ALARA or Not?

[barberj@m4lp.com (Jerry Barber)]

     We have recently had a dispute about the intent of 10 CFR 20.1702 
     (shown below). Part of our HP staff is arguing that this section means 
     that a licensee may not allow a Rad Worker into an area where the 
     airborne concentration exceeds 1 DAC without a respirator; unless 
     there are external exposure concerns (i.e., they believe it WOULD be 
     okay to allow and individual to be exposed to >1 DAC air without a 
     respirator if it maintained his/her overall TEDE ALARA).  These staff 
     members do not feel that it is appropriate to consider the cost of 
     respiratory protection in an ALARA cost benefit analysis.  These staff 
     members believe that this IS THE INTENT OF THIS SECTION OF THE REGs, 
     AND THAT THERE IS NO OTHER ROOM FOR INTERPRETATION.
     
     The other staff members feel that if it costs $30 per respirator 
     (including replacing cartridges, washing, ultimate replacement, etc.) 
     that the cost of CEDE avoided should be considered in determining 
     whether respiratory protection is required; even if there is NO 
     significant external exposure concern.  These individuals believe 
     that, for example, based on an assumed $1000 per man rem, respiratory 
     protection is only warranted if it keeps someone from receiving 30 
     millirem (both groups agree that the overall TEDE must be kept ALARA 
     in cases with significant external exposure).  
     
     Both groups understand the importance of using workplace controls to 
     limit airborne in the first place. 
     
     The individuals in the first group have polled 5 facilities by phone 
     (all Nuke Plants) and all 5 agree with them.  I would like to hear 
     from other facilities (both nuclear power and materials licensees).  
     Even an "unofficial opinion" from a regulator would be interesting.  
     Please email me directly unless you feel your response would be of 
     interest to the entire list.
     
     Thanks,
     
     Jerry Barber
     1000 Clearview Ct
     Oak Ridge TN 37830
     (423) 220-7673
     barberj@m4lp.com
     
     Section 20.1702
     
     When it is not practicable to apply process or other engineering 
     controls to control the concentrations of radioactive material in air 
     to values below those that define an airborne radioactivity area, the 
     licensee shall, consistent with maintaining the total effective dose 
     equivalent ALARA, increase monitoring and limit intakes by one or more 
     of the following means
     
     (a) Control of access;
     
     (b) Limitation of exposure times;
     
     (c) Use of respiratory protection equipment; or
     
     (d) Other controls.
     
     Does this imply that it is not ALARA to allow an individual to work in 
     an area where the airborne concentration exceeds 1 DAC or the weekly 
     exposure would exceed 12 DAC-hours per week (the definition of an 
     airborne area)?