[ RadSafe ] Fw: [ As low as possible

William Lipton doctorbill34 at gmail.com
Wed Mar 2 22:31:23 CST 2011


I have to disagree with your statement that there is no clear guidance on
ALARA implementation.  In addition to NRC guidance documents, the nuclear
power industry has established a wealth of technical reports, industry
benchmarks, and good practices that provide clear, job specific guidance.
For the most part, a good ALARA program is also a good work program.

I am particularly interested in your "horror story" regarding the prevention
of tritium releases.  You don't provide enough detail for a judgment on
this, but it seems to be part of the industry's "Groundwater Protection
Program."  This is a voluntary effort which is unanimously supported by
every nuclear utility CEO.  The industry realizes the importance of public
confidence.  If you are skeptical, consider what happened at
Brookhaven<http://www.powerreactorrp.com/References/Groundwater/GAO_Brookhaven.pdf>.
A leak at the high flux beam reactor resulted in a tritium plume.  Although
the potential dose was minimal, public outcry forced the permanent shutdown
of the facility and the firing of the contractor.

Bill Lipton
It's not about dose, it's about trust.


On Wed, Mar 2, 2011 at 8:06 PM, Jerry Cohen <jjc105 at yahoo.com> wrote:

>
>
>
>
> ----- Forwarded Message ----
> From: Jerry Cohen <jjc105 at yahoo.com>
> To: William Lipton <doctorbill34 at gmail.com>
> Sent: Wed, March 2, 2011 3:58:49 PM
> Subject: Re: [ RadSafe ] [ As low as possible
>
>
> I hope that you are not suggesting that ALARA guidance is clear,
> understandable,
> and universally understood. I am quite familiar with this "guidance" which
> includes: taking into account economics, state of technology, cost-benefit
> assessment, and similarly undefined gibberish. I have seen a wide disparity
> in
> interpretation of ALARA, and have presented a paper at an ANS meeting
> detailing
> ALARA "horror stories" including: a $2 million expenditure for a tritium
> retention system to prevent releases of << 1.0 curie/yr., and more millions
> to
> maintain occupational exposures to a small fraction (<0.1) of MPC levels.
> To say
> the least, there has been a wide diversity of opinion on what is considered
> "reasonable". As a result, judgement as  to what meets ALARA requirements
> has
> been largely arbitrary .
> Jerry Cohen
>
>
>
>
> ________________________________
> From:William Lipton <doctorbill34 at gmail.com>
> To:Jerry Cohen <jjcohen at prodigy.net>; The  International Radiation
> Protection
> (Health Physics) Mailing List <radsafe at health.phys.iit.edu>
> Cc:Jerry Cohen <jjc105 at yahoo.com>
> Sent:Wed, March 2, 2011 1:27:28 PM
> Subject:Re: [ RadSafe ] [ As low as possible
>
>
> Before going on with your all too predictable rant, consider the definition
> of
> "ALARA," in 10 CFR 20.1003:
>
> "ALARA(acronym for "as low as is reasonably achievable") means
> making every reasonable effort to maintain exposures to radiation as far
> below
> the dose limits in this part as is practical consistent with the purpose
> for
> which the licensed activity is undertaken, taking into account the state of
> technology, the economics of improvements in relation to state of
> technology,
> the economics of improvements in relation to benefits to the public health
> and
> safety, and other societal and socioeconomic considerations, and in
> relation to
> utilization of nuclear energy and licensed materials in the public
> interest."
> Note the terms, "practical consistent with the purpose...," "taking into
> account
> ... the economics of improvements...," and "in relation to utilization of
> nuclear energy and licensed materials in the public interest."
> This is NOT, as you put it:  "... no matter how low the level of
> exposure, it could  always be made yet lower by expending more and more
> resources toward that end."
> If you feel there is a case where ALARA is being misinterpreted, point that
> out,
> not some far fetched hypothetical case.
> Bill Lipton
> It's not about dose, it's about trust.
>
>
>
>
> On Wed, Mar 2, 2011 at 3:25 PM, Jerry Cohen <jjc105 at yahoo.com>wrote:
>
> Michael,
> >It is interesting that in your article, you conjectured on a possible
> future
> >policy of "as low as unreasonably achievable" (ALAURA). It should be noted
> that
> >a precursor to the current ALARA policy was ALAP (as low as possible).
> ALAP was
> >superseded by ALARA  because of an awareness that no matter how low the
> level
> of
> >exposure, it could  always be made yet lower by expending more and more
> >resources toward that end.
> >     The "preisthood" (ICRP, etc) who advise such policies are composed of
> >experts on radiation effects. They are not stupid people; so why do they
> propose
> >policies that many of us consider ill advised? It may stem from a genuine
> >concern for human well-being---or--- could it possibly be from enlightened
> >self-interest? It is hard to get funding to protect people against
> anything
> that
> >is not harmful.
> >
> >Jerry Cohen
> >
> >
> >
> >________________________________
> >From: "Stabin, Michael" <michael.g.stabin at Vanderbilt.Edu>
> >To: " radsafe at agni.phys.iit.edu" <radsafe at agni.phys.iit.edu>
> >Sent: Wed, March 2, 2011 10:44:00 AM
> >Subject: [ RadSafe ] Health Physics News March 2011
> >
> >
> >Ann, thanks very much for your kind comment. If you don't get the
> newsletter, I
> >have posted a copy of this article (with permission) on the RADAR site:
> >
> >http://www.doseinfo-radar.com/Roentgen.html
> >
> >
> >Mike
> >
> >Michael G. Stabin, PhD, CHP
> >Associate Professor of Radiology and Radiological Sciences
> >Department of Radiology and Radiological Sciences
> >Vanderbilt University
> >1161 21st Avenue South
> >Nashville, TN 37232-2675
> >Phone (615) 343-4628
> >Fax   (615) 322-3764
> >e-mail      michael.g.stabin at vanderbilt.edu
> >internet   www.doseinfo-radar.com
> >
> >
>
> >------------------------------------------------------------------------------------
> >
> >
> >Date: Wed, 2 Mar 2011 08:21:50 -0600
> >From: Ann Troxler < Ann.Troxler at LA.GOV>
> >Subject: [ RadSafe ] Health Physics News March 2011
> >
> >Anyone who has not yet read the article by Michael Stabin and Jeffrey
> Siegel in
> >the March issue is in for a treat.  They treat the current "proposal" to
> climb
> >on to the IAEA bandwagon for dose reduction with humor, intelligence and
> >courage.   A must read.
> >
> >
> >
> >Ann M. Troxler,  BS, MEd
> >Environmental Scientist Senior
> >Louisiana Department of Environmental Quality
> >Office of Environmental Compliance
> >602 N Fifth Street
> >Baton Rouge, La. 70802
> >225-219-3991 W
> >225-219-3154 Fax
> >
> >
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