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)