View source for Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be as Low as Is Reasonably Achievable

{{Adams
| number = ML13350A229
| issue date = 07/31/1973
| title = Information Relevant to Maintaining Occupational Radiation Exposure as Low as Practicable (Nuclear Reactors)
| author name = 
| author affiliation = US Atomic Energy Commission (AEC)
| addressee name = 
| addressee affiliation = 
| docket = 
| license number = 
| contact person = 
| document report number = RG-8.008
| document type = Regulatory Guide
| page count = 4
}}
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tIREGULATORY
UL :Y DiRECTORATE 
OF REGULATORVY 
SAD-ARDS REGULATORY 
GUIlDE4.8:.8 July 1973 G UIDE)RMATION RELEVANT.

TO 
IONAL RAD IATION EXPOSURE AS LOW-AS.PRACTICABLE (NUCLEAR REACTORS)A.:INTiODUCTION
lPalgraph.

20.() of.:10 CFR Part 20-states that:..licensees should, in* addition to complying with the limits set forth in :that part,. ake every reasonable effort to maintain radiation exposures, and releases: 
of"raioactive, materials 
'in :effluentS.tO 
unrestricted areas, as -far below the limits specified in that part as practicable.

This'guide outlines the information needed:in .license applications and safety analysis reports (SAR)for nuclear reactors concerning the maintenance
.. of oc'cupational doses as low as practicable (ALAP).

==B. DISCUSSION==
The objective o f efforts to 'ensure that occupational exposures, are ALAP is to further ,reduce:avoidable exposurcs and therebyjreduce.

the:low risks that are presumed to result from small, doses. It.thas long, been recognized by radiation control professionals that iti.is prudent to avoid unnecessary. -exposure: 
and to .hold doses ..as :low0. as practicable.

Piacticability is determined.. 
by the- state, of techuiologY 
and the economics of. improvements in raIlationi to the'benefits from, these improvemen s.The": available data suggest..that past efforts have been.. relatively successful.

in' that,- enerallys in .AEC l-,icensed activities, occupational' 
exposures haie. been wellibelow0 
the applicable.limnits..of 
10 CFR Part 20.' ,2 Thus,. the provisions of this.guide are not intended to.,precipitate dramatic departures from past practice.Rather, they are intended to promote a more formal approach to keeping doses ALAP, to identify, and promote continuance " of. good practices, and to promote further improvements where practicable.

The: .
of lineatity bv wcen do.se -,rid respornse,"recmmnended again by the Biulogical Effects of loni7ing Radiation 
.(BEIR) committee." mdi-alcs concern, about :both population 
'dose and individwlk" doses. This it is; not. sufficiei nierulyv to control maximum dose to individuals; 
the total dose to the group (melasured in .man-rem) 
must be kept as low as practicable.

It. would be inappropriate it) hold the individual doses to a fraction of the applicable limit it.this .resulted in the irradiatiun of more people und increased the total. man-remi dose.Effective contrul of: radiation exposure involves the major considerations*
1. 'Management.cOmniitment and support;2.. Careful:design of facilities and equipment: 
and.3:.. Good radiation protection practices, including good planning and the proper use .of appropriate equipment by qualified, well-trained personnel.

C. REGULATORY 
POSITION'Detailed information, as outlined in subsequent sections of tils guide,.should be provided in the license application about, each of the above major considerations.

i. 'Management Philosophy and Organization.

Maintaining occupational exposures.

at the lowest practicablie level requires management commitment.

A clear statement of operating philosophy regarding occupational radiation exposure should be included' 
in the license application (or SAR) and reflected in the licensee's facility design, policy documents, and written operating procedures and close and continuing management followu

====p. USAEC REGULATORY ====
GUIDES Reguist" Gulden ie Inued' t de..t...b and' uakes avaihele' 
to'the public nmanhodgtcteptable to the AEC PlegulatofY 
stall of implemenlting specific Part$ ofton'ts reguliaonsl. .to dellineate tchnique' .used by the staff. In l .em.a ostustad'acidents; 
of to prOVt, guidance to ,tpU.k ae.., 
u 41 .s not' Wterlitutal for raegulatioi and complialnc with tem .h-not rquired-.. 
Meth)= and solutions different from thosa Wtut In th" *l ldetyttl be If they pr6owide a beth for the findingll "quISIt to the hauntta or tontituefla of.s permit or lictnse by the Commision.

llauttieftd 
' pidet wioltbe- rose..d periodically, asapitaO.Ojwrvdatt comments mid to reflect row information r experience*
Coone l of pubtihi guides may be obtained by fequett indicating the divitsont desired to the. US, Atomic Energy Co.,iuon, , Washlrolal D.. 20545.Attention: 
Director of R4egulC01fY.Stadthls.

Commenfts and tuggirstiontfor Inp ostte nts in theta guide are encouraged end thould be sent to the Secretary of the Commission, U.S. Atomic Energy Commission.

Washinton.

DC. 20545.Attaenion: 
Chief. Public Proceedings Staff.1.P0V~tRa dO 8. ProduJct'2.' Sneirch andt Test Re~ti.orn 
7. Tramnc.-ti
2. 'uels andlMaterials IF.-Xlties 
6.cjccufrt'n
5; Materials arsd Plant Proiect~o 
10. cervill tinn WL. etv- AI A specific individual (i.e., the health physics chief or manager) should be given explicit responsibility and authority i'or ensuring that exposures are ALAP. He should be directly responsible to someone at a high management level. The health physics group should not be a part of operations- or production-oriented divisions.

A nmember of upper management should be given responsibility for ensuring that the ALAP policy is implemented.

He should conduct periodic reviews of procedures and practices for achieving ALAP exposures, 2. Personnel Qualification and Training The individual responsible for recommending and implementing the radiation control program (i.e., the healdt physics chief or manager) should be a professional of recognized competence in this field, preferably with power reactor experienc,. 
Where this individual does not have qualifications equivalent to those required for certification by the American Board of' Health Physics. he should be supported by and have available immediate access to one (or more) consultant and/or staff member who is so qualified and who is in the facility at least once a month. Company commitment to this principle should be stated in the license application.

Any person whose duties entail entering restricted areas or directing the activities of others who enter restricted areas should be instructed in the fundamentals of health physics and should be made aware of, and given the authority to implement, the licensee's commitments for maintaining doses ALAP in his areas of responsibility.

His training should be commensurate with his duties and responsibilities as well as the degree of radiation hazard anticipated.

Personnel policies should include screening to ensure that radiation workers are responsible and conscientious and qualified to perform their duties safely.Personnel whose duties do not entail entering restricted 
-.reas should be (1) made aware of the reasons for keeping out of restricted areas and (2)denied access to restricted areas.Personnel responsible for the design or approval of facilities including restricted areas or equipment for use in restricted areas should (I) receive instructions in the fundamentals of health physics including the importance of maintaining doses ALAP and (2) have ready access to and use a competent professional health physicist.

3. Facility and Equipment Design Radiation exposures may be minimized by proper design of facilities and equipment.

This requires a definite commitment by the applicant to provide preliminary and periodic design reviews by competent health physicists (with the support of other specialists)
before and during construction specifically to ensure that occupational exposures will be ALAP.Since a major portion of the occupational radiation dose is received during niaintenance, inservice inspection, refueling, and nonroutine operations (including activities complicated by leakage and spillage of ra&#xfd; oactive materials), these activities warrant special attention during design. Also, decommissioning can involve serious radiation exposures and should be considered during design. Designs should be reviewed to ensure that provisions have been included to achieve ALAP exposures in these situations.

Specifically, the license application (at the PSAR stage) should provide information demonstrating that: a. Equipment which may require servicing will be designed and located to minimize service time;b. Instruments requiring in situ calibration will be located in the lowest practicable radiation fields-c. Equipment and components requiring servicing will be located in or designed to be movable to the lowest practicable radiation fields-d. Best available valves, Valve packing, and gaskets will be used to minimize leakage and spillage of radioactive materials- e. Penetrations of shielding and containment walls by ducts and other openings will be designed to minimize exposure and that shield design specifications will limit void content;f. Radiation sources and occupied areas will be separated if possible (in particular, pipes or ducts containing potentially highly radioactive fluids will not pass through occupied areas), g. Precautions will be provided (1) to minimize the spread oh' contamination and (2) to facilitate decontamination in the event spillage occurs;h. Interior surfaces as well as the layout of ducts and pipes will be designed to minimize buildup of contamination;
t. Systems which may become contaminated will be designed to include provisions for flushing or remote chemical cleaning prior to servicing;
j. The ventilation system will be designed to ensure control of airborne contaminants, especially during maintenance operations when the normal air flow patterns may be disrupted (e.g., open access portals);k. Wherever practicable, radiation and airborne contamination monitoring equipment with remote readout will be *included in areas to which personnel normally have access (where special conditions warrant, portable instrumentation may be substituted);
1. The ventilation system will be d&signed for easy access and service to keep doses ALAP during alterations, maintenance, decontamination, and filter changes;8.8-2 ip*1 m. Where practicable, shielding will be provided etween radiation sources and areas to which personnel may have normal or routine access, and shielding will be designed for maintaining doses ALAP;n. Movable shielding and convenient means for its utilization will be available for use where permanent shielding is needed but impractical;
o. Adequate shielding will be provided for radioactive wastes;p. Remote handling equipment will be provided wherever it is needed antl practicable:
q. All design features for radiation control will be designed to accommodate maximum expected (technical specification limit) failures such as fuel element cladding and steam generator failures; 
and r. Sampling sites will be located so exposures will be ALAP during such routine operations as sampling offgas, primary coolant, and liquid waste.4. Plans and Procedures Considerable dose reduction may be achieved through a carefully conceived and properly implemented planning and procedures program. As stated previously, a major portion of the occupational radiation dose is received during the activities of maintenance, inspection, refueling, and nonroutine operations.

It is therefore essential that approaches to Atlese activities involve a program of careful planning d preparations, use of well.trained and qualified prsonnel, and utilization of spec,-ific exposure reduction techniques as circumstances allow.Procedures governing implementation of such a program should be developed and included as routine operating procedures.

As such, the license applications should include (1) at the PSAR stage, a commitment to and guidelines for providing these procedures and (2) at the FSAR stage. a description of the procedures to be utilized for maintaining exposures ALAP. The procedures proposed in the applications should project exposures for various groups as well as identify sources, source strength, radiation levels, and contamination levels and include plans to: a. Minimize source strength and contamination levels by flushing tanks, lines, etc., prior to performing the operation;
b. Minimize radiation levels in the work area by use of permanent and/or movable shielding;
c. Minimize airborne contamination by proper use of the ventilation system, including purging area before entering temporary ducts into the work area, and other modifications as appropriate;
d. Further minimize inhalation of radioactive materials by the proper use of state-of-the-art respiratory protection:
e. Ensure that the task is completed with the least practicable time in .the radiation field (the availability and use of all appropriate tools and equipment, as well as the conduct of "dry runs." are especially important);
f. Complete the task with the fewest people in the radiation field consistent with safe operalion g. Cope as expeditiously as possible with fires.spills. equipment failure, and oilier accidents which may occur;h. Use remote handling equipment and other special tools which can help reduce external dose: i. Provide adequate supervision and monitorinig to ensure (hat procedures are followed.

that the planned and proper precautions are taken, and that all the radiation hazards are identified;
j. Provide personnel monitoring eqti.pmeint such as direct reading pocket dosimeters or pocket aliarm meters, which will permit early evaluation of individual doses and the association of personnel exposure with specific operations (see Regulatory Guide 8.4);k. Provide contamination control procedures to achieve ALAP exposures;
1. Ensure that radiation and contamination monitoring instruments are tested and calibrated correctly and frequently enough to provide a high degree of confidence in the data they provide (see Regulatory Guide 8.6);m. Conduct postoperational debriefings to improve plans, identify shortcomings, and determine whether ALAP was achieved: n. Maintain records including exposure data.contamination problems, airborne hazards, and internal exposure data as shown by bioassay analyses and whole body counters that will be helpful in providing guidance for future similar operations (see Regulatory Guide 8.7);o. Perform as much work as practicable outside radiation areas;p. Minimize personnel radiation exposures by planning for access to and exit from work areas and by providing service lines and work area communications prior to beginning the work;q. Consider the use of special tools or jigs which could reduce radiation exposure through simplification, reduction in time, or reduction of mistakes;r. Post radiation levels in the work area so that the areas of highest and lowest radiation level are clearly identifiable;
s. Minimize disconifort of workers so that efficiency will be increased and less time will be spent in radiation areas; and t. Estimate total man-remn to be expended on large jobs and set man-rem goals.8.8-3 REFERENCES
I. A. W. Klemenm. Jr.. C. R. Miller. R. P. Mluix and U. Shleicn. "Estimates of Ionizing Radiation Doses in the United States Environnetital Protection Agency Report ORP;CSI) 72-1, August 1072.2. "Fourth Annual Report of the Operation of the US. Atomic Energy Commission's Central Repository of Individual Radiation Exposure Inf'ormalion," USAEC Repor

====t. September ====
1972.3. C. L. Comar, Chmn. NAS-NRC 1EIR Committee.

'"he Effects on Populations of txposure Io Low I.evels of Ionizing Radiation." National Academy of S,'iences-National Research Council, Washington.

D.C. 1972.8.8-4}}

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