The Division of Radiation Safety (DRS) is launching a new policy for all authorized users registered to improve tracking of Monthly Surveys for posted labs using/storing radioactive material.
Authorized Users (AU) already know that submission of monthly surveys for contamination monitoring (Form NIH 88-12) is a requirement of the NRC license.
For many years, DRS has accepted monthly surveys, which show more than one lab module on the survey form itself, so long as it was clear from the diagrams what was surveyed and the LSC/gamma printouts were attached. DRS would then ensure that all modules represented on the form would get credit for their monthly survey. This was obviously applicable for double-module labs, for example, and likely started as a way to save paper.
For a "no-use" monthly survey, in which no smears (or LSC/gamma printouts) are required, even more paper can be saved by e-submission. DRS created a pathway for monthly survey credit through the Authorized User Portal. Use of the Portal for submission of "no-use" monthly surveys became a requirement in 2011. This has made tracking of labs' monthly surveys much easier, and no deciphering of surveys is needed on our part. One "no-use" survey submission equals monthly survey credit for one lab module. [Note there is NO AU Portal submission capability for "use" surveys as yet, due to the requirement to include smear results as an attached document; however DRS will aim for this goal at some point in the future. Preliminary feedback from our outreach efforts indicate that most AUs are in favor of this approach.]
In the spirit of improved database tracking such as was realized in the "no-use" portal submissions, DRS now wishes to avoid the need for deciphering surveys submitted in hard copy (the "use" surveys). Records will show there are not many lab groups left who are consistently placing multiple lab modules on one monthly survey form, but for those who do, the review and crediting of these labs for monthly survey completion can be quite challenging for DRS. It is not always easy to identify all of the lab modules represented on the form, and this can lead to unwarranted enforcement action for the AU.
It will be a tremendous help to DRS, and allow for the AU to avoid this unhappy situation, if each lab module receives monthly survey credit on an individual basis. For labs who are currently using one monthly survey form to represent multiple lab modules for "use" surveys, this will necessitate a change in the template lab diagram. Now each lab module will need its own monthly survey form, each month.
DRS hopes to implement this change in policy effective immediately. They have already targeted an outreach effort to specific labs who consistently submit multiple labs on one survey form, and provided specific guidance to them on re-drawing their template survey form. Please share this information with the surveyor(s) in your lab group so that they can start sending in one lab module per form on all "use" monthly surveys.
Your Area Health Physicist can help in your transition to this new approach for "use" monthly survey tracking. Call on DRS staff at 301-496-5774.
