[ RadSafe ] Re:Reasonable risk?
sandyfl at earthlink.net
Fri Apr 21 14:41:29 CDT 2006
On 21 Apr 2006 at 12:47, Glenn R. Marshall wrote:
> But in a court of law, it means whatever a sleazy lawyer can convince a judge and
> jury to agree to.
Fortunately there is case law where courts have ruled that meeting
the regulatory limits determines that the individual was not exposed
to any harmful dose of radiation, and was deemed not to be adversely
affected. I say this is fortunate because if that were not the
situation, then any court based on any legal proposition that ALARA
was not met, would be difficult to judge, since as you pointed out,
what is reasonable to one may not be reasonable to another.
While the De Minimis rule was never promulgated, there are many
instances of De Minimis in 10 CFR 20 for example. The 10% rule
requiring monitoring is one. The 0.1 Rem public dose limit is another
one. the 0.5 rem fetal dose limit is another one (which coincides
with the 10% rule for required monitoring).
ALARA is simply a bad philosophy considering that it really can't be
defined due to the subjectiveness. If I use $10,000 per manrem as
compared to another facility using $30,000 per manrem, which one of
us is not ALARA? Since there is no definitive criteria, the
reasonableness is assumed, and I say that both are. However I
hypnotize that the facility spending the $30,000 per manrem saved is
actually doing their employees, stakeholders and management a dis-
service, since they have spent considerably more money and show no
real positive benefits, not have they really averted any significant
adverse affects. Those who state they can justify really can not show
positive causal relationship, nor benefit. It is all simply assumed
to be. That doesn't make it so.
Senior Vice President, Technical Operations
Global Dosimetry Solutions, Inc.
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Tel: (949) 296-2306 / (888) 437-1714 Extension 2306
E-Mail: sperle at dosimetry.com
E-Mail: sandyfl at earthlink.net
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