Question 381: (a) For nuclear power facilities does
conformance with Regulatory Guides 8.8 and 8.10 fully meet
the requirements of 20.1101 (b) regarding ALARA programs?
(b) If not, does the NRC plan to update these Regulatory
guides to conform to new requirements?
Answer: No, to both questions. (a) Regulatory Guide 8.8
Rev. 3 is now (in 1993) 15 years old, the second proposed
revision to this guide is now 11 years old, and Regulatory
Guide 8.10 is 16 years old. These guides do not adequately
cover all the means that the nuclear power industry has
developed and shown to be practical and cost-effective for
maintaining occupational doses ALARA. For example, these
guides do not recognize the importance of water chemistry
controls and radiation source and field controls for
maintaining doses that are ALARA.
(b) The NRC staff has not yet established a schedule for
updating these guides. The staff did issue Draft
Regulatory Guide DG-8004, "Radiation Protection Programs
for Nuclear Power Plants," to provide guidance on
compliance with 10 CFR 20.1101, "Radiation Protection
Programs," including guidance on the ALARA requirements of
10 CFR 20.1101 (b). However, representatives of the
nuclear power industry stated that this guide was not
needed and it has been withdrawn. (Reference: 10 CFR
20.1101).