That is why HPs 
     with technical and years of experience are needed. IF we are required 
     to continually just take sample points, then a qualified HP isn't 
     necessary. More importantly, massive wasted resources would be 
     utilized where there exists no cost benefit or improvement in the 
     overall rad protection program.
     
     Conclusion: It's not broken, don't fix it.
     
     Sandy Perle
     
     sandy_perle@email.fpl.com
     sandyfl@ix.netcom.com
     
     http://www.netcom.com/~sandyfl/home.html


______________________________ Reply Separator _________________________________
Subject: Lab Surveys & Documentation
Author:  radsafe@romulus.ehs.uiuc.edu at Internet-Mail
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.