UNRESTRICTED | ILLIMITÉ
Regarding the claim that “Operators of nuclear facilities are able to cope just fine with LNT and ALARA because in that environment it is understood that these are operational strategies.” – I’m not so sure that things are “just fine” here.
Utilities are rated on their performance in various ways – including ALARA, as measured by worker doses.
While it may be considered “unreasonable” by us, there are instances where utilities have reduced the scope and frequency of inspections, and then received high praise for great ALARA performance.
I have seen this claim w.r.t. the Davis Besse near-disaster, where corrosion chewed right through the reactor’s vessel head, leaving only a thin stainless steel liner to retain the enormous pressure.
Hopefully things like this wind up in Lessons Learned presentations – and in changes in ALARA implementation.
From: cdn-nucl-l-admin@mailman1.CIS.McMaster.CA [mailto:cdn-nucl-l-admin@mailman1.CIS.McMaster.CA] On Behalf Of Bill Garland
Sent: February 21, 2011 12:08 PM
Subject: Re: [cdn-nucl-l] Innovative radiobiology at Chalk River
I tend to agree with you that the last sentence of the CRL report smacks of bum covering but since the actual dose levels are not given, there may indeed be some evidence of increased cancer risk. They are talking about doses at clinical treatment levels, not background type levels, ie low compared to tumor radiation levels.
Whether statements that perpetuate a cancer scare about low doses are ethical or not is, by definition, context sensitive. I agree that the misapplication of LNT and its progeny ALARA has done more harm than good. Or at least it appears to have done so in hindsight. A judgement on ethics would likely have to rest on establishing intent and reasonable expectations. No doubt that the regulators are trying to do good and they have been quite open on the intent of be conservative. In this very nonlinear world, it is difficult to say what the world would have looked like if, say, LNT with a cutoff had been used rather than LNT down to zero. One can argue that we don't employ LNT and ALARA so religiously in any other endeavour, medication being one relevant example, and yet the world has not ended. Maybe that is acceptable because the individual member of the public can count pills readily. Not so with radiation. So I personally will hold off on a judgement of ethics until I learn more about what constitutes unethical behaviour in this instance. I suspect that regulatory bodies such as the PEO would not judge LNT and ALARA as unethical. One could easily defend ALARA too since it is common sense really - for 'reasonable' people.
Operators of nuclear facilities are able to cope just fine with LNT and ALARA because in that environment it is understood that these are operational strategies. I bet within the walls of a pill factory the workers are not permitted to pocket even one benign pill. Ditto for the national mint. Seems to me what we need to do is work on making clear the distinction between administrative strategies and dose effects on the body. I would bet that the regulators and the policy makers would be on our side in that task. I keep saying that one cannot deduce car accident death rates from speed limits.