Re: ALARA or Not?

[Judd Sills <sillsj@GAT.COM>]

At 03:23 PM 4/29/97 -0500, you wrote:
>     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)?
>