Health Physics Questions and Answers - Question 374

Question 374: In general, do established respirator effectiveness programs at nuclear power plants meet the intent of the regulation in providing assurances of the effectiveness of chosen respiratory protection?

Answer: Yes. There is no explicit requirement in 10 CFR Part 20 for a "respirator effectiveness program" other than the requirement of 10 CFR 20.1703 (a) (3) (ii) for "surveys and bioassays, as appropriate, to evaluate actual intakes." 10 CFR 20.1704 specifies that the Commission may impose additional restrictions to ensure that the respiratory protection program is adequate and to limit the extent to which a licensee may use respiratory protection equipment instead of process or other engineering controls. The NRC staff does not anticipate a need to impose further restrictions on the use of respiratory protection equipment at nuclear power plants pursuant to 10 CFR 20.1704. Also as indicated in the (revised) answer to Question 54, information from a "respirator effectiveness program" can be used to justify the assumption that the concentrations of radionuclides in air to be used for determining whether or not monitoring is required [pursuant to 10 CFR 20.1502 (b)] are the concentrations that include credit for the assigned protection factors when respirators are to be used, rather than the concentrations without that credit. See the answer to the related Question 376.

(References: 10 CFR 20. 1703, 10 CFR 20.1704, 10 CFR 20.1502)