Hot Particles/Un-Productive Surveys

["Greg & Claudia Yuhas" <uhaskep@castles.com>]

Dr. Charles,

The hot particle issue has been driven by power reactors experiencing poor
fuel clad integrity.  The decision to operate plants with poor fuel
activity, but still within the Technical Specification limits for reactor
coolant activity, is a business decision.  One cost in making that decision
is the expense of managing the contamination during outages, spent fuel
handling, and fluid systems maintenance.

The performance of surveys to limit dose from hot particles that may cause
non-stochastic effects should not be considered unproductive exposure.

When I work, I expect to be informed of those hazards which might hurt me so
that I may protect myself.  For example, chemicals in a laboratory, live
electrical circuits, lasers, and other possible sources of non-stochastic
injury, that my senses can't detect, should be labeled or posted.  Employers
are expected to implement policies and procedures that protect employees
from even minor injuries.  Surveys to identify and control these types of
hazards are considered the cost of doing business.

My question is, at what dose, averaged over one square centimeter, is there
a high expectation that the individual will observe a deleterious effect?
One should also consider the impact of that dose should the hot particle
expose the eye, ear or other internal organs.  That being decided, the
survey protocol based on source term, engineering controls, and protective
clothing can be implemented.

Given the litigious nature of the industry, the user should also plan its
survey program to defend itself from claims that dose from hot particles was
unmonitored and that someone's skin cancer resulted from the unmonitored
dose.

The hot particle issue is not limited to power reactors; materials users,
fuel storage facilities, and DOE  activities could be surprised at their
liability if they conducted adequate surveys.

The bottom line is that NRC has struggled with finding a more appropriate
administrative dose limit for highly non-uniform exposure to small areas for
over ten years.  The issue is, will the proposed limit be acceptable to most
workers and the public.

Greg Yuhas


G.P. Yuhas and Associates


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