DG-8022, Resp. Protection

[Les Slaback <lester.slaback@nist.gov>]

1. Responses to pskierkowski's note were, I think, missing the point.  The
point is that non-radiological risks are explicitly acknowledged to be part
of the risk balancing process.  And once the camel has its nose under the
tent one's expectations of what might follow are a bit clearer.

2. Section C has some very clear, explicit, and (in my opinion) excellent
statements about ALARA, which in effect address the standard-of-care issue.
 ****Question:  Have these appeared elsewhere as an official NRC position
(besides public statements)?

3. In section B it is stated "If a respiratory protection device is
assigned or permitted to be used, the device is considered by the NRC as
being used to limit intakes of airborne radioactive materials unless the
device is clearly *** and exclusively *** used for protection against
nonradiological hazards." [emphasis added is mine]  References to NRC Q&As
are noted.
Since one cannot design a respirator that does not offer some protection
from airborne radioactivity, and this statement seems unconcerned as to how
low the level of the airborne activity might be, in effect this says that
one cannot use a respirator at a licensed facility without having a
NRC-compliant and approved program.  Other words make clear that NRC does
not allow such nonradiological use based on 'intent', but only on the end
result.  As I read this one has two choices, have a NRC approved program or
do not have any respirators in the facility for any reason (unless all you
have are sealed sources).  ****Question:  Is there any experience otherwise?

4. OPINION:  This whole topic of detailed guidance on respiratory
protection seems like a legacy of the 'old days' when avoiding internal
exposure was paramount.  Despite all the words on minimizing TEDE, in
effect 20.1701-3 is micromanagement of mrem exposures.  Internal exposures
are a very small portion of total exposures.  Aside from meeting basic OSHA
safety objectives/requirements (which could be done more simply) this would
seem to be a prime example of misdirected resources of both the regulator
and the licensees. [Said before, but I cannot resist repeating myself when
the opportunity presents itself.]

Disclaimer:  the above are the personal musings of the author, and do not
represent any past, present, or future position of NIST, the U.S. government,
or anyone else who might think that they are in a position of authority. 
Lester Slaback, Jr.  [Lester.Slaback@NIST.GOV] 
NBSR Health Physics 
Center for Neutron Research 
NIST 
Gaithersburg, MD  20899 
301 975-5810
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