FW: ALARA

["Neufang, Theodore O." <Theodore.Neufang@pseg.com>]

If at first you don't succeed...

Ok you all sucked me in.
***%#@!From Jerry's comments to Jeff's comments we have the gamut.  "Dumb
idea" to "whatever it takes" to paraphrase.
Whether it's hormesis or LNT is really not the issue, ALARA is the law.
Unfortunately, the term "reasonable" seems to get left out.
Yes I should "reasonably" limit my exposure to radiation, as well as fatty
foods, nitrates, alcohol and ill reputes.  Do I spend the money to ensure
this happens ALL the time (ALAA)?  No.  Do I do the best I can?  Most of the
time.  Am I being reasonable?  Depends on who you ask.  Better yet it
depends on who is making and enforcing the law.

For the nuclear power plant industry, the problem is 2 fold.  

As long as we continue to push everyone to "Top Quartile" dose performance,
the industry will be forced(?) to demonstrate that they have complied with
"the LAW" and made every "reasonable" effort to reduce personnel exposures.
So small plants, large plants, 5 years old, 25 years old,  HWCI, non HWCI,
Noble metal injected, shutdown, or extended outage, We ALL get lumped
together and judged as equals.  WE all know there are differences, but INPO
and the NRC still judge us on our total dose performance.  (the lower the
better)  No fudge factors.  Just straight numbers.  

Secondly, we have deregulation.  So we must lower exposures, and lower
costs.   All the money spent must basically relate directly to MWh
generated.  Whether the value of a man-Rem is $2000 or $10000, rarely can a
large expenditure (permanent shielding for example) be justified for dose
savings over the life of an old plant.  The limited monetary resources are
now doled out with even greater scrutiny.  ALARA has a much harder time
competing for that money.
But again in the eyes of the regulatory agencies, if you are higher than
Plant X, you must not be doing enough. 

So my soap box aside, what is the answer? 

Well ALARA is  a good idea, just like the abstinence of fatty foods and the
like, (I'm not quite sure about the alcohol and ill reputes) and should be
applied reasonably whenever possible.  However, plants should be judged on a
more apples to apples basis, and not simply on numbers.  A low dose plant
could have a crappy ALARA program but "rank" higher than an old plant with a
high source term and a great ALARA program.  This is an unfair comparison. 
 
The second thing, which will probably bring more debate, is that the
industry needs to realize that generally, deregulation is here to stay.
Money IS the bottom line.  Outages have to be short, and money is not as
free as it used to be.  Business is business.  This means that the
"REASONABLE" part of ALARA may have a different definition than we are used
to.  It may mean that we decide to educate, inform and train our radworkers
(advanced training so to speak) on methods to reduce their exposure, rather
than have an HP tech lead them by the hand and put lead on every source that
they could encounter.  We may decide to forego an ALARA purchase, because
increasing MWh by installing new condenser tubes would benefit the company
more.  These decisions may now be "reasonable".  In turn, the regulatory
agencies should follow suit, and consider what is reasonable.

MY opinion, finally, is that yes, we are spending a lot of time, money and
effort being concerned with minimal doses that probably have little
detrimental effect to the worker. (OK I'll say it, hormesis may be a
reasonable theory!) BUT, until the industry, the regulators and all of us
pontificators decide what "reasonable" is, each of us in our own way will
have to do our collective best to keep exposures ALARA with whatever
resources are available!

Please keep all personal responses personal!  Theodore.Neufang@pseg.com 
Everything said here is not meant to offend or defame anyone in particular.

Ted Neufang
ALARA Supervisor
PSEG Nuclear LLC
856-339-2832
Theodore.Neufang@pseg.com 


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