Re: DOE regulation

[Al Tschaeche <antatnsu@pacbell.net>]

Robert_A_Jones@RL.gov wrote:
> 
> What I believe that Al is saying is that the operation would always be
> substandard if the NRC regulated the DOE.  

Well, not actually.  But maybe unless we get some creative thinking
about the regulatory system.  And I don't know what the proper system
should be yet.

> We should analyze the real problem (e.g., too many government agencies
> regulating the exact same thing) and look to a model that works for
> fixing that problem.  

There isn't one because there is no problem to fix. (see below)

> I bet that simply shuffling one government agency
> under another will increase the problems. 

You hit the nail right on the head.  I have yet to see good evidence
(perhaps scientific even) that demonstrates the AEC/DOE has actually
hurt workers or the public from radiation or radioactive material from
its activities during the past 20 years.  All in all, the AEC/ERDA/DOE
radiological safety system has functioned exceptionally well vis-a-vis
worker and public radiological safety.  What it hasn't done too well is
comply with the myriad additional revisions to and new requirements it
put on itself (its contractors) or had put on it by Congress.  If we had
had a good management system to tell us quantitatively how much each new
or revised requirement bought us in increased radiological safety, we
would see that all the money we have spent in DOE for radiological
safety "improvements" has resulted in no measurable reduction in health
and safety over what we had in 1974 when the AEC was divided into NRC
and ERDA.  And don't tell me that reducing the average dose to workers
from 2 or 3 rem per year to 200 mrem per year has any real, measurable
health benefit!  I don't see why the DOE can't continue to regulate
itself except for the antis who want to make the system as complex and
expensive as possible and who have control of the political process
vis-a-vis radiation right now.

I have worked for contractors under the old AEC manual chapter for
radiological safety, under the Order system, under the DOE Radiological
Control Manual and under 10CFR 835.  I see absolutely no measurable
improvement in radiological safety during those many years, and safety
was great at the start.  It is as Laurie Taylor said in his 1980 Sievert
Lecture (Health Physics, vol 39, pg 851, Dec. 1980 which I highly
recommend to all radsafers at this point): "Today (1980) we know about
all we need to know for adequate protection against ionizing radiation.
... No one has been identifiably injured by radiation while working
within the first numerical standards set by the NCRP and then the ICRP
in 1934."  The same thing can be said today, even in the light (or
darkness) of the NCRP committee 6.1 draft report on the LNTH that is now
available on the net.

If anyone can give me the quantitative management tool that really
measures safety increase for dollars spent in new or revised
radiological safety requirements (such as real lives saved because of
reducing dose from 2000 to 200 mrem per year, or actual minutes of life
lost because of an increase in radiation dose of 10 rem), I would dearly
love to see it.  

Absent that measurement tool and the demonstration using that tool that
safety is measurably improved by all the regulatory changes in the last
20-30 years, why have we (ICRP, NCRP, NRC, DOE, etc. etc.) been revising
regulatory requirements and changing recommendations for radiation
safety all these years?  (Don't answer that question; I know the
answer.)  Even the NRC, when required by its own backfit regulations did
not find that the latest major revision of 10CFR 20 was necessary to
improve radiological safety.  But it did it anyway. Sorry, the emperor
has no cloths.

Al Tschaeche antatnsu@pacbell.net
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