U.S. Nuclear Regulatory Commission

Intervals Between Physical Examinations for Respirator Users

HPPOS-219 PDR-9111220025

Title: Intervals Between Physical Examinations for

Respirator Users

See the letter from M. C. Thadani to H. W. Keiser (Senior

Vice President-Nuclear, Pennsylvania Power and Light

Company) dated May 30, 1989. This letter states that

physical examinations for respirator users are prescribed

every 12 months by 10 CFR 20.103 (c) (2). However, a

physical examination conducted every 9-15 months, provided

that three consecutive exams do not exceed 39 months, is

consistent with NRC staff interpretations of interval

requirements. This health physics position also applies to

"new" 10 CFR 20.1703 (a) (3) (v).

A written request was made for exemption from the

requirement of 10 CFR 20.103 (c) (2) regarding the 12 month

time interval for physical examinations to assure an

individual is physically able to use respiratory protective

equipment. Specifically, Pennsylvania Power and Light

Company requested an exemption to permit physical

examinations every 9-15 months, providing that the total

time of the three consecutive physical examinations does

not exceed 39 months.

It was determined that the request was consistent with the

NRC staff's position on implementation of the time interval

requirements of 10 CFR 20.103 (c) (2), and therefore, an

exemption was not needed.

Regulatory references: 10 CFR 20.103, 10 CFR 20.1703

Subject codes: 1.1, 8.10

Applicability: All