From somewhere I have taken it... may be some bridge general or particular specifications of here. In any case, the "prequalified" values in the standing NBE AE-88 spanish code for loads are
Angle of inner friction for...
natural soils
compact sand gravel 30 deg
soft sand gravel 30 deg
clay 20 deg
back-fills
"vegetal" earth 25 deg
cohesionless 30 deg
crushed rock 40 deg
sexagesimal.
I don't think so to take 37 deg for something that has such angle of inner friction may be in definitive criticable if the applicable code or specification does not forbids so.
In any case, I think that precisely is the fear of submerged or saturated soils lubricating the ground what may be exacting any of the conservative evaluations of the angle of inner friction.
Now I list for you the angles of inner friction listed for the submerged parts in figures of the book on sheet piles
Cálculo Práctico de Pantallas de Tablestacas
ARBED-BELVAL
Columetal-Luxembourg
G. Colling
Madrid 1971
first a table
Sand and gravel 30 to 40 deg
Clayey Sand 25 to 35 deg
Clay 10 to 25 deg
now the angles of inner friction in embedded part in figures, deg
30, 30, 30, 30, 30, 30, 30
it is clearly a normalization but also an opinion on what one that works in the field thinks has to pass to pupils.
Also look table 5.5.5.B in AASHTO, gives delta friction at interface...that even if being less than the angle of inner friction out of natural behaviour, sometimes is allowed to go as high as the angle of inner friction itself: the highest delta listed is 35 deg and most are around 20...also suggesting angles of inner friction of around 30 typically for poorly characterized soils.
So my advice is only going high in angle on inner friction and the interface if the values standing at the worse likely situation (for some sites, the soil being submerged) are well characterized by test.
Yet if in the code you use you don't see anything contrary it is logical to assume to use the warranted value is allowed.