Regulatory Guide 8.10
| ML12220A071 | |
| Person / Time | |
|---|---|
| Issue date: | 09/30/1975 |
| From: | Office of Nuclear Regulatory Research, NRC/OSD |
| To: | |
| References | |
| RG-8.010, Rev. 1 | |
| Download: ML12220A071 (3) | |
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 achievabl
e.
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 Commenis should be sent to the Secretary of the Commission U S Nuclear Regulatory Commission. Washington. D C 20555. Attention Docketing and Reguitoy 6-id- are issued to describe and make available to the public Service Section.
methoIds acieptable to the NRC statt of implementing specific parts of the Conrri*sion s regulations to delineate techniques used by the staff in evalc The guides are issued in the following ten broad divtsions atinq specific problerms o, postulated accidents, or to prnovide guidance to appli cants Regulatory Guides are not substitutes tor regulations. and compliance 1 Power Reactors 6 Products
2 Research and Test Reactirs 7. Transportation with them is not required Methods and solutions different from those set out in
- he guides wiI be acceotahle i they provide a basis or the findings requisite to 3 Fuels and Materials Facilities 8. Occupational Health the issuace or conrnuaiice of a permit or license by the Commission 4 Environmental and Siting 9 Antitrust Review Comments aod ,,uggestions for improveenits in these guides are encouraged 5 Materials and Plant Protection 10 General
00 at all times, and guides will be revised, as appropriate io accommodate cow Copres of published guides may be obtained by written request inidicatimg the nrenrs and to -fleI new information or experience However. comments on this iiiide, if ,ived within aohuto two nionths after Its issuance, will be par divisions desired 1o the U.S Nuclear Regulatory Commission. Washington,. D C
iun.uiaiivi ,sefiil iii evaluatigh theed for ar, -, *lr evision 20555. Attention Director. Office of Standards Development
b. 'Management should periodically perform a for- demonstrate that improvements have been sought, 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 2. Vigilance by the RSO and the Radiation Protection groups of workers are receiving the highest exposures, Staff what discussions they have had with the radiation protection staff or outside consultants, and what steps It should be the responsibility of the RSO and the they have taken to reduce exposures. radiation protection staff to conduct surveillance pro- grams and investigations to ensure that occupational
c. The management should ensure that there is a exposures are as far below the specified limits as is well-supervised radiation protection capability with reasonably achievable. Additionally, they should be well-defined responsibilities. The qualifications for the vigilant in searching out new and better ways to perform Radiation Protection Manager for a nuclear power all radiation jobs with less exposure. There are several reactor facility are presented in Regulatory Guides 1.8 aspects to this responsibility.
and 8.8. Applicants submitting applications for any specific license other than a nuclear power reactor a. The RSO and the radiation protection staff license should select and state the qualifications for the should know the origins of radiation exposures in the lead individual who will be responsible for implementing plant. They should know these by location, operation, the radiation protection program for the facility, i.e., the and job category and should be aware of trends in Radiation Safety Officer (RSO).' The qualifications exposures. Where radiation work permits are used, selected should be commensurate with the potential exposures received should be recorded on the permits.
problems anticipated to be encountered in a facility of The RSO and the radiation protection staff should be the type subject to the license. able to describe which locations, operations, and jobs are associated with the highest exposures and why exposures d. The management should see that plant workers are increasing or decreasing.
receive sufficient training. Section 19.12 of 10 CFR Part
19 requires instruction of personnel on radiation protec- b. The RSO and the radiation protection staff tion. The radiation worker should understand how should look for ways to reduce exposures. When unusual radiation protection relates to his job and should be exposures have occurred, the radiation protection staff tested on this understanding at least once per year. He should direct and participate in an investigation of the should have frequent opportunities to discuss radiation circumstances of such exposures to determine the causes safety with the radiation protection staff whenever the and take steps to reduce the likelihood of similar future need arises. Management should be committed to a occurrences. For each such occurrence, the RSOshould review of radiation protection at least once every three be able to demonstrate that such an investigation has years. Training should be sufficient to ensure that the been carried out, that conclusions were reached as a workers can correctly answer questions on radiation result of the investigation, and that corrective action was protection as it relates to their jobs. taken, as appropriate.
e. The RSO should be given sufficient authority The RSO and the radiation protection staff to enforce safe plant operation. The RSO should have should periodically review operating procedures that the authority to prevent unsafe practices and to com- may affect radiation safety and survey plant operations municate promptly with an appropriale level of manage- to identify situations in which exposures can be reduced.
ment about halting an operation he deems unsafe. Indicated changes should be promptly implemented.
Operating procedures related to radiation safety should Procedures for receiving and evaluating suggestions be reviewed and approved by radiation protection relating to radiation protection from employees.should personnel. This authority should be demonstrable by be established. Workers should be knowledgeable of the written policy statements.
procedures for making suggestions on radiation protec- tion.
f. Modifications to operating and maintenance procedures and to plant equipment and facilities should c. Adequate equipment and supplies for radiation be made where they will substantially reduce exposures protection work should be provided. The RSO should be at a reasonable cost. The management should be able to responsible for ensuring that proper equipment and supplies are available, are maintained in good working I*Lines indicate substantive changes from previous issue.
order, and are used properly. Written procedures for the ltThe term "Radiation Safety Officer" is used by many licensees;
other term$ are equally acceptable. use of the equipment should be available and followed.
8.10-2
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 applicants and licensees regarding the NRC staff's for a specific license.
plans for utilizing this regulatory guide.
Regulatory Guides 1.8 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.
8.10-3