ML20055H733
| ML20055H733 | |
| Person / Time | |
|---|---|
| Issue date: | 07/20/1990 |
| From: | Carr K NRC COMMISSION (OCM) |
| To: | Baucus M, Bilirakis M, Bliley T, Boucher F, Burdick Q, Chafee J, Dannemeyer W, Dingell J, Durenberger D, Eckart D, Fields J, Randy Hall, Lent N, Luken T, Madigan E, Mitchell G, Moorhead C, Moynihan D, Nielson H, Oxley M, Rowland J, Scheuer J, Sharp P, Sikorski G, Simpson A, Slattery J, Swift A, Synar M, Tauzin W, Waxman H, Whittaker B, Wyden R HOUSE OF REP., SENATE |
| References | |
| NUDOCS 9007270204 | |
| Download: ML20055H733 (67) | |
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'o UNIT,D STATES
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W ASHING TON. D. C. 20666 ss;;;;.J July 20. 1990 CHAIPMAN i
I The Honorable Alan K. Simpson United States Senate Washington, D.C.
20510 j
Dear Senator Simpson:
The Nuclear Regulatory Commission (NRC) appreciates the I
opportunity to present its views on 5.1630 and H.R.3030, now before the Conference Committee, to amend the Clean Air Act.
The provision of most immediate relevance to the NRC's respoli-sibilities is the section of the Senate bill ctaling with radienuclide emissions from NRC-licensed facilities (Section 301 of 5.1630, adding a new Section 112(d)(11)).
This section, which has no equivalent in the Houst bill, states in pertinent part:
No standard for radiontclide crissions from iacilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be promulgated under this section if the t
Administrator determines, after consultation with the Nuclear Rtgulatory Commission, that the regulatory program established by the Nuclear Regulatory Commission pursuant to the Atonic Energy Act provides an ample margin of safety to protect the public health.
The NRC believes that this provision is both a valuable and necessary compenent of the legislation.
It builds upon, and provides clarification of, the existin which directs that EPA and NRC shall, g Section 122 of the Act, to the maximum extent practicable...
minimize duplication of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)....' 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this. time, as there has been legal controversy in the past several years on the precise question of whether EPA is required to set radionuclide standards.
notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin of safety.
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. Clearly, it is wasteful of governmental resources and contrary to principles.of good government to compel an agency to regulate emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote their resources to addressing health and safety problems.that remain to be resolved, rather than wasting effort on problems that have already been satisf actorily resolved by another agency.
By spelling out that EPA need not regulate where it finds that NRC regulation is adequate, this provision of the legislation will address this unnecessary duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Acting Surgeon General Mason also called upon Congress to eliminate altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to the-Congress commenting on this issue, ere attached.
We thank you for the opportunity to comment on this issue.
Sincerely, k
M.
Kenneth M. Carr Attachments:
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July 20.1990 CHAIRMAN
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The Honorable Quentin N. Burdick United States Senate Washington, D.C.
20510 7
Dear Senator Burdick:
The Nuclear Regulatory Commission (NRC) appreciates the opportunity to present its views on S.1630 and H.R.3030, now before the Conference Committee, to amend the Clean Air Act.
The provision of most immediate relevance to the NRC's respon-sibilities is the section of the Senate bill dealing (with radionuclide emissions f rom NRC-licensed f acilities Section
- 30) of S.1630, aeding a new Section 112(d)(11)).
This section.
which has no equivalent in the House bill, states in: pertinent part:
No standard for radionuclide emissicos from f acilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be promulgated under this section if the Administrator determines, after consultation with the Nuclear Regulatory Commission, that the regulatory program established by the Nuclear l
Regulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety to protect l
the public health.
The hRC believes that this provision is both a valuable and necessary component of the legislation.
It builds upon, and provides clarification of, the existing Section 122 of the Act, which directs that EPA and NRC shall, "to the maximum extent practicable..., minimize duplication of effort and conserve administrative resources in the establishment, impismentation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time, as there has been legal controversy in the past several years on the precise question of whether EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully i
adequate to protect public health with an ample margin of safety.
1 l
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Clearly, it is wasteful of governmental resources and contrary L
to principles of good government to compel an agency to regulate emissions already regulated adequately by a sister l
agency.
Agencies should be allowed to devote their resources to addressing health and safety problems that remain to be resolved, rather than wasting effort on problems that have already been satisfactorily resolved by another agency.
By spelling out that' EPA need not regulate where it finds that-NRC regulation is adequate, this provision of the legislation will address this unnecessary duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg end HHS. Assistant Secretary for Health and Acting Surgeon General Mason also called upon Congress to eliminate l
altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative."
This t
letter, together with earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely, I
wuk.
Kenneth M. Carr Attachments:
At stated
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July 20,1990 1
CHAIRMAN i
The Honorable George J. Mitchell United States Senate Washington, D.C.
20510
Dear Senator Mitchell:
The Nuclear Regulatory Commission (NRC) appreciates the i
opportunity to present its views on S.1630 and H.R.3030, now before the Conference Committee, to amend the Clean Air Act.
The provision of most immediate relevance to the NRC's respon-sibilities is the section of the Senate bill dealing (with radionuclide emissions from NRC-licensed facilities Section-301 of S.1630, adding a new Section 112(d)(11),'.
This section.
which has no equivalent in the House bill, states in pertinent part:
No standarc for radionuclide emissions from facilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be promulgated under this section if the Administrator determines, after consultation with i
the Nuclear Regulatory Commission, that'the regulatory program established by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety to protect the public health.
The NRC believes that this provision is both a va'luable and necessary component of the. legislation.
It builds.upon, and provides clarification of, the existing SectionL122 of the Act, which directs that EPA and NRC shall, "to the maximum extent practicable..., minimize duplication of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities.(substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time, as there has been legal controversy in the past several years on the precise question of whether EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin of safety.
1
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Clearly, it is wasteful of governmental resources and contrary t
to principles of good government to compel an agency to regulate emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote their resources to addressing health and safety problems that remain to be
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resolved, rather than wasting effort on problems that have already been satisf actorily resolved by another agency.
By spelling out that EPA need not regulate where it-finds that i
NRC regulation is adequate, this provision of the legislation 1
will address this unnecessary. duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator
. - 2=
j Rosenberg and HHS Assistant Secretary for Health and Acting l
Surgeon General Mason also called upon Congress to eliminate
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altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative."
This letter, together with earlier t:RC. letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely, uW.
Kenneth M. Carr Attachments:
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July 20,1990 CHAIRMAN
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The Honorable John H. Chafee United States Senate Washington, D.C.
20510
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Dear Senator Chefee:
The Nuclear Regulatory Commission (NRC) appreciates the opportunity to present its views on S.1630 and H.R.3030,- now before the Conference Committee, to amend the Clean Air Act.
The provision of most immediate relevance to the NRC's respon-sibilities is the section of the Senate bill dealing with radionuclide emissions from NRC-licensed facilities (Section 301 of S.163C adding a now Section 112(d)(11))..
This section, which hes no e,quivalent in the House bill, states in pcrtinent part:
No standard for radionuclide emissions from-i facilities licensed by the Nuclear Regulatory l
Commission (or an Agreement State) is required to be promulgated under this section if the Administrator determines, after consultation with the Nuclear Regulatory Commission, that the regulatory program established by the Nuclear EcCulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety to protect the public health.
The NRC believes that this provision is both a valuable and necessary component of the legislation.
It builds upon, and l
provides clarification cf. the existing Section 122 of the Act, which directs that EPA and NRC shall, "to the maximum extent practicable..., minimize duplication of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of l
performance and other requirements and authorities'(substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time as there has been legal r
controversy in the past several years o,n the precise question of whether EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin of safety.
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l Clearly, it is wasteful of governmental resources and contrary to principles of good government to compel an agency to regulate emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote their resources to addressing health and safety problems that remain to be resolved, rather than wasting effort on problems that have already been satisf actorily resolved by another agency.
By spelling out that EPA need not regulate where it finds that NRC regulation is adequate, this provision of the legislation will address this unnecessary duplication of responsibility.. A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Acting 9
Surgeon General Mason also called upon Congress to eliminate altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely, 1
-h, Kenneth M. Carr Attachments:
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The Honorable Dave Durenberger United States Senate Washington, D.C.
20510
Dear Senator Durenberger:
The Nuclear Regulatory Commission (NRC) appreciates'the opportunity to present its views on S.1630 and H.R.3030, now before the Conference Committee, to amend the Clear. Air Act.
The provision of most immediate relevance to the NRC's respon-sibilities is the section of the. Senate bill ctaling(with radionuclide ensissions fren: NRC-licensed facilities Section 301 of S.1630, adding a new Section 112(d)(11)).
This section, which has no equivalent in the House bill, states in pertinent part:
No standard for radionuclide erissions from facilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is requirel to be promulgated under this section if the Administrator determines, after consultation with the Nuclear Rcgulatory Commission, that the regulatory program established by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety to protect the public health.
The NRC believes that this provision is both a valuable and necessary component of the legislation.
It builds upon, and provides clarification of, the existing Section 122 of the Act, which directs that EPA and NRC shall, "to the maximum extent practicable..., minimize duplication of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time, as there has been legal controversy in the past several years on the precise question of whether EPA is required to set-radionuclide standards, notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin of safety.
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Clearly, it is wasteful of governmental resources and contrary to principles of good g)vernment to compel an agency to regulate emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote their resources to addressing health.and safety problems that remain to be resolved, rather than wasting effort on problems that have already been satisfactorily resolved by another agency.
By spelling out that EPA need not regulate where it finds that NRC regulation is adequate, this provision of the legislation will address this unnecessary duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Acting Surgeon General Mason also called upon Congress to eliminate altogether EPA's authority to regulate radionuclide emissions since such regulatier was " unnecessary and duplicative."
This letter, together with earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely, i
.k i
Kenneth M. Carr Attachments:
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CHAIRMAN The Honorable Max S. Baucus United States Senate Washington, D.C.
20510
Dear Senator Baucus:
The Nuclear Regulatory Commission (NRC) appreciates the opportunity to present its views on S.1630 and H.R.3030, now before the Conference Committee, to amend the Clean Air Act.
The provision of most immediate relevance to the NRC's respon-sibilities is the section of the Senate bill dtaling with radienuclide emissions free NRC-licensed facilities (Section 301 of S.1630, adding a new Section 112(d)(11)).
This section, which has no equivalent in the House. bill, states in pertinent part:
No stardard for radionuclide emissions from facilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be promulgated under this section if the Administrator determines, after consultation with the Muclear Regulatory Commission, that the regulatory program established by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety to protect the public health.
The NRC believes that this provision is both a valuable and necessary component of the legislation.
It builds upon,-and provides clarification of, the existing Section 122 of the Act, which directs that EPA and NRC shall, "to the maximum extent practicable..., minimize duplication of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time as there has been legal controversy in the past several years o,n the precise question of whether EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin of safety.
1
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Clearly, it is wasteful of governmental resources and contrary i
to principles of good government to compel an agency to l
regulate emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote their resources to addressing health and safety problems that remain to be resolved, rather than wasting effort on problems that have l
already been satisfactorily resolved by another agency.
By spelling out that EPA need not regulate where it finds that NRC regulation is adequate, this provision of the' legislation i
will address this unnecessary duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Acting Surgeon-General Mason also called upon Congress to eliminate altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to'the Congress l
commenting on this issue, are attached.
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We thank you for the opportunity to comment on this issue.
Sincerely, i
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Kenneth M. Carr l
Attachments:
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July 20, 1990 i
CHAIRMAN l
The Honorable Daniel P. Moynihan i
United States Senate Washington, D.C.
20510
Dear Senator Moynihan:
The Nuclear Regulatory Commission (NRC) appreciates the opportunity to present its views on S.1630 and H.R.3030, now before the Conference Committee, to amend the Clean Air Act.
The provision of most immediate relevance to the NRC's.respcn-sibilities is the section of t:ie Sencte bill dealing with radionuclide enissions from NRC-licensed facilities (Section 301 of S.1630, adding a new Section 112(d)(11)).
This section, which has ne equivalent in the House bill, states in pertinent part:
No standard for radionuclide emissions from ftcilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be pronulgated under this section if the Adniristrator determines, after consultation with the Nuclear Regulatory Commission, that the regulatory program established by the Nuclear Regulatory Commission pu*setnt to the Atonic Energy Act provides an amnic margin of safety to protect the public health.
The NRC believes that this provision is both a valuable and necessary component of the legislation.
It builds upon, anc provides clarification of, the existing Section 122 of the Act, which directs that EPA and NRC shall, "to the maximum extent practicable..., minimize duplication of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time as there-has been legal controversy in the past several years o,n the precise question of whether EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC progrcm fully i
adequate to protect public health with an ample margin of safety.
1 1
l i
2 Clearly, it.is wasteful of governmental resources and contrary to principles of good government to compel an agency to
. regulate emissions already regulated adequately by a sister I
agency.
Agencies should be allowed to devote their resources i
to addressing health and safety problems that remain to be resolved, rather than wasting effort on problems that have already been satisf actorily resolved by another agency.
By spelling out that EPA need not regulate where it. finds that NRC regulation is adequate, this provision of the legislation will address this unnecessary duplication of responsibility.
A l
November 15. 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Acting Surgeon. General Mason also called upon Congress to eliminate i
altogether EPA's authority to regulate radionuclide emissions i
since such regulation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely.
mW.
Kenneth M. Carr Attachments:
As stated
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UNITED STATES
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July 20,1990 I
CHAIRMAN t
The Honorable John D. Dingell United States House of Representatives Washington, D.C.
20515 Dear Congressman Dir. gell The Nuclear Regulatory Commission (NRC) appreciates the opportunity to present its views on S.1630 and H.R.3030, now before the Conference Committee, to amend the Clean Air Act.
The provision of.most irmediate relevance to the NRC's respon-sibilities is the section of the Senate bill dealing with radienuclide emissions from NRC-licensed facilities (Section 301 of S.1630,-adding a new Section 112(d)(11)).
This section, which has no equivalent in the House bill, states in pertinent part:
No stardard for radionuclide emissions from facilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be promulgated under this section if the Aoministrator determines, after consultation with the Nuclear' Regulatory Comnission, that the regulatory program established by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety to protect the public health.
The NRC believes that this provision is both a valuable and necessary component of the legislation.
It builds upon, and provides clarification of, the existing Section 122 cf the Act, i
which directs that EPA and NRC shall, "to the maximum extent practicable..., minimize duplication of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time, as there has been legal controversy in the past several years on the precise question of whether EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the NRC regulator." program and that EPA finds the NRC progrem fully adequate no protect public health with an ample margin of safety.
a i l l
Clearly, it is wasteful of governmental resources and contrary-to principles of good government to compel an agency to regulate.cmissions already reculated adequately by a sister agency.
Agencies should be allowed to devote their resources to oddressing health and safety problems that remain to be resolved, rather than wasting effort on problems that have already been satisf actorily resolved by another agency.
By spelling cut that EPA need not regulate where it finds that NRC regulation is adequate, this provision of the legislation will address this unnecessary duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Actir.g Surgeon General Mason also ce11ed upon Congress to eliminate altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and dupligative."
This letter, together with earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely.
.b Kenneth M. Carr
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Attachments:
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July 20,1990 CHAIRMAN The Honorable James Hi Scheuer United States House of Representatives Washington, D.C.
20515
Dear Congressman Scheter:
The Nuclear Regulatory Commission (NRC) appreciates the opportunity to present its views on S.1630 and H.R.3030, now before the Conference Committee, to amend the Clean Air Act.
The provision of most immediate' relevance to the NRC's respon-sibilities is the section of the Senate bill dealing. tith radionuclide emissions from NRC-licensed facilities (Section 301 of S.1630, adding a new Section 112(d)(11)).
This section.
l which has no equivalent in the House bill, states'in pertinent part:
No standard for radionuclide emissions from facilitier licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be prcmulgated under this section if the Administrator determines, after consultation with the Nuclear Regulatory Commissien, that the regulatory program established by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety to protect the public health.
1he NRC believes that this provision is both a valuable and necessary component of the legislation.
It builds upon, and provides clarification of, the existing Section 122 of the Act, which directs that EPA and NRC shall, "to the maximum extent i
practicable..., minimize duplication of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this tie.e controversy in the past several years o as there has been legal n the precise question of whether EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin of safety.
J 2.
Clearly, it is wasteful of governmental resources and contrary l
to principles of good government to compel an agency to regulate emissions already regulated adequately.by a sister agency.
Agencies should be allowed to devote their resources to addressing health and safety problems that remain to be resolved. rather than wasting effort on problems that have already been satisfactorily resolved by another agency.
By spelling out that EPA need not regulate where it finds that NRC regulation is adequate this provision of the legislation will address this unnecessa,ry duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Acting.
Surgeon General Mason also ce11ed upon Congress to eliminate altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue..
Sincerely,
- wxW, Kenneth M. Carr Attachments:
As stated
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July 20,1990 CHAIRMAN The Honorable Henry A. Waxman United States House of Representatives Washington, D.C.
20515
Dear Congressman Waxman:
The Nuclear Regulatory Commission (NRC) appreciates the opportunity to present its views on S.1630 and H.R.3030, now before the Conference Committee, to amend the Clear Air Act.
The provision of most irmediate relev6nce-to the NRC's respon-sibilities is the section of the Senate bill ctaling with radienuclide emissions from NRC-licensed facilities (Section 301 of S.1630, adding a new Section 112(d)(11)).
This section, which has no equivalent in the House bill, states in pertinent part:
No stardard for radionuclide emissions from facilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be promulgated under this section if the Acniinistrator determines, af ter consultation with thc Huclear Regulatory Commission, that the regulatory program established by the Nuclear Regulatory Commisrion pursuant to the. Atomic Energy Act provides an ample margin of safety to protect the public health.
The NRC believes that this provision is both a valuable and necessary component of the legislation.
It builds upon, and provides clarification of, the existing Section 122 of the Act, which directs that EPA and NRC shall, "to the maximum extent practicable..., minimize duplication of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time as there has been legal controversy in the past several years o,n the precise question of whether EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the NRC regelatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin of safety.
i
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i i
-2 Clearly, it is wasteful of governmental resources and contrary to principles of good government to compel an agency to regulate emissions already regulated adequately by.a sister agency.
Agencies should be allowed to devote their resources to addressing health and safety problems that remain to be resolved, rather than wasting eff ort on problems that have already been satisfactorily resolved by-another agency.
By spelling out that EPA need not regulate where it finds that NRC regulation is adequate, this provision of the legislation i
will address this unnecessary. duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg ano HHS Assistant Secretary for Health and Acting Surgeon General Mason also called upon Congress to eliminate-altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to the Congress commenting cn this issue, are attached.
We thank you f or the opportunity to comment on this issue.
Sincerely, wah Kenneth M. Carr Attachments:
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The Honorable Philip R' Sharp United States House of Representatives Washington, D.C.
20515 l
Dear. Congressman Sharp:
The Nuclear Regulatory Commission.(NRC) appreciates the opportunity to present its views on S.1630 and H.R.3030, now before the Con.ference Committee, to amend the. Clean Air.Act..
The provision of most immediate relevance to the NRC's respon-sibilities is the section of the Senate-bill dealing (with radionuclide emissions from NPC-licensed facilities Section 301 ef S.1630, adding a new Section 112(d)(11))..
This section, which has no ecuivalent in the House bill, states in pertinent part:
No' standard for radionuclide emissions'from facilities licer. sed by the Nuclear Regulatory-Commission (or an Agreement State) is required to be promulgated under this section if the
. Administrator determi.m), after consultation with the Nuclear Regulator. Sommission, that the regulatory program established by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety,to -protect the public health.
The NPC believes that this provision is both-a-valuable and necessary component of the legislation.
It builds upon, and provides clarification of, the existing Section.122 of the Act, which directs that EPA and NRC shall, "to-the maximum extent practicable..., minimize duplication of effort and conserve
~
administrative resources in the establishment,-implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time, as there has been legal controversy in the past several years on the precise question of whether EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the.NRC regulatory program and-that EPA finds the NRC program-fully adequate to protect public health with an ample margin of safety.
E 2
1 Clearly, it is wasteful of governmental resources and contrary to principles of_ good government to compel an agency to regulate emissions already regulated adequately by a sister agency..
Agencies =should be allowed to' devote their resources i
to addressing health and safety problems that remain to be l
resolved, rather than wasting effort on problems that'have l
already been satisf actorily resolved by another agency.
By.
spelling out that_ EPA need not regulate where it finds that i
NRC regulation is adequate, this provision of the legislation will address this unnecessary duplication of responsibility.
A' L
November 15, 1989 joint letter from EPA Assistant ~ Administrator Rosenberg and HHS Assistant Secretary ~for Health and Acting Surgeon General Mason also called upon Congress to eliminate altogether EPA's authority to regulate radionuclide-emissions since such regulation was " unnecessary and duplicative."
This letter, togetherLwith earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you f or the opportunity to comment on this ' issue.
Sincerely, mak.
e Kenneth M. Carr
. Attachments:
As stated c
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1 pa ttog i-Io UNITED 8TATES g
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- NUCLEAR REGULATORY COMMISSION y-
- wAsHmorow, o. c, rosos -
July 20,1990 CHAIRMAN.
The Honorable Thomas.A. Luken I
United States' House of Representatives Washington, D.C.
20S15
Dear Congressman-Luken:
The Nuclear. Regulatory Commission (NRC) appreciates: the-opportunity to present its-views on S.1630 and H.R.3030, now before the conference committee, to amend.the Clean Air Act.
The provision.of most immediate relevance to the NRC's=respon-sibilities:is the ~ sectionLof the Senate bill dealing with radionuclide emissions from NRC-licensed facilities (Section 301 of S.1630, adding a new.Section 112(d)(11)).
This; sect' ion, which has no eouivalent in the. House bill, states in pertinent part:
No standard for radionuclide emissions from f acilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required.
to be promulgated under this section if the Administrator determines, after consultation with the Nucicar Regulatory Commission, that.the o
regulatory program established by the:Huclear Regulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety;to protect the public health.
~
i The NRC believes that this provision is both a valueble and necessary component of the legislation.
ItLbu-ilds upon, and provides clarification of, the existing Section 122 of the Act, which directs that EPA and NRC shall, "to the maximum extent-practicable..., minimize duplication of effort and. conserve administrative resources in the establishment, implementation, and enforcement of emission limitations,. standards of performance and other requirements and authorities'(substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is-particularly desirable at this time, as there has been legal controversy in the past several years oon the precise question of.whether EPA'is required to set radionuclide standards, notwithstanding that such standards are duplicative of.the NRC regulatory program and that EPA' finds the NRC program fully adequate to protect public health with an ample margin of safety.
i
o.
f L
l 2
Clearly, it is wasteful of governmental resources and contrary to principles of good government to compel an agency to regulate emissions already regulated adequately by a sister r
agency.
Agencies should be allowed to-devote their resources-to addressing health and safety problems that remain to be.
resolved, rather than wasting effort on problems'that have already been satisf actorily resolved by another agency. - By spelling out that EPA need not regulate where it finds that NRC regu.lation is adequate, this provision of'the legislation will address this unnecessary duplication _of responsibility.
A November 15, 1989 joint letterLfrom EPA Assistant Administrator' Rosenberg and HHS Assistant Secretary for Health and Acting l
Surgeon General Mason also called upon Congress to eliminate altogether EPA's 6uthority to regulate radionuclide emissions since such reculation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to'the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely, waN%.
Kenneth M. Carr l
Attachments:
As stated i
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UNITED STATES NUCLEAR REGULATORY COMMISSION -
- i e
WASHINGTON, D. C. 20665 -
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July 20,1990 -
CHAIRMAN The Honorable Al Swift United States House of: Representatives Washington, D.C.
20515-
Dear Congressman-Swift:
The Nuclear Regulatory Commission -(NRC)1 appreciates the-opportunity to present its views on S.1630 and H.R.3030, now=
before the Conference Committee, to amend the Cleer Air.Act.
The provision of most immediate relevance to the NRC's'respon-sibilities is the section of the Senate bill dealing with radienuclide emissions from-NRC-licensed facilities (Section 301 of S.1630, adding a new Section 112(d)(11)).- This.section, which has no equivalent in the House bill, states in pertinent' part:
No stardard for radionuclide emissionsifrom f acilities licensed by the Nuclear Regulatory Commission-(or an Agreement State) is required-to be promulgated under this section if the Administrator determines, after consultation with the Nuclear Reculatory Commission, that the regulatory program established by -the Nuclear Regulatory Commission pursuant to the Atomic Energy Act provides an ample-marginaof safety to protect the public health.
The NRC believes that this-provision is both.o valuable an'd necessary component of the legislation.
It bu:lds upon,;and provides clarification of,-the existing Section 122 of the Act, I
which directs that EPA and NRC shall, "to the maximum-extent practicable...,, minimize duplication of ef# ort and conserve administrative resources in the establishment.Limplementation, and enforcement of emission limitations, standards of i
performance and other requirements and authorities (substantive and procedural)...." 42-U.S.C.-7422(c)(2).-
Such clarification is particularly desirable at this time, as there has been legal controversy in the past several years on the precisefquestion-of whether EPA is requ. ired to' set radionuclide standards, notwithstanding that such standards are duplicative of the NRC regulatory program and. that EPA finds -the NRC program fully 1 adequate to protect public health with an ample margin of safety.
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1 agency.
Agencies should be allowed to devote their. resources to addressing health and safety problems that remain to, be-resolved, rather than wasting 1 effort on problems that have-already been satisfactorily resolved by another agency.
By spelling out that EPA need not regulate where it. finds that NRC regulation-is adequate, this provision ~of the legislation--
will address this unnecessary duplication of responsibility.
A 1
November 15, 1989 joint letter from EPA Assistant Administrator-Rosenberg and HHS Assistant Secretary for Health and Acting-Surgeon General Mason also called upon Congress to eliminate altogether EPA's authority to regulate radionuclide emissions-since such regulation.was " unnecessary and_duplicative."
This letter, together with earlier NRC letters.to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely, a_% h.b w Kenneth M. Carr Attachments:
As stated
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NUCLEAR REGULATORY COMM SSION h
WASHINGTON, D, C. Mo66
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July 20,1990_
CHAIRMAN
?
The Honorable Mike.Synart United States House of Representatives i
Washington, D.C.
20515
Dear Congressman Synar:
The Nuclear _ Regulatory Commission (NRC) appreciates the opportunity to present its views-on_S.1630 and'H.R.3030, now before the Conference Committee, to amend the Clean Air Act.
j The provision of most.irmediate_ relevance to the NRC's respon-sibilities is the section of the Senate bill dealing with redionuclide emissions fron. NRC-licensed facilities (Section 301 of S.1630, adding a new Section 112(d)(11.)).
This section, which has no equivalent in the House bill, states in pertinent i
part:
No standard for radionuclide criss' ions'from-f acilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required l
to be_premulgated under this section if the l
Administrator determines, after consultation with I
the Nuclear Regulatory Commission, that the regulatory program established by-the Nuclear Regulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety to protect the public health.
The NRC believes that this provision is both a' valuable and necessary'corponent of the legislation.
It builds upon, and provides clarification of, the existing Section 122 of'the Act, l
which directs that EPA and NRC shall, "to the maximum extent practicable.... minimize duplication of effort and conserve administrative' resources in the establishment, implementation, and enforcement of emission limitations, standards'of E
performance and other requirements and-authorities (substantive and procedural)...-." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time as there has been-legal I
controversy in the past.several years o,n'the precise question 1
of whether EPA is required ~.to set radionuclide standards, L
notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully adequate to protect public health.with an ample margin of safety.
i
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c :-
c.
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i Clearly, it is wasteful of governmental resources and contrary to principles of good-government:to compel-an agency.to regulate ~ emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote their resources i
to addressing health and safety problems that! remain to be t
resolved, rather than wasting effort on problems that have already been satisf actorily resolved by another agency.
By 4
spelling out that EPA need not regulate where'it finds that.
NRC regulation is adequate, this provision-of the legislation I
will address-this unnecessary duplication ce responsibility.
A November 15,.1989 joint letter from EPA Assistant Administrator.
Rosenberg and HHS' Assistant Secretary for Health and Acting Surgeon General Mason also called upon Congress to eliminate altogether EPA's authority to regulate radionuclide. emissions since such regulation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to-the Congress commenting on this issue, are attached.
We thank you for 'the opportunity' to comment on this issue.
~
Sincerely, n_vW.
Kenneth M. Carr Attachments:
As stated t
0
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- - - - - - - - -=-
.f jo, UNITED STATES 8
p NUCLEAR REGULATORY COMMISSION e
t, WASHINGTON, D. C. 20666
%..... /
July 20, 1990
-l CHAIP. MAN J
1 The Honorable W. J. (Billy) Tauzin United States House of Representatives U
Washington, D.C.
20515
Dear Congressman Tauzin:
The Nuclear Regulatory Commission (NRC) appreciates the oppertunity to present its views on S.1630 and 'H.R.3030, now i
before the Conference Committee, to amend the Clean Air Act.
The provision of most immediate relevance to the NRC's respon-sibilities is the section cf the Senato billLdealing with radionuclide emissions from NRC-licensed facilities (Section 301 of S.1630, adding a new Section 112(d)(11)).
This-section, which has no ecuivalent in the House bill, states in pertinent-part:
No standard for radionuelide emissions from i
facilitict licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be promulgated under this section if the Administrator: determines, after consultation with the Nuclear Regulatcry Commissien,.that the i
regulatory program established by the Nuclear Regulatory Comnission pursuant to the Atomic Energy Act provices an ampic margin of safety -to-protect the public health, The NRC believes that this provision is both a valuable and o
i necessary component of the legislation.
It builds upon, and provides clarification of, the existing.Section 122 of the Act, t
which' directs that EPA and NRC shall, "to the maximum extent practicable..., minimize duplication of-effort'and conserve administrative resources in the establ.ishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2). -Such clarification is particularly desirable at1this time, as there has been legal controversy-in the past several' years on the precise question
-of whether EPA is required toiset radionuclide standards, notwithstanding that such standards are duplicative of the NRC
(
1 regulatory program and that EPA finds -the NRC program fully adequate to protect public health with an ample margin of safety.
~.
,~.
f 2
Clearly, it.is wasteful of governmental resources and contrary to principles of good government _to compel an agency to
~
regulate emissions already regulated adequately by a sister.
agency.
Agencies should be allowed to devote their resources!
t to addressing health and' safety problems that remain to-be resolved, rather then-wasting effort on-problems that have _
already been satisf actorily resolved 'by. another agency.
By spelling out that EPA need not regulate where it finds that NRC regulation is adequate, this provision of-the legislation-will address this unnecessary duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Acting.
Surgeon General Mason also called upon Congress to eliminate.
altogether EPA's authority to. regulate radionuclide emissions since-such regulation was " unnecessary and duplicative."
This.
letter, together with earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on' this issue..
Sincerely, l
- _-x%s.
Kenneth M. Carr l
Attachments:
L 3
As stated l
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!g-jo, UNITED 8TATES j
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NUCLEAR REGULATORY COMMISSION
'l c
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July < 20, 1990 l
' CHAIRMAN.
l
}
The Honorable Ron Wyden~
l United States. House of Representatives-Washingtcn, D.C.
20515
Dear Congressman Wyden:
The Nuclear Regulatory Commission (NRC) appre'ciates the:
opportunity to present its views 1on-S.1630-and H.R.3030, now before-the Conference Committee, to amend the Clean Air Act.
The provision of most immediate relevance to the NRC's respon-
~
sibilities is the section of the Senate bill dealing with
.radionuclide emissions. from NRC-licensed f acilities. (Section 301 of S.1630, adding a new Section 112(d)(11)).
This section, which has no eauivalent in the House bill,. states in pertinent-part:
No-standard for radionuclide emissions from f acilities licerted by the Nuclear Regulatory Commission (or an Agreement-State) is required to be promulgated under.this section ifnthe Administrator determines, after consultation with the Nuclear ReEulatory Commission, that the L
regulatory program established by-_the Nuclear L
Regulatory Commission pursuant to the Atomic Energy-Act provides an ample margin of safety. to protect' the public health.
The NPC believes that this prevision is both a. valuable and necessary. component of the legislation.
-It buildsJupon,-and provides clarification of, the existing Section'122 of the Act, which directs that EPA and NRC.shall, "to the maximum extent 1
practicable..., minimize duplication of effort and' conserve administrative resources in the establishment,wimplementation, and enforcement-of emission limitations.. standards-of performance and other requirements and: authorities (substantive and procedural)...." 42 U.S;C.-7422(c)(2).
Such clarification-is particularly desirable at this time, as there has been legal controversy in the past several years on the precise -question of whether EPA is requiredito set radionuclide standards, notwithstanding that such standards-are duplicative of the NRC regulatory program and-that EPA finds the NRC' program fully adequate to protect public health with an ample margin of safety.
't
.q
=
i j Clearly, it is wasteful.of~ governmental resources and contrary-to principles of good government to compel an agency to regulate emissions already-regulated adequately by a sister agency.
Agencies should.be-allowed to devote their resources.
to addressing health and safety ' problems that remain to~ be resolved, rather.than wasting effort on problemssthat have-already been satisfactorily resolved by another agency.
By.
spelling out that: EPA need not regulate where it finds that NRC regulation'is adequate, this provision'of the_legislationn will address,this unnecessary duplication of. responsibility.
A November. 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Acting Surgeon General Mason also called upon Congress to Eliminate i;
altogether EPA's authority to regulate _radionuclide emissions ~
since such regulation was " unnecessary.and duplicative."
This.
letter, together with earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for _the opportunity to comment on this issue.
Sincerely,
\\Lx.L
-Kenneth M. Carr Attachments:
As stated
.. n
.=.1 ei 12 tso UNITED STATES i NUCLEAR REGULATORY COMMISSION
_ p
,{
WASHINGTON. D. C. 20666 i
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j July 20,1990
{
CHAINMAN i
The Honorab1'e: Ralph M. Hall:
United States House of-Representatives-Washington,-D.C.-
20515
Dear Congressmar' Hall:
TFeJNuclear Regulatory Commission (NRC) appreciates the opportunity to present its views-on S.1630 and H.R.3030 now before the Conference Committee, to amend the Clean Air Act.
The provision of most immediate relevance:to'the NRC's respon-sibilities is the sect' ion of the Senate bill dealing (with radionuclide emissions from NRC-licensed 1 facilities Section 301 of S.1630, adding a new.Section.112(d)(11)).
This section, which has no equivalent in~the-House bill, states in pertinent part:
No standard 1or radionuclide emissions from facilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be promulgated under this section if the Administrator determines, after.consultationLwith the Nuclear Regulatory _ Commissien, that thec regulatory program established by.the Nuclear ReSulatory Commission pursuant to the Atomic Energy Act provides an: ample margin of safety.to protect the;public health.
j The NRC believes that this provision is both a valuable ~and necessary component of the-legislation.
It builds upon,'and provides clarification of, the existing Section'122'of the Act, which directs that EPA and NRC shall, "to the maximum extent E
practicable..., minimize duplication of_ effort-and conserve l"
administrative resources,in the establishment, implementation, and enforcement of emission limitations, standards of-performance and other requirements'and-authorities-(substantive and procedural)...." 42 U.S.C.'7422(c)(2).
Such clarification-is particularly desirable at this' time, as there has been legal controversy in the past: several years on the -precise question of whether EPA is required to set radionuclide strndards, notwithstanding that such standards are'duplicative of the NRC regulatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin.of-safety.
l
-p.
' Clearly, it is wasteful of governmental resources and contrary to principles of good government to ' compel an agency to regulate emissions already-regulated adequately-by a' sister Agencies should be allowed to devote-their resources agency.
7 to addressing health and safety problems that remain =to:be resolved, rather than wasting effort-on problems that have already been satisf actorily resolved by another agency.
By spelling out that EPA need not. regulate where it finds'that HRC regulation is adequate, this provision of the legislation will address this unnecessary duplication of responsibility.
A-November-15,.1989 joint letter from EPA Assista't-Administrator i
Rosenberg and HHS Assistant Secretary Efor Health and Acting l
Surgeon General. Mason also called upon. Congress to eliminate altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and'duplicative."
This letter, together with earlier NRC letters to' the Cot <gress 4
commenting on this issue, are attached.
We thank you for the cpportunity to. comment on this issue.-
Sincerely,
\\
mW.
Kenneth M..Carr Attachments:
As stated
(
l
,.1 E[ ' wp uoy[o UNITED STATES -
yy NUCLEAR REGULATORY COMMISSION
. r,
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Ouly;20,1990 l,
CHAIRMAN l
The Honorable-Dennis E. Eckart United States House of Representatives l
' Washington, D.C.
20515 j
l
Dear Congressman Eckart:
i The Nuclear 1 Regulatory Commission (NRC) appreciates. the l
opportunity to presaat its views on S.1630 and H.R.3030, now-a before the Conferens. Committee, to amend the Clean Air /Act.-
The provision of most immediate. relevance to the NRC'sz respon-sibilities-is the'section of the Senate bill dealing (with l
radionuclide emissions from NRC-licensed facilities Section
'301 of S.1630, adding.a new Section-1.12(d)(11)).
This section, i
which'has no equivalent in the House bill, states in pertinent i
part:
No standard for radionuclide emissions from f acilities licensed by_ the Nuclear Regulatory Commission (or an-Agreement State) is required.
to be promulgated under this section_if the Admir.istrator determines, after_ consultation with j
the-Nuclear Regulatcry Commission, thatuthe regulatory program established by the Nuclear a
Regulatory Commission' pursuant to the' Atomic Energy q
Act provides an-ample margin of safety: to protect i
the public hcalth, i
The NRC believes.that this provision;is'both a-valuable and 4
necessary component of the legislation.
It-builds upon, and provides clarification of, the existing-Section~122 of.the Act,
'3 which directs that EPA and NRC shall, "to the maximum extent practicable..., minimize duplication of effort and conserve-administrative' resources in the establishment,-implementation, and. enforcement of emission limitations, standards of s
performance'and-other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this. time, as there has been legal controversy -in the past several years on the precise question-of whether EPA is required to set radionuclide. standards, notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully 3
adequate to protect public health with-an ample margin of safety.
7,<
1 i
-2 i
Clearly, it is~ wasteful of governmental resources'and contrary l
to principles of good government to compel an agency to' regulate emissions already. regulated adeountely by a sister l'
agency.
Agencies should be allowed to devote their resources to addressing health and-safety problems that-remain to be resolved, rather than wasting effort on problems that have already been satisf actorily resolved by-another agency.- By spelling out that EPA need not regulate where it finds-that NRC regulation is adequate, this provision of the legislation-will. address-this unnecessary duplication of, responsibility. L A'.
l November 15, 1989; joint 11etter from EPA Assistant Administrator j
Rosenberg and. HHS Assistant Secretary for Health and Acting.
Surgeon General Mason.also-called upon. Congress to eliminate altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative'."
This letter, together-with earlier 1NRC letters to the Congress-commenting on this issue, are attached-.
We. thank you for the opportunity to comment on this issue.
Sincerely,
'W.
J l
Kenneth M. Carr Attachments:
As stated i
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NUCLEAR REGULATORY COMMISSION-n h
WASHINGTON, D. C. 20555 July 20,1990 CHAIRMAN
/
The Honorable Jim Slattery United States House of Representatives Washington, D.C'.
20515
Dear Cengressman Slattery:
l The Nuclear Regulatory Commissioni(NRC) apprecia'tes-the-opportunity to present,its views on S.1630 and H.R.3030, now-before the Confertnce Committee, to amend the Clean Air Act.
The provision of most immediate relevance.to:the NRC's respon-sibilities is the section of the Senate bill dealingJwith radionuclide enissions from NRC-licensed facilities (Section 301 of 5.1630, adding a new Section 112(d)(11)).
This.section, which has nc equivalent-in the House bill, states'in pertinent part:
No standard for radionuclide emissions from facilities licensed by the Nuclear Regulatory Commissicn (or an Agreement State)-is required-to be promulgated under this section if the Administrator determines, after consultation'with t
l the Nuclear Regulatory Commission,--that the regulatory program established by 'theJ Nuclear Regulatory Commission pursennt to the Atonic Energy Act provides an ample margin of safety to protect the.public health.
The NRC believes that this provision is'both-a valuable and-l necessary component-of the legislation.
It builds upon,_and' provides clarification'of, the existing Section;122 of.the-Act, which directs that EPA and NRC.shall, "to the maximum extent practicable...
minimize duplication of effort and conserve administrative resources in the establishment,. implementation, and enforcement of emission limitations, standards:of performance and other requirem'ents and authorities (substantive a nd procedura l).... " 42 U.S.C. -7422(c)(2).
Such clarification is particularly desirable at.this time, as there has been legal controversy in.the past several. years on the precise question of whether EPA.is required to set radionuclide standards, notwithstanding-that such standards are duplicative of the NRC regulatory p70 gram and-that EPA finds -the NRC program fully adequate to protect public health with-an ample margin of safety.
l l
z.
1 Clearly, it is wasteful of governmental resources and contrary to principles of good government to compel an agency to regulate. emissions.already regulated adequately by a sister agency.
Agencies should be allowed to devote-their resources to addressing health andssafety problems that remain terbe-resolved, rather than wasting' effort on problems that have already been satisf actorily resolved by another agency.
By-spelling out that EPA need not-regulate where.it finds that NRC regulation-is adequate, this provision of the legislation-will address this unnecessary duplication of responsibility. J A November 15,-1989. joint letter:from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Acting Surgeon General Mason also called upon Congress to eliminate altogether EPA's authority to regulate radionuclide-emissions since such regulation was " unnecessary and duplicative."
This
. letter, together with earlier NRC letters to the Congress commenting on this issue, are attached, he thank you for the opportunity to comment on this issue.
Sincerely, ou
-Kenneth M. Carr Attachments:
As stated 4
i l
i l
y
'. 4"# Ni UNITED STATES 8
g NUCLEAR REGULATORY COMMISSION a
WABHINGTON, D. C. 20666 Ouly 20,1990
- ep e
- CHAIRMAN 1
The Honorable Gerry Sikorski United States House of Representatives Washington, D.C.
20515
Dear Congressman Sikorski:
The Nuclear Regulatory Commission.(NRC) appreciates'the opportunity to present'its views onLS.1630 and'H.R.3030, now before the Conference Committee, to amend'the_ Clean Air Act..
The provisionuof most-immediate relevance to-the NRC's respon-sibi'ities is the section of the. Senate bill dealing with j
i radionuclide emissions from NRC-1icensed fccilities-(Section 301 of S.1630, adding a new Section 112(d)(11)).. This_section, which has no equivalent _in the. House bill, states in pertinent part:
No standard for radionuclide emissions from f acilities licensed by the Nuclear Regulatory _
Commission'(or an Agreement State) is rcquired to be promulgated under this section if the Administrator deterrines, after consultation with the Nuclear Regulatory Commission, that the re0ulatory program established by -the Nuclear' _
I,egulatory Commission pursuant to -thes Atomic-Energy-Act provides an ample _ margin of-saf ety to protect the public health.
1 1
The NRC believes that this' provision is.both a valuable and i
necessery component of the= legislation.
It builds upon, and i
provides clarification of, the existing Section 122 of. the Act, which directs that EPA and.NRC shall,_"to'the maxirem extent practicable..., minimize duplication.of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission;1 imitations, standards of-performance end other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time, as-there has been lega.1:
controversy in the past several years on the precise question of whether EPA is required to set radionuclide standards, notwithstanding~that such standards are-duplicative of the NRC regulatory program and that EPA finds the NRC program. fully adequate to protect public health with an ample margin of.
- safety, f
s 8
a 2-l Clearly, it is westeful of' governmental resources and contrary-to principles of good government to compel an agency to L
regulate emissions already regulated-adequately by a sister L
agency._ Agencies should be allowed to devote:their resources to, addressing health and safety problems that remain to be resolved, rather;than wasting effort on problems that have already been satisf actorily resolved by - another. agency.- By-1 spelling out that. EPA need not regulate where it finds that:
NRC ret..lation is adequate,Lthis provision ofEthe legislation; will address this. unnecessary duplication of responsibility.
'A:
November 15, 1989 joint letter from EPA Assistant Administrator.
- Rosenberg and HHS Assistant Secretary for-Health and Acting-
. Surgeon General Mason also called upon Congress to eliminate' altogether EPA's authority toLregulate radionuclide emissions-since such regulation was " unnecessary and-duplicative." :This-letter, together with earlier NRC letters to'the Congress commenting on this issue, are attached.
We thank you for the opportunity' to' comment on this issue.
Sincerely, a uh.
Kenneth M. Carr-Attachments:
As stated t
b i
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UNITED STATES '
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NUCLEAR REGULATORY COMMISSION -
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" WASHINGTON, D. C. N555 r
July 20, 1990 CHAIRMAN
,)
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The Honorable 1 Frederick C. Boucher United States House ~of. Representatives Washington, D.C.;
20515
Dear. Congressman Boucher:
L The Nuclear Regulatory Commission (NRC) appreciates the opportunityz to present its views'on S.1630 and H.R.3030, now before the Conference' Committee, to1 amend the Clean. Air Act.
The provision of most immediate relevance'to the NRC's respon-sibilities is the section of the Senate bill:_ dealing. with radionuclide emissions from NRC-licensed facilities (Section 301 of S.1630, adding a new Section 112(d)(11))._.This section, whichLhas no eouivalent in the House. bill,' states in pertinent part:-
l No standard for-radionuclide emissions from' r
facilities licensed.by the Nuclear Regulatory Commission (or an Agreement-State)'is required' L
to be promulgated under this-section if the Administrator determines, after-censultation with the Nuclear _ Regulatory Commission, that the regulatory program established by the-Nuclear.
Reguletory Commission pursuant, to the Atamic. Energy.
3 Act provides an ample margin of safety to protect the public health.
The !!PC. believes that this prevision is both a valuable and; necessary component of' the legislation.
It builds upon, and-provides clarification of, the existing Section 122 of the Act, which directs that EPA and NRC shall, "to the maximum extent 4
practicable..., minimize duplication-of. effort and conserve l
administrative ~ resources in1the establishment,. implementation, and enforcement of~ emission limitations, standardsJof performance and other requirements and authorities (substantive l
and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time, as=there has been legal controversy sin.the past several years on the precise question of_whether EPA'is required to set radionuclide standards,.
notwithstanding that such standards are duplicativc of the NRC.
regulatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin of
- safety, f
. - - -.. ~,.
,-4
.,~
,y
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i Clearly, it is wasteful of governmental resources and contrary.
to principles of good government to compel ~an agency to regulate emissions already regulated adequately by a; sister i
agency.
Agencies should be allowed to devote theirl resources l
to addressing health and safety problems that remain to be ra:vived, rather than wasting effort on problems that have.
already been satisf actorily resolved by another agency.- By spelline out that= EPA need n'ot regulate where it finds that-NRC regulation is adequate, this provision offthe legislation-
. will address this unnecessary? duplication 1of. responsibility.
A.
November-15, 1989-joint' letter from EPA Assistant Administrator:
Rosenberg and HHS Assistant Secretary' for_ Health.and Acting.
Surgeon General Mason also. called-upon Congress to eliminate altogether EPA's authority to regulate radionuclide emissions.
since such regulation was " unnecessary and duplicative."
This:
. letter, together with earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely, eM.
Kenneth M. Carr Attachments:
As stated 1
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o July 20, 1990 L
l CHAIRMAN i
The Honorable J. Roy Rowland United States House of Representatives Washington, D.C.
20515
Dear Congressman Rowland:
The Nuclear RegulatorycCommission.(NRC) appreciates the L
opportunity to present its views on;S.1630 and H.R.3030, now before the Conference' Committee,.tofamend the Clean-Air Act.
The provision of=most immediateLrelevance to the NRC's respon-sibilities is the section cf the Senate bill dealing (with:
radionuclidt emissions from NRC-licensed facilities Section 301 of-S.1630, adding.a new Section.112(d)(11)). '
which has no equivalent in the House. bill, statess-This section~,
in pertinent part:
(
No standard for radionuclide emissions from
~
facilities licensed by the Nuclear Regulatory-Commission (or an Agreement State) is required to be promulgated under this section if the Administrator' determines, after consultation with the Nuclear Regulatory'Commissien, that the-regulatory program 1 established--by-the, Nuclear Regulatory Commission pursuant to thefAtomic Energy Act provides an ample margin of, safety to protect the public health.
The NRC believes that this provision is both a valuable and necessary component of the legislation..
It builds upon, and.
provides clarification of,- the existing Section 122 of the:Act, which directs that EPA and-NRCLshall, "to-the maximum extent
. practicable..., minimize duplication of~ effort and' conserve; administrative resources in the establishment,l implementation, and enforcement of emissionilimitations, standards of performance and other requirements and-authorities (substantive and procedural)...." 42 U.S.C' 7422(c)(2).
Such clarification-is particularly desirable -at this time, Las there has.been legal controversy in the past several years on the preciseEquestion of whether EPA is required to set radionuclide. standards, notwithstanding that such standards are duplicative of the NRC~
regulatory program and. that EPA-finds the NRC program fully.
adequate to protect public health with an-ample margin of
~
safety.
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Clearly, it is wastefal of go'vernmental-resources and contrary to principles of good government to compel an agency-to:
regulate emissions already. regulated adequately by a-sister l
agency.
Agencies shou'd be allowed to devote their resources to addressing health at d safety problems _that-remain to be resolved, rather.than wisting effort on problems that have a1 ready been satisf actorily ' resolved by another agency.
By spelling out that EPA need not regulate where it finds that NRC regulation is adequate, this provision of the legislation =
will address this unnecessary' duplication: of responsibility.
A_
November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS~ Assistant. Secretary f or Health ~and Acting Surgeon General Masonlaiso' called upon Congress to eliminate altogether EPA's authority 1to-regulate radionuclide emissions' since such regulation was " unnecessary -and duplicative."
.This letter, together with earlier NRC letters to-the' Congress comrenting on this issue, are attached.
We hank you-for the opportunity ta comment on this issue.
Sincerely,
\\
'Kenneth M. Carr Attachments:
As stated
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1 UNITED STATES
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g-NUCLEAR REGULATORY COMMISSION
,t WASHINGTON, D. C. 20555 -
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July ~20, 1990 CHAIRMAN l
The Honorable Norman F. Lent United States House of Representatives Washington,,D.C.
20515
Dear Congressman Lent:
i The Nuclear Regulatory Commission (NRC) appreciates the L
opportunity to present its views on S.1630 and H.R.3030, now before the Conference Committee, tonamend the. Clean Air Act.
The provision of most immediateLrelevance to the NRC's respon-sibilities is the-section cf the Senate bill dealing (with radionuclide emissions from NRC-licensed facilities Section 30.1 of S.1630, adding a new Section 112(d)(11)).
This section, l
whir.n has no equivalent-in the House bill, states in pertinent pait:
No standard for radionuclide emissions from l
facilitics licensed by'the-Nuclear Regulatory Commission (or an Agreement State) is required-to be promulgated under this section if~the Administrator _ determines, after' consultation with.
I the Nuclear Regulatory Commission, that the rogulatory program-established by the Nuclear Pegulatory Commission pursuant to the Atomic Energy Act provides an= ample margin'of safety'toyprotect the public health.
The NRC believes that this provision is both a valuable and necessary component of the legislation.
It builds upon, and; provides clarification of, the existing Section 122_of,the Act, which directs that~ EPA and-NRC shall, "to:the maximum _ extent practicable..., minimize duplication of effort and' conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance-and other requirements and authorities-(substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this. time, as there has been legal controversy in the past several! years on'the precise question of whether EPA is required.to set radionuclide standards.
4, notwithstanding that.such standards are duplicative of the NRC regulatory program and that EPA finds the NRC' program fully adequate to protect public health with an ample margin of safety.
1
2-L Clearly, it is wasteful _ of governmental resources and contrary _
j to principles of good governmentEto compel'an agency;to q
~
regulate emissions already regulated adequately by a sister agency.. Agencies s50uld:be allowed to:-devote their resources 4
to addressing health and safety; problems that' remain to be resolved, rather than wasting effort on' problems that_have s
already been satisf actorily resolved 'by/ another agency.- By-spelling-out that EPA need not regulate where it-finds that NRC regulation is adequate, this provision of theElegislation wi.11 address this unnecessary ' duplication-of responsibility.
A-November 15, 1989 joint letter from' EPA Assistant Administrator i
Rosenberg and HHS' Assistant Secretary for-Health and Acting-Surgeon General-Mason also called upon Congress to eliminate altogether _ EPA's authority to. regulate radionuclide emissions-since such regulation was " unnecessary:and duplicative."
This letter, together with earlier NRC letters to1the Congress.
commenting on-this issue, are attached.
1 We thank you for. the opportunity to comment-on this issue.
Sincerely, Kenneth 11. Carr Attachment.s:
As stated t
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UNITED STATES
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WASHINGTON, D. C,20666 I
July-20,l 1990 l
CHAIRMAN j
- i The Honorable Edward R. Nadigan
-)
United States House of Representatives Washington,:D.C.
20515 i
Dea'r-Congressman Madigan:
The Nuclear. Regulatory Commission (NRC) appreciates the opportunity to present its views on S.1630 and H'.R.3030-, now before the Conference Committee, to amend-the Clean. Air Act, j
The provision'of cost immediate relevance to the NRC's:respon-sibilities is the section of the Senate bill cealing(Section with radionuclide emissions from NRC-licensed facilities 301 of S.1630, adding a new Section 112(d)(11)).
This section, which has no equivalent in the House bill, states in pertinent
,part:
i No standard for radionuclide emissions from facilities licensed by the Nuclear Regulatory j
Commission (or an Agreement > State) is required-to be promulgated under this1section if the Administrator determines, after consultation with the.Huclear Regulatory 1Comnission, that the a
regulatory program established by the-Nuclear Regulatory Commission pursuant to the' Atomic Energy Act provides an ample margin of safety to: protect-the public health.
The HRC believes that this provi: ion is both a valuable-and necessary component'of the legislation.
It' builds upon, and provides clarification of, the existing Section-122 of.the Act, which directs that EPA and NRC.shall, "to theimaximum extent practicable..., minimize duplication.of effort:and conserve-administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities'(substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particular1y' desirable at this : time Las there has been legal controversy in the past several years o,n the precise question of whether EPA is required ~to set radionuclide standards, notwithstending that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully adequate to protect'public health with an ample margia of safety.
6 4
1 2-Clearly, it is wasteful of governmental resources and contrary I
to principles of good government to compel an agency to.
f regu' late emissions already regulated adeoustely by a sister.
agency.
Agencies should be allowed to devote their resources to addressing health and safety problems that remain to be resolved, rather than wasting effort on problems that have already: been-satisfactori.ly resolved by another agency.
By spelling out that= EPA need not regulate where it finds-that-NRC regulation is adequate, this provision;of the legislation j
will address this unnecessary duplication ofrresponsibility.
A -
November 15, 1989 joint letter _from EPA-Assistant: Administrator-Rosenberg and HHS Assistant Secretary for Health and Acting-Surgeon General Mason diso called upon Congress to eliminate-i altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary -and duplicative.".Thi s -
letter, together with earlyr NRC letters to the Congress comment ing-on thi s is sue, ate a t ta ched'.
We thank you for the opportunity to comment. on this issue.-
Sincerely, ionah,
Kenneth M. Carr l
Attachments:
As stated i
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NUCLEAR RE ULATORY COMMISSION
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July 20,1990 l
CHAIRMAN i
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The Honorable Carlos J. Moorhead United States House of Representatives Washington, D.C.
20515
Dear Congressman Moorhead:
i The Nuclear Regulatory Commission (NRC) abpreciates the opportunity to present its vi(ws en S.163 and H.R.3030, now before the Conference Committee, to amend the Clear. Air Act.
The provision of most immediate relevence to the NRC's respot.-
sibilities is the section of the Senate bill d(eling(with radienuclide estissions f ret NRC-licensed facilities Section 301 of 5.1630, adding a new Section 112(o)(13 )).
This section, which has to equivalent in the Houst bill, states in pertinent part:
No standard for radionuclide trissions from facilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be promulgated under this section if the i
Adninistrator determines, af ter consultation with the Nuclear Regulatory Commission, that the I
regulatory program established by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act providet an ample margin of safety to protect the pu.
Mealth.
The NRC believes that this provision is both a valuabu Ind necessary corponent of the legislation.
It builos upon, and provides clarification of, the existing Section 122 of the Act, i
which directs that EPA and NRC shall, "to the msximum extent practicablo..., minimize duplication of effort and conserve cdministrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time, as there has been legal controversy in the past several years on the precise question of wh2ther EPA is requireo to set radionuclide standards, notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC. program fully adequate to protect public health with an ample margin of 1
safety.
, _ ~.. -
. ~..
o e,
Clearly, it is wasteful of governmental resources and contrary to principles of good government to compel an agency to regulate emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote their resources to addressing health and safety problems that remain to be resolved, rather than wasting effort on problems that have already been satisfactorily resolved by another agency.
By spelling out that EPA need not regulate where it finds that NRC regulation is adequate, this provision of the legislation will address this unnecessary duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Acting Surgeon General Mason also called upon Congress to eliminate altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative."
This letter, together with ehrlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue, j
Sincerely,
\\Lu.6 Kenneth M. Carr Attachments:
As stated
_j
- ga ucg j
o UNITED STATES
{
NUCLEAR REGULATORY COMMIS$10N wAsmwotoN, D. C. 20666 Ouly 20,1990 CHAIRMAN J
l 1
l The Honorable William E. Dannemeyer United States House of Representatives Washington, D.C.
20515
Dear Congressman Dannemeyer:
The Nuclear Regulatory Commission (NRC) appreciates the I
opportunity to present its views on S.1630 and H.R.3030 now before the Conference Committee, to amend the Clean Air Act, The provision of most immediate relevance to the NRC's respon-i i
sibilities is the section of the Senate bill cealing(with radionuclide emissions f ron. NRC-licensed f acilities Section 301 cf S.1630, adding a new Section 112(d)(11)).
This section, l
which has no equivalent in the House bill, states in pertinent part:
l No standard for radionuclide emissions from f acilities licensed by the Nuclear Regulatory Commission (or en Agreement State) is required te be promulgated under this section if the Administrator determines, after consultation with the Nuclear Regulatory Commission, that the regulatory program established. by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety to protect the public health.
The NRC believes that this provision is both a valuable and l
necessary component of the legislation, it builds upon and provides clarification of, the existing Section 122 of the Act, which directs that EPA and NRC shall, "to the maximum extent practicable..., minimize duplica tic.; of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and proc'edural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time, as there has been legal controversy in the past several years on the precise question of whether EPA is required to set radionuclide standards, l
notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully l
adequate to protect public health with an ample margin of safety.
t
4 t'
a 2
Clearly, it is wasteful of governmentel resources and contrary to principles of good government to compel an agency to regulate emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote th:1r resources i
to addressing health ano safety problems that remain to be resolved, rather than wasting effort on problems that have already been satisfactorily resolved by another agency.
By saelling out that EPA need not regulate where it finds that N3C regulation is adequate, this provisich of the legislation t'
will address this unnecessary duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for. Health and Acting Surgeon General Mason also called upta Congress to eliminate altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to the Corgress commenting on this issue, are attached.
We thank you f or the opportunity to comment on this issue.
Sincerely, l
.eh.b Kenneth M. Carr Attachments:
I As stated 1
5 l
((9n%\\
UNITED STATES
)m l g NUCLEAR REGULATORY COMMISSION "e
W ASHINGT ON, 0. C. 20666
\\.',7,.
July 20, 1990 CH A!RMAN The Honorable Bob Whittaker United States House of Representatives Washington, D.C.
20515'
Dear Congressmar Whittaker:
The Huclear Regulatory Commission (NRC) appreciates the opportunity to present its views on S.1630 and H.R.3030, now before the Conference Committee, to amend the Clean Air Act.
The provision of most immediate relevance to the NRC's respon-sibilities is the section of the Senate bill dealing with radionuclice emissions from NRC-licensed facilities (Section 301 of S.1630, adding a new Section 112(d)(11)).
This section, which has no equivalent in the House bill, states in pertinent part:
No standcrd for radionuclide emissions from f acilities licensed by the Nuclear Regulatory Commissic.n (or an Agreement State) is required to be prcmulgated under this-section if the Administrator determines, after consultation with the Nuclear Regulatory Commissien, that the regulatory program established by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act provides an am the public health.ple margin of safety to protect The NRC believes that this provision is both a valuable and necessary component of the legislation, it builds upon, and provides clarification of, the existing Section 122 of the Act, which directs that EPA and NRC shall, "to the maximum extent practicable..., minimize duplication of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performsnce and other requirements and authorities (substantive i
ano procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly-desirable at this time as there has been legal controversy in the past several years o,n the precise question oV whether EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin of safety.
(
t i 6 Clearly, it is wasteful of governmental resources and contrary to principles of good government to compel an agency to regulate emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote their resources to addressing health and safety problems that' remain to be resolved, rather than wasting effort on problems that have I
already been satisf actorily resolved by another agency.
By spelling out that EPA need not regulate where it finds that l
NRC regulation is adequate, this provision of the legislation will address this unnecessary duplication of. responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Acting Surgeon General Mason also called upon Congress to eliminate i
altogether EPA's authority to regulate radionuclide emissions l
since such regulation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to the Congress commenting en this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely, wh.
Kenneth M. Carr Attachments:
As stated f
l w
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s WASHl880 TON, D. C. 20666
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Ouly 20, 1990
,u CHAIRMAN i
The Honorable Thomas J. Bliley, Jr.
i United States House of Representatives Washington, D.C.
20515
Dear Congressman Bliley:
The Nuclear Regulatory Commission (NRC) appreciates the opportunity to present its views on S.1630 and H.R.3030, now t
before the Conference Committee, to amend the Clean Air Act.
The provision of most immediate relevance to the NRC's respon-sibilities is the section of the Senate bill dealing with radionuclide emissions from NRC-licensed facilities (Sectiore 301 of 5.163C, adding a new Section 112(d)(11)).
This section, which has no ecuivalent in the House bill, ttates in pertinent part:
1 No standard for radionuclide emissions from facilitics licensed-by the Nuclear Regulatory Commission (or an Agreoment State) is required to be promulgated under this section if the Administrator determines, after consultation with i
the Nuclear Regulatory Commission, that the regulatory program established by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act provides an ampic margin of safety to protect the public health.
The NRC believes that thit-provision is both a valuable and necessary component of the legislation.
It builds upon, and provides clarification of, the existing Section 122 of the Act, i
which directs that EPA and NRC shall, "to the maximum extent-practicable..., minimize duplication of effort and conserve t
administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time, as there has been legal controversy in the past several years on the precise question of whether EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the NRC i
regulatory program and that EPA finds the NRC program fully acequate to protect public health with an ample margin of safety.
l c
c I
t 2
Clearly, it is wasteful of governmental resources and contrary to principles of good government to compel an agency to regulate emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote their resources to addressing health and safety problems that remain to be resolved, rather than wasting effort on problems that have already been satisf actorily resolved by another agency.
By spelling out that EPA'need not regulate where it finds that NRC regulation is adequate, this provision of the legislation will address this unnecessary duplication of responsibility.
A November 15, 198g joint letter from EPA Assistant Administrator Rosenberg and-HHS Assistant Secretary for Health and Acting Surgeon General Mason al.co called upon Congress to eliminate altogether EPA's authority to regulate radionuclide emissions' since such regulation was *.nnecessary and dJplicative."
This letter, together with earlie NRC lette's to the Congress commenting on this issue, art attached.
We thank you for the opportunity to comment on this issue.
Sincetely, i
- veh, Kenneth M. Carr Attachments:
l As stated l
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Io, UNITED STATES e
,.c NUCLEAR PEGULATORY COMMISSION i
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July 20,1990
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CHAIRMAN The Honorable Jack Fields United States House of Representatives Washington, D.C.
20515
Dear Congressman Fields:
)
i i
The Nuclear Regulatory Commission (NRC) appreciates the opportunity to present its views on S.1630 and H.R.3030, now before the Conference Committee, to amend the Clean Air Act.
The provision of most immediate relevance to the NRC's respon-
)
sibilities is the section of the Senate bill dealing (with radionuclide emissions from NRC-licensed facilities Section 301 of 5.1630, adding a new Section 112(d)(11)).
This section, t
which has no equivalent in the Hcuse bill, states in pertinent part:
No standard for radionuclide emissions from facilitics licensed by the Nuclear Regulatcry 2
Commission (or an Agreement State) is required to be promulgated under this section if the Administrator determines, after consultation with i
the Nuclear Regulatory Commissien, that the regulatory program established by the-Nuclear Petulatory Commission pursuant to the Atomic Energy Act provioes an ample margin of safety to protect the public health.
The NRC believes that this provision is both a valuable and necessary component of the legislation.
It builds upon, and crovides clarification of, the existin which directs that EPA and NRC shall, g Section 122 of the Act.
to the maximum extent practicable..., minimize duplication of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time as there has been legal controversy in the past several years o,n the precise question of whether EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin of
- safety, 1
,n,--
...,.-.,,,,.,.,,_.n--,,v..r-e n
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o 2
Clearly, it is wasteful of governmental resources and contrary to principles of good government to compel an agency to regulate emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote their resources to addressing health and safety problems.that remain to be resolved, rather than wasting effort on problems that have already been satisf actorily resolved by another agency.
By,
spelling out that EPA need not regulate where it finds that NRC regulation is adequate this provision of the legislation will address this unnecessa,ry duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS. Assistant Secretary for Health and Acting Surgeon General Mason also called upon Congress to eliminate altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely,
\\L.w A~
Kenneth M. Carr Attachments:
As stated 4
1 l
l l
g f F
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/so rs %q'o, UNITED STATES 8",#
NUCLEAR REGULATORY COMMISSION a
I wAsmwoTow, p. c. gosss s
J
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July 20,1990 l
CHAIRMAN The Honorable Michael Oxley United States House of Representatives-Washington, D.C.
20515
Dear Congressman Oxley:
The Nuclear Regulatory Commission (NRC) appreciates the oppertunity to present its views on S.1630 and H.R.3030, now before the Conference Committee, to amend the Clean Air Act.
l The provision of most immediate relevance to the NRC's respon-sibilities is the sectior, of the Senate bill dealing with radionuclide croissions f rom NRC-licensed f acilities (Section 301 of S.1630, adding a new Section 112(d)(11)).
This section, which has no equivtleut i n the House bill, states in pertinent
{
part:
No standaro for radionuclide emissions frou i
facilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required L
to be promulgated under this section if the Adrair.istrator determines, af ter consultation with the Nuclear Regulatory Commissicn, that the regulatory program established by the Nuclear l
Regulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety to protect the public health.
The NRC believes that this provision is both a valuable and necessary component of the legislation.
It builds upon, and provides clarification of, the existin which directs that EPA and NRC shall, g Section-122 of the Act,
to the maximum extent practicable..., minimize duplication of effort and conserve administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)...." 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time as there has been legal controversy in the past several years o,n the precise question of whe her EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin of safety.
=w g
r-7
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,-em
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1 Clearly, it is wasteful of governmental resources and contrary i
to principles of good government to compel an agency to retslate emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote their resources to addressing health and safety problems that remain to be resolved, rather than wasting effort on problems that have i
already been satisfactorily resolved by another agency.
By spelling out that EPA need not regulate where it finds that N1C regulation is adequate, this provision of the legislation will address this unnecessary duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg end HHS Assistant Secretary for Health and Acting Surgeon General Mason also celled upon Congress to eliminate i
altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely, Kenneth M. Carr Attachments:
As stated t
e i
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c-s-
+
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W ASHINGTON. D. C. 20$55
%,(( f July 20,1990 CH AIRM AN The Honorable Howard C. Nielson United States House of Representatives Washington, D.C.
20515
Dear Congressman Nielson:
The Nuclear Regulatory Commission.(NRC) appreciates the opportunity to pre: ent its views on S.1630 and H.R.3030, now before the Confererce Committee, to amend the Clean Air Act.
The provision of most immeciate relevence to the NRC's respon-sibi ities is the section of the Senate bill cealing(with radionuclide emis sions f ron. NRC-licensed f acilities Section 301 of S.1630, adding a new Section 112(d)(11)).
This section, which has no equivalent in the House bill, states ir, pertinent part:
No standard for radionuclide emissions from f acilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be promulgeted under this section if the Administrator determines, after censuItation with the Nuclear Regulatory Commission, that the regulatory program established by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety to protect the public health.
The HRC believes that this provision is both a valuable and necessary component of the legislation.
It builds upon, and i
provides clarification of, the existing Section 122 of the Act, which directs that EPA and NRC shall, "to the maximum extent practicable..., minimize duplication of effort and conserve administrative resources-in the establishment.. implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and pt9cedural)...." 42 U.S.C. 7([2(c)(2).
Such clarification is particularly desirable at thic time as there has been legal controve*sy in the past several years o,n the precise question I
of whether EPA is required to set radionuclide standards, notwithstaeding that such standards are duplicative of the NRC regulatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin of safety.
2 Clearly, it is wasteful of governmental resources and contrary to principles of good government to compel an agency to regulate emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote their resources to addressing health and safety problems that remain to be resolved, rather than wasting effort on problems that have already been satisfactorily resolved by another agency.
By spelling out that EPA need not regulate where it finds that NRC regulation is adequate, this provision of the legislation will address this unnecessary duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Acting Surgeon General Mason also called upon Congress to eliminate altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely,
.1 h,
Kenneth M. Carr Attachments:
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l The Honorable Michael Bilirakis United States House of Representatives j
Washington, D.C.
20515 l
1 Dear Congressman Bilirakis.
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The Nuclear Regulatory Commission (NRC) appreciates the opportunity to present its views on S.1630 and H.R.3030, now before the Conference Committee, to amend the Clean Air Act, i
The provision of most i mmediate relevcnce to the NRC's respon-I sibilities is the section of the Senate bill dealing (with radionuclide emissions f roni NRC-licensed f acilities Section 301 of S.1630, adding a new Section 112(d)(11)).
This section, which has no equivalent in the House bill, states in pertinent part:
No standard fur radionuclide emissions from facilities licensed by the. Nuclear Regulatory Commission (or an Agreement State) is required to be promulgated under this section if the Administrator determines, after consultation with the Muclear Regulatory Comnission, that the regulatory progran established by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act provides an ample margin of safety to protect the public health.
The NRC believes that this provision is both a valuable and necessary component of the legislation.
It builds upon, and provides clarification of, the existin which directs that EPA and NRC shall, g Section 122 of the Act, to the maximum extent practicable..., minimize duplication of effort and conserve-administrative resources in the establishment, implementation, and enforcement of emission limitations, standards of performance and other requirements and authorities (substantive and procedural)....' 42 U.S.C. 7422(c)(2).
Such clarification is particularly desirable at this time, as there has been legal controversy in the past several years on the precise question of whether EPA is required to set radionuclide standards, notwithstanding that such standards are duplicative of the'NRC regulatory program and that EPA finds the NRC program fully adequate to protect public health with an ample margin of safety.
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f tiearly, it is wasteful of governmental resources and contrary to principles of good government to compel an agency to regulate emissions already regulated adequately by a sister agency.
Agencies should be allowed to devote their resources to addressing health and safety problems that remain to be resolved, rather than wasting effort on problems that have already been satisf actorily resolved by another agency.
By spelling out that EPA need not regulate where it finds that-NRC regulation is adequate this provision of the legislation will address this unnecessa,ry duplication of responsibility.
A November 15, 1989 joint letter from EPA Assistant Administrator Rosenberg and HHS Assistant Secretary for Health and Acting Surgeon General Mason also called upon Congress to elimir. ate altogether EPA's authority to regulate radionuclide emissions since such regulation was " unnecessary and duplicative."
This letter, together with earlier NRC letters to the Congress commenting on this issue, are attached.
We thank you for the opportunity to comment on this issue.
Sincerely, ih (b~
Kenneth M. Carr Attachments:
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Honorable Que'ntin N. Burdick 1
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Chairman, committee on Environment and Public Works United states senate Washington, D.c. 20510 Dear Mr. Chairman 1
On October 31, 1989 EPA promulgated a standard for radionuelide emissions un, der section 112 of the Clean Air Act (CAA), as required undar a decision of the U.S for the District of columbia.
. Court of Appeals Ir 1 x 10'} the rule EPA established a benchmark of m For several categcries in the radionuclide rulemakings individual risks of 2 or 3 x 10** were found accepta
, maximus small population exposures and uncertainty in ris including Legislation has been introduced regarding air toxies regulatiog that would establish a rigid requirement of 1 x 10*'
or 1 x 10'.
We would like to share with you the unintended consequences that would result from such an inflexible policy If 1 x 10', EPA has been forced to use a bright line of 1 x 10 or in its recent rulamaking concerning radionuclide university laboratories which administer radioact isotopes),
at 1 x 10', at 1 x 10 the EPA standard would be 3 aren/yr, and the EPA standard would be 0.03 mram/yr.
standard was actually set at 10 mre were set, particularly the 1 x 10** a/yr.)
If these s(tandards The Institutes of Health has stated that many larger faciliti 1evel, the National i
'g forced to close their radiciodine treatment facilities.
es would I is the treatment of choice for hyperthyroidism Since not be used, surgery or drugs would be required.
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, if it could associated with these therapies would greatly exceed anJ' Fatclities theoretically predicted increase in thyroid cancer from.,'I i
the atmosphere.
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to a radionuclideIt should not be ass;::t that these kinds of costl j
rulemaking, but could be the unforthnate sesult of a bright line i
approach to air toxic ru)==aking in radionuclide rulemaking based on 10', general.
As evidenced by a
, the. desired goal.of achieving lasting health benefits could, in fact, be undermined i
by a rigid approach that debilitates the effort.
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Further, the ' Administration was advised by many facilities currently rmistad by the NRC reactors, medical facilities, a,nd the National Institutes ofincluding resea Nealth, that regulatory schemes that involve unnecessary duplication of compliance end implementation needlessly raise costs and divert resources from needed research and other activities.
This could adversely affect patient care at eene-facilities.
DOE shares our concern over the dual regulations and absolute risk standards and their potential impacts on nuclear energy commercial, and research' industries. Therefore, we believe, that the pending revisions to the clean Air Act should contain a provision to eliminate unnecessary and duplicative authority to regulate radionuclide emissions from NRC-licensed facilities.
To be consistent, DOE believes the language will be 4
needed as an amendment to the Atomic Energy Act to require that i
additional facilities, not licensed by the NRC radionuclides emissions.and non-reactor nuclear facilities), meet NRC reg i
s neerely Honorable William G. Rosenberg Assistant Administrator for Air and Radiation Environmental Protection Agency James o. Mason, MD, Dr. P.H..
M O' kO4<M.
I Assistant secretary for Health
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and Acting surgeon Genera)
Department of Health and Human services
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IDENTICAL COPIES SENT Tot i
Nonorable John D. Dingell
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Chairman, subcommittee on oversight and Investigations committee on Energy and commerce t
Nouse of Representatives Washington, D.C.
'20515 senator Max 8. Baucus i
United stetes Senate Washington, D. c. 20510 Honorable Quentin N. Burdick Chairman, ceamittee on I
Environment and Public Works United States Senate Washington, D.C. 20510 Nonorable Henry A. Waxman Chairman, Subcommittee on Health and the Environment Committee on Energy and commerce House of Representatives Washington, D.C. 20515 1
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CMamMaN November 14,1989 The Honerable John D. Dingell, Chairman Committee on Energy and Commerce Washington, DCUnited states House of Representatives 20515 Dear Mr. Chairman Regulatory Commission's (NRC)The purpose of thin lette o
e Nuclear regulatory scheme for emissions of radconcerns about the duplicative current clean Air Act and to urge you,ionuclides contained in the forward with reauthorization of this legislatias the Congress moves most serious problem by eliminating the duplicativon, to address thi regime for such emissions from facilities that are al e regulatory regulated by the NRC.
ready By way of background, when the Clean Air Act was granted the authority to rereauthorised in 1977, the Env was last a variety of different sources,gulate radionuclide emissione from ncy (EPA) facilities already regulated by the NRC including emissions from was adopted without any Congressional hearingsThis authority, wh opportunity for affected agencies to provide command without the to be wholly unnecessary from a health and view of the comprehensive NRC regulatory programsafety pers ents has proven for radionuclide emissions.
regulatory authorit Additionally, this duplicativealready in place regulatory regimes,y will, if implemented, lead to two separate one established by the NRC and one established by EPA, with the attendant costs and b for the government and the affected private s urdens -- both invariably result when two agencies are charried with ector -- that the same activity.
regulating Under th9 Ato ic Energy Act comprehensive regulatory pro, gram that regulatesthe NRC has an esta radionuclides in air and water from all faciliti emissions of the Commission.
operating nuclear power plants, uranium millsThese NRC-reg t
es licensed by universities, and thousands of nuclear medicine d j
, ma or hospitals nationwide.
regulatory scheme has been to keep public exposurThe result risk to minuscule levels.
By EPA's own calculations,e and public of radionuclidra from all NRC licensees combine the total 0.33 r emissions fatalitira per year.
s less than duplicative EPA regulation in the face of NRC'Fo acxnowledged, s
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2 November 14, 1989 regulatory pro perspective." gram is "hard to defend from any logica issue, " existing emissions from these sources are alread that the public health is already protected with an y so low of safety..."
1985).
on this point,50 Federal Register 1190, ample mattin 5191 (Febru'ry 6, position that EPA expressed.we couldn't agree more strongly with the a
Despite this lack of need for additional regulation licensed facilities, EPA has advised us that they feel of HRC-constrained by existing law to issue standards for such facilities and, accordingly, on october 31, Unfortunately, the result of this action will be a dregula regulatory scheme that is unnecessary from any public health uplicative standpoint, wasteful of public and private resources, and even potentially harmful to public health.
National Institutes of Health (NIH)
In the latter regard patients, as well as divert resources from patient ca research, and thus could cause more deaths than they pr yroid medicine consunity,Similar comments were filed by representatives and evented.
of the nuclear i
EPA regulations will lead to the unnecessary exit is al i
i onal set of resources by EPA, NRC, In its final rule, EPA acknowledged the seriousits Agreement States penditure of perhaps conflicting, concerns raised about the possible effects of duplic i
ness of the EPA noted that:
standards on NRC-licensees.
ve, and In particular, the NRC standard is generally comparable to th"Wh er difforent in form, and the means of demonstratinreq at compliance with each standard impose significantly g
different regulatory requirements."
In chert, burden of demonstrating compliance with federal rEPA's re no attendant additional protection for the public health e
safety, thereby diverting egulations, with important safety concerns. limited resources from other more.
and address this problem.For the foregoing reascns, we urge you in the st the clean Air Act offers an ideal opportunity tThe current Congression rongest terms to exclusive authority over radionuclide emissions from o resolve the facilities and activities to NRC.
y givinq C-licensed innerantly unsound as a matter of public policy and gDuplicative regulatio 4
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Noveeer 14,198!/
funds should not be wasted on parallel programs iIn a agencies for the same activity
, public n two sister protection for public health an,d safety resultsespecially when no addit scheme such a on licensees,s this will impose significant unnecessaryulatory i
A reg require the expenditure of ad burdens additional costs to consumersresources to assess and enforce i
i and interfere with proper medicalresu i
treatment for patients of some, medical license
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es.
The consission cannot emphasize too strongly th t regulatory program provides adequate protection against the current NRC a
radionuclide emissions from NRC-regulated facilities Wit i
ample margin of ~ safety.
Additional regulation of these protection of the public health and safety. facilit an i
provide no further eliminating duplicative regulation under the clea e situation by Commission strongly urges you to do so n Air Act.
The sincerely,
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Kenneth M. Carr cc:
i The Honorable Norman F. Lent I
William K. Reilly, Administrator, EPA James B. Mason, M.D., Assistant Secretary f or Health, HMS 6
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waawemeroe, o.c. aess November 14, 1989 CMalAMAN The Honorable Quentin N. Burdick, Chaihinan Committee on Environment and Public Works United States Senate Washington, DC 20510
Dear Mr. Chairman:
Regulatory Commission's (NRC)The purpose of this letter is to share concerns about the duplicative regulatory scheme for emissions of radionuclides contained in the current clean Air Act and to urge you, as the Congress moves forward with reauthorization of this legislation most serious problem by eliminating the duplicative regulatory to address this regime for such emissions from facilities that are already
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regulated by the NRC.
By way of background, when the Clean Air Act was last was granted the authority to regulate radionuclide emis a variety of different sources, including emissions from s from facilities already regulated by the NRC.
opportunity for affected agencies to provide commentswa e
to be wholly unnecessary from k health and safety
, has proven view of the comprehensive NRC regulatory program already in pl perspective, in for radionuclide emissions.
regulatory authority will, if implemented, Additionally, this duplicative ace regulatory regimes, one established by the NRC and onelead to two separate established by EPA, with the attendant costs and burdens for the government and the affected private sector
-- both invariably result when two agencias are charged with r
-- that the same activity.
egulating Under the Atomic Energy Act, I
the NRC has-an established and comprehensive regulatory program that regulates emissions of radienuclides in air and water from all facilities licensed by the Commission.
These NRC-regulated facilities include over 100 operating nuclear power plants, uranium mills, major universities, and thousands of nuclear medicine departments i i
hospitals nationwide.
The result of this ccaprehensive n
regulatory scheme has been to keep public exposure and public risk to minuscule levels.
By EPA's own calculations, of radionuclides from all NRC licensees combined is the total s
0.33 fatalities per year.
acknowledged, duplicative EPA regulation in the face of URC'sFor.th U
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regulatory pro perspective." gram is "hard to defend from any logical or policy Indeed, as EPA indicated in pr issue, " existing emissions from these sources!or comments on th:,s that the public health is already protected with anare already so low of safety.
50 Federal Register 5190 ample margin 1985).
position that EPA expressed.On this point, we couldn't agree mo,re strongly w 5191 (February 6, e
licensed facilities, EPA has advised us that they feelD constrained by existing law to issue standards for such facilities and, accordingly, on October 31, 1989, regulations for radionuclide emissions from such facilitiesEPA promulgate Unfortunately, the result of this action will be a du li regulatory scheme that is unnecessary from any public health p
cative standpoint, wasteful of public and private resources, and even potentially harmful to public health.
National Institutes of Health (NIH)
In the latter regard advised EPA that these, the patients, as well as divert resources from patient care o
research, and thus could cause more deaths than they prevented Similar comments were filed by representatives of th medicine community.
e nuclear It is also evident that compliance with this additi EPA regulations will lead to the unnecessary expendit onal set of resources by EPA, NRC, i
EPA acknowledged the seriousness of theits Agr ure of In its fit.a1 rule, concerns raised about the possible effects of du perhaps conflicting, standards on NRC-licensees.plicative, EPA noted that:
and In particular, "While the level of health protection achieved the NRC standard is generally comparable to that under different in form, and the means of demon:tratingre ecmpliance with each standard impose significantly different regulatory requirements."
In short, burden of demonstrating compliance with federal reEPA's reg safety, thereby diverting limited resources from other m gulations, with i
important safety concerns.
1 address this problem.For the foregoing reasons, we urge you in the stron the Clean Air Act offers an ideal opportunity toThe current Congressiona gest terms to exclusive authority over radionuclide emissions - fro resolve the facilities and activities to NRC.
ng sed inherently uncound as 1 Duplicative regulation is
.atter Of public policy and good
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funds should not be wasted on parallel programs in tw agencies for the'same activity, especially when no additional er protection for public health and safety results.
on licensees, require the expenditure of addition A reg burdens
'i additional costs to consumers, and interfere with
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treatment for patients of some medical licensees The Commission cannot emphasise too strongly that the cur regulatory progran provides adequate protection against rent NRC radionuclide emissions from NRC-regulated facilities with an ample margin of safety.
Additional regulation of these facilities by EPA under the clean Air Act will provida n protection of the public health and safety.
l o further eliminating duplicative regulation under the clean A The Congress now has Co:tmission strongly urges you to do so.
The Sincerely,
--1%.h Kenneth M. Carr cc:
The Honorable John H. Chafee William K.
t Reilly, Administrator, EPA James B. Mason, M.D., Assistant Secretary for Health, NHS l
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