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)