[ RadSafe ] Improper Application of ALARA following stabilization of Fukushima Nuclear Reactors

Victor Anderson victor.anderson at frontier.com
Fri Mar 15 18:17:40 CDT 2013

Good Afternoon,

Interesting ideas presented below.  While I agree with the spirit of the
opinions, I must differ with the arguments being made.  First off, ALARA
only applies to doses within the appropriate regulatory envelope.  If the
applied dose limits are too strict or too loose, one cannot argue that the
doses are or are not ALARA on the basis of the limits and requirements to
comply with them.  The next step in determination of ALARA is to determine
if there is a net benefit to all.  The argument below does make the case for
a lack of net benefit.  Finally, one must show that the dose has been
optimized: that the most benefit has been achieved for the minimum dose.
The real problem lies in determining what the appropriate regulatory limit
is for both Japan and the USA.  In the United States, there is only guidance
as listed in EPA 400.  As far as I know there are no regulations that
require evacuation at an immediate dose of between 1 and 5 rem.  Licensee's
(NPP) and the jurisdictions they are in are only required by regulation to
adopt emergency plans.  The limits for evacuating, shelter-in-place, and so
forth are just guidelines.  The problem I have with the US radiological
emergency response community is that they are overly focused on avoiding
radiation dose.  There is an appearance of doing "flips and twists" to avoid
even fractions of a millirem of dose with little or no consideration to the
consequences.  In this Mohan is absolutely correct.  Our nuclear emergency
planning needs to look at the whole picture.  For example, the EPZ area is
going to be subjected a blizzard with low temperatures.  Homes within the
EPZ are built to withstand these kinds of weather conditions.  The
evacuation shelters are not adequate to withstand the blizzard conditions.
Evacuation because of a 2 rem projected dose would be most unwise.  We need
to change our thinking to reflect a philosophy of considering the entire
situation in taking protective actions.


-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu
[mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of Mohan Doss
Sent: Friday, March 15, 2013 2:33 PM
To: The International Radiation Protection (Health Physics) Mailing List
Subject: [ RadSafe ] Improper Application of ALARA following stabilization
of Fukushima Nuclear Reactors

Dear All,
      A few days ago I attended a meeting dedicated to the Japanese 
people affected by the nuclear reactor accidents at Fukushima two years 
ago.  Because of the steps taken immediately following the accidents 
including evacuation, there were no acute effects from the radiation, 
and little long-term ill effects are expected from the low dose 
exposures the public received.  However, the prolonged evacuation based 
on radiation safety regulations, which is still continuing for about 
200,000, has resulted in severe emotional stress, and there is increased 
incidence of depression, PTSD, etc.  I have also read published articles 
and newspaper reports describing the evacuation stress-related deaths to 
be several hundred and may be even a thousand.  It does not seem right 
that following the radiation safety regulations should be resulting in 
thousands of people being sick with these mental illnesses and hundreds 
of deaths.  I think the reason for the radiation safety 
regulation-related casualties are because of an improper application of 
the ALARA principle that is part of the regulations.
     Of course we all know NRC website defines ALARA as "an acronym for 
'as low as (is) reasonably achievable,' which means making every 
reasonable effort to maintain exposures to ionizing radiation as far 
below the dose limits as 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. "
    In my interpretation, the key point in this long definition is 
benefit to public health, i.e. the steps for dose reduction should be 
taken so long as the efforts involved and costs incurred are 
commensurate with improvement to public health, and that implies, of 
course, that the steps taken should not be harming public health.  Since 
the emotional toll the long-term evacuation took in Chernobyl was 
already known, the emotional effects should have been factored into the 
ALARA considerations and calculations, balanced by the expected 
reduction in cancers from the long-term evacuation based on the LNT 
model.  Though it is assumed that low dose radiation increases the 
cancer risk using the LNT model, the public's cancer risk could be 
reduced by engaging a larger fraction of the public in regular physical 
exercise through more education, facilities, incentives etc., since 
exercise is known to reduce the risk of cancer by 20% or even higher. 
In view of this, it appears as if we have accepted immediate definitive 
depressions and related deaths in order to achieve a slightly reduced 
risk of cancer (LNT model-based) far into the future.  Does not appear 
to me to be a wise trade, considering the risk of cancer can be reduced 
by encouragement of exercise among the public, and making other 
lifestyle adjustments.  It is hard for me to imagine being in this 
situation, of being evacuated and living in temporary shelters for 2+ 
years.  If my family were evacuated in this manner, some members of my 
friends or family went through depression or died from depression, and 
the radiation safety officers or other officials there told me "I am 
sorry about the depressions and deaths in your family and friends,  but 
look how I have saved all of you from having increased cancer risk 10 
years from now", I would have fired them all right there (if I had the 
    I would like to know if you all agree with this assessment regarding 
the misapplication of ALARA.  If this assessment is correct, we should 
be ending the evacuation soon, even if it involves somewhat higher 
radiation doses to some of the public, in view of the likely improvement 
to their emotional health. If there is sufficient agreement among the 
radiation safety professionals here that we should end the evacuation 
soon based on such considerations, we can present the arguments to the 
Japanese government as our collective opinion, and encourage a return to 
normalcy soon in Fukushima.  If it is a collective opinion with a large 
number of professionals supporting it, they might listen.  Of course it 
will be difficult to end the evacuation now, since we have been telling 
the public the low dose radiation is dangerous, the public has believed 
us, and will undergo emotional stress in returning to their homes from 
the cancer concerns.  But we can discuss how to reduce those concerns if 
there is general agreement about ending the evacuation.
    Please answer the short anonymous survey at the following link soon, 
as I want to get a quick pulse on the community's thoughts.  Therefore, 
the survey will close on Monday, Mar 18, 2013, at 5:00 pm EDT: 
https://www.surveymonkey.com/s/7F2K3HR .  I will post the results here 
shortly thereafter.  You can of course discuss the ideas here, but the 
survey enables getting the pulse quickly, so we can decide whether to 
proceed further along the suggested lines, or accept the status quo. 
Thanks in advance for answering the survey.
    With best regards,

Mohan Doss, Ph.D., MCCPM
Medical Physicist,
Associate Professor, Diagnostic Imaging,
Fox Chase Cancer Center, R427
333 Cottman Avenue,
Philadelphia, PA 19111-2497.
Phone: 215 214-1707
Fax:   215 728-4755
E-mail:Mohan.Doss at fccc.edu

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