NUREG-1537, Part 2 - NRC

11 RADIATION PROTECTION-PROGRAM AND
WASTE MANAGE-MENT--
This chapter provides guidance for the review and evaluation of Chapter 11 of the
applicant's SAR, which should contain information about radiation protection and
radioactive waste management provisions at the facility. Information should
include radiological design bases of the reactor structures, systems, components,
experimental facilities, and laboratories under the reactor license; procedures,
policies, and practices employed to ensure compliance with applicable standards
and regulations on radiation doses and protection; procedures, policies, and
practices to ensure that radioactive wastes are managed in compliance with
appli6able regulations and standards; and the program to keep radiation exposure
at the facility as low as is reasonably achievable (ALARA). The responsibilities of
the health physics organization at the reactor facility and of any other onsite
radiation protection and radioactive waste management organizations should also
be described. Throughout this chapter, the applicant should show that licensed
activities will be conducted in compliance with applicable regulations, with
emphasis on 10 CFR Part 20.
This chapter should address all radioactive materials and radiation sources that are
produced in the reactor or used within the reactor facility and that are possessed
under the authority of the reactor operating license. Radioactive standards, check
sources, and other byproduct material used in the reactor program, reactor startup
sources, fuel and other special nuclear material, and source material that may be
under the authority of the reactor license should be included.
The complexity'of reactor facilities Will vazy widely from one non-power reactor to
another, as will the risks due to radiation. Furthermore, a non-power reactor..
facility may be only a small component of a large organization, such as a university
or corporation, and could obtain its radiation protection and radioactive waste
management services from other parts of the organization. Therefore, the scope
and magnitude of the radiation protection and radioactive waste management
programs should be expected to vary, and may be found acceptable as long as the
program is consistent with a uniform requirement to adequately protect the health
and safety of the public.
In some places in this chapter, reference is made to conservative best estimates or
conservative but realistic' calculations.: This means that estimates or calculations
performed by the applicant should always give results that are conservative
However, the applicant should try to avoid such large'levels of conservatism that
results are orders of magnitude from the expected true'answer. In -some cases,
non-power reactor applicants have used assumptions or calculation methods that
have produced very conservative, but acceptable results. Subsequently, regulatory
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