ML20196K829

Rev 1 to Reg Guide 8.10, Operating Philosphy for Maintaining Occupational Radiation Exposures Alara

ML20196K829
Person / Time
Issue date:	09/30/1975
From:	NRC
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ML20196G742	List: ML20196K829
References
NUDOCS 8807070129
Download: ML20196K829 (3)

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U.S. NUCLEAR REGULATORY COMMISSION Revision 1

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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.l(c) of 10 CFR Part 20. "Standards the doses received by all exposed individuals should also for Protection Against Radiation," states, m part, that be maintained at the lowest practicable level. It would hcensees should make every reasonable effort to rnain- not be desirable, for example, to hold the highest doses tain radiation esposures as far below the hmits specified to indisiduals to some fraction of the applicable limit if in that part as practicable. This guide desenbes 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 Oecupational Radiation any program for keeping occupational exposures as far Exposun 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 facihty 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 achievabic, 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 appbes to all means to reduce exposures.

specific licensees, is that Regula tory Guide 8.8 is addressed to apphcants for a license and tells them what 1. Management Commitment information relevant to "as low as is re.isonably achiev-able" should be mcluded in their hcense appbcations. The commitment made by licensee management to This guide, on the other hand, describes an operatmg minimize exposures should provide clearly defined radia.

philosophy that the NRC staff behe<es all specific tion protection responsihdities and an environment m licensees should follow to keep occupational exposures which the radiation protection staff can do its job to radiation as low as is reasonably ach;evable. properly. There are several aspects to this commitment:

a. Plant personnel should be made aware of B. DISCUSSION management's commitment to keep occupational ed posures as low as is reasonably achievable. The commit-Even though current occupational exposure hmits 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 exrosures as far below the men t that they can explain what the management specified limits as is reasonably achievable by means of commitment is, what "as low as is reasonably acluevable good radiation protection planning and practice, as well exposure to radiation" means, why it is recommended, as by management commitment to pohcies that foster and how they have been advised to implement it on their vigilance against departures from good practice, jobs.

USNRC REGULATORY GUlDES u s Noce.,

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8807070129 871106 REG 1 LIC30 29-28080-01 PDR J

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b. ' Management should periodically perform a for. demonstrate that improvements have been sought, that mal audit to detennine how exposures might be loweeed. modifications have been considered, and that they han 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 desenbe the reasons for consultants. As a minimum, rrnnagement should be able not implementing thent 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, Sg,ft what d2scussions 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. De rnanagement should ensure that there is a exposures are as far below the specified limits as is well supervised radiation protection capab0ity with reasonably achievable. Additionally, they should be well-defined responsibilities. The quabfications 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 facihty are presented in Regulatory Guides 13 aspects to this responsibility.

and 8.8. Appbcants submitting applications for any specific license other than a nuclear power reactor a. ne RSO and the radiation protection staff l> cense 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 quali0 cations 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 facili:y of ne 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 exporures have occurred, the radiation protection staff tested on this understand ng 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 hkehhood of similar future need arises. Management should be committed to a occurrences. For each such occurrence, the RSO should review of radiation protection at least once every three be able to demonstrate that such an investigation has years. Traming should be sufficient to ensure that the been carried out, that conclusions were reached as a l

workers can correctly answtr questions on radiation result of the investigation, and that corrective action was l protection as it relates to their jobs. taken, ai appropriate.

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e. De RSO should be given sufficient authority The RSO and the radiation protection staff j to enforce safe plant operation. The RSO should hase should periodical;y review operating procedures that j the authority to prevent unsafe practices and to com- may affect radiation safety and survey plant operations municate promptly with an appropriate level of manage- to identify situttions in which exposures can be reduced.

ment about hajting an operation he deems unsafe. Indicated changes should be promptly implemented.

Operating procedures related to radiation safety should Procedures for recching and evaluating suggestions l

be reviewed and approved by radiation protection relating to tdiation protection from employees should personnel. His authority should be demonstrable by be established. Workers should be knowledgeable of the wntten policy statements, procedures for making suggestions on radiation protec.

f. Modifications to operating and maintenance procedures and to plant equipment and faculties should c. Adequate equipment and supplies for radiation l be made where they will substantially reduce exposures protection work should be provided. The RSO should be at a reasonable cost. The management sftould be able t responuble for ensunng that proper equipment and supplice are available, are maintained in good working

• Lines indicate substantive changes from previous issue order, and are used properly. Written procedures for the

'The term "Radution safety Officer"is used by many licensees, use of the equipment should be available and followed.

l other terms are equaDy acceptable 8.10 2

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0. IMPLEMENTATION with the specified portions of the Commission's regula.

tions, the methods described herein will be uxd in the The purpou of this section is to provide informs. evaluation of submittals in connection with applications tion to applicants and licenues regarding the NRC staff's for a specific license, plans for utilizing this regulatory guide.

Regulatory Guides 1.8 ar.d 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 altemative method for complying with licensing setions for nuclear pour reactors.

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