Re: Leak Testing

[Leo Bobek <bobek@WPI.EDU>]

On Wed, 11 Jan 1995, Sujita Pierpoint wrote:

>   We were tagged for the same offense.  However, we were not allowed
> the 10 day grace period.  Our inspectors said 6 months, not 6 months
> and 1 day.  My solution is to ensure that they are done before the
> magic 6 month date.  So far I have been able to do it, but it may not
> last.  We are also an agreement state, and the requirement comes from
> license restrictions and conditions.  If others have another method,let
> me know also.

Oh those wonderful regulators.  Isn't this one reason most of us voted 
Republican???

More seriously, one possibility is to submit a license change that includes 
definitions of surveillance intervals.  Most, if not all, reactor 
licenses use such definitions in the tech. spec. portion of their license,
i.e., Annual (not to exceed 15 months), Semiannual (not to exceed 7 1/2 
momths), etc.   This avoids the problem of "ratcheting", whereby for each 
surveillance interval you either perform the surveillance on exactly the 
same date or you ratchet back one day.  Obviously, this makes surveillance 
scheduling difficult to manage.  Amazingly, the NRC recognizes this and 
will allow you this flexiblity IF written into your license.  I can't 
speak from experience with state licensing authorities, though.