U.S. Nuclear Regulatory Commission

Question 132: How are nuclear power plant licensees to

identify the "potential" hazard using air sampling

techniques as specified in 10 CFR 20.1703 (a) (3) (i)?

(Air sampling is only useful in hazard identification after

radioactive material becomes airborne).

Answer: 10 CFR 20.1703 (a) (3) (i), which requires that a

respiratory protection program include "air sampling

sufficient to identify the potential hazard . . .", uses

the word "potential" with respect to the hazard because

airborne radioactive material is only a "potential" hazard

to a worker until the worker is exposed to it. Before

workers enter an area containing airborne radionuclides,

the concentrations of these radionuclides should be

estimated using air sampling. This is not a new

requirement (see 10 CFR 20.103 (c) (2). The potential

hazard of radioactive material that may become, but that

has not yet become, airborne can't be identified by air

sampling. The potential hazard must be identified by other

means (e.g., using the experience gained in previous

similar activities that cause radioactive material to

become airborne). Procedures that have been acceptable in

the past for identifying potential hazards of airborne

radioactive material, or of radioactive material that may

become airborne, will continue to be acceptable.

(Reference: 10 CFR 20.1703)