ALARA Program Plan

1.1 We, the management of the Augusta University, are committed to a program for keeping individual and collective doses as low as is reasonably achievable (ALARA). In accord with this commitment, we maintain a technical organization for radiation safety and have developed the necessary written policy, procedures, and instructions to foster the ALARA concept within our institution. The organization includes a Radiation Safety Committee (RSC) and a Radiation Safety Officer (RSO), and Radiation Safety Office.

1.2 The program includes a formal annual review of the radiation safety program, including ALARA considerations. This will consist of reviews of operating procedures and past dose records, inspections, and consultations with the Radiation Safety staff.

1.3 Modifications to operating and maintenance procedures and to equipment and facilities will be made if they will reduce exposures unless the cost, in our judgment, is considered to be unjustified. We will be able to demonstrate, if necessary, that improvements have been sought, that modifications have been considered, and that they have been implemented when reasonable. If modifications have been recommended but not implemented, we will be prepared to describe the reasons for not implementing them.

1.4 In addition to maintaining doses to individuals as far below the limits as is reasonably achievable, the sum of the doses received by all exposed individuals will also be maintained at the lowest practicable level. It would not be desirable, for example, to hold the highest doses to individuals to some fraction of the applicable limit if this involved exposing additional people and significantly increasing the sum of radiation doses received by all involved individuals.

2.1 Review of Proposed Users and Uses

2.1.1 The RSC will review the qualifications of each applicant with respect to the types and quantities of materials and methods of use for which application has been made to ensure that the applicant will be able to take appropriate measures to maintain exposure ALARA.

2.1.2 When considering a new use of radioactive material, the RSC will review the efforts of the applicant to maintain exposure ALARA.

2.1.3 The RSC will ensure that the users justify their procedures and that individual and collective doses will be ALARA.

2.2 Delegation of Authority
Realizing that the judicious delegation of RSC authority is essential to the enforcement of an ALARA program,

2.2.1 The RSC will delegate authority to the RSO for enforcement of the ALARA concept.

2.2.2 The RSC will support the RSO when it is necessary for the RSO to assert authority. If the RSC has overruled the RSO, it will record the basis for its action in the minutes of the RSC quarterly meeting.

2.3 Review of ALARA Program

2.3.1 The RSC will encourage all users to review current procedures and develop new procedures as appropriate to implement the ALARA concept.

2.3.2 The RSC will conduct a quarterly review of occupational radiation exposure with particular attention to instances in which the investigational levels in Table 1 are exceeded. The principal purpose of this review is to assess trends in occupational exposure as an index of the ALARA program quality and to decide if action is warranted when investigational levels are exceeded (see Section 6.0 below for a discussion of investigational levels).

NOTE: It is emphasized that the investigational levels in this program are not new dose limits but, as noted in ICRP Report 26, "Recommendations of the International Commission on Radiological Protection," serve as check points above which the results are considered sufficiently important to justify investigations.

Table I - Quarterly Investigation Levels

Part of Body	Level I	Level II
Whole Body: head and trunk	125 mrem	375 mrem
Eyes	375 mrem	1125 mrem
Extremities and skin of the whole body	1250 mrem	3750 mrem

 2.3.3 The RSC will evaluate our institution's overall efforts for maintaining doses ALARA on an annual basis. This review will include the efforts of the RSO, authorized users, and workers as well as those of management.

3.1 Annual and Quarterly Review

3.1.1 Annual review of the radiation safety program. The RSO will perform an annual review of the radiation safety program for adherence to ALARA concepts. Reviews of specific methods of use may be conducted on a more frequent basis.

3.1.2 Quarterly review of occupational exposures. The RSO will review at least quarterly the external radiation doses of authorized users and workers to determine that their doses are ALARA in accordance with the provisions of Section 6.0 of this program and will prepare a summary report for the RSC.

3.1.3 Quarterly review of records of radiation surveys. The RSO will review radiation surveys in unrestricted and restricted areas to determine that dose rates and amounts of contamination were at ALARA levels during the previous quarter and will include summary data in the minutes of the RSC meeting.

3.2 Education Responsibilities for ALARA Program

3.2.1 The RSO will include ALARA program efforts in regularly scheduled briefings and educational sessions.

3.2.2 The RSO will ensure that authorized users, workers, and ancillary personnel who may be exposed to radiation will be instructed in the ALARA philosophy and informed that management, the RSC, and the RS0 are committed to implementing the ALARA concept.

3.3 Reviewing Instances of Deviation from Good ALARA Practices
The RSO will investigate all known instances of deviation from good ALARA practices and, if possible, will determine the causes. When the cause is known, the RSO will implement changes in the program to maintain doses ALARA.

4.1 New Methods of Use Involving Potential Radiation Doses

4.1.1 The authorized user will consult with the RSO and/or RSC during the planning stage before using radioactive materials for new uses.

4.1.2 The authorized user will review each planned use of radioactive materials to ensure that doses will be kept ALARA. Trial runs may be helpful.

4.2 Authorized User's Responsibility to Supervised Individuals

4.2.1 The authorized user will explain the ALARA concept and the need to maintain exposures ALARA to all supervised individuals.

4.2.2 The authorized user will ensure that supervised individuals who are subject to occupational radiation exposure are trained and educated in good health physics practices and in maintaining exposure ALARA.

 5.1 Workers will be instructed in the ALARA concept and its relationship to work procedures and work conditions.

5.2 Workers will be instructed in recourses available if they feel that ALARA is not being promoted on the job.

 This institution has established investigational levels for occupational external radiation doses which, when exceeded, will initiate review or investigation by the RSC and/or the RSO. The investigational levels that we have adopted are listed in Table 1. These levels apply to the exposure of individual workers. 

The RSO will review and record on the dosimeter processor's report results of personnel monitoring not less than once in any calendar quarter. The following actions will be taken at the investigational levels as stated in Table 1:

6.1 Personnel dose less than Investigational Level I.
Except when deemed appropriate by the RSO, no further action will be taken in those cases where an individual's dose is less than Table 1 values for the Investigational Level I.

6.2 Personnel dose equal to or greater than Investigational Level I but less than Investigational Level II.

The RSO will review the dose of each individual whose quarterly dose equals or exceeds Investigational Level I and will notify the individual and his/her Department Chairman in writing. The RSO will ask the individual to review his/her work procedures to evaluate the cause of the exposure and whether there are reasonable measures which can be taken to reduce future exposures. Radiation Safety Office review and consultation will be offered.

6.3 Personnel dose equal to or greater than Investigational Level II.

The RSO will conduct an investigation, in a timely manner, of the causes of all personnel doses equaling or exceeding Investigational Level II. The investigation will include an interview with the individual.  The individual will be provided a copy of the report for review, and a copy will be sent to his/her Department Chairman. Conclusions drawn from the investigation provide a basis for confirming or modifying the dose and for establishing corrective actions. A report of the investigation and any actions taken will be presented to the RSC at its first meeting following completion of the investigation. The details of these reports will be included in the RSC minutes.

6.4 Reestablishment of investigational levels to levels above those listed in Table 1.

If there are cases where a worker's or a group of workers' doses need to exceed an investigational level, a new, higher investigational level may be established for that individual or group on the basis that it is consistent with good ALARA practices. Justification for new investigational levels will be documented. The RSC will review the justification and must approve or disapprove all revisions of investigational levels.