Re: regulations

["Sandy Perle" <sandyfl@ix.netcom.com>]

Lester Slaback wrote:

> What fraction of the regulatory compliance activities you are involved in
> have a direct or immediate influence on operational safety?

Very little, if any. The regulations are more of an "awareness" 
indicator. Some focus too much on the regulatory compliance aspects 
at the expense of working on improving real safety.


> I would argue that....
> 1. The two ARE largely exclusive.  Although obviously not completely so
> the overlap is sufficiently small as to be ignorable.  While the
> underlying purpose of the regulations is public and worker safety the bulk
> of the regulations have a very tenuous relationship to safety.  Many
> regulations exist simply to make the regulatory system work. 

As already said, many focus on meeting the letter of the law and not 
the intent, which is supposed to be the worker and the public's 
safety. The regulators seem to use the regulations as a mechanism to 
advance themselves by issuing "many" violations" .. as if they were a 
traffic police officer. The more violations, the faster they rise in 
the chain of command. Unfortunately, the significance of the 
violations is lost, and even though the NRC categorizes them, i.e., 
Level 1 to 5, the significance is lost when the public sees the 
numbers of violations issued. Granted, regulations are needed, but 
the type of regulations and the depth they go to should be evaluated.

 2. It is
> entirely appropriate that they are largely exclusive since they serve
> different purposes.  "Operational safety" is the function of maintaining
> and administering a safe operation on a day to day basis. "Regulatory
> compliance" is just that, and a large fraction (if not most) of the
> regulations are only remotely related to operational safety. 

Not only do I agree with this staement, it is the regulatory 
compliance that drives up the costs of operations and maintenance. I 
once worked on a project that identified that approximately 45% of 
our O&M (power reactor) was attributable to regulatory compliance. 
What makes this estimate difficult is the stratification of 
activities to purpose, i.e. surveys. We know that surveys are done to 
assure safety from contamination and exposure. The difference is, how 
much of a survey program is needed, and how much of the cost is 
attributable to regulatory compliance rather than good common sense 
for safety purposes?


 3. Confusing
> the two functions is detrimental to the successful accomplishment of both.

I don't agree with this conclusion. With all of the faults thst the 
regulations might pose, I do not agree that safety can not be 
accomplished. We already have evidence to disprove this hypothesis. 
We are still the safest industry, are we not?

Sandy Perle
Director, Technical Operations
ICN Dosimetry Division
Office: (800) 548-5100 Ext. 2306 
Fax: (714) 668-3149

E-Mail: sandyfl@ix.netcom.com    

Personal Homepages:

http://www.netcom.com/~sandyfl/home.html
http://www.geocities.com/CapeCanaveral/1205