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Re: Son of ALARA!



Thank you, though I disagree with you on three points:

1)  "The results of research have provided strong validation toward the 
notion of radiation hormesis."  The research is not so strong as to 
demonstrate a hormetic effect in humans to the point we start calling nuclear 
plants health spas.

2)  "Regulators have NO authority to require licensees and registrants to 
achieve exposures that are below the regulatory limits."  They not only have 
the authority; they rightly exercise it.  It's called ALARA.

3)  "[T]he battle waged by Cohen et al is deeply rooted in the fertile soil 
of compromise."  I don't see it.

Glenn A. Carlson, P.E.
glennacarlson@aol.com

In a message dated 4/4/2000 4:56:03 PM Central Daylight Time, 
stanley_fitch@nmenv.state.nm.us writes:

<< Subj:     Son of ALARA!
 Date:  4/4/2000 4:56:03 PM Central Daylight Time
 From:  stanley_fitch@nmenv.state.nm.us (Stanley Fitch)
 Sender:    radsafe@romulus.ehs.uiuc.edu
 Reply-to:  radsafe@romulus.ehs.uiuc.edu
 To:    radsafe@romulus.ehs.uiuc.edu (Multiple recipients of list)
 
 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!
 
 ------------------------------------------------------------------
 This is an unofficial correspondence, stating my own opinions.
 
 Stan Fitch
 stanley_fitch@nmenv.state.nm.us
 
 
 
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