ALARA: Great Philosophy but too Subjective for Regulation
G. E. Roberts
Nuclear proponents and opponents will agree that the most subjective word in the "as low as reasonably achievable" (ALARA) philosophy is the reasonably. What is reasonable to one is not reasonable to another. Reasonable ALARA goals in one application may not be reasonable in another. What is reasonable in theory or on paper often is not reasonable in practical application. If litigation is involved, the differences between viewpoints of what is reasonable require expression on a logarithmic scale. When regulations are developed in a conservative manner, is it reasonable to require licensees to demonstrate how they will maintain measured parameters as far below the regulatory limits as is reasonably possible? Why is it necessary to keep radiation doses ALARA when it is not necessary to maintain exposures to other hazardous materials as far below established limits as is possible? The concept, when required by regulation, augments the public's fears, apprehension, and misunderstandings about radiation and its potential effects. The incorporation of subjective terms into regulations creates problems for both regulators and licensees and should be avoided. ALARA is a great philosophy but a bad regulation.
This abstract was presented at the 34th Annual Midyear Meeting, "Radiation Safety and ALARA Considerations for the 21st Century", ALARA Session, 2/4/2001 - 2/7/2001, held in Anaheim, CA.