U.S. NUCLEAR REGULATORY COMMISSION 

REGULATORY

July 1993

GUIDE

OFFICE OF NUCLEAR REGULATORY RESEARCH 

REGULATORY GUIDE 8.37 

(Draft issued as DG-8013) 

ALARA LEVELS FOR EFFLUENTS FROM MATERIALS FACILITIES

A. INTRODUCTION 

In 10 CFR Part 20, "Standards for Protection 

Against Radiation," § 20.1302(b) requires that: 

"A licensee shall show compliance with the 

annual dose limit in § 20.1301 by (1) Dem

onstrating by measurement or calculation that 

the total effective dose equivalent to the indi

vidual likely to receive the highest dose from 

the licensed operation does not exceed the 

annual dose limit; or (2) Demonstrating that 

(i) The annual average concentrations of 

radioactive material released in gaseous and 

liquid effluents at the boundary of the unre

stricted area do not exceed the values speci

fied in Table 2 of Appendix B to 

§§ 20.1001-20.2401; and (ii) If an individ

ual were continually present in an unrestricted 

area, the dose from external sources would 

not exceed 0.002 rem (0.02 mSv) in an hour 

and 0.05 rem (0.5 mSv) in a year." 

in addition, 10 CFR 20.1101(b) requires that: 

"The licensee shall use, to the extent practica

ble, procedures and engineering controls 

based upon sound radiation protection princi

ples to achieve occupational doses and doses

USNRC REGULATORY GUIDES 

Regulatory Guides are issued to describe and make available to the pub lic such information as methods acceptable to the NRC staff for imple menting specific parts of the Commission's regulations, techniques 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 permits and licenses. Regulatory Guides are not substitutes for regula tions, and compliance with them is not required. Methods and solutions different from those set out in the guides will be acceptable If they pro vide a basis for the findings requisite to the issuance or continuance of a permit or license by the Commission. 

This guide was Issued after consideration of comments received from the public. Comments and suggestions for improvements in these guides are encouraged at all times, and guides will be revised, as ap propriate, to accommodate comments and to reflect new information or 

experience.

to members of the public that are as low as is 

reasonably achievable (ALARA)." 

This regulatory guide provides guidance on de

signing an acceptable program for establishing and 

maintaining ALARA levels for gaseous and liquid ef

fluents at materials facilities. Materials facilities are 

those facilities at which the possession or use of 

source, byproduct, or special nuclear material is 

licensed under 10 CFR Parts 30, 40, 60, 61, and 70. 

Additional guidance on ALARA programs can be 

found in other regulatory guides. While these guides 

deal primarily with occupational exposure and may be 

specific to one type of licensee, they contain pro

grammatic information that may be useful to all licen

sees. They are as follows: 

" Regulatory Guide 8.10, "Operating Philoso

phy for Maintaining Occupational Radiation 

Exposures As Low As Is Reasonably Achiev

able." This guide delineates the components 

of an ALARA program. 

"* Regulatory Guide 8.18, "Information Rele

vant to Ensuring that Occupational Radiation 

Exposures at Medical Institutions Will Be As 

Low As Reasonably Achievable." 

" Regulatory Guide 8.31, "Information Relevant 

to Ensuring that Occupational Radiation Ex

posures at Uranium Mills Will Be As Low As 

Is Reasonably Achievable."

Written comments may be submitted to the Regulatory Publications 

Branch, DFIPS, ADM, U.S, Nuclear Regulatory Commission, Washing ton, DC 20555. 

The guides are issued in the following ten broad divisions: 

1, Power Reactors 6. Products 

2. Research and Test Reactors 7. Transportation 3. Fuels and Materials Facilities 8. Occupational Health 

4. Environmental and Siting 9, Antitrust and Financial Review 

5. Materials and Plant Protection 10, General 

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. 

Government Printing Office, Post Office Box 37082, Washington, DC 

20013-7082, telephone (202)512-2249 or (202)512-2171. 

Issued guides may also be purchased from the National Technical Infor

mation Service on a standing order basis. Details on this service may be 

obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161.
9 Regulatory Guide 10.8, "Guide for the 

Preparation of Applications for Medical Use 

Programs." Section 1.3 and Appendix G deal 

specifically with ALARA programs for medi

cal facilities. 

In addition, further information can be found in 

Revision 1 to NUREG-0267, 1 "Principles and Prac

tices for Keeping Occupational Radiation Exposures 

at Medical Institutions As Low As Reasonably 

Achievable" (October 1982). 

Any information collection activities mentioned 

in this regulatory guide are contained as requirements 

in 10 CFR Part 20, which provides the regulatory ba

sis for this guide. The information collection require

ments in 10 CFR Part 20 have been approved by the 

Office of Management and Budget, Approval No. 

3150-0014. 

B. DISCUSSION 

At the relatively low levels of radiation exposure 

in the United States, it is difficult to demonstrate a 

relation between exposure and any health effects. 

The dose limits in 10 CFR Part 20 are based on limit

ing dose to what is considered to be an acceptable 

level of risk to the exposed individual. Still, any ra

diation exposure may carry some risk. Thus, the NRC 

requires licensees to take actions, to the extent practi

cable, utilizing procedures and engineering controls to 

further reduce risk below the levels implicit in the 

dose limits in keeping with the principle that expo

sures should be as low as is reasonably achievable. 

This is the goal and purpose for radiation protection 

programs. In order to achieve this goal, licensees 

must control the way radioactive material is handled 

from receipt through disposal. 

NRC licensees have traditionally reduced expo

sures and effluents to small fractions of the dose limits 

using the ALARA process. Recently, the Environ

mental Protection Agency (EPA) conducted 2 studies 

of materials facilities. The first was a survey of 367 

randomly selected nuclear materials licensees. The 

highest estimated dose to a member of the public 

from effluents was 8 mrem/yr, based on very conser

vative modeling. In addition, 98% of the facilities ex

amined had doses to members of the public resulting 

from effluents less than 1 mrem/yr. The second study 

evaluated effluents from 43 additional facilities that 

were selected because of their potential for effluent 

releases resulting in significant public exposures. Of 

these, none exceeded 10 mrem/yr to a member of the 

public, and 75% of them were less than 1 mrem/yr to 

a member of the public. Based upon this information, 

and the ongoing NRC program of licensing and in

spection, the NRC expects that the goals suggested in 

'Copies are available for purchase from the U.S. Government 

Printing Office, P.O. Box 37082, Washington, DC 

20013-7082, telephone (202) 512-2249 or (202) 512-2171.

this guide will be easily achievable by all NRC materi

als licensees. 

The NRC staff will be examining licensee pro

grams to determine compliance with the requirements 

of 10 CFR Part 20. In the event that a particular ma

terials facility licensee establishes ALARA goals that 

are less stringent than the goals identified in this 

guide, or consistently fails to achieve ALARA goals it 

has established pursuant to this guide, the NRC staff 

will conduct a more detailed review of that licensee's 

program to determine the rationale for the greater 

levels. In such circumstances, the NRC will evaluate 

the rationale provided by the licensee, as well as the 

licensee's operations, to determine whether the licen

see has established an adequate ALARA program 

and is operating that program in compliance with 10 

CFR 20.1101(b). 

This guide deals with only a part of a licensee's 

overall radiation protection program. Specifically, it 

deals with the application of ALARA in controlling 

gaseous and liquid effluents. In addition to controlling 

doses resulting from the release of effluents, licensees 

must implement a radiation protection program that 

controls dose rates in unrestricted areas to maintain 

overall doses to workers and members of the public 

ALARA and below the limits in 10 CFR Part 20. Li

censees may choose to focus their evaluation of pub

lic dose to members of a critical group as suggested by 

the International Commission on Radiological Protec

tion (ICRP) as a means of identifying and controlling 

the exposure to the individual member of the public 

likely to receive the highest exposure. 

NRC licensees have taken actions to maintain 

doses to both workers and members of the public 

ALARA under the admonition contained in 

10 CFR 20.1(c), 2 which requires that licensees 

"make every reasonable effort" to maintain doses 

and effluents ALARA. NRC licensees have generally 

reduced doses to relatively small fractions of the dose 

limits. Therefore, the NRC staff does not expect that 

most licensees will need to make significant changes 

to procedures, operations, and equipment in order to 

be in compliance with the requirements of 10 CFR 

20.1101(b). 2 However, for those licensees who have 

not previously developed a radiation protection pro

gram that includes written procedures and policies as 

well as a commitment to ALARA, additional steps 

may be necessary to demonstrate compliance with 

requirements now explicit in 10 CFR Part 20 to main

tain doses ALARA. 

Components of an effective radiation protection 

program, as required by 10 CFR 20.1101 (b), include 

radiation exposure control, written procedures and 

2In 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

mains in effect until January 1, 1994, or when licensees vol

untarily implement the requirements of 10 CFR Part 20 §§ 

20. 1001 through 20.2401, whichever is earlier.

8.37-2

I
policies, control of radioactive materials, radioactive 

contamination control, radioactive waste manage

ment, training, program reviews, and audits. Guid

ance on other facets of a radiation protection pro

gram for materials facilities is currently under devel

opment. 

C. REGULATORY POSITION 

An ALARA program for effluent control to con

trol doses to members of the public should contain 

the following program elements: 

1. Management commitment to ALARA, includ

ing goals, 

2. Procedures, engineering controls, and process 

controls, 

3. Surveys and effluent monitoring, 

4. ALARA reviews, 

5. Worker training. 

These program elements, while given specifically 

for effluents in this guide, are also applicable to the 

control of direct exposure. 

1. MANAGEMENT COMMITMENT TO 

ALARA, INCLUDING GOALS 

The single most critical aspect of successfully 

achieving ALARA in the radiation safety program is 

the commitment of management to maintain doses 

ALARA, both occupational and to the public. The 

licensee's radiation protection program (including ALARA elements) should be commensurate with the 

potential hazards associated with the licensed activity. 

1.1 ALARA Policy 

The licensee should establish an ALARA policy 

that is issued and supported by the highest level of 

management. All employees should be made aware of 

the ALARA policy through training. This policy 

should make clear that all personnel will be responsi

ble for ensuring that work they perform is in accor

dance with ALARA procedures. 

1.2 ALARA Goals 

To assist in demonstrating compliance with the 

requirements of 10 CFR Part 20, the licensee should 

set ALARA goals for effluents at a modest fraction of 

the values in Appendix B, Table 2, Columns 1 and 2, 

to §§ 20.1001-20.2401. These goals may be set 

independently for gaseous and liquid effluents. Past 

experience and effluent information reported to the 

NRC staff indicate that goals within a range of 10 to 

20% of Appendix B values or less can be achieved by almost all materials facility licensees. However, estab

lishing a goal is not intended as setting a precedent or 

a de facto limit. Goals may need to be adjusted up or

down on the basis of the annual review of what may 

be ALARA for the particular circumstance. 

If the licensee chooses to demonstrate compli

ance with 10 CFR 20.1301 through a calculation of 

the total effective dose equivalent (TEDE) to the in

dividual likely to receive the highest dose, the licen

see should set the ALARA goal at a modest fraction 

of the dose limit for members of the public. Experi

ence indicates that values of about 0.1 mSv/yr (10 

mrems/yr) or less should be practicable for almost all 

materials facility licensees. Licensees need not as

sume worst case models when calculating dose but 

rather should make assumptions that will result in re

alistic estimates of actual dose received by the mem

ber of the public likely to receive the highest dose. 

If the circumstances of a particular case are such 

that the licensee cannot achieve effluent concentra

tions less than 20% of the Appendix B values or dem

onstrate by calculation that the TEDE to the individ

ual likely to receive the highest dose is less than 0.1 

mSv/year (10 mrems/year), the ALARA philosophy 

continues to apply, and the licensee should demon

strate compliance with the requirements of 10 CFR 

20.1101(b) by evaluating procedures, engineering 

controls, and process controls as described in Regula

tory Position 2 below. 

1.3 Investigation Levels 

In addition to ALARA goals, the licensee should 

establish investigation levels at effluent values that are 

close to normal or anticipated release levels. If ex

ceeded, an investigation should be initiated and cor

rective actions should be taken, as appropriate. 

1.4 Radiation Safety Committee 

For licensees that have a radiation safety commit

tee, one responsibility of that committee should be to 

establish ALARA goals. The committee must meet at 

least annually to review the radiation protection pro

gram content. The committee should also review 

ALARA goals and discuss ways to further reduce 

doses if necessary. Goals may need to be adjusted on 

the basis of the committee's review. The committee 

should assess short-term and long-term performance 

in terms of achieving the ALARA goals. ALARA 

goals and the results of reviews should be reported at 

least annually to senior management with recommen

dations for changes in procedures or equipment 

needed to accomplish the requirements of the 

ALARA policy as appropriate. 

For licensees with no radiation safety committee, 

the radiation safety officer should be responsible for 

setting, adjusting, and periodically reviewing the ra

diation protection program and the ALARA goals. 

2. PROCEDURES, ENGINEERING 

CONTROLS, AND PROCESS CONTROLS 

Licensees should consider available engineering 

options to control the release of effluents to the

8.37-3
environment. Examples of the available options in

clude filtration, encapsulation, adsorption, contain

ment, and the storage of liquids for decay. If further 

reductions in effluents are needed to achieve ALARA 

goals, the recycling of process fluids, leakage 

reduction, and modifications to facilities, operations, 

or procedures should be considered. These 

modifications should be implemented unless an analy

sis indicates that a substantial reduction in collective 

dose would not result or costs are considered unrea

sonable. A determination of reasonableness may be 

based on a qualitative analysis requiring the exercise 

of judgment and consideration of factors that may be 

difficult to quantify. These factors could include 

nonradiological social or environmental impacts, the 

availability a-nd practicality of alternative technolo

gies, and the potential for unnecessarily increasing 

occupational exposures. 

Alternatively, reasonableness may be based on a 

quantitative cost/benefit analysis. Preparation of an 

ALARA cost/benefit analysis requires the use of a 

dollar value per unit dose averted. The NRC staff is 

conducting a review and analysis of various methodo

logical approaches to setting dollar values, and the 

staff recognizes that varying degrees of justification 

exist for a wide range of dollar values. However, the 

value of $1000 per person-cSv (man-rem) is accept

able to the NRC staff and may be used pending com

pletion of that reassessment. 

3. SURVEYS AND EFFLUENT MONITORING 

Licensees must perform surveys and 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

termine whether radiation levels and effluents meet 

the licensee's established ALARA goals. These sur

veys should include air and liquid effluent monitoring, 

as appropriate, as well as surveys of dose rates in un

restricted areas. 

If the licensee chooses to demonstrate compli

ance with dose limits to the member of the public 

likely to receive the highest dose by calculating the 

TEDE, all significant environmental pathways should 

be evaluated. Some of the equations included in 

Regulatory Guide 1.109, "Calculation of Annual 

Doses to Man From Routine Releases of Reactor Ef

fluents for the Purpose of Evaluating Compliance with 

10 CFR Part 50, Appendix I," and Regulatory Guide 

3.51, "Calculational Models For Estimating Radiation 

Doses to Man from Airborne Radioactive Materials 

Resulting from Uranium Milling Operations," may be 

useful in performing dose assessments. However, 

pending the anticipated revision of these regulatory 

guides, the dose conversion factors should be based

on the methodology described in ICRP 30, "Limits for 

Intakes of Radionuclides by Workers."3 

3.1 Airborne Radioactive Effluent Monitoring 

When practicable, releases of airborne radioac

tive effluents should be from monitored release points 

(e.g., monitored stacks, discharges, vents) to ensure 

that the magnitude of such effluents is known with a 

sufficient degree of confidence to estimate public ex

posure. Licensees should verify the performance of 

effluent monitoring systems by regular calibration (at 

least annually) to ensure that these monitors provide 

reliable indications of actual effluents. Further guid

ance can be found in Regulatory Guide 4.15, "Qual

ity Assurance for Radiological Monitoring Programs 

(Normal Operations)--Effluent Streams and the Envi

ronment." 

Effluent monitoring systems should be designed 

in accordance with ANSI N13.1 (1969), "Guide to 

Sampling Airborne Radioactive Materials in Nuclear 

Facilities," 4 and ANSI N42.18, "Specification and 

Performance of On-site Instrumentation for Continu

ously Monitoring Radioactive Effluents." 4 

NCRP Commentary No. 3, "Screening Tech

niques for Determining Compliance with Environ

mental Standards," 5 published in January 1989 and 

the addendum published in October 1989 provide ac

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 

as they can demonstrate that the code uses approved 

methods. 

3.2 Liquid Effluent Monitoring 

effluents should be monitored.6 Methods for calculat

ing doses from liquid effluents similar to those de

scribed in NCRP Commentary No. 3 are currently un

der development by the NCRP. In the interim, guid

ance available in Regulatory Guide 4.14, "Radiologi

cal Effluent and Environmental Monitoring at Ura

nium Mills," and Regulatory Guide 4.16, "Monitor

ing and Reporting Radioactivity in Releases of Radio

active Materials in Liquid and Gaseous Effluents from 

Nuclear Fuel Processing and Fabrication Plants and 

3Copies are available from Pergamon Press, Inc., 660 White 

Plains Road, Tarrytown, NY 10591-5153, phone (914) 594-9200. 

4Copies of ANSI standards may be obtained from the Ameri can National Standards Institute, Inc., 1430 Broadway, New 

York, NY 10018. 

"5Copies may be purchased from the National Council on Ra

diation Protection and Measurements, NCRP Publications, 

7910 Woodmont Avenue, Bethesda, MD 20814. 

8Liquid effluents do not include releases into sanitary sewerage in accordance with 10 CFR 20.2003(a) or excreta from pa tients in accordance with 10 CFR 20.2003(b).

8.37-4

I
Uranium Hexafluoride Production Plants," may be 

useful to materials licensees in calculating doses from 

liquid effluents. 

3.3 Unmonitored Effluents 

If a licensee has release points for which monitor

ing is not practicable, the licensee should estimate the 

magnitude of the unmonitored effluents. For in

stance, a research hospital or university broad scope licensee might have dozens of locations where radio

active material could be released. The licensee should 

estimate the magnitude of unmonitored releases and 

include those estimated amounts when demonstrating compliance with dose limits and the licensee's 

ALARA goals. Unmonitored releases may be esti

mated based on the quantity of material used in these areas or the number of procedures performed or other appropriate methods. When practicable, unmonitored effluents should not exceed 30% of the 

total estimated effluent releases. 

4. ALARA REVIEWS 

According to 10 CFR 20.1101(c), the content 

and implementation of the radiation protection 

programs, which would include the ALARA effluent control program, must be reviewed at least annually. This review should include analysis of trends in 

release concentrations and radionuclide usage as well as other available monitoring data. The review should 

provide a documented basis for determining whether 

changes are needed in systems or practices to achieve

ALARA effluent goals. In addition, the licensee 

should review all designs for system installations or 

modifications to ensure compliance with 

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

should be reported to senior management along with 

recommendations for changes in facilities or proced

ures that are deemed necessary to achieve ALARA 

goals. 

5. WORKER TRAINING 

Specific training on ALARA should be provided 

as a part of the annual employee radiation protection training (see 10 CFR 19.12). For an ALARA pro gram to be successful, employees must understand 

the ALARA program's goals and principles. The 

radiation protection staff should be available to help clarify the ALARA policy and its goals and to assist 

employees both during training and throughout the 

year. 

D. IMPLEMENTATION 

The purpose of this section is to provide informa

tion to applicants and licensees regarding the NRC staff's plans for using this guide. 

Except in those cases in which an applicant pro

poses an acceptable alternative method for complying with specified portions of the Commission's regula tions, the methods described in this guide will be used 

in the evaluation of applications for new ]icenses, li

cense renewals, or license amendments and for evalu

ating compliance with 10 CFR 20.1001-20.2401.

8.37-5
REGULATORY ANALYSIS

A separate regulatory analysis was not pre

pared for this regulatory guide. The regulatory 

analysis prepared for 10 CFR Part 20, "Standards 

for Protection Against Radiation" (56 FR 23360), 

provides the regulatory basis for this guide. A copy

of the "Regulatory Analysis for the Revision of 10 

CFR Part 20" (PNL-6712, November 1988) is 

available for inspection and copying for a fee at the 

NRC Public Document Room, 2120 L Street NW., 

Washington, DC, as an enclosure to Part 20.

8.37-6

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