sharing and monitoring of the general public health and safety be enhanced. In the end, the committee elected not to endorse Alternative C.

Alternative E is similar to Alternative D, But in addition provides for the exercise of limited federal authority, through the licensing of user sites and users, if a state chooses not to expand its radiation control program to include byproducts. This is the primary difference between these two alternatives. The committee's concern about Alternative E focused on the delegation of federal regulatory authority for what is likely to be a minority of states. Federal regulation of states without a program for byproducts also calls into question what minimum level of regulation would be required and the need to establish minimum standards. In effect, this alternative could replicate the existing NRC Agreement State program with potentially all the peculiar funding characteristics and practical drawbacks that are now apparent in the NRC approach. Thus, the committee arrived at its preferred choice: Alternative D.

Alternative D: The Preferred Alternative

Alternative D modifies state regulation (Alternative C) by adding a federal agency with two key roles: (1) it would be responsible for working in conjunction with the CRCPD and other professional organizations to provide voluntary guidelines and model regulations for states, and (2) it would assume a leadership role for the regulated community.

Although, under Alternative D, states cannot be compelled to accept the voluntary guidelines or SSRCR, a variety of forces can greatly influence them to do so. For example, the committee envisions a collaborative effort of the proposed federal agency, the states, the CRCPD, and other professional organizations not unlike the process utilized in developing the mammography regulations that involved the FDA, the American College of Radiology, and other professional organizations. This would facilitate an interactive process, allowing an exchange of ideas, so that controversies might be resolved before implementation. Respect for and investment in the process would foster a keen vested interest in successful implementation on the part of all participants.

Other reasons exist for states to adopt voluntary guidelines and the SSRCR. Professional peer pressure, from the people within each state who are involved in developing the SSRCR, would exert substantial influence to make the process work. Consumer groups and the media, seeking to ensure that the citizenry is protected, would also exert pressure. State medical societies would also want regulatory oversight to prevent unskilled users of radiation from embarrassing the medical profession by their questionable practices.

Finally, corporate pressure from manufacturers in a state that does not have a program cannot be underestimated. Alternative D would mean that, for facilities in any state to use byproduct materials, that state would have to establish a regulatory program that includes reactor-generated byproduct material. The NRC



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