ML20217B147
| ML20217B147 | |
| Person / Time | |
|---|---|
| Issue date: | 04/15/1998 |
| From: | Thompson H NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Wilson R ENVIRONMENTAL PROTECTION AGENCY |
| Shared Package | |
| ML20217B094 | List: |
| References | |
| NUDOCS 9804220432 | |
| Download: ML20217B147 (3) | |
Text
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April 15, 1998 Mr. Richard Wilson Acting Assistant Administrator for Air and Radiation U.S. Environmental Protection Agency 401 M. Street, S.W.
935 West Tower (M6101)
Washington, DC 20460
Dear Mr. Wilson:
I am responding to your letter of March 10,1998, regarding the Environmental Protection Agency's (EPA's) Federal Guidance Report No.13, Health Risks from Low-Leve/ Environmental Exposure h Radionuclides (FGR-13).
We are encouraged that EPA considered two of the Nuclear Regulatory Commission's (NRC's) recommendations to forward FGR 13 to EPA's Science Advisory Board (SAB) for a formal -
review, as well as to issue it for public review and comment. However, at the public meeting of EPA's SAB Radiation Advisory Committee (RAC) on March 3,1998, where the RAC received a briefing on FGR 13 from EPA staff, it became apparent that the RAC was not aware of NRC's letters to you dated February 4 and 6,1998, which raised NRC's technical concems with FGR
- 13. After this briefing, one of the RAC members asked if NRC had concems with FGR 13. After learning that NRC dici, the RAC Chairman asked the NRC staff member in attendance to briefly summarize NRC's concems.
At the conclusion of NRC's briefing, the RAC Chairman indicated that when its next meeting on FGR 13 is held on May 7-81998, the RAC's Federal Guidance Review Subcommittee would appreciate a more detailed NRC briefing about NRC's specific technical concems with FGR 13.
Consequently, plaase note the enclosed letter that is being sent concurrently to Dr. St. phen Brown, RAC Chair, confirming NRC's offer to brief the RAC Subcommittee as the members discuss the technical merits of FGR 13.
NRC continues to believe that reviewers should have the benefit of understanding the range of scientific viewpoints and issues which constitute the apparent differences of opinion. I am disappointed that you have decided not to provide copies of our concems along with copies of interim FG713 or the FederalReaister Notice of Interim FGR 13 availability which was issued on April 13,1098. This request was not made as a public commentor, but as one of the Agency's sponsoring this work. My preference would have been to have our views incorporated as an integral part of the document that was issued for public comment. I accept your offer to provide a copy of your mailing list and have asked my staff to obtain one promptly. We again request that our technical and policy concems be included on EPA's web site, which you have already agreed to do in your March 10,1998, letter.
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F 2-I trust that we can mutually resolve concerns regarding this jointly sponsored document and request that we use the Interagency Steering Committee on Radiation Standards to coordinate and address any significant public comments that are received on this report. In the event that the ISCORS effort to resolve comments on this interagency document is not successful, I suggest that we meet before final publication to discuss how differing views should be documented and the potential use of the document by NRC and Agreement State licensees.
I Please let me know if you are agreeable with this approach.
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l Sincerely, f
Hug i T ompson r.
D y Executive irect r for Regulatory Progra l
Enclosure:
As stated l
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- Attac ed ec List for Aoril 15.1998 Letter to Wilson US EPA Mr. Ltwrence Wsinstock, Acting Director 2024564 9320 :
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U.S. Environmental Protection Agency fax 565-2043 Offica of Radiation and Indoor Air (6601J) 401 M. Street, SW WIshington, DC 20460 Mr. D. Michael Schaeffer, Chairman 703-325-2407 DepIrtment of Defense fax - 2951 Radttion Research and Policy Working Group Defense SpecialWeapons Agency 6801 Telegraph Road Alexandria, VA 22310-3398 Mr. Raymond P. Berube, Deputy Assistant Secretary 202-586-5680 for Environment fax 2268 U.S. Department W Energy Washington, DC 20585 Dr. Adam Finkel, Director 202-219-7075 Health Standards Programs, N-3718 fax - 7125 Occupational Safety and Health Adminisisation 200 Constitution Avenue, NW Washington, DC 20210 202-366-44 Mr. A'an Roberts Asse:iate Administrator for Hazardous Materials Safety fax - 5713 Department of Transportation, Room 8422 400 Seventh Street, SW Wshington, DC 20590 Dr. Bruce Wachholz, Chief 301-496-9326' R diation Effects Branch fax - 1224 N tionalCancerInstitute l
Executive Plaza North, Suite 530 f
Bethesda,MD 20892 i
Mr. Art Fraas 202-395-3087 I Office of Management and Budget fax - 7285 Room 10202 New Executive Office Building Washington,DC 20503 Dr. Beverty Hartline (contact) 202-456-61 Office of Soonce and Technology Policy fax - 6027 (
17th & Pennsylvania Avenue, NW BHARTLINE@ostp.eop. gov Washington, DC 20500 Dr. Jill Lipoti, Assistant Director 609-984 5636 for Radiation Protection Programs fax - 7513 !
Division of Environmental Safety Health JLipoti@dep. state.nj.us j and Analytical Programs
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,o April 15, 1998 Dr. Stephen L. Brown, Chair Radiation Advisory Committee of the EPA Science Advisory Board R2C2 Risks of Radiation and Chemical Compounds 4700 Grass Valley Road Oakland, CA 94605
Dear Dr. Brown:
I am responding to your request to Cynthia G. Jones, of my staff, during the March 3,1998, Environmental Protection Agency (EPA) Science Advisory Board's (SAB's) Radiation Advisory Committee (RAC) public meeting. Specifically, the RAC wished to learn more about the U.S.
Nuclear Regulatory Commission's (NRC's) concern 1 regarding EPA Federal Guidance Report No.13, Health Risks from Low-LevelEnvironment v Exposure to Radionuclides (FGR-13). At that meeting, you indicated that when the next RAC meeting is held on May 7-81998, the RAC would appreciate a more detailed briefing from NRC on its specific technical concerns with this report. NRC is pleased to accept your offer to participate, at your next meeting, to brief the RAC as the members discuss the technical merits of FGR 13.
We are encouraged that EPA censidered two of the NRC's recommendations - to forward FGR 13 to the RAC for a formal review, and to issue it for public review and comment. NRC continues to believe that scientific reviewers should have the benefit of understanding the range of viewpoints and issues which constitute the apparent differences of opinion. In this regard, we are enclosing copies of our previous correspondence to EPA cn this subject, dated February 4 and 6,1998, in the hopes that this information will assist the RAC's Federal Guidance Review Subcommittee in its deliberations on this issue.
We hope that there will be a niutual resolution of coricems regarding this jointly funded and sponsored document and recommend that the interagency Steering Committee on Radiation Standards be used to coordinate and address comments that are received by the end of June 1998. Please contact Cynthia G. Jones, of my staff, at 301-415-7853, or e-mail i
cgj@nrc. gov, to coordinate our attendance at the May 1998 meeting.
I Sincer ly, f//f 1 u
L. Thomps, Jr.
uty Executiv Dire r
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for Regulatory Programs
Enclosures:
As stated I
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Attached cc List for Aoni 15.1998 Letter to Brown. Cnarr. EPA HAC Dr. Donald G. Barnes, Director Sci:nce Advisory Board (1400),
U.S. EPA 401 M Street, S.W.,1400 Washington, D.C. 20460 Dr. K. Jack Kooyoomjian, Designated Federal Official for the Radiation Advisory Committee Science Advisory Board (1400),
U.S. EPA 401 M Street, S.W.,1400 Washington, D.C. 20460 i
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- I Richard D. Wilson Acting Assistant Administrator for Air and Radiation U.S. Environmental Protection Agency 401 M. Street, S.W.
935 West Tower (M6101)
Washington, D.C. 20460
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Dear Mr. Wilson:
On January 20,1998. Mr. William Kane, ncting Deputy Cirector of our O staff informing us that the U.S. Environmental P e of Nuclear Material e
e nstock of your Guldance Report No. \\3 (FGR 13), Health Risks from Low-LevelEnviro ssue Federal Radionuclides, forinterim use and comment. On January 21 1998 nmentalExposure to Director, NMSS, informed Mr. Weinstock in a letter that we supported th Dr Ca l Paperiello, r
23,1998, Dr. Paperiello informed Mr. Weinstock that upon further cons forthcoming. As a result, we request that this do on and discussion er would be comment rather than as an interim use and comment document. We i
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forward NRC's major technical concerns, in the enclosure to this letter e ocument comments for extemal distribution as part of the dr s draft publication ese the enclosure to this letter.
comment in NRC looks forward to assisting EPA in reviewing end resolving any com
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FGR 13 during the comment period. We appreciate the opportunity to w ments received on ir,1portant document, and look forward to future meetings of the FGR 1 or with you on this mechanism to conduct this activity.
or ng Group as the If we can be of further assistance in this regard, please let me know Sincerely, 4
H g L. Thompson, r.
D ty Executive irec for Regulatory Programs
Enclosure:
Tcchnical and Policy issues Concerning Federal Guidance Report No.13 cc: See attache fd py
e' Attached cc List for 2/4/98 Letter to Richard W'ison, U.S. EPA Mr. D. Micnael Schaeffer, Chairman
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Department of Defense 703-325-2407 fax - 2951 Radiation Research and Policy Working Group Defense Special Weapons Agency 6801 Telegraph Road Alexandria, VA 22310-3398 Mr. Raymond P. Berubes Deputy Assistant Secretary 202-586-5680 for Environment fax - 2268 U.S. Department of Energy Washington, DC 20585 Dr. Adam Finkel", Director Health Standards Programs, N-3718 I
Occupational Safety and Health Administration 200 Constitution Avenue, NW
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Washington, C3 20210 Mr. Alan Roberts 202-366-4469 Associate Administrator for Hazardous Materials Safety fax - 5713 i
Department 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 l
Office of Management and Budget fax - 7 85 i
i Room 10102 New Executive Office Building Washington, DC 20503
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Dr. Beverly Hartline (contact) 202-456-6128 Office of Science and Technology Policy fax - 6027
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17th & Pennsylvania Avenue, NW BHARTLINERostp.eop. gov Washington, DC, 20500 Dr. Jill Upoti, Assistant Director 609-984-5636 for Radiation Protection Programs fax - 7513 Division of Environmental Safety, Health JLipotl@dep. state.nj.us and Analytical Programs
, Department of Environmental Protection CN 415
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i'ebruary 6, 1998 Mr. Richard Wilson Acting Assistant Administrator for Air and Radiation U.S. Environmental Protection Agency 401 M. Street, S.W.
935 West Tower (M6101)
Washington, D.C. 20460
Dear Mr. Wilson:
1 In my letter to you'of February 4,1998, conceming EPA's Federal Guidance Report No.13, I
Health Ri ks from Low-Level Environmental Exposure to Radionuclides (FGR-13), i asked that the document b Issued as a draft FGR for public c,mment rather than as an interim use and comment document. I also asked that NRC's brief (2-page) statement ofits technical and policy views on the report, which was attached to my letter, accompany the document.
I have since learned that at the time EPA received my letter, it had already distributed copies to the members of the Interagency Steering Committee on Radiation Standards and had sent the document to the printer in preparation for large-scale distribution. NRC continues to believe that in this problematic area, where there are differences of opinion regarding both science and policy, readers can only benefit by seeing a range of viewpoints and issues. We therefore request that NRC's statement on the technical and policy issues concerned be forwarded to the printer for inclusion as an appendix to FGR-13 or, failing this, that a copy of the NRC's
. statement be provided to anyone who is sent a copy of FGR-13 for comment. The statement should also be included in the Federal Reaister Notice and any other public notification plans that EPA has for FGR-13. As a co-sponsor of this effort, we renew our request that FGR-13 be issued only for comment and not for interim use. Because of the technical and policy differences that exists, no radic, logical standard setting use should occur until pu'olic comments have been received and evaluated.
Again, we look forward to working with you on this issue. If EPA sees any problem with the above request, please do not hesitate to call me directly, at 301-415-1713.
Sincerely, g L.Thompso Jr.
D ty Executive irec r i
for Regulatory Programs l
cc: See attached list l
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' Attached cc List for 02/06/98 Letter to Wilson US EPA Mr. D. Michael Schaeffer, Chairman 703-325-2407 l
Department of Defense fax - 2951 Radiation Research and Policy Working Group Defense SpecialWeapons Agency 6801 Telegraph Road Alexandria, VA 22310-3398 I
Mr. Raymond P. Berube, Deputy Assistant Secretary 202-586-5680 for Erivironment fax - 2268 U.S. Department of Energy Washington, DC 20585 Dr. Adam.Finkel, Director 202-219 7075 Health Standards Programs, N-3718 fax - 7125 Occupational Safety and Health Administration 200 Constitution Avenue, NW Washington,l'C 20210 l
i Mr. Alan Roberts 202-366-4469 Associate Administrator for Hazardous Materials Safety fax - 5713 Department of1ransportation, Room 8422 400 Seventh Street, SW l
W.'shington, DC 20590 l
Dr. Bruce Wachholz, Chief 301-496-9326
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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 l
Washington, DC 20503 1
Dr. Beverly Hartline (contact) 202-456-6128 Office of Science and Technology Policy fax - 6027 17th & Pennsylvania Avenue, NW BHARTLINE@ostp.eop. gov Washington, DC 20500 Dr. Jill Lipoti, Assistant Director 609-984-5636 for Radiation Protection Programs fax - 7513 Division of Environmental Safety, Health JLipoti@dep. state.nj.us and Analytical Programs Department of Environmental Protection ON 415 Trenton, NJ 08625-0415
.