Re: Patient Release - A Related Question

[Jim Muckerheide <jmuckerheide@delphi.com>]

Patient releases and misadministrations have a common element. There is
no hazard at such doses (500 mrem to 10s of rad; 100s for organ doses,
etc.) 

The (somewhat) more knowledgeable and demanding medical establishment,
along with the difficulty in pretending that a patient and the "system"
is as "controllable", at massive costs, as power plant valves and
operations, results in having severe and costly standards being applied
(for no health and benefit) to power and other HPs. 
This is simply because they did not care enough to limit NRC, EPA, DOE,
etc. requirements in rulemakings, where they take all they can get
because that's what bureaucracies do. They "accepted" the wholly false
premise that such severe requirements have some benefit, and then
they/we get held accountable for the regular failures to be perfect - so
nuclear always looks bad compared to alternatives who do not a cadre of
people advertising every failure as a significant event. 

The very few medical misadministrations, only a trivial few of which
have had actual health consequences, including deaths, are in a setting
that performs millions of complex procedures per year, while power
plants and mechanical/electrical systems controls have virtually no
external challenges and independent participation by the millions of
patients and others in the system who are not part of a small closed
shop in a common culture and under highly directive control, with no
consequences of delay except a little cash, where medicine is
responsible for timely decisions with peoples lives.

But of course the industry made/makes money at the deal, including
"capital costs" to go in the ratebase, sucking money from the public for
cleanup and decommissioning, by sticking it to the taxpayer, electric
ratepayer, the medical insurance company, etc. etc. or the deep pockets
of energy and manufacturing and research institutions. Now that
competition is being privatized, perhaps the challenge of having nuclear
technologies undertake more competent engineering and operations to
achieve "cost-effectiveness" may bring more responsibility instead of
maximizing rad protection at virtually any cost by generating public
fear by the regulatory agencies, readily and uncritically accepted in
the interest of the bureaucracies and profitable "cleanup",
"decommissioning", "safety analysis", based staffing and contractors.

Consider that if NRC ran the FAA we'd call airplanes "locomotives", and
they'd never get off the ground either!

Time to rethink the basis for the hole that we have dug for ourselves,
and start meeting and exceeding the more reasonable (yet even still
extreme) standards that apply to nuclear medicine and radiology, not try
to get them to meet ours. After all, if any of this "risk" nonsense were
true, radiologists would be responsible for more deaths than any
terrorist organization with "weapons of mass destruction" :-)

Finally, note that the GAO report request by Glenn in '94 noted a
difference in rad protection regs of something like 40,000!  That's
because regulators use "politics" to squeeze what they can out of any
opportunity to ratchet. They do not consider science at all. See the EPA
1991 Fed Register Notice in the last third of the brief extract of a Bob
Thomas paper at:
http://cnts.wpi.edu/RSH/Data_Docs/1-2/4/1/12417th94.html

Regards, Jim Muckerheide
the Center for Nuclear Technology and Society at WPI
Radiation, Science, and Health
muckerheide@mediaone.net
===================================================
Steven Rima wrote:
> 
>      RADSAFERs,
> 
>      In my last post on this topic, I asked a question that has bugged me
>      for quite a while. Maybe someone out there can attempt to answer it.
> 
>      Most NRC and Agreement State licensees are subject to the 100 mrem/y
>      limit for members of the public from their activities. In addition,
>      there are some pretty strict public information requirements for many
>      licensees, especially nuclear power plants, whereby they have to
>      provide information on the calculated _theoretical_ dose, and the
>      measured dose, that their plant is giving local residents. DOE sites
>      have similar requirements. There are also _very_ strict limits on how
>      much surface contamination is allowed to be released to the public on
>      material released from their sites.
> 
>      Medical licensees, on the other hand, can now release a patient to the
>      public so long as the _calculated_ dose to a member of the public is
>      less than 500 mrem, and there is obviously no way to ever measure or
>      confirm whether this was exceeded. There is also no requirement, nor
>      attempts I've heard of, from hospitals to alert the local public that
>      they may be randomly exposed to up to 500 mrem from their patients. We
>      also know that a person with tens to hundreds of I-131 will
>      contaminate everything they touch, usually to a level above what is
>      releasable from other licensees, with no monitoring or public notice
>      required.
> 
>      QUESTION: Why is there/should there be such a double standard??? I-131
>      is I-131, whether from a hospital or power plant, and a mrem is a
>      mrem, no matter the source, so why can hospitals do things that would
>      get other licensees cited, fined, or even shut down? An argument can
>      be made that residents near a power plant benefit from its operation,
>      but I don't believe that the random member of the public exposed to a
>      radioactive patient receives any benefit whatsoever.
> 
>      I'm NOT addressing patient care issues here. Dr. Marcus asserts that
>      the NRC should stay completely out of that arena, and I totally agree
>      with her on that point. However, this question has absolutely nothing
>      to do with patient care and everything to do with consistency, or the
>      lack thereof, in regulations regarding public dose limits and
>      notification.
> 
>      Anybody care to take a stab at an answer to this?
> 
>      Steven D. Rima, CHP, CSP
>      Manager, Health Physics and Industrial Hygiene
>      MACTEC-ERS, LLC
>      steven.rima@doegjpo.com
> 
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