ML20203J486

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Provides Status of Radiation Monitoring Cooperative Agreement NRC-28-83-609 Contract W/Nrc.Commission Accepted Recommendation to Sunset Independent Radiation Monitoring Program Contracts
ML20203J486
Person / Time
Issue date: 01/09/1998
From: Chris Miller
NRC (Affiliation Not Assigned)
To: Shepardwilson
NEW JERSEY, STATE OF
Shared Package
ML20203G669 List:
References
CON-NRC-28-83-609 NUDOCS 9803040163
Download: ML20203J486 (1)


Text

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UNITED S*.*ATES c

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January 9, 1998 Ms. Carol Shepard Wilson New Jersey Bureau of Radiation Protection Department of Environmental and Energy Bureau of Nuclear Engineering CN-415 Trenton, New Jersey 08625-0415

SUBJECT:

RADIATION MONITORING COOPERATIVE AGREEMENT NRC-28-83 609

Dear Ms. Shepard Wilson:

This letter is to provide you with the status of the subject contract with the U.S. Nuclear Regulatory Commission (NRC). The Commission recently accepted a staff recommendation to sunset the independent radiation monitoring program (IRMP) contracts. However, with the reduction in appropriations by Congress for this fiscal year, the Commission accelerated the closeout of the program to December 31,1997. In recognition that an abrupt termination could result in a potential hardshlp, the Commission authorized a short term (no more than six months) extension to ensure an orderiy closeout. An amendment to the contract is being prepared and should be sent to you in February 1998. The amendment will also address the disposition of materials supplied to you by the NRC or procured on behalf of the NRC under this contract.

For your information, we plan to inform licensees monitored under this program that the radiological environmental monitoring still required by the NRC may be performed under an agreement with a State agency. This action will ensure that licensees are aware of the options available to pe-form this work.

The NRC recognizes she high quality of work performed by your agency on this program over the years and looks forward to maintaining a good professional working relationship on items of mutual interest in 'he future, in closing, we encourage your agency to review its accounting records and send an invoice for any outstanding money owed so that we may proceed with an expeditious reconcillation. lf you have any question on this matter, please call Mr. Stephen Klementowicz of my staff at 301-415-1084.

Sincerely, cM. f.&

Charles L Miller, Chief Emergency Preparedness and Radiation Protection Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation l

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October 2,1997 Dr. Shirley Jackson, Chairman Nuclear Regulatory Commission Washington, D.C. 20555

Dear Chairman Jackson:

I am writing to express my deep concem with the proposed budget cut to eliminate funding for the NRC Cooperative Agrecsmnt Program eliminating the environmental radiological verification i

monitoring program, as well as the direct radiation monitoring network. In New Jersey, under Cooperative Agreement No. NRC.28 83-609 we were the recipient of about $53,000 annually for the purpose ofproviding independent analyses ofenvironmental samples taken around Oyster Creek, Salem /liope Creek, and E.R. Squibb sites. These samples included air, water, milk, fish, food producta, sediment, and thermoluminescent detectors. We have been performing these analyses for the past 16 years.

While I understand that Congress has cut the Nuclear Regulatory Commission's budget unexpectedly, and you are looking at ways to preserve your core staff, I think there are excellent scienti6c and policy reasons to continue the environmental monitoring program. Oyster Creek is one c

of the many nuclear power plants considering decommissioning. For the federal government to terminate an existing environmental program at a time when increased environmental awareness is necessary is not only short sighted but insensitive to public health concerns.

During decommisisoning, the public will be looking to the state to assure them that adjacent properties are not affected.

The cessation of the thermoluminescent detector monitoring program in addition to the l

nvironmental monitoring program is puzzling. The state of New Jersey participates in both the direct monitoring network (TLD) and environmental monitoring program. Consideration should be given to expansion of the direct monitoring network to enhance the data that will now be missing iom the environrnental monitoring program.

Recently, at the state level, our budget has been so severely constrained that we have had to

.crutinize each task we perform, asking ourselves whether it is cost effective in the protection of sublic health and safety. We had concluded that radiological laboratory services were available in he private sector at a significant cost savings over the continued support of the state radiological aboratory. We sue.cnfully changed over to an outside contractor at the close of our fiscal year, NcOr=cy u an v ro e manary i,,,,,,

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June 30,1995. We could have reduced our environmental program, but choose the correct course by building in efficiencies, saving dollars while maintaining a quality environmental surveillance I

program.

Your staff called me to ask what New Jersey would do if funding were cut off abruptly. They were particularly interested in whether we would have to lay someone off. We will not have general layoffs this year, However, we will have to rearrange our operating budget. We are considering l

taking a smaller number of samples, adjusting the frequency of sampling, and other scientifically I

responsible options to deal with the fiscal situation. We are also conaldering decreasing our support for the ingestion pathway exercise, to ameliorate some of the effects.

It is interesting to note that you base your decision on elimin.ng the environmental monitoring program due to the excellent record maintained by licensed facilities in controlling the release of radiological effluents into the environment within regulatory limits, Perhaps you should be concemed that by cutting your surveillance, you are sending a message that the licensees can also decrease their vigilance, in conclusion, I recommend that the NRC reconsider its proposed elimination of the environmental surveillance program. Although the NRC could realize a $1.2 million savings this year, and that is in of the Congressional budget cut, the potential harm to the environment and public health if an unmonitored release occurs could incur much greater cost. Within the NRC there needs to be a conscience that creatively addresses economic issues through efficencies yet maintains the quality of work to protect our public's health and their trust.

Sincerely,

'h ill Lipoti, Ph.D.

Assistant Director.

c: Hubert J. Miller, Regional Administrator Richard L Bangert, Office of State Programs

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Conference of Radiation Control Program Directors, Inc.

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no (502) 227-4543. Fox (502) 227 7862 October 3.1997 Dr. Shirley Jackson, Chairman Nuclear Regulatory Commission Washington, D.C. 20555

Dear Chairman Jackson:

On behalf of the Board of Directors of the Conference of Radiation Control Program Directors, I am writing to express our deep concern with the proposed budget cut to eliminate funding for the NRC Cooperative Agreement Program eliminating the environmental radiological verification monitoring program, as well as the direct radiation monitoring network.

The Independent hieasurements (thi) Program provides the ONLY physical oversight and l

verification of NRC licensee environmental measurements. NRC ollicials have acknowledged, through the Systematic Analysis of Licensee Perfomtance (SALP) process, that state environmental measurements performed under the lhi Program are integral to NRC's inspection program regarding nuclear power plant licensee environmental programs. Without the physical oversight provided through the lhi program, NRC would have no means by which to assess the accuracy oflicensee environmental monitoring activities. nor would NRC ha e any basis to determine whether or not the licensee has reached proper conclusions regarding the environmental impacts ofits operations.

As part of the lhi Scope of Work, NRC requires the state to compare its environmental data with data obtained by the utility through its environmental monitoring program. Absent this requirement, it is doubtful that state environmental agencies would have routine access to licensee environmental measuremems, except as provided to NRC in licensee environmental reports.

While we understand that Congress has cut tlie Nuclear Regulatory Commission's budget unexpectedly, and you are h>oking at ways to preserve your core stafT, I think there are excellent scientific and policy reasons to continue the environmental monitoring program, hiany nuclear power plants are considering decommissioning. For the federal govemment to temlinate an existing environmental program at a time when irecreased environmental awareness is necessary is not only short sighted but insensitive to public health concerns. During decommissioning, the public will be looking to the state to assure them that adjacent properties are not affected.

The cessation of the thermoluminesecat detector monitoring program in additier. to the environmental monitoring prograin is puuling. Consideration should be given to expansion of the direct monitoring network to enhance the data that will now be missing from the environmental monitoring program.

A Partnership Dedicated to Radiation Protection

-VH6T8OO &

Jackson, Page 2 It is interesting to note that you base your decision on eliminating the environmental monitoring program due to the excellent record maintained by licensed facilities in controlling the release of radiological emuents into the environment within regulatory limits. Perhaps you should be concemed that by cutting your surveillance, you are sending a message that the licensees can also decrease their vigilance.

In conclusion, we recommend that the NRC reconsider its proposed elimination of the environmental surveillance program. Although the NRC could reallie a $1.2 million savings this year, and that is 1/7 of the Congressional budget cut, the potential harm to the environment and public health if an unmonitored release occurs could incur much greater cost. Within the NRC there needs to be a conscience that creatively addresses economic issues through emciencies yet maintains the quality of work to protect our public's health and their trust.

Sincerely, kY Jill Lipoti, Ph.D.

Chairperson, CRCPD cc:

lloard of Directors Richard L llangert, Of6ce of State Programs 4