ML20198C026
| ML20198C026 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1997 |
| From: | Kane W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Weinstock L ENVIRONMENTAL PROTECTION AGENCY |
| References | |
| NUDOCS 9801070154 | |
| Download: ML20198C026 (4) | |
Text
~.
U.S Environmental Protection Agency December 31. 1997 Wr. Lawr:nce Weinstock, Acting Director Office of Radiation cnd Indoor Air (6601J) 401 M. Street, SW Washington, DC 20460 i
Dear Mr. Weinstock:
I appreciated the oppartunity, yesterday, to discuss our remaining concerns regarding the U.S.
Environmental Protection Agency's (EPA's) proposed publication of Federal Guidance Report No; 13 (FGR 13), Health Risks from Low-Level Envimnmental Exposure to Radionuclides.
- As you are aware, our agencies, along with the U.S. Department.of Energy, have cooperatively funded and worked together to develop the technical basis for FGR 13, with a goal of ensuring _
that future assessments of potential risks from radiation would be performed properly and j
consistently across the nation. In ??otember 1997, U.S. Nuclear Regulatory Commission representatives to the FGR 13 working group provided significant technical comments, as well as policy concerns, about the validity and usefulness of the document for liceneses, regulators, and the public. After a review of the December 1997 version of this document, we find that many of our technical concems have been addressed. However, as discussed, we still have concerns on three major issues: (1) the need to characterize uncertainties in the risk coefficients for cancer mortality and morbidity for lifetime exposure to radionuclides in the environment; (2) the need to verify and validate the assumptions used in calculating these risk coefficients, as well as validation of the values for the risk coefficients; and (3) the need for this document to undergo a complete review by affected members of the U.S. public, EPA's Science Advisory Board and the intemational radiation standards setting organizations. In light of these issues, as well as future efforts to characterize the uncertainties in the biokinetic models in other publications, I urge that FGR 13 be issued for public review and comment at this time.
I understand that you will consider our request for issuance of this report for public review and j
comment, rather than as a final FGR, and that your decision will likely be made in mid-January
-1998. I also understand that you will inform us of your decision a few days prior to proceeding with publication of tNs report. If you need any additbnalinformation or clarification of the issues we discussed, please contact me.- I look forward.o hearing from you in January.
>=
A Sincerely, C9 CM
[0riginal signed by:]
William F. Kane, Acting Deputy Director U5 Office of Nuclear Material Safety b'
and Safeguards I
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cc: ' See attached list t'!
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- Distribution A:\\weinstoc
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1-PDR EDO r/f MKnapp, RES VHolahan, RES e.
NMSS Central file JGreeves, DWM CTrottier, RES CWillis, NRR v b, M/
O' IMNS Central file CPoland, NMSS DCool, IMNS MCallahan, OCA h
. CCameron, OGC g.3 To voceive a copy of this document. Indicato in the box: *C" = Copy without enclosures "E" = Oopy with enclosures *N= No copy OFFICE NMSS lE Tech Ed lN NMSfff/
lE NAME-CGJones EKraus W83E lll ll DATE 12/30/97 12/30/97-12/Jl/97 OFFICIAL RECORD COPY 9901070154 971231 PDR ORQ EUSEPA FDR
~
December 31,1997 U.S. Environmental Protection Agency Mr. Lawrence Weinstock, Acting Director, Office of Radiation and Indoor Air (6601J) 401 M. Street, S.W.
Washington, D.C. 20460
Dear Mr. Weinstock:
I appreciated the opportunity, yesterday, to discuss our remaining concerns regarding the U.S.
Environmental Protection Agency's (EPA's) proposed publication of Federal Guidance Report No.13 (FGR 13), Health Risks from Low-Level Environmental Exposure to Radionuclides.
As you are aware, our agencies, along with the U.S. Department of Energy, have cooperatively funded and worked together to develop the technical basis for FGR 13, with a goal of ensuring that future assessments of potential risks from radiation would be performed properly and consistently ac,oss the nation. In September 1997, U.S. Nuclear Regulatory Commission representatives to the FGR 13 working group provided significant technical comments, as well as policy concerns, about the validity and usefulness of the document for licensees, regulators, and the public. After a review of the December 1997 version of this document, we find that many of our technical concerns have been addressed. However, as discussed, we still have concems on three major issues: (1) the need to characterize uncertainties in the risk coefficients for cancer mortality end morbidity for lifetime exposure to radionuclides in the environment; (2) the need to verify and validate the assumptions used in calculating these risk coefficients, as well as validation of the values for the risk coefficients; and (3) the need for this document to undergo a complete review by EPA's Science Advisory Board and the international community, in light of these issues, as well as future efforts to characterize the uncertainties in the biokinetic models in other puDlications, I urge that FGR 13 be issued for public review and comment at this time.
I understand that you will consider our request for issuance of this report for public review and comment, rather than as a final FGR, and that you willinform us in mid-January 1998 of EPA's decision on final publication. If you need any additionalinformation or clarificahon of the issues we discussed, please let me know. I look forward to hearing from you in January.
Sincerely, William F. Kane, Acting Deputy Director Office of Nuclear Material Safety and Safeguards cc:
Mr. D. Michael Schaeffer, Department of Defense Mr. Raymond P. Berube, Department of Energy Dr, Adam Finkel, Department of Labor Mr. Alan Roberts, Department of Transportation Dr. Bruce Wachholz, Department of Health and Human Services Dr. Jill Lipoti, New Jersey Department of Environmental Protection Mr. Art Fraas, Office of Management and Budget Dr. Beverly Hartline, Office of Science and Technology Policy Djstribution A:\\weinstoc -
PDR EDO r/f MKnapp, RES VHolahan, RES NMSS Central file JGreeves. DWM CTrottier, RES CWillis, NRR IMNS Central file CPoland, NMSS DCool, IMNS MCallahan, OCA CCameron, OGC To receive a copy of this doca.t Indicate in the box: "C" = Copy without enclosures
EKrauV/ M WKane l
DATE 12/30/97' 12/30/97
- 12/ /97 OFFICIAL RECORD COPY
. -. - ~
Attache 2 List for 12/31/97 Letter to L. Weinstock. US EPA
'U.S. Environmental Protection Agency-TEL (202) 260-7400 -.
- Mr. Richard D. Wilson, FAX: (202) 260-5155
= Acting Assistant Administrator for Air and Radiation
- 401 M. Street, SW 3
935 West Tower (M6101)
Washington, DC 20460 Mr. D. Michael Schaeffer, Chairman 703-325-2407
- Department of Defense-fax - 2951 Radiation Research and Policy Working Group Defense SpecialWeapons Agency 6801 Telegraph Road Alexandria, VA 22310 3398 Mr. Raymono P Berube, Deputy Assistant Secretary 202-586-5680' for Environmant fax - 2268 U.S. Departr,1ent of Energy Washington, DC 20585 Dr. Adam Finkel, Director Health Standards Programs, N-3718
. Occupational Safety and Health Administration 200 Constitution Avenue, NW Washington, DC 20210 Mr. Alan Roberts 202-366-4469 Associate Administrator for Hazardous Materials Safety fax - 5713 Departnnot of Transportation, Room 8422 400 Seventh Street, SW Washington, DC 20590 Dr. Bruce Wachholz, Chief 301-496-9326
- Radiation Effects Branch fax - 1224 National Cancer Institute Executive Plaza North, Suite 530 Bethesda, MD: 20892 --
Mr. Art Fraas 202-395-3087 Office of Management and Budget.
fax - 7285 -
Room 10202 New Executive Office Building-Washington, DO 20503 4
_g l;j J. l s'
q Attached CC List.
'2 Dr. Beverly Hartline (contact):
202-456-6128 Of6ce of Science and Technology Policy fax - 6027 --
l 17th & Pennsylvania Avenue,'NWx BHARTLINE@ostp.oop gov
-1
- Washington, DC '20500 J Dr. Jill Lipoti, Assistant Director :
609-984-5636 for Radiation Protection Programs '
fax - 7513 i
' Division of Environrnental Safety, Health.
JLipoti@dep. state.nj.us
.l
- and Analytical Programs i j
- Department of Environmental Protection.
CN 415
= Trenton, NJ 08625-0415:
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