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 July 1993 REGULATORY GUIDE

OFFICE OF NUCLEAR REGULATORY RESEARCH

REGULATORY GUIDE 8.37 (Draft issued as DG-8013)

ALARA LEVELS FOR EFFLUENTS FROM MATERIALS FACILITIES

A. INTRODUCTION

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

In 10 CFR Part 20, "Standards for Protection This regulatory guide provides guidance on de Against Radiation," § 20.1302(b) requires that: signing an acceptable program for establishing and maintaining ALARA levels for gaseous and liquid ef

"A licensee shall show compliance with the fluents at materials facilities. Materials facilities are annual dose limit in § 20.1301 by (1) Dem those facilities at which the possession or use of onstrating by measurement or calculation that source, byproduct, or special nuclear material is the total effective dose equivalent to the indi licensed under 10 CFR Parts 30, 40, 60, 61, and 70.

vidual likely to receive the highest dose from Additional guidance on ALARA programs can be the licensed operation does not exceed the found in other regulatory guides. While these guides annual dose limit; or (2) Demonstrating that deal primarily with occupational exposure and may be (i) The annual average concentrations of specific to one type of licensee, they contain pro radioactive material released in gaseous and grammatic information that may be useful to all licen liquid effluents at the boundary of the unre sees. They are as follows:

stricted area do not exceed the values speci fied in Table 2 of Appendix B to " Regulatory Guide 8.10, "Operating Philoso

§§ 20.1001-20.2401; and (ii) If an individ phy for Maintaining Occupational Radiation ual were continually present in 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 mSv) in a year."

"* Regulatory Guide 8.18, "Information Rele 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 licensee shall use, to the extent practica " Regulatory Guide 8.31, "Information Relevant ble, procedures and engineering controls to Ensuring that Occupational Radiation Ex based upon sound radiation protection princi posures at Uranium Mills Will Be As Low As ples to achieve occupational doses and doses Is Reasonably Achievable."

USNRC REGULATORY GUIDES Written comments may be submitted to the Regulatory Publications Regulatory Guides are issued to describe and make available to the pub Branch, DFIPS, ADM, U.S, Nuclear Regulatory Commission, Washing ton, DC 20555.

lic such information as methods acceptable to the NRC staff for imple menting specific parts of the Commission's regulations, techniques The guides are issued in the following ten broad divisions:

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 1, Power Reactors 6. Products permits and licenses. Regulatory Guides are not substitutes for regula 2. Research and Test Reactors 7. Transportation tions, and compliance with them is not required. Methods and solutions 3. Fuels and Materials Facilities 8. Occupational Health different from those set out in the guides will be acceptable If they pro 4. Environmental and Siting 9, Antitrust and Financial Review vide a basis for the findings requisite to the issuance or continuance of a 5. Materials and Plant Protection 10, General permit or license by the Commission. 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.

This guide was Issued after consideration of comments received from Government Printing Office, Post Office Box 37082, Washington, DC

the public. Comments and suggestions for improvements in these 20013-7082, telephone (202)512-2249 or (202)512-2171.

guides are encouraged at all times, and guides will be revised, as ap propriate, to accommodate comments and to reflect new information or Issued guides may also be purchased from the National Technical Infor mation Service on a standing order basis. Details on this service may be experience. obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161.

9 Regulatory Guide 10.8, "Guide for the this guide will be easily achievable by all NRC materi Preparation of Applications for Medical Use als licensees.

Programs." Section 1.3 and Appendix G deal specifically with ALARA programs for medi The NRC staff will be examining licensee pro cal facilities. grams to determine compliance with the requirements of 10 CFR Part 20. In the event that a particular ma In addition, further information can be found in terials facility licensee establishes ALARA goals that Revision 1 to NUREG-0267, 1 "Principles and Prac are less stringent than the goals identified in this tices for Keeping Occupational Radiation Exposures guide, or consistently fails to achieve ALARA goals it at Medical Institutions As Low As Reasonably has established pursuant to this guide, the NRC staff Achievable" (October 1982). will conduct a more detailed review of that licensee's program to determine the rationale for the greater Any information collection activities mentioned levels. In such circumstances, the NRC will evaluate in this regulatory guide are contained as requirements the rationale provided by the licensee, as well as the in 10 CFR Part 20, which provides the regulatory ba licensee's operations, to determine whether the licen sis for this guide. The information collection require see has established an adequate ALARA program ments in 10 CFR Part 20 have been approved by the and is operating that program in compliance with 10

Office of Management and Budget, 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

B. DISCUSSION

deals with the application of ALARA in controlling gaseous and liquid effluents. In addition to controlling At the relatively low levels of radiation exposure doses resulting from the release of effluents, licensees in the United States, it is difficult to demonstrate a must implement a radiation protection program that relation between exposure and any health effects. controls dose rates in unrestricted areas to maintain The dose limits in 10 CFR Part 20 are based on limit overall doses to workers and members of the public ing dose to what is considered to be an acceptable ALARA and below the limits in 10 CFR Part 20. Li level of risk to the exposed individual. Still, any ra censees may choose to focus their evaluation of pub diation exposure may carry some risk. Thus, the NRC lic dose to members of a critical group as suggested by requires licensees to take actions, to the extent practi the International Commission on Radiological Protec cable, utilizing procedures and engineering controls to tion (ICRP) as a means of identifying and controlling further reduce risk below the levels implicit in the the exposure to the individual member of the public I

dose limits in keeping with the principle that expo likely to receive the highest exposure.

sures should be as low as is reasonably achievable.

This is the goal and purpose for radiation protection NRC licensees have taken actions to maintain programs. In order to achieve this goal, licensees doses to both workers and members of the public must control the way radioactive material is handled ALARA under the admonition contained in from receipt through disposal. 10 CFR 20.1(c), 2 which requires that licensees

"make every reasonable effort" to maintain doses NRC licensees have traditionally reduced expo and effluents ALARA. NRC licensees have generally sures and effluents to small fractions of the dose limits reduced doses to relatively small fractions of the dose using the ALARA process. Recently, the Environ limits. Therefore, the NRC staff does not expect that mental Protection Agency (EPA) conducted 2 studies most licensees will need to make significant changes of materials facilities. The first was a survey of 367 to procedures, operations, and equipment in order to randomly selected nuclear materials licensees. The be in compliance with the requirements of 10 CFR

highest estimated dose to a member of the public 20.1101(b). 2 However, for those licensees who have from effluents was 8 mrem/yr, based on very conser not previously developed a radiation protection pro vative modeling. In addition, 98% of the facilities ex gram that includes written procedures and policies as amined had doses to members of the public resulting well as a commitment to ALARA, additional steps from effluents less than 1 mrem/yr. The second study may be necessary to demonstrate compliance with evaluated effluents from 43 additional facilities that requirements now explicit in 10 CFR Part 20 to main were selected because of their potential for effluent tain doses ALARA.

releases resulting in significant public exposures. Of these, none exceeded 10 mrem/yr to a member of the Components of an effective radiation protection public, and 75% of them were less than 1 mrem/yr to program, as required by 10 CFR 20.1101 (b), include radiation exposure control, written procedures and a member of the public. Based upon this information, and the ongoing NRC program of licensing and in 2 spection, the NRC expects that the goals suggested in In 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

'Copies are available for purchase from the U.S. Government mains in effect until January 1, 1994, or when licensees vol Printing Office, P.O. Box 37082, Washington, DC untarily implement the requirements of 10 CFR Part 20 §§

20013-7082, telephone (202) 512-2249 or (202) 512-2171. 20. 1001 through 20.2401, whichever is earlier.

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policies, control of radioactive materials, 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 reviews, and audits. Guid ance on other facets of a radiation protection pro If the licensee chooses to demonstrate compli gram for materials facilities 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

see should set the ALARA goal at a modest fraction of the dose limit for members of the public. Experi An ALARA program for effluent control to con ence indicates that values of about 0.1 mSv/yr (10

trol doses to members of the public should contain mrems/yr) or less should be practicable for almost all the following program elements: materials facility licensees. Licensees 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, engineering controls, and process ber of the public likely to receive the highest dose.

controls, If the circumstances of a particular case are such

3. Surveys and effluent monitoring, that the licensee cannot achieve effluent concentra tions less than 20% of the Appendix B values or dem

4. ALARA reviews, onstrate by calculation that the TEDE to the individ

5. Worker training. ual likely 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 effluents 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. MANAGEMENT COMMITMENT TO tory Position 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 to 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 (including ceeded, an investigation should be initiated and cor ALARA elements) should be commensurate with the rective actions should be taken, as appropriate.

potential hazards associated with the licensed activity.

1.4 Radiation Safety Committee For licensees that have a radiation safety commit

1.1 ALARA Policy tee, one responsibility of that committee should be to The licensee should establish an ALARA establish ALARA goals. The committee must meet at 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 policy through training. 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 goal

s. ALARA

goals and the results of reviews should be reported at

1.2 ALARA Goals least annually to senior management with recommen dations for changes in procedures or equipment To assist in demonstrating compliance with the needed to accomplish the requirements of the requirements of 10 CFR Part 20, the licensee should ALARA policy as appropriate.

set ALARA goals for effluents at a modest fraction of the values in Appendix B, Table 2, Columns 1 and 2, For licensees with no radiation safety committee, to §§ 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, adjusting, and periodically reviewing the ra experience and effluent information reported to the diation protection program and the ALARA goals.

NRC staff indicate that goals within a range of 10 to

20% of Appendix B values or less can be achieved by 2. PROCEDURES, ENGINEERING

almost all materials facility licensees. However, estab CONTROLS, AND PROCESS CONTROLS

lishing a goal is not intended as setting a precedent or Licensees should consider available engineering a de facto limit. Goals may need to be adjusted up or options to control the release of effluents to the

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environment. Examples of the available options in on the methodology described in ICRP 30, "Limits for clude filtration, encapsulation, adsorption, contain Intakes of Radionuclides by Workers." 3 ment, and the storage of liquids for decay. If further reductions in effluents are needed to achieve ALARA 3.1 Airborne Radioactive Effluent Monitoring goals, the recycling of process fluids, leakage reduction, and modifications to facilities, operations, or procedures should be considered. These When practicable, releases of airborne radioac tive effluents should be from monitored release points I

modifications should be implemented unless an analy (e.g., monitored stacks, discharges, vents) to ensure sis indicates that a substantial reduction in collective that the magnitude of such effluents is known with a dose would not result or costs are considered unrea sufficient degree of confidence to estimate public ex sonable. A determination of reasonableness may be posure. Licensees should verify the performance of based on a qualitative analysis requiring the exercise effluent monitoring systems by regular calibration (at of judgment and consideration of factors that may be least annually) to ensure that these monitors provide difficult to quantify. These factors could include reliable indications of actual effluents. Further guid nonradiological social or environmental impacts, the ance can be found in Regulatory Guide 4.15, "Qual availability a-nd practicality of alternative technolo ity Assurance for Radiological Monitoring Programs gies, and the potential for unnecessarily increasing (Normal Operations)--Effluent Streams and the Envi occupational exposures. ronment."

Effluent monitoring systems should be designed Alternatively, reasonableness may be based on a in accordance with ANSI N13.1 (1969), "Guide to quantitative cost/benefit analysis. Preparation of an Sampling Airborne Radioactive Materials in Nuclear ALARA cost/benefit analysis requires the use of a Facilities," 4 and ANSI N42.18, "Specification and dollar value per unit dose averted. The NRC staff is Performance of On-site Instrumentation for Continu

4 conducting a review and analysis of various methodo ously Monitoring Radioactive Effluents."

logical approaches to setting dollar values, and the staff recognizes that varying degrees of justification NCRP Commentary No. 3, "Screening Tech exist for a wide range of dollar values. However, the niques for Determining Compliance with Environ value of $1000 per person-cSv (man-rem) is accept mental Standards," 5 published in January 1989 and able to the NRC staff and may be used pending com the addendum published in October 1989 provide ac pletion of that reassessment. 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

3. SURVEYS AND EFFLUENT MONITORING as they can demonstrate that the code uses approved methods.

Licensees must perform surveys and monitoring 3.2 Liquid Effluent 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 effluents should be monitored.6 Methods for calculat termine whether radiation levels and effluents meet ing doses from liquid effluents similar to those de the licensee's established ALARA goals. These sur scribed in NCRP Commentary No. 3 are currently un veys should include air and liquid effluent monitoring, der development by the NCRP. In the interim, guid as appropriate, as well as surveys of dose rates in un ance available in Regulatory Guide 4.14, "Radiologi restricted areas. cal Effluent and Environmental Monitoring at Ura nium Mills," and Regulatory Guide 4.16, "Monitor ing and Reporting Radioactivity in Releases of Radio If the licensee chooses to demonstrate compli active Materials in Liquid and Gaseous Effluents from ance with dose limits to the member of the public Nuclear Fuel Processing and Fabrication Plants and likely to receive the highest dose by calculating the TEDE, all significant environmental pathways should 3Copies are available from Pergamon Press, Inc., 660 White be evaluated. Some of the equations included in Plains Road, Tarrytown, NY 10591-5153, phone (914)

Regulatory Guide 1.109, "Calculation of Annual 594-9200.

Doses to Man From Routine Releases of Reactor Ef 4 Copies of ANSI standards may be obtained from the Ameri fluents for the Purpose of Evaluating Compliance with can National Standards Institute, Inc., 1430 Broadway, New

10 CFR Part 50, Appendix I," and Regulatory Guide York, NY 10018.

3.51, "Calculational Models For Estimating Radiation Doses to Man from Airborne Radioactive Materials "5Copies may be purchased from the National Council on Ra diation Protection and Measurements, NCRP Publications, Resulting from Uranium Milling Operations," may be 7910 Woodmont Avenue, Bethesda, MD 20814.

useful in performing dose assessments. However, 8 pending the anticipated revision of these regulatory Liquid effluents do not include releases into sanitary sewerage in accordance with 10 CFR 20.2003(a) or excreta from pa guides, the dose conversion factors should be based tients in accordance with 10 CFR 20.2003(b).

8.37-4

Uranium Hexafluoride Production Plants," may be ALARA effluent goals. In addition, the licensee useful to materials licensees in calculating doses from should review all designs for system installations or liquid effluents. modifications to ensure compliance with

10 CFR 20.1101(b). The results of ALARA reviews

3.3 Unmonitored Effluents should be reported to senior management along with recommendations for changes in facilities or proced If a licensee has release points for which monitor ures that are deemed necessary to achieve ALARA

ing is not practicable, the licensee should estimate the goals.

magnitude of the unmonitored effluents. For in stance, a research hospital or university broad scope

5. WORKER TRAINING

licensee might have dozens of locations where radio active material could be released. The licensee should Specific training on ALARA should be provided estimate the magnitude of unmonitored releases and as a part of the annual employee radiation protection include those estimated amounts when demonstrating training (see 10 CFR 19.12). For an ALARA pro compliance with dose limits and the licensee's gram to be successful, employees must understand ALARA goals. Unmonitored releases may be esti the ALARA program's goals and principles. The mated based on the quantity of material used in these radiation protection staff should be available to help areas or the number of procedures performed or clarify the ALARA policy and its goals and to assist other appropriate methods. When practicable, employees both during training and throughout the unmonitored effluents should not exceed 30% of the year.

total estimated effluent releases.

D. IMPLEMENTATION

4. ALARA REVIEWS

The purpose of this section is to provide informa According to 10 CFR 20.1101(c), the content tion to applicants and licensees regarding the NRC

and implementation of the radiation protection staff's plans for using this guide.

programs, which would include the ALARA effluent control program, must be reviewed at least annually.

Except in those cases in which an applicant pro This review should include analysis of trends in poses an acceptable alternative method for complying release concentrations and radionuclide usage as well with specified portions of the Commission's regula as other available monitoring data. The review should tions, the methods described in this guide will be used in the evaluation of applications for new ]icenses, li provide a documented basis for determining whether cense renewals, or license amendments and for evalu changes are needed in systems or practices to achieve ating compliance with 10 CFR 20.1001-20.2401.

8.37-5

REGULATORY ANALYSIS

A separate regulatory analysis was not pre of the "Regulatory Analysis for the Revision of 10

pared for this regulatory guide. The regulatory CFR Part 20" (PNL-6712, November 1988) is analysis prepared for 10 CFR Part 20, "Standards available for inspection and copying for a fee at the for Protection Against Radiation" (56 FR 23360), NRC Public Document Room, 2120 L Street NW.,

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

.

8.37-6

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