Response to Mr. Stroud RE: CO Pocket Dos. Req.

["Ed Stroud" <ed.stroud@state.co.us>]

Mr. Bristow,

O course I disagree with your last posting. And, as I stated

previously, if you have any questions concerning the last corrective

action, please contact our office directly.  We will be happy to

schedule another enforcement meeting.  Also, I think it is a waste of

bandwidth for us to debate this issue publicly (since it involves only a

single issue with a single licensee.) In addition, do you think it wise

to draw attention to your client with these postings? I would consider

it very unprofessional to mention their name here, but anyone who is

interested could find out with an "Open Records Act" request.  Would

your client appreciate everyone on this list knowing the details of

their poor compliance history?  Remember, your client agreed to these

additional requirements in lieu of a large fine. So, if you have a

gripe, bring it to us and let's work it out like professionals and stop

this "name calling."



Ed Stroud, Health Physicist

Colorado Department of Public Health and Environment

ed.stroud@state.co.us



>>> Bruce Bristow <radcons@YAHOO.COM> 03/06/02 03:54PM >>>

Mr. Stroud,



Thank you for your response.  However, as you and I

have discussed before, the reason for the requirement

is irrelevant. The procedure being required is still

unreasonable. Whether it's being imposed as a

"punishment" (as  believe it is), or whether it's to

force some ill-conceived notion that it will reduce

exposures, it's still unreasonable and bad science.



None of the responses I've received have supported the

Colorado requirement; assuming you've been keeping up

with the responses you realize that.  At best some of

them feel that it can be applied above certain dose

levels (e.g. 100 mrem), or at higher percentages of

variance (e.g., 50% - 100%).  Those who have said that

such a requirements has been used [in general] as I

described, have almost all been talking in

applications such as power plants.  Again, as we

discussed, this is a considerably different

application than industrial radiography.  And it

certainly is bad science to make this a requirement by

a regulatory agency (for any reason) down to an

absolute dose of 1 mrem.



Again, thank you for your response but as you're no

doubt aware, the overwhelming majority of the

responses do not support your position.



Bruce Bristow

Health Physicist

Radiation Consultants

e-mail: radcons@yahoo.com 



__________________________________________________

Do You Yahoo!?

Try FREE Yahoo! Mail - the world's greatest free email!

http://mail.yahoo.com/ 

************************************************************************

You are currently subscribed to the Radsafe mailing list. To

unsubscribe,

send an e-mail to Majordomo@list.vanderbilt.edu  Put the text

"unsubscribe

radsafe" (no quote marks) in the body of the e-mail, with no subject

line.

You can view the Radsafe archives at http://www.vanderbilt.edu/radsafe/





************************************************************************

You are currently subscribed to the Radsafe mailing list. To unsubscribe,

send an e-mail to Majordomo@list.vanderbilt.edu  Put the text "unsubscribe

radsafe" (no quote marks) in the body of the e-mail, with no subject line.

You can view the Radsafe archives at http://www.vanderbilt.edu/radsafe/