dose studies vs regs

[JMUCKERHEIDE@delphi.com]

Paul Vitalis writes:

>      Dave, and all radsafers
<snip>      
>      I really didn't want to rehash the topics already discussed. I was 
>      trying to start a philosophical discussion about the ramifications of 
>      the research which shows a net beneficial effect of exposure to 
>      ionizing radiation but didn't feel I had all the info.  I have some 
>      thoughts on what I have read so far.

This isn't really a "philosophical" discussion. The hard data, including that
presented to the HPS SPI in producing a position on the lack of validity of
the linear model, refutes the basis for the linear model and current rad
protection standards. Action is required. The rules will need to be changed;
implementation by HP to use radiation safely is still required. 

However, that does not mean that HP is not necessary!  Far from it.  Without
HP the new rules can't be implemented. monitoring and analyses that today lead 
to costly requirements for personnel protection are needed to allow work at
much lower cost while accepting some increases in rad exposures. 

I'll attach below a previous comment in response to Sandy Perle at FPL. I
would note for the HP profession generally that a great mission to do real
professioanl/managerial HP credible work to reduce enormous costs (>$trillion) 
in many areas of industry, medicine, environmental cleanup, etc is an
opportunity, not a loss of jobs. The costs are not in HP, they are in the
impact of excessive dose reduction on the workers and the management systems.
HP can be the major player in fixing the problem (or perceived as the
problem). 

>      I work at a power plant.  In my industry there are those who routinely 
>      receive in excess of 3 rem per year.  By today's standards, this is 
>      considered high.  We spend much time trying to keep people's doses to 
>      below 1 rem per year or much less.  If regulations are changed to 
>      reflect data I've read about on this server, most health physicists 
>      will be out of a job.  After all, it won't take much sophistication to 
>      develop and implement a program to ensure that all rad workers receive 
>      their 5 rem per year.  University and research health physics staff, 
>      though already small will be cut as well.  If exposure is desirable, 
>      why bother monitoring releases, controlling isotopes, decomissioning 
>      old sites, etc.  
>      
>      I don't say these things because I fear for my job, I'd be delighted 
>      if everyone understood the true risks of exposure to radiation.  Then 
>      perhaps nuclear power could return to being the affordable, 
>      environmentally friendly industry it was supposed to be.
>      
>      Please comment. I'd like to hear your views on the subject.
>      
>      The above opinions are mine alone (truly, I think) and would not 
>      likely be approved by my employer.
>      
>      Paul Vitalis
>      byrpv@ccmail.ceco.com
------------------------------------------------------------------------
Sandy Perle writes:
 
>      The argument that NO actions be taken if the dose is not projected to 
>      exceed 5 rem/yr. begs the question - How will we know? If we are not 

I think this is where a LOT of confusion comes in. I don't think there will be 
a great reduction in HP work, and there will be MUCH more professionalism in
HP work, with changes that require addressing the scientific knowledge, and a
professional role to address costs.  

OF COURSE, there will need to be surveys. The real, large, costs of HP to be
saved are NOT in HP itself!  They are in the organization response/costs to
the knowledge that HP has! From work planning, controls, shielding, clothing,
etc. 

HP has the potential of becoming a real part of the facility management team
concerned about costs and benefits, and rad exposure assurances.  The current
hard driven objective to just record and reduce dose would be replaced by
making rational and well-documented plans and decisions about rad exposure and 
costs.  HP to the fore! regain a professional role in those organizations!  

BUT, when good area monitoring and surveys tell you that an area does not
require the horrendous costs of rad protection for planning, protective
clothing, time limits, placing shielding, etc, etc, YOU will potentially save
the organization $-millions/year in unnecessary and unjustified costs.  (I
also think this role plays into the issue of professional ethics. How do you
morally justify making a maintenance job cost $100,000s when it could be done
for $10,000 often at the equivalent "cost" of a few x-rays to a 5-person crew, 
or even a few rem each to a work crew, when the actual data on rad health
effects is unambiguous about the lack of adverse effect (even benefit from,
eg, the Nuclear Shipyard Worker Study?!) of such exposure. 

>      expected to take any unnecessary financial actions, then we need not 
>      take surveys, need not practice contamination control, need not 
>      provide access control, need not do anything. The fact that doses for 
>      the most part ARE < 5rem/yr. is because we HAVE taken proactive steps 
>      to reduce these exposures. 

Right.  BUT at what cost?,  and at what justifiable cost??  Again, think of
this as enhancing the role of HP.  You must still know the dose-rate to allow
work and expected dose for a job.  HP doesn't go away (though there may be
some efficiencies in making surveys and using area monitors to "screen", etc). 
 BUT, YOU can save the organization $-millions by creating sound policies and
programs that do not over-react to rad exposure forcing high costs on the
organization in the many ways they are being driven (and then we get to waste
management....   :-) 

>      Sandy Perle

Thanks.

Regards, Jim Muckerheide
jmuckerheide@delphi.com