ML19326D928
| ML19326D928 | |
| Person / Time | |
|---|---|
| Issue date: | 07/03/1980 |
| From: | Ahearne J NRC COMMISSION (OCM) |
| To: | Staggers H HOUSE OF REP., INTERSTATE & FOREIGN COMMERCE |
| Shared Package | |
| ML19326D929 | List: |
| References | |
| NUDOCS 8007250202 | |
| Download: ML19326D928 (2) | |
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UNITED STATES O
NUCLEAR REGULATORY COMMISSION Q
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. C'O July 3,1980 D'Cr CHAIRMAN The Honorable Harley 0. Staggers, Chairman Committee on Interstate and Foreign Affairs United States House of Representatives Washington, DC 20515
Dear Mr. Chairman:
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This letter responds to your request for the Nuclear Regulatory Commission's views regarding H.R. 6745, the "RadiatiorLControl Act of 1979." The proposed bill would consolidate in the Environmental Protection Agency (EPA) the major Federal Government responsibility for evaluation and control of ionizing radi-ation exposure risks to the public.
In general, the Commission does not believe that this bill would improve overall protection of the public or promote an effective Federal research program.
Because of the wide variety of existing and potential future sources of radiation exposure, we doubt that any single agency can reasonably concentrate within itself the expertise, authority, and resources to ensure comprehensive and uniform protection of public health and safety.
We recognize the need addressed by H.R. 6745 for unifying insofar as prac-ticable the Federal Government's approach to the control of ionizing radia-tion, but we believe this goal will be more readily achieved by coordination of existing authorities.
An important step toward such coordination is the President's recent formation of the Radiation Policy Council and the Inter-agency Radiation Research Committee. We recommend that proposals like H.R.
6745 for major legislative changes in the Federal radiation protection program be held in abeyance until these organizations have been given adequate time to demonstrate their effectiveness.
With regard to some of the details of H.R. 6745, we note that Section 6, the transfer of functions provisior,, speaks only in general tems and lacks entirely the specificity needed to transfer unambiguously to EPA the radiation protection functions and authorities presently dispersed among other agencies.
Because of the large number of Federal authorities and programs associated with radiation protection, this lack of clarity would almost certainly cause considerable confusion in implementing the bill.
Moreover, the transfer of Federal ionizing radiation health effects research to EPA, as proposed in Section 3 of H.R. 6745, would run counter to recent executive and legislative actions, which aim at assigning more health effects research to the Department of Health and Human P.esources.
For example, the President has directed that the Interagency Radiation Research Committee, mentioned above, be established by the Secretary of Health and Human Services (formerly Health, Education, and Wel fa re).
Similarly, it has already been provided by Title II of the Bio-nedical Research and Research Training Amendments of 1978, Public Law 95-622, that the Secretary of HEU should " establish a comprehensive program of research 8007250 M
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The Honorable Harley 0. Staggers 2
into the biological effects of low-level ionizing raJiation" and " conduct a comprehensive review of Federal programs of research b. the biological effectr
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of ionizing radiation."
92 Stat. 3435.
We note that Section 5(b)(1) of H.R. 6745 would have EPA " establish the most likely statistical relation between a given exposure dose of each form of ionizing radiation and the consequent hannful effects therefrom."
If this section is interpreted as binding all Federal agencies to use of the par-ticular risk-dose relationship established by EPA, it would represent a highly undesirable intrusion of administrative fiat on scientific judgment.
Further-more, since new data are continually being developed while changes in agency rules usually come slowly, a mandatory use of EPA's "most likely" relation could lead to persistent Government use-of risk estimates several years behind current technical information.
In summary, for the reasons discussed above, the Nuclear Regulatory Commission does not support H.R. 6745.
We appreciate this oppor.tunity to comment on the bill.
Sincerely,
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John F. Ahearne i
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