Health Physics Questions and Answers - Question 60

Question 60: In a respiratory protection program what records are needed of evaluations that demonstrate compliance with the requirement for maintaining the total effective dose equivalent ALARA? For example, must such an evaluation be made each time an individual is to wear a respirator?

Answer: Such records need not be made each time someone is to don a respirator. A licensee who performs and records such evaluations in accordance with the following guidance will be considered to be in compliance with the requirements for such evaluations:

1.

(a) If the licensee establishes a reasonable threshold value for prospective deep dose equivalent (rem) for an individual from a task/job below which a record of such an evaluation is not needed, and

(b) the licensee establishes a threshold value for prospective collective deep dose equivalent (person-rem) from a task/job below which the record of such an evaluation is not needed,

(c) in situations in which the licensee plans to use respiratory protection equipment, the licensee does not need to record such ALARA evaluations for situations in which the projected external dose to any individual is below the thresholds established under 1 (a) and 1 (b) above for both the projected individual external dose [1 (a)] and projected collective external dose [1 (b)].

2. If the licensee establishes a threshold value for prospective intake of radioactive material (as a fraction of the ALI or as DAC-hours) for an individual from a task/job below which a record of such an evaluation is not needed, in situations in which respiratory protection equipment is not planned to be used, the licensee does not need to record such ALARA evaluations when the prospective intake is below the threshold.

3. Irrespective of the statements in #1 and #2 above, the licensee does need to perform and record such evaluations for situations to which the ALARA provisions of 10 CFR 20.1703 (b) (1) apply, that is to situations in which it is anticipated that protection factor for the respiratory protection equipment to be provided is less than the multiple by which the peak concentrations of airborne radioactive materials in the working area are expected to exceed the concentrations specified in Appendix B Table 1, Col. 3.

4. Regardless of the magnitude of the projected external dose, the licensee does not need to perform or record such evaluations before requiring the use of respiratory protection equipment as a precautionary measure in situations in which there is a large uncertainty in the magnitude of the projected concentrations of airborne radioactive material to which the workers will be exposed (e.g., a new job with no history of previous similar jobs).

(References: 10 CFR 20.1101 (b), 10 CFR 20.1703)