Re[2]: linear hypothesis

["ALDEN N TSCHAECHE" <XAT@inel.gov>]

Right on!!!! If the dose is not above 5 rem per year, there would be no
resources expended to make the dose lower. Only if the dose were
projected to be above 5 rem per year would any resources be spent to see
if it could be lowered to slightly below 5 rem (say 4.999999?).

Yes, we are to say: "... 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 forced to spread exposure to lower
levels when appropriate, without additional training, pre-job and
post-job briefings." All those things take resources. If there is no
observable effect at 5 rem per year, why spend resources to reduce the
dose below that value?

Please tell me the measurable health benefit from all the resources the
nuclear power industry spent over the years to reach the numbers you
quoted. Are we observably safer having spent those resources than not
having spent them? And don't tell me the doses are lower. What I want is
a measurement of real human health effects improvement for all those
resources expended.

In the airline industry there is a very measurable result in terms of
deaths for all the resources the country spends in airline safety. The
same is true for many other industries. What is the measure for the
nuclear power industry? Again, don't tell me dose. That is not a measure
of harm at low doses such as 5 rem. It is not a measure because we don't
know, on the basis of objective evidence what harm 5 rem per year will
do. However, if you do have a measure, I sure would like to know what it
is.

*** Reply to note of 10/17/95 14:41
To: RADSAFE --INELMAIL RADSAFE

Subject: Re[2]: linear hypothesis
     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