ML003739563

R, Operating Philosophy for Maintaining Occupational Radiation Exposures as Low as Is Reasonably Achievable

ML003739563
Person / Time
Issue date:	09/30/1975
From:	Office of Nuclear Regulatory Research
To:
References
Reg Guide 8.10, Rev 1-R
Download: ML003739563 (5)

Text

U.S. NUCLEAR REGULATORY COMMISSION Revision 1-R 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 Paragraph 20.1(c) of 10 CFR Part 20, "Standards for Protection Against Radiation," states, in part, that licensees should make every reasonable effort to main-tain radiation exposures as far below the limits specified in that part as practicable. This guide describes to licensees a general operating philosophy acceptable to the NRC staff as a necessary basis for a program of maintaining occupational exposures to radiation as low as is reasonably achievable.

Both this guide and Regulatory Guide 8.8, "Infor-mation Relevant to Maintaining Occupational Radiation Exposure as Low as is Reasonably Achievable (Nuclear Power Reactors)," deal with the concept of "as low as is reasonably achievable" occupational exposures to radia-tion. The main difference between the two guides, aside from the fact that Regulatory Guide 8.8 applies only to nuclear power reactors and this guide applies to all specific licensees, is that Regulatory Guide 8.8 is addressed to applicants for a license and tells them what information relevant to "as low as is reasonably achiev-able" should be included in their license applications.

This guide, on the other hand, describes an operating philosophy that the NRC staff believes all specific licensees should follow to keep occupational exposures.

to radiation as low as is reasonably achievable.

B. DISCUSSION Even though current occupational exposure limits provide a very low risk of injury, it is prudent to avoid unnecessary exposure to radiation. The objective is thus to reduce occupational exposures as far below the specified limits as is reasonably achievable by means of good radiation protection planning and practice, as well as by management commitment to policies that foster vigilance against departures from good practice.

In addition to maintaining doses to individuals as far below the limits as is reasonably achievable, the sum of the doses received by all exposed individuals should also be maintained at the lowest practicable level. It would not be desirable, for example, to hold the highest doses to individuals to some fraction of the applicable limit if this involved exposing additional people and signifi-cantly increasing the sum of radiation doses received by all involved individuals.

C. REGULATORY POSITION Two basic conditions are considered necessary in any program for keeping occupational exposures as far below the specified limits as is reasonably achievable.

The management of the licensed facility should be committed to maintaining exposures as low as is reasonably achievable, and the personnel responsible for radiation protection should be continually vigilant for means to reduce exposures.

1. Management Commitment The commitment made by licensee management to minimize exposures should provide clearly defined radia-tion protection responsibilities and an environment in which the radiation protection staff can do its job properly. There are several aspects to this commitment:

a.

Plant personnel should be made aware of management's commitment to keep occupational ex-posures as low as is reasonably achievable. The commit-ment should appear in policy statements, instructions to personnel, and similar documents. As a minimum, workers should be sufficiently familiar with this commit-ment that they can explain what the management commitment is, what "as low as is reasonably achievable exposure to radiation" means, why it is recommended, 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. Nuclear Regu-lasory Commission, Warshington. D.C.

20555, Attention: Docketing and Service Regulatory Guides are issued to describe and make available to the public methods Branch.

acceptable to the NRC staff of Implementing specific parts 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 Guides are not substitutes for regulations, and compliance with them is not required.

1. Power Reactors

6. Products Methods and solutions different from those set out in the guides will be accept-

2. Research and Test Reactors

7. Transportation able f they provide a basis for the findings requisite to the issuance or continuance

3. f uels and Materials Facilities

8. Occupational Health of a permit or license by the Comniission

4. Environmental nd Siting

9. Antitrust Review

5. Materials and Plant Protection io. Generel Comments and suggestions for improvements in these guides are encouraged at all times, and guides will be revisedas appropriate, to accommodate comm nts and to Requests for single copies of issued guides lwhich may be reproduced) or for place.

reflect new information or experience However, the staff's consideration of corn.

ment on an automatic distribution list for single copies of future guides in specific ments received during the initial public comment period for thisguide he sresulted divisions should be made in writing to the US. Nuclear Regulatory Commission, in the determirtation that there is no need for a revision at this time.

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 REGULATORY GUIDE Revision 1 September 1975 OFFICE OF STANDARDS DEVELOPMENT REGULATORY GUIDE 8.10 OPERATING PHILOSOPHY FOR MAINTAINING OCCUPATIONAL RADIATION EXPOSURES AS LOW AS IS REASONABLY ACHIEVABLE A. INTRODUCTION Paragraph 20.1(c) of 10 CFR Part 20, "Standards for Protection Against Radiation," states, in part, that licensees should make every reasonable effort to main-tain radiation exposures as far below the limits specified in that part as practicable. This guide describes to licensees a general operating philosophy acceptable to the NRC staff as a necessary basis for a program of maintaining occupational exposures to radiation as low as is reasonably achievable.

Both this guide and Regulatory Guide 8.8, "Infor-mation Relevant to Maintaining Occupational Radiation Exposure as Low as is Reasonably Achievable (Nuclear Power Reactors)," deal with the concept of "as low as is reasonably achievable" occupational exposures to radia-tion. The main difference between the two guides, aside from the fact that Regulatory Guide 8.8 applies only to nuclear power reactors and this guide applies to all specific licensees, is that Regulatory Guide 8.8 is addressed to applicants for a license and tells them what information relevant to "as low as is reasonably achiev-able" should be included in their license applications.

This guide, on the other hand, describes an operating philosophy that the NRC staff believes all specific licensees should follow to keep occupational exposures to radiation as low as is reasonably achievable.

B. DISCUSSION Even though current occupational exposure limits provide a very low risk of injury, it is prudent to avoid unnecessary exposure to radiation. The objective is thus to reduce occupational exposures as far below the specified limits as is reasonably achievable by means of good radiation protection planning and practice, as well as by management commitment to policies that foster vigilance against departures from good practice.

In addition to maintaining doses to individuals as far below the limits as is reasonably achievable, the sum of the doses received by all exposed individuals should also be maintained at the lowest practicable level. It would not be desirable, for example, to hold the highest doses to individuals to some fraction of the applicable limit if this involved exposing additional people and signifi-cantly increasing the sum of radiation doses received by all involved individuals.

C. REGULATORY POSITION Two basic conditions are considered necessary in any program for keeping occupational exposures as far below the specified limits as is reasonably achievable.

The management of the licensed facility should be committed to maintaining exposures as low as is reasonably achievable, and the personnel responsible for radiation protection should be continually vigilant for means to reduce exposures.

1. Management Commitment The commitment made by licensee management to minimize exposures should provide clearly defined radia-tion protection responsibilities and an environment in which the radiation protection staff can do its job properly. There are several aspects to this commitment:

a.

Plant personnel should be made aware of management's commitment to keep occupational ex-posures as low as is reasonably achievable. The commit-ment should appear in policy statements, instructions to personnel, and similar documents. As a minimum, workers should be sufficiently familiar with this commit-ment that they can explain what the management commitment is, what "as low as is reasonably achievable exposure to radiation" means, why it is recommended, and how they have been advised to implement it on their jobs.

USNRC REGULATORY GUIDES Com

.ents should be sent to the Secretary of the Commission U S 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 fuggestions to Improvements In thes-guides ate encouraged 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.

mal audit to determine how exposures might be lowered.

This should include reviews of operating procedures and past exposure records, plant inspections, and consulta-tions with the radiation protection staff or outside consultants. As a minimum, management should be able to discuss which operating procedures were reviewed, in which locations most exposures are being received, what groups of workers are receiving the highest exposures, what discussions they have had with the radiation protection staff or outside consultants, and what steps they have taken to reduce exposures.

c. The management should ensure that there is a well-supervised radiation protection capability with well-defined responsibilities. The qualifications for the Radiation Protection Manager for a nuclear power reactor facility are presented in Regulatory Guides 1.8 and 8.8. Applicants submitting applications for any specific license other than a nuclear power reactor license should select and state the qualifications for the lead individual who will be responsible for implementing the radiation protection program for the facility, i.e., the Radiation Safety Officer (RSO)." The qualifications selected should be commensurate with the potential problems anticipated to be encountered in a facility of the type subject to the license.

d. The management should see that plant workers receive sufficient training. Section 19.12 of 10 CFR Part 19 requires instruction of personnel on radiation protec-tion. The radiation worker should understand how radiation protection relates to his job and should be tested on this understanding at least once per year. He should have frequent opportunities to discuss radiation safety with the radiation protection staff whenever the need arises. Management should be committed to a review of radiation protection at least once every three years. Training should be sufficient to ensure that the workers can correctly answer questions on radiation protection as it relates to their jobs.

e.

The RSO should be given sufficient authority to enforce safe plant operation. The RSO should have the authority to prevent unsafe practices and to com-municate promptly with an appropriate level of manage-ment about halting an operation he deems unsafe.

Operating procedures related to radiation safety should be reviewed and approved by radiation protection personnel. This authority should be demonstrable by written policy Statements.

f.

Modifications to operating and maintenance procedures and to plant equipment and facilities should be made where they will substantially reduce exposures at a reasonable cost. The management should be able to I *Lines indicate substantive changes from previous issue.

I The term "Radiation Safety Officer" is used by many licensees; other terms are equally acceptable.

demonstrate that improvements have been tough:, that modifications have been considered, and that they have been implemented where practicable. Where modifica-tions have been considered but not implemented, the licensee should be prepared to describe the reasons for not implementing them

2. Vigilance by the RSO and the Radiation Protection Staff It should be the responsibility of the RSO and the radiation protection staff to conduct surveillance pro-grams and investigations to ensure that occupational exposures are as far below the specified limits as is reasonably achievable. Additionally, they should be vigilant in searching out new and better ways to perform all radiation jobs with less exposure. There are several aspects to this responsibility.

a. The RSO and the radiation protection staff should know the origins of radiation exposures in the plant. They should know these by location, operation, and job category and should be aware of trends in exposures. Where radiation work permits are used, exposures received should be recorded on the permits.

The RSO and the radiation protection staff should be able to describe which locations, operations, and jobs are associated with the highest exposures and why exposures are increasing or decreasing.

b. The RSO and the radiation protection staff should look for ways to reduce exposures. When unusual exposures have occurred, the radiation protection staff should direct and participate in an investigation of the circumstances of such exposures to determine the causes and take steps to reduce the likelihood of similar future occurrences. For each such occurrence, the RSO should be able to demonstrate that such an investigation has been carried out, that conclusions were reached as a result of the investigation, and that corrective action was taken, as appropriate.

The RSO and the radiation protection staff should periodically review operating procedures that may affect radiation safety and survey plant operations to identify situations in which exposures can be reduced.

Indicated changes should be promptly implemented.

Procedures for receiving and evaluating suggestions relating to radiation protection from employees should be established. Workers should be knowledgeable of the procedures for making suggestions on radiation protec-tion.

c. Adequate equipment and supplies for radiation protection work should be provided. The RSO should be responsible for ensuring that proper equipment and supplies are available, are maintained in good working order, and are used properly. Written procedures for the use of the equipment should be available and followed.

8.10-2

D. IMPLEMENTATION The purpose of this section is to provide informa-tion to appicants and licensees regarding the NRC staffs plans for utilizing this regulatory guide.

Except in those cases in which the applicant or licensee proposes an alternative method for complying with the specified portions of the Commission's regula-tions, the methods described herein will be used in the evaluation of submittals in connection with appLications for a specific license.

Regulatory Guides I.

and 8.8 address nuclear power reactor facilities specifically and will be used by the NRC staff in evaluating submittals in connection with licensing actions for nuclear power reactors.

8.10-3