ML003739563

1975/09/30-Regulatory Guide 8.10, Revision 1-R, Operating Philosophy for Maintaining Occupational Radiation Exposures as Low as Is Reasonably Achievable

ML003739563
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Issue date:	09/30/1975
From:	Office of Nuclear Regulatory Research
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Reg Guide 8.10, Rev 1-R
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Revision 1-R U.S. NUCLEAR REGULATORY COMMISSION September 1975 REGULATORY GUIDE OFFICE OF STANDARDS DEVELOPMENT (This page reissued May 1977)

REGULATORY GUIDE 8.10 OPERATING PHILOSOPHY FOR MAINTAINING OCCUPATIONAL RADIATION EXPOSURES AS LOW AS IS REASONABLY ACHIEVABLE A. INTRODUCTION In addition to maintaining doses to individuals as far below the limits as is reasonably achievable, the sum of Paragraph 20.1(c) of 10 CFR Part 20, "Standards the doses received by all exposed individuals should also for Protection Against Radiation," states, in part, that be maintained at the lowest practicable level. It would licensees should make every reasonable effort to main-not be desirable, for example, to hold the highest doses tain radiation exposures as far below the limits specified to individuals to some fraction of the applicable limit if in that part as practicable. This guide describes to this involved exposing additional people and signifi-licensees a general operating philosophy acceptable to cantly increasing the sum of radiation doses received by the NRC staff as a necessary basis for a program of all involved individuals.

maintaining occupational exposures to radiation as low as is reasonably achievable.

C. REGULATORY POSITION Both this guide and Regulatory Guide 8.8, "Infor-Two basic conditions are considered necessary in mation Relevant to Maintaining Occupational Radiation any program for keeping occupational exposures as far Exposure as Low as is Reasonably Achievable (Nuclear below the specified limits as is reasonably achievable.

Power Reactors)," deal with the concept of "as low as is The management of the licensed facility should be reasonably achievable" occupational exposures to radia- committed to maintaining exposures as low as is tion. The main difference between the two guides, aside reasonably achievable, and the personnel responsible for from the fact that Regulatory Guide 8.8 applies only to radiation protection should be continually vigilant for nuclear power reactors and this guide applies to all means to reduce exposures.

specific licensees, is that Regulatory Guide 8.8 is addressed to applicants for a license and tells them what 1. Management Commitment information relevant to "as low as is reasonably achiev-able" should be included in their license applications.

The commitment made by licensee management to This guide, on the other hand, describes an operating minimize exposures should provide clearly defined radia-philosophy that the NRC staff believes all specific tion protection responsibilities and an environment in licensees should follow to keep occupational exposures. which the radiation protection staff can do its job to radiation as low as is reasonably achievable. properly. There are several aspects to this commitment:

a. Plant personnel should be made aware of B. DISCUSSION management's commitment to keep occupational ex-posures as low as is reasonably achievable. The commit-Even though current occupational exposure limits ment should appear in policy statements, instructions to provide a very low risk of injury, it is prudent to avoid personnel, and similar documents. As a minimum, unnecessary exposure to radiation. The objective is thus workers should be sufficiently familiar with this commit-to reduce occupational exposures as far below the ment that they can explain what the management specified limits as is reasonably achievable by means of commitment is, what "as low as is reasonably achievable good radiation protection planning and practice, as well exposure to radiation" means, why it is recommended, as by management commitment to policies that foster vigilance against departures from good practice. and how they have been advised to implement it on their jobs.

USNRC REGULATORY GUIDES Comments should be sent to the Secretary of the Commission US.

Regulatory Guides are issued to describe and make lasory Commission, Warshington. D.C. 20555, Attention: Docketing Nuclear Regu-available to the public methods and Service acceptable to the NRC staff of Implementing specific parts Branch.

of the Commissaon-s regulations, to delineate techniques used by the staff in evaluating specific problems The guides are issued in the following ten broad divisions or postulated accidents or to provide guidance to applicants. Regulatory are not substitutes for regulations, and compliance with them Guides is not required. 1. Power Reactors Methods and solutions different from those set out in the guides 6. Products able f they provide a basis for the findings requisite to the issuance will be accept- 2. Research and Test Reactors or continuance 7. Transportation of a permit or license by the Comniission 3. f uels and Materials Facilities 8. Occupational Health

4. Environmental nd Siting 9. Antitrust Review Comments and suggestions for improvements in these guides are encouraged at all

5. Materials and Plant Protection io. Generel times, and guides will be revisedas appropriate, to accommodate comm nts and to Requests for single copies of issued guides lwhich may be reproduced) reflect new information or experience However, the staff's consideration or ments received during the initial public comment period for thisguide of corn. ment on an automatic distribution list for single copies of future guides for place.

hesresulted divisions should be made in writing to the US. Nuclear Regulatory in specific in the determirtation that there is no need for a revision at this time. Commission, Washington, D.C. 20555, Attention: Director, Division of Document Control.

The first page of this guide is being reissued with the words "For Corment" deleted. The staff's consideration of comments received during the initial public comment period has resulted in the determination that there is no need for a revision at this time.

It is suggested that you attach this page to the first page of the complete guide. No changes have been made to the text of either this page or the remainder of the guide.

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U.S NUCLEAR REGULATORY COMMISSION Revision 1 September 1975 REGULATORY GUIDE OFFICE OF STANDARDS DEVELOPMENT REGULATORY GUIDE 8.10 OPERATING PHILOSOPHY FOR MAINTAINING OCCUPATIONAL RADIATION EXPOSURES AS LOW AS IS REASONABLY ACHIEVABLE A. INTRODUCTION In addition to maintaining doses to individuals as far below the limits as is reasonably achievable, the sum of Paragraph 20.1(c) of 10 CFR Part 20, "Standards the doses received by all exposed individuals should also for Protection Against Radiation," states, in part, that be maintained at the lowest practicable level. It would licensees should make every reasonable effort to main- not be desirable, for example, to hold the highest doses tain radiation exposures as far below the limits specified to individuals to some fraction of the applicable limit if in that part as practicable. This guide describes to this involved exposing additional people and signifi-licensees a general operating philosophy acceptable to cantly increasing the sum of radiation doses received by the NRC staff as a necessary basis for a program of all involved individuals.

maintaining occupational exposures to radiation as low as is reasonably achievable. C. REGULATORY POSITION Both this guide and Regulatory Guide 8.8, "Infor- Two basic conditions are considered necessary in mation Relevant to Maintaining Occupational Radiation any program for keeping occupational exposures as far Exposure as Low as is Reasonably Achievable (Nuclear below the specified limits as is reasonably achievable.

Power Reactors)," deal with the concept of "as low as is The management of the licensed facility should be reasonably achievable" occupational exposures to radia- committed to maintaining exposures as low as is tion. The main difference between the two guides, aside reasonably achievable, and the personnel responsible for from the fact that Regulatory Guide 8.8 applies only to radiation protection should be continually vigilant for nuclear power reactors and this guide applies to all means to reduce exposures.

specific licensees, is that Regulatory Guide 8.8 is addressed to applicants for a license and tells them what 1. Management Commitment information relevant to "as low as is reasonably achiev-able" should be included in their license applications. The commitment made by licensee management to This guide, on the other hand, describes an operating minimize exposures should provide clearly defined radia-philosophy that the NRC staff believes all specific tion protection responsibilities and an environment in licensees should follow to keep occupational exposures which the radiation protection staff can do its job to radiation as low as is reasonably achievable. properly. There are several aspects to this commitment:

a. Plant personnel should be made aware of B. DISCUSSION management's commitment to keep occupational ex-posures as low as is reasonably achievable. The commit-Even though current occupational exposure limits ment should appear in policy statements, instructions to provide a very low risk of injury, it is prudent to avoid personnel, and similar documents. As a minimum, unnecessary exposure to radiation. The objective is thus workers should be sufficiently familiar with this commit-to reduce occupational exposures as far below the ment that they can explain what the management specified limits as is reasonably achievable by means of commitment is, what "as low as is reasonably achievable good radiation protection planning and practice, as well exposure to radiation" means, why it is recommended, as by management commitment to policies that foster and how they have been advised to implement it on their vigilance against departures from good practice. jobs.

USNRC REGULATORY GUIDES Com .entsshould be sent to the Secretary of the Commission US Nuclear Regulatory Giides a'e issued to dssc,,be and nake avadfable to the publc Regulatory Comnission. Washington. C 2066. Attention Dockeaing and methods acieplable to the NRC staff of Implementing specitic parts of the Svice Secton Conmission , regulations to delineate techniqoes used by the slata n evelu The guides are issued in the following ton broad diisions at.nq specific problems o' postulated accidents. or to provide guidance to appT.

cents Regulatory Gu-des are not Substitutes to, regulations. and compliance 1 Po-e, Reactots 6 Products with them s not required Methods and solutions different from those set out in 2 Research and Test Reactors 7. Transportation the guides wll be acceptable If then provide a besis for the findings requisite to 3 Fuels and Materials Facilities S. Occupational Health the issuance o' tonti-- ice of a permit or license by the Commission 4 Enytronmental and Siting 9 Antitrust Review Comments aiid to Improvements In thes- guides ate encouraged fuggestions 5 Materials and Plant Protection 10 Generat at all times and guides mill be revised as appropriate to accommodate con, mentv and to ilect nen informaton o' eoperrence However, comments on Copies of published guides mov be obtained by written equest indiating the th is guide i reieiced wthin about tw0o months after -Is issuance will be par divisions desired to the U S. Nuclear Regulftorn Commission. Washington. D C X, ulaly isef aiul eoaloarui the need lo, X -ifrln-sion 20656. Attention Director. Office of Standards Oevefopment

b. Management should periodically perform a for. demonstrate that improvements have been tough:, that mal audit to determine how exposures might be lowered. modifications have been considered, and that they have This should include reviews of operating procedures and been implemented where practicable. Where modifica-past exposure records, plant inspections, and consulta- tions have been considered but not implemented, the tions with the radiation protection staff or outside licensee should be prepared to describe the reasons for consultants. As a minimum, management should be able not implementing them to discuss which operating procedures were reviewed, in which locations most exposures are being received, what groups of workers are receiving the highest exposures, 2. Vigilance by the RSO and the Radiation Protection what discussions they have had with the radiation Staff protection staff or outside consultants, and what steps they have taken to reduce exposures. It should be the responsibility of the RSO and the radiation protection staff to conduct surveillance pro-

c. The management should ensure that there is a grams and investigations to ensure that occupational well-supervised radiation protection capability with exposures are as far below the specified limits as is well-defined responsibilities. The qualifications for the reasonably achievable. Additionally, they should be Radiation Protection Manager for a nuclear power vigilant in searching out new and better ways to perform reactor facility are presented in Regulatory Guides 1.8 all radiation jobs with less exposure. There are several and 8.8. Applicants submitting applications for any aspects to this responsibility.

specific license other than a nuclear power reactor license should select and state the qualifications for the a. The RSO and the radiation protection staff lead individual who will be responsible for implementing should know the origins of radiation exposures in the the radiation protection program for the facility, i.e., the plant. They should know these by location, operation, Radiation Safety Officer (RSO)." The qualifications and job category and should be aware of trends in selected should be commensurate with the potential exposures. Where radiation work permits are used, problems anticipated to be encountered in a facility of exposures received should be recorded on the permits.

the type subject to the license. The RSO and the radiation protection staff should be able to describe which locations, operations, and jobs are

d. The management should see that plant workers associated with the highest exposures and why exposures receive sufficient training. Section 19.12 of 10 CFR Part are increasing or decreasing.

19 requires instruction of personnel on radiation protec-tion. The radiation worker should understand how b. The RSO and the radiation protection staff radiation protection relates to his job and should be should look for ways to reduce exposures. When unusual tested on this understanding at least once per year. He exposures have occurred, the radiation protection staff should have frequent opportunities to discuss radiation should direct and participate in an investigation of the safety with the radiation protection staff whenever the circumstances of such exposures to determine the causes need arises. Management should be committed to a and take steps to reduce the likelihood of similar future review of radiation protection at least once every three occurrences. For each such occurrence, the RSO should years. Training should be sufficient to ensure that the be able to demonstrate that such an investigation has workers can correctly answer questions on radiation been carried out, that conclusions were reached as a protection as it relates to their jobs. result of the investigation, and that corrective action was taken, as appropriate.

e. The RSO should be given sufficient authority to enforce safe plant operation. The RSO should have The RSO and the radiation protection staff the authority to prevent unsafe practices and to com- should periodically review operating procedures that municate promptly with an appropriate level of manage- may affect radiation safety and survey plant operations ment about halting an operation he deems unsafe. to identify situations in which exposures can be reduced.

Operating procedures related to radiation safety should Indicated changes should be promptly implemented.

be reviewed and approved by radiation protection Procedures for receiving and evaluating suggestions personnel. This authority should be demonstrable by relating to radiation protection from employees should written policy Statements. be established. Workers should be knowledgeable of the procedures for making suggestions on radiation protec-

f. Modifications to operating and maintenance tion.

procedures and to plant equipment and facilities should be made where they will substantially reduce exposures c. Adequate equipment and supplies for radiation at a reasonable cost. The management should be able to protection work should be provided. The RSO should be responsible for ensuring that proper equipment and I*Lines indicate substantive changes from previous issue. supplies are available, are maintained in good working I The term "Radiation Safety Officer" is used by many licensees; order, and are used properly. Written procedures for the other terms are equally acceptable. use of the equipment should be available and followed.

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D. IMPLEMENTATION with the specified portions of the Commission's regula-tions, the methods described herein will be used in the The purpose of this section is to provide informa- evaluation of submittals in connection with appLications tion to appicants and licensees regarding the NRC staffs for a specific license.

plans for utilizing this regulatory guide.

Regulatory Guides I . and 8.8 address nuclear power reactor facilities specifically and will be used by Except in those cases in which the applicant or the NRC staff in evaluating submittals in connection licensee proposes an alternative method for complying with licensing actions for nuclear power reactors.

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