Re: "dangerous" exposures

[BLHamrick@aol.com]

In a message dated 10/13/2002 9:04:47 AM Pacific Daylight Time, michael.g.stabin@vanderbilt.edu writes:



> My understanding is quite the opposite, from (admittedly) second hand
>
> information that I have heard from many colleagues who work in the nuclear
>
> industry - the federal authorities are often obsessed with minutae and
>
> paperwork related to low exposures, often driving licensees a bit nuts about
>
> things that are not serious hazards (anyone wish to refute or confirm this
>
> point of view?). 


I'll take the middle road.  There has been much more of a focus on "risk-informed" and "performance-based" regulation over the past 10 years.  However, in the end, it is much easier to perform compliance-based inspections and investigations, and so we still see this a lot.  In my opinion, this is due, in part, to the fact that regulatory agencies still cannot attract the "best and the brightest" in the HP field.  It is far easier to look through 100 survey reports, and find that the licensee missed one, than it is to evaluate the results of those surveys and understand the potential for actual dose, its significance, and whether the survey routine is overkill, adequate, or insufficient.


In this case, I would be interested in knowing whether the "event" was considered reportable pursuant to the regulations, or identified during an inspection that led to an investigation.  It makes a difference in the analysis of how a regulator would respond.  


The fact that they're focusing on ALARA means to me there were no regulatory overexposures.   On the other hand, I would not simply dismiss the investigation of the ALARA aspect as nitpicking.  There are legitimate reasons to use ALARA as a compliance tool, where the licensee routinely fails to adequately plan work activities with a potential for significant exposures, and only fortuitously maintains exposures below the regulatory limits.    


Barbara