Re: EPA & NRC

[Andy Hull <hull@mail.sep.bnl.gov>]

Daniel et al,
At the time of Reorganization Plan No. 3, along with Laurie Tailor end
others,  decried the abolition of the Federal Radiation Council and the
concomitant absence of an overall impartial scientifically informed entity
to propound Federal radiation standards.  Without necessarily putting down
the EPA, it seemed to me then that they were put into  conflict of interest
roles as the propounder of Federal radiation standards on one hand and of
regulators utilizing them on the other hand. In my view, one
counter-productive consequences for reasonable radiation regulation has
been a rivalry between it and the NRC to see who could set the lowest (most
protective in the public perception) limits for the exposure of the public
from anthropogenic caused radiations and/or radioactivity.  I suggest that
the Draft FGR 13 is the most recent manifestation of EPA's overzealous
measures to protect us all from questionable risks.


At 10:18 PM 3/20/98 -0600, Daniel F. Kane wrote:
>Rodger: 
>
>The EPA, not the NRC, has the responsibility to advise the President with
>respect to all radiation matters, directly or indirectly affecting health,
>including guidance for all Federal Agencies in the formulation of radiation
>standards and in the establishment and execution of programs of cooperations
>with the States. This authority stems from Executive Order 10831; the Atomic
>Energy Act of 1954 as Amended; and Reorganization Plan No. 3 of 1970. The
>EPA provides guidance for all sources of radiation exposure, interacts and
>in some cases provides standards for the NRC, DOE, NASA, DOD, Interior, HHS
>to name a few. All of these agencies (and others) get involved in the
>"radiation business" at some level.
>
>"The purpose of EPA guidance is to provide a common framework to help ensure
>that the regulation of exposure to ionizing radiation is carried out by all
>Federal Agencies in a consistent and adequately protective manner. The
>details it seems, are left to the agency but the EPA guidance is the basic,
>minimum requirements. The guidance has historically consisted of both
>qualitative and quanitiative reccomendations expressed as Federal Radiaton
>Protection Guides." EPA commentary, not mine.
>
>There was not battle to be won or lost, rather the EPA continues in the same
>role it always has had, as the refrences below show.
>
>Journal of Nuclear Medicine Technology, Vol.24, No.1, March, 1996 and the
>Federal Register, Volume 59, No. 246 page 66414 and 66415.
>
>Daniel F. Kane
>dankane@mindspring.com
>Associates in Medical Physics, LLC
>
>www.medphysics.com
>(770) 980 - 0714
>FAX (770) 980 - 1278
>
>
>