Re: Agreement State - NRC relationship

["Spell, Bill" <bills@deq.state.la.us>]

Thanks, Rita.  I can find absolutely nothing with which to take issue.  I 
believe you have put the question in proper perspective, as usual.  Those 
who were not aware of this will, perhaps, take another look at the question. 
 Certainly Uncle Sam (translated "NRC, GAO, the President, and members of 
Congress") should.

Bill Spell
bills@deq.state.la.us

Only my opinion (but I think it's shared by others).
 ----------
From: radsafe
To: Multiple recipients of list
Subject: Re: Agreement State - NRC relationship
Date: Wednesday, December 04, 1996 12:27PM


To all Radsafe:

When considering the future of the relationship between NRC and Agreement
States, the following points should be borne in mind:

1.   The only tangible support (i.e. monetary) that NRC has ever provided
Agreement States was funding for training of state personnel. NRC has 
already
discontinued this funding as of  October 1, 1996. In all other respects the
States have always fully funded their own regulatory programs from licensee
fees
and taxpayer monies.

2.   The regulation of AEA materials makes up only 25% or less of Agreement
State Rad Health Programs.  The States independently regulate NARM and
machine
sources of ionizing and non-ionizing radiation, without NRC's assistance, 
and
this makes up about75% of their programs.

3.   Agreement States now regulate about 70% of all AEA materials licensees
nationwide, and will soon regulate about 80%.

4.   NRC recently estimated in its re-baselining document that if it
converted
50% of its remaining "specific" licensees to "general" licensees (no license 

document issued, no expirations or renewals and no inspections), it would
only
cut 50 NRC-positions (out of a total of 3,000).  One wonders what that would
do
to fees for the remaining "specific" licensees.

5.   The only logical objective for the Agreement States program is to 
effect
the complete transfer of regulatory authority for AEA materials back to the
States, from whence it came. (The Atomic Energy Act of 1954 usurped the
States'
traditionally held authority under the constitution to protect the health 
and
safety of their citizens.) This is in keeping with the March 4, 1995
Presidential Memorandum, "Regulatory Reinvention Initiative," which required 

federal regulators to address several specific questions.  One of these was
"whether the states or local governments could do the job, making federal
regulation unnecessary."

6.   As NRC's licensee base becomes vanishingly small, its licensees' fees
will
become horrendously large; and/or it will try to make the Agreement States
contribute to its support.  The latter would be so far at odds with the
Regulatory Reinvention Initiative as to be ludicrous (i.e., having
relinquished
authority to States, NRC converts to regulating the States instead of
licensees,
and tries to make the States pay the cost).

We believe that it is time for a reality check on how best to regulate the
use
of radioactive materials in this country in a cost effective manner.





































******All the usual disclaimers apply.  ***********

______________________________________________
Rita Aldrich                              voice: 518/457/1202
Principal Radiophysicist                  fax:     518/457-5545
NYS DOL/Radiological Health Unit
"Rad Health Unit"<raldrich@emi.com>
______________________________________________