tag:blogger.com,1999:blog-4170623839736191950.post8058114402400481023..comments2022-12-03T19:22:46.911-08:00Comments on Safetymatters: Safety culture information, analysis and management: The European Union Shows Stronger Interest in Nuclear Safety CultureBob Cudlinhttp://www.blogger.com/profile/08502712287881656493noreply@blogger.comBlogger1125tag:blogger.com,1999:blog-4170623839736191950.post-4406496476328651462014-07-24T11:57:13.321-07:002014-07-24T11:57:13.321-07:00Of interest in the review of this Directive is the...Of interest in the review of this Directive is the norm of ultimate "protection and safety" afforded by conformance with the standard and its intent. In this regard there appears to be a division of opinion that is somewhat glossed over in the treatment of what is "reasonably practicable."<br /><br />In the preamble to the description of specific directive changes we find:<br /><br />"(19) Where 'reasonably practicable' is used in this Directive it should be applied in accordance<br />with established definitions, in particular the WENRA and IAEA definitions."<br /><br />However, a little research of the IAEA Glossary (PUB 1290 circa 2007) indicates that the term ALARA is defined, but not ALARP. <br /><br />WENRA in its establishment of recommendations that new plants be designed such that significant offsite consequences be "practically eliminated" ["In this context, the possibility of certain conditions occurring is considered to have been practically eliminated if it is physically impossible for the conditions to occur or if the conditions can be considered with a high degree of confidence to be extremely unlikely to arise (from IAEA NSG1.10)."]<br /><br />Interestingly, ALARP is a legal term of art in the UK; although challenged by the European Commission as not satisfying the more absolutist statements of an employer's Duty of Care for health and safety, as seen here [Reference: http://en.wikipedia.org/wiki/ALARP] this challenge was rebuffed by the EU Courts. <br /><br />Unlike the US, the Europeans via WENRA opted to rely upon a qualitative expression of its Reactor Safety Objective/Goals. And the directive establishes a "continuously improved" requirement upon all aspects of Nuclear Safety achievement which seems very far removed from "risk-informed" regulation. <br /><br />Given the context of the Fukushima lesson learned regarding the perils of nuclear safety responsible government parties "over-promising," that is, a level of "optimization" which lacks any historical precedent of achievement, I find it hard to take the added language regarding Nuclear Safety Culture as much more than Marketing and window-dressing.<br /><br />The question I would like to ask is this: Why ALARA for cumulative exposure of workers? There doesn't appear to be any opening to do that.Bill Mullinsnoreply@blogger.com