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)