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Re:RE: Missing Potentially Contaminated Material
For further clarification:
The tools have already been reported as "missing." This means that they either
left the contamination area or were inadvertently disposed of (we'll probably
never know). Because of the possibility that the tools left the contamination
area without a survey, should we classify this as a 10CFR835 violation?
Rodney Bauman
____________________Reply Separator____________________
Subject: RE: Missing Potentially Contaminated Material
Author: <radsafe@romulus.ehs.uiuc.edu>
Date: 4/19/99 9:25 AM
I would advise your management to officially report the missing potentially
contaminated material that you just unofficially reported here on Rad Safe.
> -----Original Message-----
> From: Rodney Bauman
> [SMTP:rodney_bauman%wssrap-host.wssrap.com@inet.rfets.gov]
> Sent: Monday, April 19, 1999 7:53 AM
> To: Multiple recipients of list
> Subject: Missing Potentially Contaminated Material
>
> 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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information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html