Re: Senate Bill 1043

[BLHamrick@AOL.COM]

In a message dated 7/11/2003 5:51:21 AM Pacific Standard Time, 

csmarcus@ucla.edu writes:



> There is no regulatory void to fill.  Materials programs were meant to be 

> state functions in the Atomic Energy Act.  The states are doing fine 

> regulating NARM---do you think we need NRC or EPA for this? 



The EPA's reach extends to those things not regulated under the AEA.  They 

delegate programs to the States, as in California where many functions under 

RCRA fall to DTSC, and under the CWA to our Waterboards, or under the CAA to the 

Air Quality Management Districts.  The California Department of Health 

Services (DHS) has traditionally had control over all sources of ionizing radiation 

including NORM/NARM (and DHS is given statutory authority over them under state 

law), but, as many of us are well aware, that could change at the drop of a 

bill, and that is not the standard in all Agreement States.  



Under the scenario where NRC did undertake the control of NORM/NARM, nothing 

would really change in California, since DHS regulates them under the same 

laws as byproduct material, etc. anyway.  The most significant changes would be 

in NRC states, or in Agreement States at federal facilities (e.g., the VA 

Hospitals), or in Agreement States.



And, now, it's time for a simple reminder:  I am writing from my own personal 

email address, with my own personal opinion on matters, expressed as a 

private citizen, and which does not in any way purport to represent the views of the 

agency for which I work.



Barbara