ML19312E422
| ML19312E422 | |
| Person / Time | |
|---|---|
| Issue date: | 04/04/1980 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Forman H COMMERCE, DEPT. OF |
| References | |
| NUDOCS 8006040390 | |
| Download: ML19312E422 (2) | |
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1980 Mr. Howard I. Forman Deputy Assistant Secretary for
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U.S. Department of. Comerce -
7 Washington, D.C.
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Dear Mr. Forman:
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I have reviewed the proposed draft procedures ur implementing OMB Circular
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A-119 (Draft with change,s made to'3/26/80) and have the following comments:
I consider it important to provide these implementing procedures ~
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in a timely' manner.'.Therefore', I urge that they be published promptly for public coment and that after resolution of comments 1
1l they be adopted with as little delay as possible..
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The OMB. Circular requires that in order for voluntary standards x
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3 bodies to be listed (as a precondition to Fedecal participation) g
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Included in these due process and other criteria cf the OMB q
Circular is "that public notice of meetings and other standards; o ' '.;
.T j activities is provided in an appropriate and timely fashion; and
..m.h to invite broadly-based representation, through media which are
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designed to reach those persons reasonably expected to have an
_l interest in the subject."' Page.8 of the draft procedures fleshes u a 1
out this requirement. I believe these implcmentation instructions.
can be interpreted, as now written, to impose a comparatively '
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greater and inequitable burden.on the voluntary standards bodies
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S relative to that on the interested persons to assure that all; w;
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_ persens reasonably expected to have an interest in the subject
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If these instructions are taken literally, the procedures defined are so extensive and cover such y? ~
a broad r.ange of activity that it would be extremely time-consuming and expensive to carry them out with', I think, a return that would not be comensurate with the effort.
I would rather i
i see the procedures modified to emphasize that both the voluntary r
u standards bodies and the interested persons or groups have an obligation in this regard and that there should be initiatives on
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both sides to assure adequate notification and comunication.. For u
example, the ' voluntary standards bodies should assure that -
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notification of such meetings and other standards activities is'
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published in newsletters', trade'or professional journals', or.
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similar. publications. Similar'.y, persons or groups.that are w
likely to have an interest should take the -initiative to review such publications or contact standards bodies directly indicating -
fl areas of interest so that they can be.approp-iately apprised of r -.
/ Ql meetings and other standards activities.
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NRC Form 3188 (4-79) NRCM 0240
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Robert J. Budnitz,
Rather than propose specific additional research activities regarding these issues, we wish to point out to the research comunity, represented in the Interagency Radiation Research Comittee and to the Strategy Subcomittee identified in your memorandum, that the above mentioned regulatory policy, and the concomitant research issues could provide a basit for some of the future research strategy emphasis. The research results could be used to
' determine whether regulations should-1 include dose rate criteria; 2.
lower or raise individual annual dose limits; 3
place a restriction on collective exposure; and 4.
set a de-minimus exposure level and rate, under which radiation exposures cre not included in the annual inventory for individuals.
Although the above is not condensed in a single statement as requested in your memorandum it nevertheless identifies the regulatory policy to which NRR believes radiation exposure effects research should be addressed.
Ori fnal S%:ed by 3
H. R. De::tcn Harold R. Denton, Director Office of Nuclear Reactor Regulation cc: WJDircks VStello RBMinogue JGDavis FArsenault EJHanrahan GWKerr RCunningham KGoller LHigginbotham RAlexander Dross TMurphy RGotchy Dr. Elliott Stonehill
Contact:
W.E. Kreger DSE/SA
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, Robert J. Budnitz Although the above is not condensed in a single state nt it nevertheless identifies the regulatory issues to which NRR belk s radiation exposure effects research should be addressed.
H ld R. Denton, Director fice of Nuclear Reactor Regulation l
cc: WJD1rcks VSTello RBMinogue l
JGDavis FArsenault i
EJHanrahan I
GWKerr RCunningham KGoller LHigginbotham RAlexander Dross TMurphy RGotchy Dr. Elliott St rc.? ;ii Con act:
W.E. Kreger, DSE/SA
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