Section 1.3 of Reg Guide 8.32 directs tritium urinalysis: "...should be performed when an employee can come into skin contact with, ingest, or absorb into the body through cuts, abrasions, or accidental (hypodermic) injection, water or any other substance with concentrations of tritium greater than or equal to 0.01 mCi/kg (0.01 uCi/cc) such as may be common in laboratory applications."
At Ginna, our Reactor Coolant and Spent Fuel Pool tritium concentration both exceed this threshold. Based on Reg Guide 8.32, our procedures direct tritium bioassay for SFP and Reactor Cavity diving evolutions. The question is whether tritium bioassay should also be required for minor skin exposure to this tritium-containing water (for example, a low level skin contamination due to exposure to a few drops of spent fuel pool water)? Do your procedures direct tritium bioassay due to skin exposure to tritium containing water? If so, are there thresholds of exposure below which bioassay is not required? Do you have a basis that you would be willing to share to support your position? Thanks, -Steve Stephen J Holmes, CHP, PE Sr. Plant Health Physicist, CENG-RE Ginna NPP [email protected] 585-771-3577 This e-mail and any attachments are confidential, may contain legal, professional or other privileged information, and are intended solely for the addressee. If you are not the intended recipient, do not use the information in this e-mail in any way, delete this e-mail and notify the sender. -EXCIP
