Regulatory Guide 8.37

(Draft Issued as DG-8013) ALARA Levels for Effluents from Materials Facilities

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Issue date:	07/31/1993
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U.S. NUCLEAR REGULATORY COMMISSION

REGULATORY

July 1993 GUIDE

OFFICE OF NUCLEAR REGULATORY RESEARCH

REGULATORY GUIDE 8.37 (Draft issued as DG-8013)

ALARA LEVELS FOR EFFLUENTS FROM MATERIALS FACILITIES

A.

INTRODUCTION

In 10 CFR Part 20, "Standards for Protection Against Radiation," § 20.1302(b) requires that:

"A licensee shall show compliance with the annual dose limit in

§ 20.1301 by (1) Dem onstrating by measurement or calculation that the total effective dose equivalent to the indi vidual likely to receive the highest dose from the licensed operation does not exceed the annual dose limit; or (2) Demonstrating that (i) The annual average concentrations of radioactive material released in gaseous and liquid effluents at the boundary of the unre stricted area do not exceed the values speci fied in Table

2 of Appendix B

to

§§ 20.1001-20.2401; and (ii) If an individ ual were continually present in an unrestricted area, the dose from external sources would not exceed 0.002 rem (0.02 mSv) in an hour and 0.05 rem (0.5 mSv) in a year."

in addition, 10 CFR 20.1101(b) requires that:

"The licensee shall use, to the extent practica ble, procedures and engineering controls based upon sound radiation protection princi ples to achieve occupational doses and doses USNRC REGULATORY GUIDES

Regulatory Guides are issued to describe and make available to the pub lic such information as methods acceptable to the NRC staff for imple menting specific parts of the Commission's regulations, techniques used by the staff in evaluating specific problems or postulated acci dents, and data needed by the NRC staff in its review of applications for permits and licenses. Regulatory Guides are not substitutes for regula tions, and compliance with them is not required. Methods and solutions different from those set out in the guides will be acceptable If they pro vide a basis for the findings requisite to the issuance or continuance of a permit or license by the Commission.

This guide was Issued after consideration of comments received from the public.

Comments and suggestions for improvements in these guides are encouraged at all times, and guides will be revised, as ap propriate, to accommodate comments and to reflect new information or experience.

to members of the public that are as low as is reasonably achievable (ALARA)."

This regulatory guide provides guidance on de signing an acceptable program for establishing and maintaining ALARA levels for gaseous and liquid ef fluents at materials facilities. Materials facilities are those facilities at which the possession or use of source, byproduct, or special nuclear material is licensed under 10 CFR Parts 30, 40, 60, 61, and 70.

Additional guidance on ALARA programs can be found in other regulatory guides. While these guides deal primarily with occupational exposure and may be specific to one type of licensee, they contain pro grammatic information that may be useful to all licen sees. They are as follows:

"

Regulatory Guide 8.10, "Operating Philoso phy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achiev able." This guide delineates the components of an ALARA program.

"* Regulatory Guide 8.18, "Information Rele vant to Ensuring that Occupational Radiation Exposures at Medical Institutions Will Be As Low As Reasonably Achievable."

"

Regulatory Guide 8.31, "Information Relevant to Ensuring that Occupational Radiation Ex posures at Uranium Mills Will Be As Low As Is Reasonably Achievable."

Written comments may be submitted to the Regulatory Publications Branch, DFIPS, ADM, U.S, Nuclear Regulatory Commission, Washing ton, DC 20555.

The guides are issued in the following ten broad divisions:

1, Power Reactors

6. Products

2. Research and Test Reactors

7. Transportation

3. Fuels and Materials Facilities

8. Occupational Health

4. Environmental and Siting

9, Antitrust and Financial Review

5. Materials and Plant Protection

10, General Copies of Issued guides may be purchased from the Government Printing Office at the current GPO price, Information on current GPO prices may be obtained by contacting the Superintendent of Documents, U.S.

Government Printing Office, Post Office Box 37082, Washington, DC

20013-7082, telephone (202)512-2249 or (202)512-2171.

Issued guides may also be purchased from the National Technical Infor mation Service on a standing order basis. Details on this service may be obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161.

9 Regulatory Guide

10.8,

"Guide for the Preparation of Applications for Medical Use Programs." Section 1.3 and Appendix G deal specifically with ALARA programs for medi cal facilities.

In addition, further information can be found in Revision 1 to NUREG-0267, 1 "Principles and Prac tices for Keeping Occupational Radiation Exposures at Medical Institutions As Low As Reasonably Achievable" (October 1982).

Any information collection activities mentioned in this regulatory guide are contained as requirements in 10 CFR Part 20, which provides the regulatory ba sis for this guide. The information collection require ments in 10 CFR Part 20 have been approved by the Office of Management and Budget, Approval No.

3150-0014.

B.

DISCUSSION

At the relatively low levels of radiation exposure in the United States, it is difficult to demonstrate a relation between exposure and any health effects.

The dose limits in 10 CFR Part 20 are based on limit ing dose to what is considered to be an acceptable level of risk to the exposed individual. Still, any ra diation exposure may carry some risk. Thus, the NRC

requires licensees to take actions, to the extent practi cable, utilizing procedures and engineering controls to further reduce risk below the levels implicit in the dose limits in keeping with the principle that expo sures should be as low as is reasonably achievable.

This is the goal and purpose for radiation protection programs. In order to achieve this goal, licensees must control the way radioactive material is handled from receipt through disposal.

NRC licensees have traditionally reduced expo sures and effluents to small fractions of the dose limits using the ALARA process. Recently, the Environ mental Protection Agency (EPA) conducted 2 studies of materials facilities. The first was a survey of 367 randomly selected nuclear materials licensees. The highest estimated dose to a member of the public from effluents was 8 mrem/yr, based on very conser vative modeling. In addition, 98% of the facilities ex amined had doses to members of the public resulting from effluents less than 1 mrem/yr. The second study evaluated effluents from 43 additional facilities that were selected because of their potential for effluent releases resulting in significant public exposures. Of these, none exceeded 10 mrem/yr to a member of the public, and 75% of them were less than 1 mrem/yr to a member of the public. Based upon this information, and the ongoing NRC program of licensing and in spection, the NRC expects that the goals suggested in

'Copies are available for purchase from the U.S. Government Printing Office, P.O.

Box

37082, Washington, DC

20013-7082, telephone (202) 512-2249 or (202) 512-2171.

this guide will be easily achievable by all NRC materi als licensees.

The NRC staff will be examining licensee pro grams to determine compliance with the requirements of 10 CFR Part 20. In the event that a particular ma terials facility licensee establishes ALARA goals that are less stringent than the goals identified in this guide, or consistently fails to achieve ALARA goals it has established pursuant to this guide, the NRC staff will conduct a more detailed review of that licensee's program to determine the rationale for the greater levels. In such circumstances, the NRC will evaluate the rationale provided by the licensee, as well as the licensee's operations, to determine whether the licen see has established an adequate ALARA program and is operating that program in compliance with 10

CFR 20.1101(b).

This guide deals with only a part of a licensee's overall radiation protection program. Specifically, it deals with the application of ALARA in controlling gaseous and liquid effluents. In addition to controlling doses resulting from the release of effluents, licensees must implement a radiation protection program that controls dose rates in unrestricted areas to maintain overall doses to workers and members of the public ALARA and below the limits in 10 CFR Part 20. Li censees may choose to focus their evaluation of pub lic dose to members of a critical group as suggested by the International Commission on Radiological Protec tion (ICRP) as a means of identifying and controlling the exposure to the individual member of the public likely to receive the highest exposure.

NRC licensees have taken actions to maintain doses to both workers and members of the public ALARA

under the admonition contained in

10 CFR 20.1(c), 2 which requires that licensees

"make every reasonable effort" to maintain doses and effluents ALARA. NRC licensees have generally reduced doses to relatively small fractions of the dose limits. Therefore, the NRC staff does not expect that most licensees will need to make significant changes to procedures, operations, and equipment in order to be in compliance with the requirements of 10 CFR

20.1101(b). 2 However, for those licensees who have not previously developed a radiation protection pro gram that includes written procedures and policies as well as a commitment to ALARA, additional steps may be necessary to demonstrate compliance with requirements now explicit in 10 CFR Part 20 to main tain doses ALARA.

Components of an effective radiation protection program, as required by 10 CFR 20.1101 (b), include radiation exposure control, written procedures and

2In June 1991, 10 CFR Part 20 §§ 20.1001 through 20.2401 became effective, and compliance with these sections be comes mandatory on January 1, 1994. However, 10 CFR Part

20 §§ 20.1 through 20.601 became effective in 1957 and re mains in effect until January 1, 1994, or when licensees vol untarily implement the requirements of 10 CFR Part 20 §§

20. 1001 through 20.2401, whichever is earlier.

8.37-2 I

policies, control of radioactive materials, radioactive contamination control, radioactive waste manage ment, training, program reviews, and audits. Guid ance on other facets of a radiation protection pro gram for materials facilities is currently under devel opment.

C.

REGULATORY POSITION

An ALARA program for effluent control to con trol doses to members of the public should contain the following program elements:

1. Management commitment to ALARA, includ ing goals,

2. Procedures, engineering controls, and process controls,

3. Surveys and effluent monitoring,

4. ALARA reviews,

5. Worker training.

These program elements, while given specifically for effluents in this guide, are also applicable to the control of direct exposure.

1. MANAGEMENT COMMITMENT TO

ALARA, INCLUDING GOALS

The single most critical aspect of successfully achieving ALARA in the radiation safety program is the commitment of management to maintain doses ALARA, both occupational and to the public. The licensee's radiation protection program (including ALARA elements) should be commensurate with the potential hazards associated with the licensed activity.

1.1 ALARA Policy The licensee should establish an ALARA policy that is issued and supported by the highest level of management. All employees should be made aware of the ALARA policy through training. This policy should make clear that all personnel will be responsi ble for ensuring that work they perform is in accor dance with ALARA procedures.

1.2 ALARA Goals To assist in demonstrating compliance with the requirements of 10 CFR Part 20, the licensee should set ALARA goals for effluents at a modest fraction of the values in Appendix B, Table 2, Columns 1 and 2, to §§ 20.1001-20.2401. These goals may be set independently for gaseous and liquid effluents. Past experience and effluent information reported to the NRC staff indicate that goals within a range of 10 to

20% of Appendix B values or less can be achieved by almost all materials facility licensees. However, estab lishing a goal is not intended as setting a precedent or a de facto limit. Goals may need to be adjusted up or down on the basis of the annual review of what may be ALARA for the particular circumstance.

If the licensee chooses to demonstrate compli ance with 10 CFR 20.1301 through a calculation of the total effective dose equivalent (TEDE) to the in dividual likely to receive the highest dose, the licen see should set the ALARA goal at a modest fraction of the dose limit for members of the public. Experi ence indicates that values of about 0.1 mSv/yr (10

mrems/yr) or less should be practicable for almost all materials facility licensees. Licensees need not as sume worst case models when calculating dose but rather should make assumptions that will result in re alistic estimates of actual dose received by the mem ber of the public likely to receive the highest dose.

If the circumstances of a particular case are such that the licensee cannot achieve effluent concentra tions less than 20% of the Appendix B values or dem onstrate by calculation that the TEDE to the individ ual likely to receive the highest dose is less than 0.1 mSv/year (10 mrems/year), the ALARA philosophy continues to apply, and the licensee should demon strate compliance with the requirements of 10 CFR

20.1101(b) by evaluating procedures, engineering controls, and process controls as described in Regula tory Position 2 below.

1.3 Investigation Levels In addition to ALARA goals, the licensee should establish investigation levels at effluent values that are close to normal or anticipated release levels. If ex ceeded, an investigation should be initiated and cor rective actions should be taken, as appropriate.

1.4 Radiation Safety Committee For licensees that have a radiation safety commit tee, one responsibility of that committee should be to establish ALARA goals. The committee must meet at least annually to review the radiation protection pro gram content. The committee should also review ALARA goals and discuss ways to further reduce doses if necessary. Goals may need to be adjusted on the basis of the committee's review. The committee should assess short-term and long-term performance in terms of achieving the ALARA goal

s. ALARA

goals and the results of reviews should be reported at least annually to senior management with recommen dations for changes in procedures or equipment needed to accomplish the requirements of the ALARA policy as appropriate.

For licensees with no radiation safety committee, the radiation safety officer should be responsible for setting, adjusting, and periodically reviewing the ra diation protection program and the ALARA goals.

2.

PROCEDURES, ENGINEERING

CONTROLS, AND PROCESS CONTROLS

Licensees should consider available engineering options to control the release of effluents to the

8.37-3

environment. Examples of the available options in clude filtration, encapsulation, adsorption, contain ment, and the storage of liquids for decay. If further reductions in effluents are needed to achieve ALARA

goals, the recycling of process fluids, leakage reduction, and modifications to facilities, operations, or procedures should be considered.

These modifications should be implemented unless an analy sis indicates that a substantial reduction in collective dose would not result or costs are considered unrea sonable. A determination of reasonableness may be based on a qualitative analysis requiring the exercise of judgment and consideration of factors that may be difficult to quantify. These factors could include nonradiological social or environmental impacts, the availability a-nd practicality of alternative technolo gies, and the potential for unnecessarily increasing occupational exposures.

Alternatively, reasonableness may be based on a quantitative cost/benefit analysis. Preparation of an ALARA cost/benefit analysis requires the use of a dollar value per unit dose averted. The NRC staff is conducting a review and analysis of various methodo logical approaches to setting dollar values, and the staff recognizes that varying degrees of justification exist for a wide range of dollar values. However, the value of $1000 per person-cSv (man-rem) is accept able to the NRC staff and may be used pending com pletion of that reassessment.

3.

SURVEYS AND EFFLUENT MONITORING

Licensees must perform surveys and monitoring sufficient to demonstrate compliance with the requirements of 10 CFR 20.1302. This includes the monitoring and surveys that may be necessary to de termine whether radiation levels and effluents meet the licensee's established ALARA goals. These sur veys should include air and liquid effluent monitoring, as appropriate, as well as surveys of dose rates in un restricted areas.

If the licensee chooses to demonstrate compli ance with dose limits to the member of the public likely to receive the highest dose by calculating the TEDE, all significant environmental pathways should be evaluated. Some of the equations included in Regulatory Guide

1.109,

"Calculation of Annual Doses to Man From Routine Releases of Reactor Ef fluents for the Purpose of Evaluating Compliance with

10 CFR Part 50, Appendix I," and Regulatory Guide

3.51, "Calculational Models For Estimating Radiation Doses to Man from Airborne Radioactive Materials Resulting from Uranium Milling Operations," may be useful in performing dose assessments. However, pending the anticipated revision of these regulatory guides, the dose conversion factors should be based on the methodology described in ICRP 30, "Limits for Intakes of Radionuclides by Workers."3

3.1 Airborne Radioactive Effluent Monitoring When practicable, releases of airborne radioac tive effluents should be from monitored release points (e.g., monitored stacks, discharges, vents) to ensure that the magnitude of such effluents is known with a sufficient degree of confidence to estimate public ex posure. Licensees should verify the performance of effluent monitoring systems by regular calibration (at least annually) to ensure that these monitors provide reliable indications of actual effluents. Further guid ance can be found in Regulatory Guide 4.15, "Qual ity Assurance for Radiological Monitoring Programs (Normal Operations)--Effluent Streams and the Envi ronment."

Effluent monitoring systems should be designed in accordance with ANSI N13.1 (1969), "Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities," 4 and ANSI N42.18, "Specification and Performance of On-site Instrumentation for Continu ously Monitoring Radioactive Effluents." 4 NCRP Commentary No. 3, "Screening Tech niques for Determining Compliance with Environ mental Standards," 5 published in January 1989 and the addendum published in October 1989 provide ac ceptable methods for calculating dose from airborne radioactive effluents. In addition, there are several computer codes available that perform these calcula tions. Licensees may use such computer codes as long as they can demonstrate that the code uses approved methods.

3.2 Liquid Effluent Monitoring effluents should be monitored.6 Methods for calculat ing doses from liquid effluents similar to those de scribed in NCRP Commentary No. 3 are currently un der development by the NCRP. In the interim, guid ance available in Regulatory Guide 4.14, "Radiologi cal Effluent and Environmental Monitoring at Ura nium Mills," and Regulatory Guide 4.16, "Monitor ing and Reporting Radioactivity in Releases of Radio active Materials in Liquid and Gaseous Effluents from Nuclear Fuel Processing and Fabrication Plants and

3Copies are available from Pergamon Press, Inc., 660 White Plains Road, Tarrytown, NY 10591-5153, phone (914)

594-9200.

4Copies of ANSI standards may be obtained from the Ameri can National Standards Institute, Inc., 1430 Broadway, New York, NY 10018.

"5Copies may be purchased from the National Council on Ra diation Protection and Measurements, NCRP Publications,

7910 Woodmont Avenue, Bethesda, MD 20814.

8Liquid effluents do not include releases into sanitary sewerage in accordance with 10 CFR 20.2003(a) or excreta from pa tients in accordance with 10 CFR 20.2003(b).

8.37-4 I

Uranium Hexafluoride Production Plants," may be useful to materials licensees in calculating doses from liquid effluents.

3.3 Unmonitored Effluents If a licensee has release points for which monitor ing is not practicable, the licensee should estimate the magnitude of the unmonitored effluents. For in stance, a research hospital or university broad scope licensee might have dozens of locations where radio active material could be released. The licensee should estimate the magnitude of unmonitored releases and include those estimated amounts when demonstrating compliance with dose limits and the licensee's ALARA goals. Unmonitored releases may be esti mated based on the quantity of material used in these areas or the number of procedures performed or other appropriate methods.

When practicable, unmonitored effluents should not exceed 30% of the total estimated effluent releases.

4.

ALARA REVIEWS

According to 10 CFR 20.1101(c), the content and implementation of the radiation protection programs, which would include the ALARA effluent control program, must be reviewed at least annually.

This review should include analysis of trends in release concentrations and radionuclide usage as well as other available monitoring data. The review should provide a documented basis for determining whether changes are needed in systems or practices to achieve ALARA effluent goals.

In addition, the licensee should review all designs for system installations or modifications to ensure compliance with

10 CFR 20.1101(b). The results of ALARA reviews should be reported to senior management along with recommendations for changes in facilities or proced ures that are deemed necessary to achieve ALARA

goals.

5.

WORKER TRAINING

Specific training on ALARA should be provided as a part of the annual employee radiation protection training (see 10 CFR 19.12). For an ALARA pro gram to be successful, employees must understand the ALARA program's goals and principles. The radiation protection staff should be available to help clarify the ALARA policy and its goals and to assist employees both during training and throughout the year.

D.

IMPLEMENTATION

The purpose of this section is to provide informa tion to applicants and licensees regarding the NRC

staff's plans for using this guide.

Except in those cases in which an applicant pro poses an acceptable alternative method for complying with specified portions of the Commission's regula tions, the methods described in this guide will be used in the evaluation of applications for new ]icenses, li cense renewals, or license amendments and for evalu ating compliance with 10 CFR 20.1001-20.2401.

8.37-5

REGULATORY ANALYSIS

A separate regulatory analysis was not pre pared for this regulatory guide. The regulatory analysis prepared for 10 CFR Part 20, "Standards for Protection Against Radiation" (56 FR 23360),

provides the regulatory basis for this guide. A copy of the "Regulatory Analysis for the Revision of 10

CFR Part 20" (PNL-6712, November 1988)

is available for inspection and copying for a fee at the NRC Public Document Room, 2120 L Street NW.,

Washington, DC, as an enclosure to Part 20.

8.37-6

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