U.S. Nuclear Regulatory Commission

Applicability of Regulatory Position 1.3 of Regulatory Guide 8.32 to Nuclear Reactor Facilities

HPPOS-233 PDR-9111210342

Title: Applicability of Regulatory Position 1.3 of

Regulatory Guide 8.32 to Nuclear Reactor Facilities

See the memorandum from L. J. Cunningham to J. H. Joyner

(and others) dated February 6, 1991. The memo states that

although there are relatively few workers at nuclear

reactor facilities who meet the criteria of Regulatory

Position 1.3, those employees who can come into skin

contact, ingest or absorb water or other substances with

concentrations of tritium greater than 0.01 mCi/kg must be

identified.

The purpose of this memorandum was to respond to a question

as to whether or not Regulatory Position 1.3 of Regulatory

Guide 8.32, "Criteria for Establishing a Tritium Bioassay

Program," applies to nuclear reactor facilities. As

discussed below, Regulatory Position 1.3 does apply to

nuclear reactor facilities (and other facilities); however,

there are a relatively small number of workers, if any, at

nuclear reactor facilities who meet the criteria of

Regulatory Position 1.3 and, therefore, a relatively small

number of workers, if any, at nuclear reactor facilities

for which bioassay is recommended as a result of Regulatory

Position 1.3.

Table 1 of Regulatory Guide 8.32 has two columns listing

quantities of tritium and a third (right-hand) column

listing concentrations of tritium in water. Regulatory

Position 1.1 refers to the first two (tritium quantity)

columns of Table 1 and does not apply to nuclear reactor

facilities. Regulatory Position 1.2 refers to the third

(tritium concentration) column of Table 1, and, as stated

in the position, applies to nuclear reactor facilities;

however, nothing in Position 1.2 or elsewhere in the guide

indicates that Position 1.2 is the only position that

applies to nuclear reactor facilities. Regulatory

Positions 1.1 and 1.2 are based on considerations of

intakes of tritium, as a gas or vapor, from the air.

Regulatory Position 1.3 supplements Positions 1.1 and 1.2

and is based on considerations of intakes of tritium in the

form of tritiated liquids that pass through the skin.

Regulatory Position 1.3 is applicable to all licensed

facilities, including nuclear reactor facilities, for the

situation described in that position.

Regulatory Position 1.3 is as follows: "1.3. Bioassays

should also 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 micro-Ci/cc)

such as may be common in laboratory applications."

The stipulation "... when an employee can ..." should be

interpreted reasonably. We understand the intended meaning

of this statement to be much nearer to "... when an

employee can reasonably be expected to ..." than it is to

"... when there is even a remote possibility that an

employee can ...." Thus, there are relatively few workers

at nuclear reactor facilities that meet the criteria of

Position 1.3 and those that do meet the criteria must be

identified by radiation protection professionals, based on

considerations of the circumstances of the particular

duties of the workers in a particular plant.

Examples of workers who may meet the criteria of Position

1.3 include, but are not necessarily limited to, (1) divers

in pools of water with tritium concentrations greater than

or equal to 0.01 micro-Ci/cc, and (2) workers who routinely

sample, and may be sprayed with, or otherwise come into

contact with, water with tritium concentrations greater

than or equal to 0.01 micro-Ci/cc.

Regulatory references: Regulatory Guide 8.32

Subject codes: 8.2

Applicability: Reactors