U.S. Nuclear Regulatory Commission

Guidance Concerning 10 CFR 20.103 and Use of Pressure Demand SCBA's

HPPOS-094 PDR-9111210195

Title: Guidance Concerning 10 CFR 20.103 and Use of

Pressure Demand SCBA's

See the memorandum from L. J. Cunningham to L. R. Greger

dated September 8, 1983. Personnel having any condition,

including facial hair, that prevents a leak-tight seal and

proper operation, should not be qualified respirator

wearers. For emergency entries, a licensee can use

post-work whole body counts to show compliance with 10 CFR

Part 20 intake limits. The health physics position was

written in the context of 10 CFR 20.103, but it also

applies to "new" 10 CFR 20.1703. HPPOS-116 contains a

related topic.

Guidance was requested concerning 10 CFR 20.103 [or 10 CFR

20.1703] and the use of pressure demand SCBA's. A Region

III licensee's proposed respiratory protection plan to

allow bearded personnel to use pressure demand SCBA's was

discussed with RES and NIOSH. Region III objected to the

licensee's proposal but could find no clear regulatory

basis for the objection. IE supported the objection and

felt there was a strong technical basis for that objection.

IE found several technical flaws in the licensee's proposal

to deviate from the normal industry practice of requiring

clean-shaven faces in the seal area of tight fitting

respirators. One serious problem is the potential to

"overbreathe" (e.g., a person working under heavy physical

stress, such as fire fighting efforts, can exceed the

SCBA's air supply capacity). When a beard-caused leak

exists in the seal area, the additional "makeup" air is

drawn from the outside atmosphere through the leak area.

Another problem is the beards interference with the

operation of the facepiece's exhaust (exhalation) valve. A

beard can hold this valve open, and on a deep breath, could

allow outside, contaminated air to enter the facepiece.

Also, on a normal volume inhalation an open exhaust valve

could allow loss of air, thereby reducing the user's

service time.

A major problem with the licensee's proposal centers on the

high probability for increased outward leakage caused by

beard interference with the seal. The Industrial Hygiene

Support Group at Lawrence Livermore National Laboratory

(LLNL) has noted during testing of bearded personnel that

the SCBA advertised 30-minute air supply (which normally

lasts about 20 minutes) ran out in 10 to 12 minutes at a

moderate work load. As reported in an article, "Facial

Hair and Breathing Protection" (The International Fire

Chief, December 1980): "It must be emphasized again that

facial hair characteristics change daily, so any test of

facepiece fit or how long the breathing air cylinder will

last on one day will be different on succeeding days." IE

and NIOSH believe that a daily quantitative fit test would

probably be required to ensure adequate air supply service

time for bearded users who have facial hair in the seal

area. The administrative costs and problems with such a

program seem to be tremendous.

IE also addressed a specific question on whether 10 CFR

20.103 (a) (3) [or 10 CFR 20.1204 (a)] permits the use of

post-exposure whole body counts to determine compliance

with Part 20 intakes. The regulations allow licensees who

choose not to fully implement the respiratory protection

program of 10 CFR 20.103 (c) (2) [or 10 CFR 20.1703 (a)

(3)] to use respirators, but does not allow them to take

any credit for protection factors [see 10 CFR 20.1204 (b)].

IE feels this is a reasonable position from the perspective

of providing workers protection during routine, planned

operations in airborne radioactivity areas. For these

operations, the degree of hazard can be pre-determined by

air sampling, and licensees can then assume no protection

factors and limit the stay time such that administrative

intake "overexposures" should not occur. However, the case

for fire fighters differs drastically.

Prompt emergency response does not lend itself to pre-work

assessment of airborne hazards. In emergency situations,

it is clearly illogical to take a "no-protection"

assumption for entry into IDLH areas of unknown hazards.

In the case of fire fighters, exposure to radioactive

materials is generally of secondary importance, and toxic

fumes / gases are the principal hazard. However, a strict

legal reading of the regulations leads us to conclude that

nothing prohibits using post-work whole body counts for

demonstrating compliance with Part 20 limits. From a

routine radiological perspective, IE is comfortable with

this reading; however, in the case of unqualified

respirator wearers performing emergency response actions in

high risk areas with the attendant unknown level of

protection, IE strongly believes the regulations should

require high quality respiratory protection.

Regulatory references: 10 CFR 20.103, 10 CFR 20.1204, 10

CFR 20.1703

Subject codes: 8.2, 8.4, 8.10

Applicability: All