Re[2]: linear hypothesis

[sandy_perle@email.fpl.com]

     Some courts have already declared that ALARA is proven IF the 
     individual stays within the regulatory limits. Other courts have 
     mandated lower values in litigation decisions. There is no rhyme or 
     reason.
     
     I have a problem with several comments. I see a confusion between what 
     is deemed to be BRC and ALARA. IF 5 rem/yr. is considered BRC, then 
     the regulators for all practical purposes would not be interested in 
     anything below that value. Therefore, ALARA would only pertain to 
     exposures that are ABOVE 5 rem/yr. If that is the case, then we need 
     to go back to the old regulatory limits. I have a real problem with 
     that. Are we to say that it doesn't matter whether or not an 
     individual should be allowed to reach the 5 rem/yr. without any 
     intervention, without any planning, without any goals or targets, 
     without any trending, without using engineering techniques to reduce 
     exposure, without utilizing a varied work force to spread exposure to 
     lower levels when appropriate, without additional training, pre-job 
     and post-job briefings? I don't believe that is what is suggested, for 
     if it is, then the whole concept of ALARA is ignored.
     
     I can only speak for the nuclear power industry, well, not the 
     industry, but from a health physics perspective. Approximately 186,000 
     workers received occupational exposure in the power industry in 1993. 
     Over half received no measurable exposure. Very few exceeded 2 rem/yr. 
     We have dealt with the ALARA issue, even when there was no regulatory 
     requirement, via Reg. Guide 8.8 and 8.10, for many years. Through a 
     lot of work and good planning, the collective dose, as well as 
     individual doses came down, significantly I might add. ALARA helped do 
     this. Are we to ignore this excellent tool? I would hope not. 
     
     As more information and data is collected we need to do more to reduce 
     the exposures our workers are receiving. The one negative I see, and 
     EPA is a major source of my consternation, is the idea that is we 
     don't have any exposures that exceed 2 rem/yr. say, and the average 
     exposure per worker is .31 rem/yr, then let's keep lowering the 
     limits. The only way to maintain a lower average is to put more 
     workers into the exposed category, forcing the average lower. This 
     method can not and will not continue. With restructuring taking place 
     I believe that within the next year or two, we will see the trend turn 
     around, with the average exposure per worker begin to creep up. I 
     expect that we will be seeing more accusations that ALARA isn't 
     working, which is not the case at all ... but will be a faborite 
     target of those who don't believe in following what it preaches.
     
     Sandy Perle
     Supervisor Health Physics
     Florida Power and Light Company
     
     (407) 694-4219  office
     (407) 694-3706  fax
     
     sandy_perle@email.fpl.com


______________________________ Reply Separator _________________________________
Subject: Re: linear hypothesis
Author:  radsafe@romulus.ehs.uiuc.edu at Internet-Mail
Date:    10/17/95 2:39 PM


     
Thanks for your 5 points. Yes, the linear hypothesis is used for other 
potentially harmful agents, particularly chemicals, by the EPA 
especially. However, ALARA is not. Just wait until EPA mandates ALARA 
for chemicals. One can't "prove" safety if the background is too high. 
Most chemicals don't have a natural background so it is easier to 
"prove" safety than for radiation where the background gets in the way.
     
Yes, the debate is about ALARA at BRC doses. I'm suggesting 5 rem per 
year is the BRC dose. Use ALARA ABOVE that value, not below. Then study 
prospectively those whose doses exceed the BRC value to see if there are 
any harmful effects.
     
     T