U.S. Nuclear Regulatory Commission

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)