Re: News Blurb on Caldicott and Millstone -Reply

[High Plains Drifter <ddchaney@castles.com>]

David W. Lee wrote:

.........You and Dean Chaney have been and continue to be
active, valued participants on the RADSAFE net.  From both
of your NRC perspectives, I think other RADSAFERS would
appreciate your considered comments on the recent letter
that Carol Marcus posted to RADSAFE addressed to Shirley
Jackson wherein Carol, amongst other things, basically
accused the NRC of regulatory mismanagement of medical
research, specifically as related to the hazards of
exempting 1 microcurie capsules of C-14 ........
 >>>>.
David......I cannot speak for Kent, but I found Dr. Marcus's
letter and ear full, but somewhat confusing.  She would find
this "normal" for me since I am just a Regulator possessing
only experience in operational health physics associated
with reactors, fuel cycle facilities, and decommissioning.
However, I understand where she is coming from based on my
limited experiences working at NRC Headquarters.  A quick
back of the envelope calculation does seem to indicate that
exemption of 1 microCurie quantities of C14 urea capsules is
clearly not very risky.  In fact, it appears that the
spilling (or uniform relocation) of the contents of 700 such
capsules onto a floor of a 12' X 12" room would not exceed
the new decommissioning criteria of 25 mrem/yr TEDE (after
pencil whipping out an ALARA statement using the NRC's own
words as to the insignificance of C14 exposures) .  Three
years is a long time.  I wonder what the cost is for
something that takes 3 years of regulatory review?

As for the NRC's efficiency and personnel, I personally know
that there are many dedicated health physicist in the NRC.
Many are working exceedingly hard to ensure that the
regulation of the use of radioactive materials is
consistently applied and based on a risk perspective.
However, they cannot help it if their manager-of-the-day
(merri-go-round managers) have little or no technical
knowledge of radiological matters and risk perspectives.  I
have observed in my 35+ years of government service that
governmental managers as a whole seem to find it easier to
bow to public hysteria and uninformed political hacks,  than
do whats right and scientificly sound.

I guess I would say more about regulatory agencies, but upon
searching the RADSAFE archives I notice very little
discussion by Dr. Marcus on the credibility of one Dr.
Caldicott or other medical illuminaries trying to cause mass
hysteria over trivial amount of radiation and nuclear
programs in general.  Since Dr. Marcus doesn't say anything
public about Dr. Caldicott, a fellow MD.  Evidently Dr.
Marcus considers Dr. Caldicott one of the "normal people"
she cites in her letter to Chairman Jackson.

By the way, Dr. Marcus's letter is just another one that
will be added to the pile of scathing letters regarding
Nuclear Medicine regulations sent in to the NRC by the good
Doctor.
--
High Plains Drifter
Fairfield, CA
ddchaney@castles.com
These ramblings are my own and do
not constitute any NRC policy or
thinking along those lines.....I think?