[ RadSafe ] ALARA

[garyi at trinityphysics.com]

Hi Mike,

I'm officially out of this topic, but I'm still interested so I'll respond under an assumed name.  
I'm tempted to use Salsman but that's already taken by someone using assumed names.  
How about Joe?  

OK, Mike, if what you say is true, then there would be less flexibility if we got rid of Alara.  So 
how would that happen?  I just don't believe that people who were previously capable of 
flexibility would suddenly, without Alara, be rigidly constrained to following SOPs when faced 
by emergencies.  

I'll concede that making up strategies to avoid trivial risks is a creative exercise, and that 
Alara makes people get creative in order to satisfy the Alara requirement.  Taking away Alara 
as a regulatory requirement would probably reduce that creativity - no more lead lined 
underwear! 

No, in fact Alara makes us less flexible.  Alara is a constraint, a burden.

-Joe, who is not Gary

> SOPs and regulations both rest on the assumption that a group of
> people sitting in an office writing them up know more than the person
> who is dealing with a particular situation.  This is often true, but
> not always, and the times it is not true are often the most important
> one.  Having well thought-out, well written regs and SOPs is
> important, but they are not the whole solution



On 23 Jun 2008 at 11:35, Brennan, Mike  (DOH) wrote:

Subject:        	RE: [ RadSafe ] ALARA
Date sent:      	Mon, 23 Jun 2008 11:35:27 -0700
From:           	"Brennan, Mike  (DOH)" <Mike.Brennan at DOH.WA.GOV>
To:             	<radsafe at radlab.nl>

[ Double-click this line for list subscription options ] 

I believe that what we get from ALARA that we cannot get from just
writing clear regs is flexibility.  My formative years were spent in
the Navy's nuclear submarine community, both on subs and teaching at
Officer Submarine School.  The submarine community had (and presumably
has) very well developed Standard Operating Procedures, designed to
cover every foreseeable, or at least foreseen, possibility.  The crews
are taught the SOPs, and use them to the point where many are
memorized.  But additionally there is a program of training and
testing of individuals so that they not only understand the SOPs, but
the reasons behind them, and the assumptions that go into them, and
the underlying principles that go into those assumptions.  This is the
process that leads to someone becoming "Qualified in Submarines", and
it is a non-trivial achievement to earn your dolphins.  The point of
the qualification process it to produce people who can use the SOPs,
but who also can recognize when the SOPs aren't moving the situation
in the direction it should go, and creativity backed by deep knowledge
is called for.  I can think of several dozen cases in which the crew
had to leave the SOPs in order to save the ship or prevent highly
undesirable consequences.  I was the person in charge in one such
case.  

SOPs and regulations both rest on the assumption that a group of
people sitting in an office writing them up know more than the person
who is dealing with a particular situation.  This is often true, but
not always, and the times it is not true are often the most important
one.  Having well thought-out, well written regs and SOPs is
important, but they are not the whole solution.

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of garyi at trinityphysics.com Sent: Monday, June 23, 2008 10:45
AM To: radsafe at radlab.nl; WILLIAM LIPTON Subject: Re: [ RadSafe ]
ALARA

Bill,

Did Alara produce the successful facility, or did the successful
facility produce doses that were Alara?

In other words, if you went into a "dirty" plant and made them
implement Alara, would the plant become a model facility?  Or would it
still be "dirty" wherever scrutiny was lacking?  I agree that the
correlation you recall exists, but I strongly doubt that Alara is the
causative factor.

Unless you are willing to insist that Alara is a causative factor,
your concluding statement is unfounded.  I assert that the well run
facilities you recall would have been just as well run (perhaps
better) if Alara had never been conceived, had never been made a part
of the compliance requirement.

So I'm back to this:  Do we get anything from ALARA that we could not
have just by writing clear regs? 

And, this is the last I will post on this issue.  I am so busy keeping
things Alara that I have no more time to think about whether this is a
good policy.  :P

-Gary Isenhower

-
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