ML20056G035

Reg Guide 08.037, ALARA Levels for Effluents from Matls Facilities

ML20056G035
Person / Time
Issue date:	07/31/1993
From:	NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:
References
TASK-DG-8013, TASK-RE REGGD-08.037, REGGD-8.037, NUDOCS 9309010199
Download: ML20056G035 (8)

Text

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U.S. NUCLEAR REGULATORY COMMISSION July 1993 p,, m ows

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REGULATORY GUIDE e*

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OFFICE OF NUCLEAR REGULATORY RESEARCH e*e9 REGULATORY GUIDE 8.37 (Draft issued as DG-8013)

ALARA LEVELS FOR EFFLUENTS FROM MATERIALS FACILITIES l

A.

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

In 10 CFR Part 20. " Standards for Protecuon This regulatory guide provides guidance on de-Against Radiation, s 20.1302(b) requires that:

signing an acceptable program for establishing and maintaining ALARA levels for gaseous and liquid ef-

" A bcensee sha!! thow comphance with the fluents at matenals facihties. Materials facilities are those facilities at which the possession or use of annual dose liinit m 9 20.1301 by (1) Dem-onstrating b> measurement or calculation that source, byproduct, or special nuclear material is the total ellecove dose equivalent to the indi-licensed under 10 CFR Parts 30, 40, 60, 61, and 70.

t sidual hkely to receise the highest dose from l

thc licensed operanon does not exceed the Additional guidance on ALARA programs can be annual dose limit; or (2) Demonstrating that found in other regulatory guides. While these guides deal primarily with occupational exposure and may be O) The annual aserage concentrations of radioactne material released in gaseous and specific to one type of licensee, they contain pro-hquid ef flue nts at the boundary of the unre-grammatic information that may be useful to all licen-sees. They are as follows:

stricted area do not exceed the values speci-fed m Table 2 of Appendix B to e

Regulatory Guide 8.10, " Operating Philoso-5 20 1001-20.2401; and (n) If an mdivid-phy for Mamtaining Occupational Radiation ual were conunually present m an unrestricted Exposures As Low As Is Reasonably Achiev-area, the dose from external sources would able

• This guide delineates the components not exceed 0.002 rem (0.02 mSv) in an hour of an ALARA program.

and 0.05 rem (0.5 mss) m a year."

Repu!atory G,..de 8.18,,Information Rele-o ui in addition,10 CFR 20.1101(b) requires that:

vant to Ensuring that Occupational Radiation Exposures at Medical Institutions Will Be As Low As Reasonably Achievable "

"The hcensee shall use, to the extent practica-Regulatory Guide S.31, "Information Relevant ble, procedures and engmeermg controls to Ensuring that Occupational Radiation Ex-based upon sound radiation protecuon princi-posures at l'ranium Mills Will Be As Low As plcs to achieve occupational doses and doses is Reaso-ably Achievable ~

twC H GL LA1DM Ct1Dts W"iten commeats may t,e submtied to t%e Aegiatory Pachcations Branch, o5iPS. A9M U S. Noctear Aegatary Comm'ssion. WasNng-RevaWv Gsnes a-o assed to oesente and make o.aamb<a to 15e put-ton. oc 20sss Mg II',.MJ,'. U$3*J1* $ ','e*g$aYo'.",N[1 T* Woe * *e '5 sad 'n "* 'o"o*as 'e taad **=

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d'"erent from those set out m the gsces mm De acceptab e if they pro-

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• comes of issued woes mar t= pe="a$ed trom tw Go vament Pr'ntins o*.ce at i-earrent coo pnee. rwmanon on curre,i cPo onces may te obtained by contat.Ung 1Se Sape miencent of DOCumen!S. u S.

Th E psde w a s +5 0seC a*ter CT5 0 'aSon Of Co"ime"?5 rece'ved trom Government Ponting othce. Post Othee Box 370r$2. WasNn; ton, cC the putDC. Coma *n's and S/,';;esbons fJr imVoweme"t B M f **F>e 2')O13 7D62, teasphone (202)512-22ap or (2021512-2171, poes re encourased at an times. and geoes wm to reosed. as ao-isssed peces may a'so be p# chased trom 15 p onsee in see-mece co-me. and to etect r+~ e.on o,

-ason sevee o, a seand,ng var t,ao. 09,e National Techmchl infr-8o on tm..evice may te egeoence oDia:ned by woteng NTIS s2M Port Royal AC,ad. Sprmgf. eld. VA 22161.

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08.037 R PDR hW

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" Guide for the this guide will be easily achievable by all NRC materi-e als licensees.

Pre;,aration of Apphcat ons for Medical Use Prm rams.' Section 13 and Appendix G deal The NRC staf f will be examining licensee pro-specihcally u nh AL AR A procrams for medi.

grams to determine compliance with the requirements t ai laahties.

cf 10 CFR Part 20. In the event that a particular ma-I tenals facihty bcensee establishes ALARA goals that in addanon. further mformation can be found in than the goals identified in this are less stringent Remon 1 to NUREG-026'? "Pnncip!cs and Prac-guide, or consistently fails to achieve ALARA goals it tices f or Keeping Occupational Radiauon Exposures has estabbshed pursuant to this guide, the NRC staff at Niedical In stituuc ns As Low As Reasonably will conduct a more detailed review of that licensee's Actnevable" (October 1982).

program to determine the rationale for the greater mformauon collection actisines mentioned levels. In such circumstances, the NRC will evaluate Any m this regulatory gu de are contamed as requirements the rationale provided by the licensee, as well as the in 10 Cl R Part 20. uhich provides the regulat ry ba-licensee's operations, to determine whether the licen-sis for this guide. The mformanon collection requae-see has established an adequate ALARA program rnents m 10 CFR Pan 20 hase been approved by the and is operating that program in compliance with 10 Olkce of Slanagement and fiudget, Approval No.

CFR 20.1101(b).

3150-0014 This guide deals with only a part of a licensee's overall radiation protection program. Specifically, it deals with the apphcation of ALARA in controlling IL DISCUSSION pascous and liquid effluents. In addition to controlhng doses resulting from the release of ef fluents, licensees At the relauveh low levels of rad:ation exposure must implement a radiation protection program that m the I nned 5tates, it n dilheult to dernonstrate a controls dose rates in unrestricted areas to mamtain relauon between exposure and any health effects.

overall doses to ucrkers and membets of the public The dose limas m 10 Cl R Part 20 are based on limit-ALARA and below the limits in 10 CFR Part 20. Li-m dose to what n considered to be an acceptable censees may choose to focus their evaluation of pub-Jesel of rak to the exposed individual. Sull, any ra-lic dose to members of a critical group as sugcested by diat on exposure ma) carry some nsk. Thus, the NFC the International Commission on Radiological Protec-requucs hcensees to take acuons, to the extent practi-tion (ICRP) as a means of identifying and controlling cable, uuhnng procedures and engineenng controls to the exposure to the individual member of the public funher reduce rok below the levels imphcit in the dose hmits m keepmg wah the principle that expo-hkely to receive the highest exposure.

sures shnuld be as low as is reasonably achievable.

NRC licensees have taken actions to mamtain Tins is the goal and purpose for radiation protection doses to both workers and members of the public programs. In order to achiese this goal, licensees ALARA under the admonition contained in mutt control the wat r adioactise matenal is handled 10 CFR 20.1(c),2 which requires that licensees f rom receipt through chsposah "make every reasonable effort" to maintain doses and effluents ALARA. NRC licensees have generally NRC hcensees hace tradaionally reduced expo-reduced doses to relatively small fractions of the dose sures and effluents to small fracuons of the dose limits hmus, Therefore, the NRC staff does not expect that usm; the AL AR A process. Recendy, the Environ-most hcensees will need to make significant clnnges menta! Protection Agency (EPA) conducted 2 studies to procedures, operations, and equipment in order to of matenals f acdues. The i rst was a survey of 367 be in compliance with the requirements of 10 CFR randomly selected nuclear materials licensees. The highest esumated dose to a member of the pubhc 20.1101(b) 2 Iloweser, f or those licensees who have not previously developed a radiation protection pro-from effluents was 8 mrem / r. based on very conser-gram that includes written procedures and policies as 3

vative ruodehng. In addinon,95G of the facilities ex-well as a commitment to ALARA. additional steps amined had doses to members of the pubhc resulting may be necessary to demonstrate compliance with from ef fluents less than 1 mrem / r. The second study requirements now exphcit in 10 CFR Part 20 to main-3 evaluated elfluents from 43 addiuonal facihties that tain doses ALARA.

were selected because of their potential for effluent releases resultmg in significant public exposures. Of Components of an effective radiation protection these, none exceeded 10 mrem /yr to a member of the program, as required by 10 CFR 20.1101(b), include public, and 759 of them were less than 1 miem/yr to radiation exposure control, written procedures and a member of the pubhc. Based upon this information, and the angoing NRC program of licensmg and m-

'In June 1991,10 CFR Part 20 $$ 20.1001 through 20.2401 spection, the NRC expects that the coals suggested in became effectise, and compliance with these r,ccunns I c-comes mandatory on January 1,1994. However,10 CFR Part 1

20 $$ 20.1 through 20301 became effccuve in 1957 and re-mains in cHect until January 1, ;994, or when licensees vol-

'Cepics are asanable f or purchsse from the U.S. Government untanly imi ement the requirements of 10 CFR Pan 20 $$

l Prmung Othce.

P.O.

Box 37082 Was hingion, DC 20.1001 t hr ough 20.2401, whichever is earlier.

20013-7082. telephone (202) $12-2249 cr (202) 512-2171.

837-2

1 policies, control of radioactive materals, radioactive down on the basis of the annual review of what may contamination control, radioactive waste manage-be ALARA for the particular circumstance.

ment, training, program renews, an j audits. Guid-ance on other facets of a radiation protection pro-If the licensee chooses to demonstrate comph,-

gram for materials facdities is currently under devel-ance with 10 CFR 20.1301 through a calculation of opment the total effective dose equivalent (TEDE) to the in-dividual likely to receive the highest dose, the licen-C.

REGULATORY POSITION ee should set the ALARA goal at a modest fraction of the dose limit for members of the pubbc. Experi-An ALARA program for effluent control to con-en e c e va es of abut 0.1 mW @

trol doses to members of the public should contain mrems/yr) r less should be practicable for almost a!!

the following program elements:

maten is a ty kemes. Wnsees need not as-sume worst case models when calculating dose but

1. Management commitment to ALARA, includ-rather should make assumptions that will result in re-ing goals, alistic estimates of actual dose received by the mem-

2. Procedures, engineenng controls, and process ber of the public likely to receive the highest dose.

comrols, if the circumstances of a particular case are such Suneys and eifluent momtonng, that the licensee cannot achieve effluent concentra-x

4. ALARA reviews, tions less than 20Tc of the Appendix B values or dem-onstrate by calculation that the TEDE to the individ-S. Worker training'.

ual hkely to receive the highest dose is less than 0.1 mSv/ year (10 mrems/ year), the ALARA philosophy These program elements, while given specifically continues to apply, and the licensee should demon-for ef fluents in this guide, are also applicable to the strate compliance with the requirements of 10 CFR control of direct exposure.

20.1101 (b) by evaluating procedures, engineering controls, and process controls as described in Regula-1.

M ANAGEMENT COMMl! MENT TO t ry Positi n 2 below.

ALARA. INCLUDING GOALS 1.3 Investigation Levels The single most critical aspect of successfully achieving ALARA in the radiation safety program is in addition la ALARA goals, the licensee should the commitment of management to maintain doses establish investigation levels at effluent values that are ALARA, both occupational and to the public. The close to normal or anticipated release levels. If ex-licensee s radiation protection program (includmg ceeded, an irnestication should be initiated and cor-

~

ALARA clements) should be commensurate with the redive actions should be taken, as appropriate.

potential hazards associated with the hcensed activity.

1.4 Radiation Safety Committee For hcensees that have a radiation safety commit-1.1 ALAR A Policy tee, one responsibility of that committee should be to establish ALARA goals. The committee must meet at The hcensee should estabbsh an ALARA policy least annually to review the radiation protection pro-that is issued and supported by the highest level of gram content. The committee should also review management. All employees should be made aware of ALARA goals and discuss ways to further reduce the ALARA pohey through traming. This policy doses if necessary. Goals may need to be adjusted on should make clear that all personnel will be responsi-the basis of the committee's review. The committee ble for ensuring that work they perform is in accor-should assess short-term and long-term performance dance with ALARA procedures.

in terms of achieving the ALARA goals. ALARA goals and the results of reviews should be reported at 1.2 ALAR A Goals least annually to seniar management with recommen-dations for changes in procedures or equipment To assist m demonstrating comphance with the needed to accomphsh the requirements of the requirements of 10 CFR Part 20. the hcensee should ALARA policy as appropriate.

set ALARA goals for effluents at a modest fraction of the values m Appendm B Table 2, Columns 1 and 2 For licensees with no radiation safety committee.

to s9 20.1001-20.2401. These goals may be set the radiation safety officer should be responsible for independently for gaseous and liquid effluents. Past setting, adjusung, and periodically reviewing the ra-experience and effluent mformation reported to the diation protection program and the ALARA goals.

NRC staff indicate that goals within a range of 10 t 2.

PROCEDURES, ENGINEERING

.0% of Appendix B values or less can be achieved by almost a!! materials facihty bcensees. However, estab-CONTROLS, AND PROCESS CONTROLS l

hshing a goalis not intended as setting a precedent or Licensees should consider available engineering a de facto hnit. Goals may need to be adjusted up or opuons to control the release of effluents to the 837-3

on the methodology described in ICRP 30," Limits for environment. Examples of the available options in-Intakes of Radionuclides by Workers."3 clude fdtration, encapsulation, adsorption, contain-rnent, and the storage of liquids for decay. If further reductions in effluents are neeced to achieve ALARA 3.1 Airborne Radioactive Effluent Monitoring goals, the recy cling of process fluids, leakage Whm practicable, releases of airborne radioac-reduction, and modificat ons ta facihties, operations, tise effluents should be from monitored release points or procedures should be considered. These (e.g., monitored stacks, discharges, vents) to ensure modifications should be implem mted unless an analy-that the magnitude of such effluents is known with a sis indicates that a substantial reduction in coHecuve suf ficient degree of confidence to estimate public ex-dose would not result or costs, ire considered unrea-posure. Licensees should serify the performance of sonable. A determination of reasonableness may be effluent monitoring systems by regular cahbration (at based on a qualitative analysis requinng the exercise least annuaHy) to ensure that these momtors provide of judgment and consideration of factors that nay be rehable indications of actual effluents. Further guid-dif ficult to quantif y. Thete factors could include ance can be found in Regulatory Guide 4.15. " Qual-nonradiolog. cal social or enuranmental impacts, the ny Assurance for Radiolopcal Monitoring Programs as ailability and pracucahty o' alternative technolo-pes, and the potential f or unnecessanly increasing (Normal Operations)-Ef fluent Streams and the Envi-r onme nt. "

occupational exposures.

Effluent monitoring systems should be designed m accordance with ANSI N13.1 (1969), ' Guide to Ahernatnely, reasonaNener may be based on a Samphng Airborne Radioactise Materials in Nuclear quanntattre cost ' benefit analys:s. Preparanon of an and ANSI N42.18 " Specification and Facihnes,"'

AL ARA costinenef i analpis requires the use of a Performance of On-site Instrumentation for Continu-doHar value per umt dose aserted. The NRC staff is ous!" Monitoring Radioactive Ef fluents."'

conducting a renew md analysis of various methodo-lopcal approaches ta setting dollar values, and the NCRP Commentary No. 3 " Screening Tech-staf f recognaes that varung Jegrees of jusufication niques for Determining Compliance with Environ-est for a w& rarg e of' dol ar values. Howeser, the mental Standards "5 pubbshed in January 1969 and value of 11000 per person-c5v (man-reml is accept-the addendum pubbshed in October 1989 proudc ac-able to the NRC staf f and may be used pending com.

ceptable methods for calculating dose from airborne pienon of that reassessment.

radioactive effluents. In addition, there are several computer codes available that perform these calcula-tions. Licensees may use such computer codes as long 3.

SURVE15 AND LITLUENT MONITORING as they can demonstrate that the code uses approved methods.

3.2 Liquid Effluent Monitoring Licensees must perform sunep and moratonnp sul hCle nt to de monstra t e Compliance wah the When practicable, releases of liquid radioactive requactnents of 10 CFR 20.1302. This mcludes the ef fluents should be monitored.6 Methods for calculat-momtonng and surven that mw be necessarv to de_

ing doses from liquid effluents similar to those de-ternune whether radianon leuls and effluerits meet scnbed in NCRP Commentar) No. 3 are currently un-the hanu c's estabbshed ALARA goals. These sur-der development by the NCRP. In the mterim, guid-sep should mclude air and hquic' ef tiuent moratonng, ance available in Regulatory Guide 4.14 "Radiologi-mie u weH as sunep of dose rates in un-cal Effluent and Enuronmental Morntoring at Ura-

.n g r d area, mum MiHs," and Regulatory Guide 4.16. " Monitor-r e e.n c t e mg and Reportmg Radioactivity in Releases of Radio-actne Materials in Liquid and Gaseous Effluents from If the h;ensee chooses to demonstrate comph.

Nuclear Fue! Processing and Fabrication Plants and nce wah dose hmns to the member of the pubhc hkeh to recene the highest dose by calculating the b

TE DE. a u signifi. ant en, vnmr tal pa'hw a,',.hou!d acore are aui:Ac f ren Pergamon P*ess. Inc., 663 White be etaluated. Some of the equanons included m Ptains Road. Tarntown. NY 1G591-5153, phone (914)

Regulatory Guide 1 109, " Calculation of Annual 594-9200.

Doses to Man From Rounne Releases of Reactor Ef-

• Cepies of ANSI standards may be obtained from the Ameri-fluents for the Purpose of Evaluatmg Comphance with can National standards Institute, Inc.,1430 Broadway, New 10 CFR Part 50, Appenda 1." and Regulatory Gu de nrt NY loom i

3.51. " Calculational Models For Estimating Radiation

$ceries may be purchased from the National Council on Ra-Doses to Man f rom Airbarne Radioacute Matenals d;ation Protecuon and Measurements. NCRP Pubbcations.

7910 Woodmont Avenue, Bethesda, MD 20814.

Resuhing from Uranium Milhng Operations," may be useful m performing ciose assessments. How es er*

uid effbents do not include releases inta sanitary sewerage

'l

,ending the annc

pated rension of these regulatory in accordance wnh to CFR 20 2003(a) or excreta from pa-tients in accordance with 10 CFR 20 2003(b).

guides. the dose cornernon factors should be based S.37-4

Uranium flexafluoride Production Plants, may be ALAR A - effluer i goals. In addition, the licensee useful to materials hcensees in calculating doses from should resiew a 1 desigrn for system installations or hquid elliuents.

modifications to ensure compliance with 10 CFR 20.110)(b). The results of ALARA retiens 3.3 Unmonitored Effluents should be reported to senior management along with recommendations for changes in facihties or proced-If a license has release points for which monitor-ures that are de:med necessary to achiese ALARA ing is not practicable, the hcensee should estimate the goah.

rnagmtude of the unmonitored effluents. For in-stance, a research hospital or unisersity broad scope 5.

WO RKER 'I R AINING bcensee might I ave dozens of locations where radio-actise m:.terial could be released. The licensee should Specihc trair ing on ALARA should be provided estimaie the munitude of unmonitored releases and as a pan f the annual employee radiation protection include those esUmated amounts when demonstrating trammg (see 10 CFR 19.12). For an ALARA pro-comphance w ith dose hmits and the beensee's

[vam to be sucteufuh employees must understand the ALARA pragwni goah and principles. The ALARA goah. Unmonitored releases mas be esti-mated based on die quannty of material used in these radwtion protection staff should be available to help nreas or the nun ber of procedures performed or clarW the ALARA pokcy and its goah and to anist t

other oppropriite methods. When practicable, employees bodi during training and throughout the unmonitored effluents should not exceed 30% of the year.

total est mated (ifluent releases.

D.

I M PLEM ENTATION 4.

AI AR A RI; VIEWS The pcrpose of this section is to provide mforma-Accordmg t a 10 CFR 20.1101(c), the content tion to a;)plicarts and licensees regarding the NRC staff's plans for using this guide and nrplementation of the radiation pr otection prograrrs, which would include the ALARA effluent Except in those cases in which an applicant pro-control program, must be reviewed at least annually.

poses an acceptable alternative method for compl>mg Tim revieu should mclude analysis of trends in with specified fortions of the Commission's regula-rdcase concentr;.tions and radionuclide usage as well tions, the n ethods descobed in this guide will be used

.s other asail;iNe monitonng data. The review should in the evaluation of apphtations for new licenses, !i-provide a documented basis for determiaing whether cense renewals, or liter se arnendments and for evalu-changes are neet ed in systems or practices to achieve ating compt ance wah 10 CFR 20.1001-20.2401.

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1 8.37-5

l REGULATORY ANALYSIS of the " Regulatory Analysis for the Revision of 10 A separate regulatory analysis was not pre-CFR Part 20" (PNL-6712. November 1988) is pared for this regulatory guide. The regulatory available for inspection and copying for a fee at the analysis prepared for 10 CFR Part 20. " Standards NRC Public Document Room, 2120 L Street NW.,

for Protection Against Radiation" (56 FR 23360),

provides the regulatory basis for this guide. A copy Washington, DC, as an enclosure to Part 20, l

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