Re: Leak Testing

[tdc@ehssun.lbl.gov (Ted M. de Castro)]

>>Recently UCSB was inspected by the California DHS Rad. Health Branch, and 
as
>>usual a few violations were issued. One of them was regarding the 
frequency
>>of sealed source leak testing, more specifically that it was (and I quote)
>>"not (exactly) timely."   Both instances cited were sources that were
>>tested 13 or 14 days after the six-month anniversary of the last leak 
>>test.
>>The inspector stated that within 10 days was timely, but 14 was not.
>>This is not written in the California code of regulations anywhere that I 
>>can
>>find (California being an agreement state), and I was wondering if anyone
>>knows of similar problems or their resolution.  It seems to me that as 
>>things
>>are it is totally up to the individual inspector to decide what is 
>>reasonable
>>and that the next inspector could be even stricter!  Comments or 
>>suggestions?


To interject a bit of maybe total irrelevance ........

Measuration is a well developed and well defined  discipline.

Once if its provision is to specify the PRESUMED error of a specification 
when not specifically provided.

That default "error" specification is ALWAYS 1/2 the least significant digit 
in the units stated.

THUS - a 6 month interval is by default 6 month +/- 1/2 month and 180 days 
+/- 1/2 day and 6.0 month +/- about a day and a half.

So for this discussion in question - since California State Law says the 
testing interval is not to exceed 6 months - the "grace period" _SHOULD_ 
(and can legitimately be assumed to) be 15 days.

IF legislators wrote GOOD LAW - they would be cognisant of this and such 
would be the case.

But ............