Re: Appropriateness of RADSAFE Posting of Y90 Spill -Reply

[Kenneth Prendergast <KMP@nrc.gov>]

I would like to second Mr. Cowdreys comments.  I am sure we can all benefit from
past mistakes and truthfull discussions about problems faced in real life.

KMP@NRC.Gov

>>> Eric Cowdrey <ericc@mctrf.mb.ca> 03/06/98 08:57am >>>
Opinions on a subject are often as varied as the people holding them.
Sometimes, it may not be possible to gain a consensus of opinion on a
particular matter; in such situations, where it may also be necessary to
have a decision on an appropriate course of action, the best that can be
done is a considered judgement after weighting the various attibutes of the
situation.

Regarding Jim's specific question below about the appropriateness of using
RADSAFE for comment about the case he mentions, I would tend to assign a
fairly high importance to the value of RADSAFE as an open forum for
discussion in its stated subject area of radiation safety and, hence, have
no objection in principle to his request for comment.  Another aspect that
I believe to be important is the desirability of having good dialogue with
regulatory agencies and their staff.  The stated objectives of regulators
usually include something related to education of, or the conveying of
information to, those regulated.  It seems to me that RADSAFE can provide
another opportunity for this important task.

At 07:12 AM 3/6/98 -0600, you wrote:
>
>     
>     Radsafers,
>     
>     I have received some criticism of my RADSAFE
>     posting regarding the Y90 spill.
>     
>     I would like to state my purpose/motivation
>     for the posting and welcome any comments
>     for my actions.
>     
>     First, I must explain that the regulatory environment
>     in Canada is somewhat less 'prescriptive' than that
>     in the US.
>     Our regulations are somewhat general and open to
>     interpretation. This has certain advantages and
>     disadvantages over a strict prescriptive appraoch.
>     
>     For example :
>     Section 24 states
>     "Every person operating a nuclear facility ....
>     shall.....
>     ...take all reasonable precautions in relation to the nuclear facility 
>     or the prescribed substance to protect persons and property from
>     injury or damage ;"
>     
>     Now. so far this clause has not been interpreted by a judge for us
>     so at times, people like myself are asked to interpret this clause and
>     others like it.
>     
>     While I (and I guess my employer) consider myself competent to carry 
>     out such interpretations, I do not consider myself infallible by
>     any means.
>     
>     With regard to the  Y90 spill, I have my own strong opinion
>     on this matter, which I have not stated so as not to influence the
>     requested responses. However, others have stated quite different
>     opinions on this incident and this brings me to RADSAFE.
>     
>     By posting the message on RADSAFE I wanted to tap the immense, 
>     combined knowledge and experience available in this forum to see
>     if perhaps my opinions might be out of line with other radiation
>     safety professionals.
>     
>     If you respond publicly to this, I respectfully ask that you
>     aim your comments at the use of RADSAFE, not to a discussion of
>     the incident itself. Discussions of the incident should be
>     directed to me personally.
>     
>     Jim Presley
>     Senior Health Physicist
>     Atomic Energy Control Board
>     presley.j@atomcon.gc.ca
>
>
>
>

*************************************************************
Eric Cowdrey
Radiation Protection Officer
Department of Medical Physics
Manitoba Cancer Treatment and Research Foundation
100 Olivia Street
Winnipeg, Manitoba  R3E 0V9
CANADA

Telephone:  (204) 787-2166/4145
Fax:        (204) 775-1684
E-mail:     ericc@mctrf.mb.ca

    "I don't even know what side of the street Canada is on."

                                                - Al Capone