Missing Potentially Contaminated Material

["Rodney Bauman"<rodney_bauman@wssrap-host.wssrap.com>]

Quick question:

A small gang-box filled with tools is reported missing.  Problem - the items
were last used in a Contamination Area (10CFR835.2).  Although the contamination
area is large (many acres, including a disposal cell), it is generally believed
that the items are no longer within the area  (an exhaustive search was
performed).  Next problem - there is no evidence (i.e., survey documentation) to
support the performance of a release survey.

It is generally believed that the tools were stolen and removed from the
contamination area without a survey.  However, some argue that there is no
evidence that the tools were actually removed from the area, and if so, were not
surveyed.

10CFR835.1101(a) generally prohibits the unrestricted release of material and
equipment with removable surface contamination.  Subsequently, Project
Management wants to know if the lost tools present a 10CFR835 violation.  What
would you advise them?

Rodney Bauman, CHP, RRPT
Weldon Spring Site Remedial Action Project
rodney_bauman@wssrap-host.wssrap.com

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