Son of ALARA!

[Stanley Fitch <stanley_fitch@nmenv.state.nm.us>]

The results of research have provided strong validation toward the
notion of radiation hormesis.  Even so, hormesis should not be used to
drive regulatory limits for exposure.   The results of hormetic research
have provided ammunition to certain parties who wish eliminate ALARA in
favor of AHARJ (as high as reasonably justifiable).

As eluded to in "ALARA What?", the battle waged by Cohen et al is deeply
rooted in the fertile soil of compromise.  If their viewpoint is
victorious, it could signal the second advent of nuclear power in
America.  Are visions of accolades dancing around in the heads of Cohen
et al?  Indeed their battle is not waged against LNT or ALARA, instead
they fight in favor of the nuclear industry’s unfettered success.  To
achieve this success, they must redefine acceptable risk.  They must
somehow cause a shift in the paradigm of public opinion here in
America.  Let’s be realistic, such a shift will never occur in our
democratic society.

The pendulum has now started to swing the other direction.  In the
beginning, erythema of the skin was the acceptable limit.  Then
governmental standards were created to minimize risk.  Recently the U.S.
Environmental Protection Agency began pushing for the ridiculously low
limit of 15 mrem/yr for the public.  Now days Cohen et al inform us that
ALARA is a stupid, indefensible concept.  As erythema was extreme, so
are the positions of both the USEPA and Cohen et al.

It’s like the old horror movies when they finally kill Godzilla.
Eventually Godzilla is reborn in the sequel "Son of Godzilla".  Cohen et
al are chanting "ALARA is dead, ALARA is dead."  But wait!  What’s that
I hear?  It’s…it’s…it’s Son of ALARA!  Run Hormesis…..RUN!!!!  Your
power is not sufficient to vanquish the mighty Son of ALARA!  Hopefully
both Hormesis and USEPA will stumble on each other, and Son of ALARA
will gobble them up!

Why ALARA?  Quite simply this:  One ionizing event can cause a single
unrepaired double strand break, which may result in a fatal malignancy.

A good ALARA concept seeks the beneficial uses of ionizing radiation
while controlling its intrinsic hazards.  It seeks to minimize exposures
to levels below regulatory limits.  A good ALARA concept does not define
the standards, instead it enforces those standards.  Neither does
hormesis define the standards, but recognizes that not all radiation
exposure is detrimental.

Regulators have NO authority to require licensees and registrants to
achieve exposures that are below the regulatory limits.  They DO have
the authority to require licensees and registrants to:  1) achieve
exposures that satisfy regulatory limits, and 2) evaluate their programs
for tenable controls to further reduce exposures.  Once identified,
these controls must then be implemented.  This reflects proper
implementation and enforcement of ALARA.

What is acceptable risk for radiological workers?  Should it be 8
fatalities per 100,000 or perhaps 1 per 1,000?  Who determines
acceptable risk?  Is it the USEPA or Cohen et al?  I hope not.

A great majority of people who take radiological work do so because they
seek a higher standard of living for themselves and their loved ones.
They are similar to many Appalachian coal miners who in the past
contracted black lung because they were unable to seek better
employment.  Certainly life is more important than nuclear money or
accolades.

The exposure pendulum is swinging wildly back and forth.  Let’s stop the
pendulum.  Arise from the ashes, oh Son of ALARA!  Your day is at hand!

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This is an unofficial correspondence, stating my own opinions.

Stan Fitch
stanley_fitch@nmenv.state.nm.us



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