(1) Where is DOE today? - I'll present an example I'm familiar with: the High Flux Beam Reactor, at Brookhaven National Laboratory. Consider General Accounting Office Report GAO/RCED-98-26, "Department of Energy - Information on the Tritium Leak and Contractor Dismissal at Brookhaven National Laboratory." Here are a few excerpts: "Because Brookhaven employees did nto aggressively monitor its reactor's spent-fuel pool for leaks, years passed before tritium contamination was discovered in the aquifer near the spent-fuel pool ... Although the tritium poses little threat to the public, Brookhaven's delay in installing the monitoring wells raised serious concerns in the Long Island community about (1) the laboratory's ability to take seriously its responsibilities for the environment and for human health and safety and (2) DOE's competence as an overseer of the laboratory's activities." Although you may think that, "their safety practices are perfectly fine...", this resulted in the shutdown of the High Flux Beam Reactor. Was the safety program for the HFBR "good enough?" Not if it wanted to keep running. If you don't believe that "perception is reality," I assure you that it's real enough for the employees who were laid off and the researchers whose projects were cancelled.
(2) "If regulations aren't good enough, why aren't they?" I hope that there aren't any regulatory agencies out there who take that seriously. If so, the response would be, "Make my day!" Regulations that are "good enough" follow when the regulated community does not pursue excellence on its own. This is what's happened with the EPA, in RCRA and CERCLA. Here's one example. EPA is concerned about the long term storage of hazardous waste. There have been situations where unscrupulous companies stored waste and then abandoned the facility, forcing the public to pay for cleanup. As a result, there are strict time limits on hazardous waste storage, for example, 90 days for "large quantity generators." If you exceed that, here are a few of the things that can happen: (1) You are subject to a fine of $25K/day. This is for an inadvertent violation. If it can be shown as "willful," you are subject to criminal penalties. (2) The EPA can consider your facility to be an unpermitted storage facility, and, hence, subject the requirement for a "closure" plan, which can cost $ millions. Is storing waste for 91 days a threat to pubic health and safety? Probably not, but many waste generators decided to follow the regulations and nothing more. EPA obliged, and made the regulations "good enough." I hope that the NRC is never forced to make its regulations "good enough."
3. "What is good enough?" I'll admit that this is a tough one. Two points, however: (a) If you can do better, you're not "good enough." (b) If we don't define, "good enough," ourselves, the regulators will do it for us; probably by shutting us down.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.
Bill Lipton
liptonw@dteenergy.com
RuthWeiner@AOL.COM wrote:
In a message dated 9/9/02 8:46:18 AM Mountain Daylight Time, liptonw@dteenergy.com writes:
It's that kind of thinking that got DOE facilities where they are, today.And where is that? In the course of working on various projects, I have visited and worked at a number of DOE facilities (yes, including Hanford) that handle large amounts of radioactive material under a variety of circumstances in addition to reactors, and their safety practices are perfectly fine. Yes accidents happen. Yes, waste disposal 30 and 40 years ago was not what it is today (nor was pesticide use, nor most ordinary health practices, nor dentistry, nor dietary considerations...).
Why there is an apparent compulsion to beat up on DOE and its contractors with this kind of innuendo beats me. Moreover, the DOE sites were not regulated by any outside agency until the pilot program begun under the Clinton Administration. So you can't "blame" not meeting NRC regs for DOE self-regulation.
"We need to do better than the regulations" is one of those mantras that sounds good and is too vague to mean much.
I would really like to have the following questions addressed:
1. If regulations aren't good enough, why aren't they? Is there a specific example that you can give of a regulation not being good enough?
2. What is "good enough" and how is it determined, if not by the public process that determines regulation?Ruth Weiner, Ph. D.
ruthweiner@aol.com