Re: Special handling of individuals with lifetime dose gr

["Sandy Perle" <sandyfl@earthlink.net>]

> The "nuclear industry" has proudly blown both feet off and is working 
> on both its knee caps. 

That we have. While we all do recognize that litigation issues have 
to be treated differently than regulatory issues, the industry should 
pick and chose which elements need to be more conservative. The 
decision should be based on an analysis of the data and available 
evidence. This is not what actually happens. The current focus is to 
treat every item within a nuclear plant (and I will only speak to 
nuclear plants, since other areas are handled quite differently) with 
kid gloves. If the regulations are 5 rem/year, we'll restrict our 
employees to 1 rem/year, and perhaps, treat a contractor a little 
differently, allowing a little more dose. Why, we need them and their 
expertise. In other words, when we have to, we eliminate the 
conservatism. It's really a cost issue in the end. When the current 
Part 20 was being revised, I participated on the NUMARC/EEI/NEI Task 
Force that dealt with the NRC (Bob Baker and Walt Cool, Sr.). They 
were realistic and understood the regulatory issues, as well as the 
socio-economic issues. The life-time limit was discussed, and 
rejected, and therefore not included in the rule-making. The 
reasoning was that there was no real issue, the majority of the 
workers were not being exposed to levels even near the limits, nor 
had they for many years, and, the aging work-force was becoming 
younger in essence. There are very few individuals out there with 
significant life-time dose.  So what does the industry do? They 
become more restrictive.

If one listens to Jerre Forbes of ANI, and I have many times, and I 
always walk away learning something new each and every time, you will 
hear that a lawsuit being brought forth has absolutely nothing to do 
with the dose the individual receives. There is absolutely NO 
correlation to dose and lawsuit, period. In fact, the lawsuits 
brought forth basically center around an individual with an annual 
dose on the order of 200 to 300 mrem (let me reiterate - per year). 
So, taking steps to limit the life-time dose is contrary to what the 
lawsuit statistics show us. If we were really concerned, we'd limit 
dose to ZERO!!! The annual dose is < the dose that even requires 
monitoring. Do we just limit dose to the public dose limits? Is that 
realistic? The statistics tell us the lawsuits will still occur.

Want to avoid lawsuits? Be receptive and communicative with your 
employees. Treat them with respect. Umm, now that one gets a raise 
out of me. Respect is the key. When was the last time you felt 
respected by your plant management???? How much dose do you have? How 
many skeletons do you know involving your plant? How many lawyers for 
a plaintiff know how to find you?

Food for thought..........

------------------------------------------------------------------------
Sandy Perle					Tel:(714) 545-0100 / (800) 548-5100   				    	
Director, Technical				Extension 2306 				     	
ICN Worldwide Dosimetry Division		Fax:(714) 668-3149 	                   		    
ICN Biomedicals, Inc.				E-Mail: sandyfl@earthlink.net 				                           
ICN Plaza, 3300 Hyland Avenue  		E-Mail: sperle@icnpharm.com          	          
Costa Mesa, CA 92626                                      

Personal Website:  http://www.geocities.com/capecanaveral/1205
ICN Worldwide Dosimetry Website: http://www.dosimetry.com

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