Re: time definitions-reply

[SKorc007@aol.com]

In a message dated 7/12/98 11:29:07 AM Eastern Daylight Time,
cpt_daniel_hamilton@WBAMC.SMTPLINK.AMEDD.ARMY.MIL writes:

<<  Written clarification was provided in a general 
      presentation given by Scott Moore, NRC, on "Time Requirements":
      
          Annual:  Once each year, anytime during the year, e.g. performing  
          an action on 1/1/90 and then again on 12/31/91 meets annual.
      
          Year:  Year must begin in January. Start date may change if made   
          at beginning of the year and if no day is omitted or duplicated in 
          consecutive years.
      
          Quarterly:  Once each quarter, anytime during the quarter.
      
          Quarter:  One-fourth of the year, beginning the first quarter on   
          the start date of the year.
      
      Also see 10 CFR Part 20.1003, Definitions. Hope this helps. >>

I have had this discussion with my partner for a while now.  I contend that
while this is fine for Part 20, it sheds no light on Part 35 requirements.
For example, a sealed source leak test is required every six months.  While I
believe that doing it February 1st and August 31st would meet the requirement,
I have never gotten an "official" ruling on this by NRC.  The same goes for
quarterly Radiation Safety Committee meetings  and linearity checks, etc.

In the end, since no definition is in Part 35, it depends on the inspector
being reasonable.  If your sealed source leak tests have been conducted every
February and August for the previous five years, I think a reasonable
inspector wouldn't cite you for being more than 182 days out, but it would
sure be nice to get someone from NRC to answer this one.

Stu Korchin
Radiation Protection Services
265 Highland Avenue
Cheshire CT 06410
SKorc007@aol.com