ML20217Q361
| ML20217Q361 | |
| Person / Time | |
|---|---|
| Issue date: | 04/22/1998 |
| From: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | GENERAL, OHIO, STATE OF, OKLAHOMA, STATE OF, PENNSYLVANIA, COMMONWEALTH OF |
| References | |
| SP-98-033, SP-98-33, NUDOCS 9805080068 | |
| Download: ML20217Q361 (10) | |
Text
a ALL AGREEMENT STATES APR 2 21998 OHIO, OKLAHOMA, PENNSYLVANIA TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-98-033)
Your attention is invited to the enclosed correspondence which contains:
INCIDENT AND EVENT INFORMATION.......
PROGRAM MANAGEMENT INFORMATION...
TRAINING COURSE INFORMATION.....
TECHNICAL INFORMATION......
..XX FEDERAL GUIDANCE REPORT NO.13, " HEALTH RISKS FROM LOW-LEVEL ENVIRONMENTAL EXPOSURE TO RADIONUCLIDES
- OTHER INFORMATION..
Supplementary information: This is to inform you that the U.S. Environmental Protection Agency (EPA) has issued Federal Guidance Report No.13 (FGR 13), Health Risks from Low-Level Environmental Exposure to Radionuclides, as an interim document with a request for comments. A copy of the preface of this report is enclosed (Enclosure 1) for your reference.
The complete report can be obtained on the Internet (www. epa.goviradiation/ federal) or by phone (1-800-490-9198).
Enclosures 2,3,4 and 5 are exchanges of correspondence between NRC and EPA, and include NRC's major technical and policy issues concerning FGR 13. Enclosure 6 provides pa comments on FGR 13 from the Illinois Department of Nuclear Safety.
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If you have any questions about this correspondence or the NRC letters, please contact 003 Cynthia G. Jones, Senior Level Advisor for Health Physics, NMSS, at (301) 415-7853 or e-mail
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Enclosures:
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CPaperiello, NMSS DCool, NMSS A/S File DOCUMENT NAME: G:\\KPH\\ SP98033.KPH
- See previous concurrence.
Ta receive a coto of this document. Indicate in the box: "Cs Cppy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFFICE OSP OS$b NMSS l6 j OSP:D NAME KHsueh:nb //,h.
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ALL AGREEMENT STATES OHlOc OKLAHOMA, PENNSYLVANIA TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORM ION (SP-98-00 Your attention is invited to the enclosed correspondence which c tains:
I INCIDENT AND EVENT INFORMATION..........
PROGRAM MANAGEMENT INFORMATION....
TRAINING COURSE INFORMATION...............
TECHNICAL INFORMATION.............................XX DERAL GUIDANCE L
EPORT NO.13, " HEALTH RISKS ROM LOW-LEVEL l-ENVIRONMENTAL EXPOSURE TO RADIONUCLIDES" OTHER INFORMATION.................................
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Supplementary information: This is to inform you that he U.S. Environmental Protection l
Agency (EPA) has issued Federal Guidance Report o.13 (FGR 13), Health Risks from Low-Level Environmental Exposure to Radionuclides, as n interim document with a request for comments. A copy of the preface of this report is e losed (Enclosure 1) for your reference.
The complete report can be obtained on the Intern (www. epa. gov / radiation / federal) or by l
phone (1-800-490-9198).
Enclosures 2,3,4 and 5 are exchanges of corre ondence between NRC and EPA, and
-include NRC's major technical and policy issues oncerning FGR 13. Enclosure 6 provides comments on FGR 13 from the Illinois Departm nt of Nuclear Safety.
If you have any questions about this correspo ence or the NRC letters, please contact Cynthia G. Jones, Senior Level Advisor for H lth Physics, NMSS, at (301) 415-7853 or e-mail at CGJ@NRC. GOV.
Paul H. Lohaus, Deputy Director Office of State Programs l
Enclosures:
As stated Distnbution DIR RF DCD (SP03) l SDroggitis PDR (YES_y') (NO_)
RSAOs CPaperi llo, NMSS RSLOs DCool, MSS A/S File FAXED TO STATES:
l DOCUMENT NAME: G:\\KPH\\EPALTR.KPH Ta receive a cop of mis document, indicate in the boa: "Cae Copy ithout attachrnent/ enclosure "E" a Copf with attachtnent/ enclosure "N" a No copy OFFICE OSP l
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A UNITED STATES 7'o j
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~ April 22, 1998-I ALL AGREEMENT STATES l
l OHIO, _ OKLAHOMA, PENNSYLVANIA :
TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-98-033)
- Your attention is invited to the enclosed correspondence which contains:
L' INCIDENT AND EVENT INFORMATION..........
)
r-t PROGRAM MANAGEMENT INFORMATION....
TRAINING COURSE INFORMATION..........
TECHNICAL INFORMATION..........................XX FEDERAL GUIDANCE.
REPORT NO.13, " HEALTH RISKS FROM LOW-LEVEL ENVIRONMENTAL EXPOSURE TO RADIONUCLlDES" OTHER INFORMATION...........................
Supplementary information: This is to inform you that the U.S. Environmental Protection
~ Agency (EPA) has issued Federal Guidance Report No.13 (FGR 13), Health Risks from Low-Level Environmental Exposure to Radionuclides, as an interim document with a request for comments. A copy of the preface of this report is enclosed (Enclosure 1) for your reference.
The complete report can be obtained on the Internet (www. epa. gov / radiation / federal) or by l
phone (1-800-490-9198).
p l
Enclosures 2,3,4 and 5 are exchanges of correspondence between NRC and EPA, and include NRC's major technical and policy issues concerning FGR 13. Enclosure 6 provides comments on FGR 13 from the'lllinois Department of Nuclear Safety.
If you have any' questions about this correspondence or the NRC letters, please contact L
Cynthia G.' Jones, Senior Level Advisor for Health Physics, NMSS, at (301) 415-7853 or e-mail at CGJ@NRC. GOV Paul H. Lohaus, Deputy Direc r Office of State Programs
Enclosures:
As stated I
r DIt.L."!,
enclosure 1.
l l
Federal Guidance Report No.13 Part I-Interim Version l
HEALTH RISKS FROM LOW-LEVEL ENVIRONMENTAL EXPOSURE TO RADIONUCLIDES l
Radionuclide-Specific Lifetime Radiogenic Cancer Risk Coefficients for the U.S. Population, Based on Age Dependent Intake, Dosimetry, and Risk Models Keith F. Eckerman Richard W. Leggett Christopher B. Nelson Je ome S. Puslan Allan C. B. Richardson j
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f Oak Ridge National Laboratory Oak Ridge, Tennessee 37831 Office of Radiation and Indoor Air United States Environmental Protection Agency
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j PREFACE The Federal Radiation Council (FRC) was fonned in 1959, through Executive Order 10831.
A decade later its functions were transferred to the Administrator of the newly formed Environmental Protection Agency (EFA) as part of Reorganization Plan No. 3 of 1970. Under these authorities it is the responsibility of the Administrator to " advise the President with respect to radiation matters, directly or indirectly affecting health, including guidance for all Federal agencies in the formulation of radiation standards and in the establishment and execution of programs of cooperation with States." The purpose of this guidance is to ensure that the regulation of e':posure to ionizing radiation is adequately protective, reflects the best available scientific information, and is carried out in a consistent manner.
Since the mid-1980s EPA has issued a series of Federal guidance documents for the purpose ofproviding the Federal agencies technical information to assist their impkmentation of radiation protection programs. The first report in this series, Federal Guidance Report No.10 (EPA,1984a),
presented derived concentrations of radioactivity in air and water corresponding to the limiting annual doses recommended for workers in 1960. That report was superseded in 1988 by Federal Guidance Report No. I1 (EPA,1988), which provided dose coefficients for internal exposure of members of the general public and limiting values of radionuclide intake and air concentrations for workers, based on updated biokinetic and dosimetric models. Federal Guidance Report No.12 (EPA,1993) tabulated dose coefficients for external exposure to radionuclides in air, water, and soil.
When final, this report is intended to promote consistency in assessments of the risks to health from radiation by Federal agencies and others and to help ensure that such assessments are based on sound scientific information. It is intended as the first of a set of documents, referred to collectively as Federal Guidance Report No.13, that will address risks to health from exposure to specific radionuclides. These documents will make use of state-of-the-art methods and models for estimating the risks to health from internal or external exposure. These methods and models take I
into account, for the first time in a comprehensive compilation, the age and gender-specific aspects of radiation risk. This interim version of Federal Guidance Report No.13, Part 1, provides tabulations of risk estimates, or " risk coefficients", for cancer attributable to exposure to any of approximately 100 important radionuclides through various environmental media. These risk coefficients apply to populations that approximate the age, gender, and mortality experience characterized by the 1989 91 U.S. decennial life tables. The tabulations in the final version of Part I will extend the methodology of the interim version to the other radionuclides included in Federal Guidance Reports 11 and 12. Subsequent pans of Federal Guidance Report No.13 may extend the iii
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exposure pathways, and health endpoints addressed.. As nece reissued to update the information provided. EPA has chose i
cations will be Report No.13 as an interim report at this time in order to provid e eralGuidance interested parties an opportunity to become familiar with it and it n a agencies and other
[
provide comments for the Agency's consideration before publis In this report, the risk coefficient for exposure to a given t s on.
L environmental medium is expressed as the probability ofradiop g a given per unit activity inhaled or ingested, for internal exposure, or per s
r a ty or morbidity concentration in air or soil, for external exposure. These risk coeff grated activity chronic or acute exposure to environmental radionuclides. That e applied to either
- interpreted either as average risk per unit exposure for oefficient may be
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acdvity concentration of e radionuclide in an environmental mediu ant i
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exposure forpersons acutely exposed to the radionuclide through the rage risk per unit
. as the exposure involved is properly characterized as n a medium,aslong
" low dose" and " low dose rate" are defined in terms of the ra risk models applied, rather than as regulatory concepts.
nge of applicability of the radiogenic The risk estimates tabulated in this report are intended main of estimated cancer risks from long-term exposure to radionuclid ve assessments example, it is anticipated that this document will be used in such activ ental media. For i
environmental impact statements and development of assessm es as preparation of for control ofradiation exposure. While it is recognized that these eneric rule making to is used in retrospective analyses ofradiction exposures of populati c ents are likely also analyses should be limited to estimation.of total or average risk tabulations are not intended for application to specific individuals 1
populations. The example, children, and should not be used for that purpose. Also, 1
- on radiation risk models developed for application either to l c ents are based these risk coefficients should not be applied to accident cases invol i us, 3
4 either in prospective or retrospective analyses. Finally, some risk established as a matter of policy, and additional steps ma procedures are i
coefficients. For example, EPA recommends that radiation risk a Priorities List under the Comprehensive Environmental Response s on the National be performed.using the Health Effects Assessment Summa a on, and Liability Act periodically updated to reflect new information.
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Documents in EPA's Federal Guidance Report series provide reference values for assessing both radiation dose and risk from exposure to radionuclides. Federal Guidance Report Nos.11 and 12, which address radiation dose, are intended for use in determining conformance with the radiation j
protection guidance to Federal agencies issued by the President. The present report does not replace either of those documents or affect their use for radiation protection purposes, even though many of the biokinetic and dosimetric models used here are updates of models used in Federal Guidance Report No. I1. The dose coefficients in Federal Guidance Report Nos. I1 and 12 continue to be recommended for determinations of compliance with dose-based regulations and, where applicable, for use in dose assessments. Those reports will be updated in the future as warranted. Federal Guidance Report 13 has a different purpose - it is intended for use in assessing risks from radionuclide exposure, in a variety of applications ranging from analyses of specific sites to the general analyses that support a rule making. Although its use, especially by Federal agencies, is encouraged to promote consistency in risk assessment, such use is, of course, discretionary.
This report would not have been possible without the contributions of the many investigators who produced the building blocks that provided the basis for the results presented here. These include: Jerome S. Puskin and Christopher B. Nelson, who assembled the models for age-dependent, organ-specific cancer risks; Richard W. Leggett, Keith F. Eckerman and many other contributing scientists who developed and compiled the age-specific biokinetic and dosimetric models published by the Intemational Commission on Radiological Protection; Robert Armstrong, who supplied pre-l publication values for the 1989-91U.S. decennial life tables; and Keith F. Eckerman and Richard W.
Leggett, who provided the basis for calculation of doses from internal and external exposure. Allan C.B. Richardson initiated preparation of this, as well as Reports 10,11, and 12, and provided guidance on its broad outline. The major effort required to prepare the report itself was carried out by Keith F. Eckerman, Richard W. Leggett, Christopher B. Nelson, Jerome S. Puskin, and Allan C.B. Richardson. Technical review was contributed by William J. Bair, Bemd Kahn, Charles E.
Land, John R. Mauro, and Alan Phipps. Preparation of the report was funded by the U.S.
Environmental Protection Agency, U.S. Department of Energy (DOE), and U.S. Nuclear Regulatory 1
Commission (NRC). Its technical content has been reviewed by these agencies.
We gratefully acknowledge the work of the authors, the agencies who contributed funding i
for this work, and the helpful comments by technical reviewers of this interim version of the report.
We would appreciate receiving any comments by June 30,1998, so that they may be taken into v
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be addressed to Allan C. B. Richardson, A n nthefallof1998. Commentssh Protection' Division (66021), U.S. Environmental Pr t rector for o ection Agency, Washington, DC 20460.
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WA/W Lawrence G. Weinstock, Acting Director Office ofRadiation andIndoor Air
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- 8 February 4, 1998 Richard D. Wil' on s
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:
On January 20,1998, Mr. William Kane, Acting Deputy Director, of our Office of Nuclear Material Safety and Safeguards (NMSS), received a telephone call from Mr. Lawrence Weinstock of your
. staff informing us that the U.S. Environmental Protection Agency (EPA) plans to issue Federal Guidance Report No.13 (FGR 13), Health Risks from Low-LevelEnvironmentalExposure to Radionuclides, for interim use and comment. On J inuary 21,1998, Dr. Carl Paperiello, Director, NMSS, informed Mr. Weinstock in a letter that we supported this approach. On January 23,1998, Dr. Paperiello informed Mr. Weinstock that upon further consideration and discussion with the Commission, he was withdrawing his January 21 letter and that another letter would be forthcoming. As a result, we request that this document be issued only as a draft FGR for public comment rather than as an interim use and comment document. We request that the document
'N forward NRC's major technical concems, in the enclosure to this letter, with this draft publication as outlined in our December 31,1997, letter. Accordingly, we.have summarized these comments for extemal distribution as 'part of the draft FRG 13 that is published for comment in the enclosure to this letter.
NRC looks forward to assisting EPA in reviewing and resolving any comments received on FGR 13 during the comment period. We appreciate the opportunity to work with you on this important document, and look forward to future meetings of the FGR 13 Working Group as the 1
mechanism to conduct this activity.
if we can be of further assistance in this regard, please let me know.
Sincerely, H g L. Thompson r.
Executive ire for Regulatory Programs
Enclosure:
Technical and Policy issues Concerning Federal Guidance Report No.13
'A.
cc: See attached list
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THE U.S. NUCLEAR REGULATORY COMMISSION'S TECHNICAL AND POLICY ISSUES CONCERNING FEDERAL GUIDANCE REPORT NO.13 -
1.
The NRC is concemed that the radiogenic cancer risk estimates tabulated in this Federal Guidance Report (FGR) use several different methods and recommendations of the Intemational Commission on Radiological Protection (ICRP). Although most of this report uses the updated biokinetic and dosimetric models from ICRP Publication No. 60 I
o and beyond,' there are instances where ICRP Publications 26 and 30 dose methodology was used, because of the lack of recommendations concoming environmentalintakes of certain elements. Currently, neither the U.S. Environmental Protection Agency (EPA)
Federal Guidance (FGR Nos.11 and 12) nor existing Federal and State regulatory framework has fully adopted the use of the updated methods and recommendations of the ICRP 60 publication or of any of the ICRP publications issued since then.
NRC believes that the use of different biokinetic and dosimetric modeling schemes can only continue to hamper efforts to harmonize Federal and State regulatory efforts in the U.S. for two reasons. First, the report directs users to apply one set of models and parameter values (i.e., FGR Nos.11 and 12) when addressing one aspect of a problem, and ther switches to another set of updated models and parameter values (i.e., FGR No.13) when addressing another aspect of the problem. Clearly, the potentialimpacts will be confusion among the public, licensees, and regulators, and a serious public communications issue. Second, having this published as an interim use FGR without the benefit of previous public, State, or international comment would be a serious contributor to the growing problem of regulatory instability in the radiological protection arena.
2.
_ NRC is concemed that although there have been attempts to describe and quantify the uncertainties associated with the risk coefficients, the report is unacceptably vague for an officialinterim use publication. Efforts to characterize the uncertainties in the biokinetic models used in FGR 13 vaguely rely on several reports (all yet to be published) by: (1) the ICRP, on the reliability of its models and dose coefficients for members of the public; (2) the National Council on Radiation Protection and Measurements (NCRP), on the reliability of the models and dose coefficients of ICRP Publication 30; (3) the Commission of the European Communities (CEC) in coordination with the NRC, on the uncertainties in the blokinetic, dose, and risk models used in probabilistic risk assessmerit codes for reactor releases; and (4) Leggett, et al., which will summarize work done by the aforementioned authors, as part of the uncertainty analysis of the NCRP, ICRP and the CEC-NRC (see FGR No.13, p. 66). NRC believes that the need to characterize uncertainties in the risk coefficients for cancer mortality and morbidity for lifetime exposure to radionuclides in the environtnent is essential for a FGR.
'ICRP publications used and referenced in this report are listed on pp. R-5 through R-6 of the final report. These include ICRP Publications 59,60, and 66-72.
Enclosure i
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NRC, as well as many within the scientific community, is concerned that the uncertainties associated with estimating risks from radiation at low doses and low dose rates are significant, and that there is significant disagreement among scientists regarding the magnitude of the actual health effects at these leve'a. This scientific uncertainty occurs because evidence of radiation dose health effects has only been observed at high dose levels and dose rates and significant uncertainty is introduced i
.. when extrapolating to estimate the health effects at very low dose levels and dose rates.-
NRC believes that because the FGR has radiogenic risks that are expressed as
" mortality or morbidity per becquerel," as Tables 2.3a and 2.3b state, there is an implied -
scientific certainty down to these minute levels, when, in fact, there is substantial s uncertainty and lack of reliability.
4.
EPA has stated in the Preface that it is anticipated that this document will be used for the preparation of environmentalimpact statements, environmental assessments,' and -
development of assessments in support of generic rulemaking for control of radiation exposure.8 Although the Preface indicates that "...its [the Report's] use, especially by Federal Agencies, is... of course, discretionary...." the NRC is concemed that other Federal and State agencies would ultimately be required to use its methodology if it is used as the basis of a rulemaking that ultimately impacts those agencies. The Preface should make it clear that it is anticipated that the document, when finalized may, but will not be required to, be used for EISs, EAs and rulemaking.
1 5.
NRC is concerned that the interagency working group members have not received a copy of the CD-ROM which was intended as a useful tool to accompany this document.
The CD-ROM should have been available during the development of this report.
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Although NRC has high regard for the principal author of the report, none of the participating Federal agencies can state that it has been able to independently confirm these results.
i 8See Preface of this report page iv.
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t UNITED STATES enclosure 3.
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NUCLEAR REGULATORY COMMISSION
/g WASHINGTON, D.c. 20555-0001 February 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:
In my letter to you of February 4,1998, conceming EPA's Federal Guidance Report No.13, Health Risks imm Low-LevelEnvironmentalExposure to Radionuclides (FGR-13), \\ asked that the docur1ent be issued as a draft FGR fe r pJblic comment 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 teamed 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 Realster Nghg.e. 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 radiological standard setting use should occur until public 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.Thoropso Jr.
y Executive ire r
for Regulatory Programs cc See attached list 3//
Attached cc List for 02/06/98 Letter t' Wilson US EPA o
Mr. D. Michael Schaeffer, Chairman 703-325-2407 Department of Defense fax - 2951 Radiation Research and Policy Worldng Group Defense SpecialWeapons Agency 6801 Telegraph Road Alexandria, VA 22310-3398-Mr. Raymond P. Berube, Deputy Assistant Secretary 2C2-586-5680 for Environment '
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 Avereue, NW Washington, DC 20210 Mr. Alan Roberts 202-366-4469 Associate Administrator for Hazardous Materials Safety fax - 5713 Department of Transportation, Room 8422 400 Seventh Street, SW Washington, DC 20690
. 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, DC 20503 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 JLipotl@dep. state.nj.us and Analytical Programs Department of Environmental Protection
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CN 415 Trenton, NJ 08625-0415
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Attmehad ec List for 02/08/98 Letter to Wilson US EPA Mr. D. Michael Schaeffer, Chairman 703-325-2407
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Department of Defense fax - 2951 Radiation Research and Policy Working Group
- Defense SpecialWeapons A ency 0
6801 Telegraph Road.
Alexandria,VA '22310-3398 Mr. Raymond P. Berube, Deputy Assistant Secretary 202-586-5680 l
for Environment -
fax - 2268
' U.S. Department of Energy J
Washington, DC 20585 Dr. Adam Finkel, Director 202-219 7075 Health Standards Programs, N-3718 fax - 7125 Occupational Safety and Health Administration L
200 Constitution Avenue, NW Washington, DC 20210 i
- Mr. Alan Roberts 202-366-4469 l
Associate Administrator for Hazardous Materials Safety fax - 5713 l
Department of Transportation, Room 8422 i
400 Seventh Street, SW Washington, DC.20550 Dr. Bruce Wachholz, Chief 301-496-9326 i
Radiation Effects Branch fax - 1224 National CancerInstitute 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, DC 20503 l
Dr. Beverly Hartline (contact) 202-456-6128
. Office of Science and Technology Policy fax - 6027 17th & Pennsylvania Avenue, NW BHARTLINE@ostp. cop. gov
_ Washington, DC 20500 Dr. Jill Lipoti, Assistant Director 609-984-5636 I
for Radiat!on Protection Programs fax - 7513 Division of Environmental Safety, Health JUpotigdep. state.nj.us and Analytical Programs Department of Environmental Protection CN 415 Trenton, NJ 08625-0415
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' gh Yg UNITED STATES ENVIRONMENTAL PROTECTION AGENCY enclosure 4.
I WASHINGTON, D.C. 20460 j
i Hugh L. Thompson, Jr.
Deputy Executive Director for Regulatory Programs Nuclear Regulatory Commis. tion Washington, DC 20555
Dear Mr. Thompson:
I am writing in response to your letters ofFebmary 4 and 6,1998, questioning the Environmental Protection Agency's (EPA) release of an interim version ofFederal Guidance Repon No.13 (FGR 13). EPA remains convinced that this technical report, " Health Risks from Low-level Environmental Exposure to Radionuclides," has already undergone appropriate internal ar.d exterr.al peer review. The document benefitted throughout its development from the comments received from work group members representing your agency, the Department of Energy (DOE), and other recognized experts.
Nevertheless, the Nuclear Regulatory Commission (NRC) urged EPA to solicit additional review and public comment before releasing a final version of the report. We responded in two ways. First, we asked our Science Advisory Board to review interim FGR 13, even though they have previously endorsed its underlying parts. Second, we proposed issuing the report as an 1
interim document with a request for comments. We revised the document to explain this new process and sent it to be published.
Enclosed with your letter of February 4 was a statement containing Sve concerns that NRC has with FGR 13. You requested that we widely distribute this statement along with copies ofinterim FGR 13. Distributing your comments would be an unusua: 4_viation from standard practice for either of our agencies and would require EPA to distribute all comments received to all interested panies. We will soon have a docket available at EPA Headquarters where all the comments received regarding interim FGR 13 will be available for public inspection When we announce the availability ofinterim FGR 13 in the Federal Register, we will inform the public of the docket. This standard process for collecting comments and making them available to the O LOVf fp V
2 public is adequate, fair, and satisfies the essence of your request. However, we will provide you a copy ofour rnaisng list should you wish to distribute your comments. In addition, we will post your comme.ms on the Internet (nmv. epa. gov / radiation / federal). Finally, we will develop a response-to-comments document once all comments have been collected and analyzed. A formal response to your list of concerns will be included in this document.
I am convinced that FGR 13 is unquestionably a step forward in our approach to estimating cancer risks from radiation exposure. EPA, in line with the President's priorities, is focusing considerable effort on understanding and protecting special at-risk populations from environmental hazards. FGR 13 is a good example of our succeu in this area because it allows us to estimate better the doser that infants, young children, and adolescents receive from inhaled and ingested quantities of radionuclides. For the first thne, this is done by making use of dosimetric data specific.to these special age groups, not by extrapolating from adults. It uses the updated lung model recommended by the International Commission on Radiological Protection (ICRP) in its Publication 66 for making better assessments oflung doses in these special age groups as well as in adults. It alt 3 incorporates improved biokinetic d'ta, published by the ICRP,- for 45 elemems that represent most of the radionuclides of concern at NRC-licensed 1,ites and DOE facilities.
Much of the work that supports the ICRP's publication of biokinetic and dosimetric data is being performed at Oak Ridge National Laboratory (ORNL). Two of the co-authors ofinterim FGR 13 are part of the group at ORNL whose work was recently favorably acknowledged by the Interagency Steering Committee On Radiation Standards. They have applied a rigorous quality assurance process to the preparation of the document to insure it correctly interprets ICRP's recommended values.
By incorporating these data, FGR 13 has improved the modeling for determining the metabolic fate ofinhaled and ingested radionuclides, and thereby has improved the associated risk estimates. These improvements iustify EPA's publishing this report, even though the resulting changes to age-averaged radionuclide-specific risk factors are, for the most part, small. EPA does not accept NRC's argument that we should withhold these technical improvements in our ability to quantify risks using the linear-no-threshold model until the model itselfis validated. EPA, like every major regulatory organization including NRC, accepts the current recommendations of the National Academy of Sciences (NAS), the National Council on Radiation Protection and Measurements, the ICRP, and the United Nations Scientific Committee on the Effects of Atomic
' Radiation to use this model in our risk estimates. In funher support of this position, the NAS 'aas just released the National Research Council's report of the sixth Committee on Biological Effects ofIonizing Radiations (BEIR VI) which asserts that there is cellular evidence of harm sufficient to promote carcinogenesis following a hit to a cell by a single alpha particle.
EPA anticipates that FGR 13 will be finalized in the fall with the inclusion of risk coefficients for edditional radionuclides (including all of the radionuclides currently found in FGR 11 and 12). Although these additional radionuclides are needed for completeness, they are 2
[.
l 3
generally less important than those found in the current interim version because they de not normally drive cleanup and decommissioning decisions.
~ We look forward to wod6g collegially with NRC staffin the development of the remainder of this report. Thank you for your willingness to assist us in this effort.
Sincerely yours, j
j A
Richar i son I
/ cting Assistant Administrator for Air and Radiation ec:
Michael S -haeffer(DOD)
Raymond Berube (DOE)
Adam Finkel(OSHA)
Alan Robeits (DOT)
Bruce Wachholz (NCI)
Art Fraas (OMB).
Beverly Hartline (OSTP)-
Jill Lipoti(NJDEP).
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UNITED STATES enclosure 5.
j NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 20565 4001
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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 to 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 concerns with FGR
- 13. After this briefing, one of the RAC members asked if NRC had concerns with FGR 13. After learning that NRC did, the RAC Chairman asked the NRC staff member in atterrJance te beiefly 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 concerns with FGR 13.
Consequ.ntly, please note the enclosed letter that is being sent concurrently to Dr. Stephen 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 FGR 13 or the FederalReaister Notice of Interim FGR 13 availability which was issued on April 13,1998. 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 ac 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.
e,
4
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' I trust thai we can' mutually resolve concems regarding this jointly sponsored document and request that we use the Interagency Steering Committee on Radiation Standards to coordinate and address any significant puialic 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.
j Please let me know if you are agreeable with this approach.
Sincerely, v
Hu ompson r.
D y Executive ire r
i for Regulatory Progra
Enclosure:
As stated cc: See attached list 4
F I
Attached'cc List for Anril 15.1998 Letter to Wilson US EPA t
< Mr.LawrenceWeinstock, Acting Director 202-564 9320
. U.S. Environmental Protection Agency fax 565-2043
, OfRce of Radiabon and Indoor Air (6601J) 401 M. Street, SW.
3 Washington,DC 20400 l
f Mr. D. Michael Schaeffer, Chairman
.703-325-2407 :
Department of Defense fax - 2951 Radiation Research and Policy Working Group -
l Defense SpecialWeapons Agency l
6801 Telegraph Road Alexandria,VA 22310-3398 i
. Mr, Raymond P. Berube, Deputy Assistant Secretary 202-586-5680 1 for Environment fax-2268 '
'- U.S. Department of Energy Washington,DC 20585 Dr. Adam Finkel. Director :
202-219-7075
- Health Standards Programs, N-3718 fax - 7125 l -- ' Occupational Safety and Health Administration l ' : Washington, DC 20210 7200 Constitution Avenue, NW -
Mr. Alan Roberts 202-366-4469 Associate Administrator for Hazardous Materials Safety fax - 5713 1 Department of Transportation, Room 8422 l
. 400 Seventh Street, SW L W^shington, DC 20590
' Dr. Bruce Wachholz, CNef '
301-496-9326-l Radiation Effects Branch fax - 1224 l l.
National CancerInstitute E - Executive Plaza North, Suite 530 L.
c Bethesda, MD - 20892 Mr. Art Frans 202-395-3087 Office of Management and Budget fax - 7285 !
Room 10202 New Executive Office Building 7 1 Washington,DC 20503 Dr. Bewerty Hartline (contact) 202-456-6128 L ; Office of Science and Technology Policy fax - 6027 17th & Pennsylvania Avenue, NW ~
BHARTLINE@ostp.eop. gov. '
I-Washington, DC : 20500.-
' Dr. Jill Upoll, 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 CN 415 -
L Trenton,NJ 08625-0415.
1 i
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION f
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WASHINGTON, D.C. 20565 0001 p$
...o April 15, 1998 q
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 1
Oakland, CA 94605
Dear Dr. Brown:
i 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) concerns regarding EPA Federal Guidance Report j
No.13, Health Risks from Low-Level Environmental Exposure to Radionuclides (FGR-13). At that meeting, you indicated that when the next RAC meeting is held on May 7-81998, the RAC i
would appreciate a more detailed briefing from NRC on its specific technical concerns with this i
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 considered two of the NRC's recommendations - to forward j
FGR 13 to the RAC for a formal review, and to issue it for public review and comment. NRC i
continues to believe that scientific reviewers should have the benefit of understanding the range i
of viewpoints and issues which constitute the apparent differences of opinion. In this regard, we are enclosing copies of our previous correspondence to EPA on this subject, dated j
February 4 and 6,1998, in the hopes that this information will assist the RAC's Federal i
Guidance Review Subcommittee in its deliberations on this issue.
I We hope that there will be a mutual resolution of concerns 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 egj@nrc. gov, to coordinate our attendance at the May 1998 meeting.
Sincer ly, j
f l
K tm i
u L. Thomps, Jr.
uty Executiv Dire r
for Regulatory Programs
Enclosures:
As stated cc: See attached list
Attac"had cc List for Anril 15.1998 Letter to Brown. Chair. EPA RAC Dr. Donald G. Bames, Director:
Science Advisory Board (1400),
U.S. EPA
' 401 M Street, S.W.,1400 Washington, D.C. 20460 j
Dr. K. Jack Kooyoomjian,
. Designated Federal Officla! for the '
Radiation Advisor / Committee Science Advisory Board (1400),
U.S. EPA 401 M Street, S.W.,1400 Washington, D.C. 20460 i
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001
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February 4, 1998 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
Dear Mr. Wilson:
On January 20,1998, Mr. William Kane, Acting Deputy Director, of our Office of Nuclear Material Safety and Safeguards (NMSS), received a telephone call from L'r. Lawrence Weinstock of your staff informing us that the U.S. Environmental Protection Agency (i'PA) plans to issue Federal Guidance Report No.13 (FGR 13), Health Risks from Low-LevelE lronmentalExposure to Radionuclides, for interim use and comment. On January 21,1998, Dr. Carl Paperiello, Director, NMSS, informed Mr. Weinstock in a letter that we supported this approach. On January 23,1998, Dr. Paperiello informed Mr. Weinstock that upon further consideration and discussion with the Commission, he was withdrawing his January 21 letter and that another letter would be forthcoming. As a result, we request that this document be issued only as a draft FGR for public comment rather than as an interim use and comment document. We request that the document forward NRC's major technical concerns, in the enclosure to this letter, with this draft publication as outlined in our December 31,1997, letter. Accordingly, we have summarized these comments for external distribution as part of the draft FRG 13 that is published for comment in the enclosure to this letter.
NRC looks fonvard to assisting EPA in reviewing and resolving any comments received on FGR 13 during the comment period. We appreciate the opportunity to work with you on this important document, and look forward to future meetings of the FGR 13 Working Group as the mechanism to conduct this activity.
If we can be of further assistance in this regard, please let me know.
Sincerely, j
V 4
H g L Thompson, r.
De ty Executive irec for Regulatory Programs l
Enclosure:
l Technical and Policy Issues Concerning Federal Guidance Report No.13 cc: See attached list k
f
q, e
f THE U.S. NUCLEAR REGULATORY COMMISSION'S
.:I TECHNICAL AND POLICY ISSUES CONCERNING FEDERAL GUIDANCE REPORT NO.13 1.
The NRC is concemed that the radiogenic cancer risk estimates tabulated in this
- Federal Guidance Report (FGR) use several different methods and recommendations of the Intemational Commission on Radiological Protection (ICRP). Although most of this report _ uses the updated biokinetic and dosimetric models from ICRP Publication No. 60.
and beyond,' there are instances where ICRP Publications 26 and 30 dose methodology was used, because of the lack of recommendations conceming environmentalintakes of T certain elements. Currently, neither the U.S. Environmental Protection Agency (EPA)
Federal Guidance (FGR Nos.11 and 12) nor existing Federal and State regulatory framework has fully adopted the use of the updated _ methods and recommendations of the ICRP 60 publication or of any of the ICRP publications issued since then.
NRC believes that the use of different blokinetic and dosimetric modeling schemes can only continue to hamper efforts to harmonize Federal and State regulatory efforts in the
~ U.S. for two reasons. First, the report directs users to apply one set of models and
. parameter values (i.e., FGR Nos.11 and 12) when addressing one aspect of a problem, and then switches to another set of updated models and parameter values.(i.e., FGR No.13) when addressing another aspect of the problem. Clearly, the potential impacts will be confusion among the public, licensees, and regulators, and a serious public communications issue. Second, having this published as an interim use FGR without '
the benefit of previous public, State, or international comment would be a serious '
' contributor to the growing problem of regulatory instability in the radiological protection arena.
2.
NRC is concerned that although there have been attempts to describe and quantify the uncertainties associated with the risk coefficients, the report is unacceptably vague for an official interim use publication.. Efforts to characterize the uncertainties in the blokinetic models used in FGR 13 vaguely rely on several rsports (all yet to be published) by: (1) the ICRP, on the reliability of its models and dose coefficients for members of the public; (2) the National Council on Radiation Protection and
. Measurements (NCRP), on the reliability of the models and dose coefficients of ICRP Publication 30;(3) the Commission of the European Communities (CEC)in coordination with the NRC, on the uncertainties in the biokinetic, dose, and risk models used in l
probabilistic risk assessment codes for reactor releases; and (4) Leggett, et al., which j
will summarize work done by the aforementioned authors, as part of the uncertainty -
i analysis of the NCRP, ICRP and the CEC-NRC (see FGR No.13, p. 66). NRC believes l
. that the need to characterize uncertainties in the risk coefficients for cancer mortality i
- and morbidity for lifetime exposure to radionuclides in the environment is essential for a FGR.
'lCRP publications used and referenced in this report are listed on pp. R-5 through R-6
. of the final report. These include ICRP Publications 59,60, and 66-72.
Enclosure
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3.
NRC, as well as many within the scientific community, is concerned th' t the a
uncertainties associated with estimating risks from radiation ~at low doses and low dose rates are significant, and that there is significant disagreement among scientists regarding the magnitude of the' actual health effects at these levels. This sclentific uncertainty occurs because evidence of radiation dose health effects has only been observed st high dose levels and dose rates and significant uncertainty is introduced when extrapolating to estimate the health effects at very low dose levels and dose rates.
NRC believes that because the FGR has radiogenic risks that are expressed as
" mortality or morbidity per becquerel," as Tables 2.3a and 2.3b state, there is an implied scientific certainty down to these minute levels, when, in fact, there is substantial uncertainty and lack of reliability.
+
4.
EPA has stated in the Preface that it is anticipated that this document will be used for the preparation of environmental impact statements, environmental assessments, and L development of assessments in suppcrt of generic rulemaking for control of radiation exposure.2 Although the Preface indicates that "...its [the Report's) use, especially by Federal Agencies,'is... of course, discretionary...." the NRC is concemed that other
. Federal and State agencies would ultimately be required to use its methodology if it is used as the basis of a rulemaking that ultimately impacts those agencies. The Preface should make it clear that it is anticipated that the document, when finalized may., but will not be required to, be used for EISs, EAs and ruleinaking.
5.
NRC is concerned that the interagency working group members have not received a copy of the CD-ROM which was intended as a useful tool to accompany this document.
The CD-ROM should have been available during the development of this report.
' Although NRC has high regard for the principal author of the report, none of the participating Federal agencies can state that it has been able to independently confirm these results.
2See Preface of this report. page iv.
Attached cc List for 2/4/98 Letter to Richard Wilson, U.S. EPA Mr. D. Michael Schaeffer, Chairman Depetment of Defense.
703-325-2407
~
Radiation Research and Policy Working Group '
fax - 2951 Defense SpecialWeapons Agency 6801 Telegraph Road Alexandria, VA 22310-3398 Mr. Raymond P. Berube, Deputy Assistant Secretary 202-586-5680 for Environment U.S. Department of Energy fax - 2268
~ 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 Mat.erials Safety Department of Transportation, Room 8422 fax - 5713 400 Seventh Street, SW Washington, DC 20590 Dr. Bruce Wachholz, Chief Radiation Effects Branch 301-496-9326 National Cancer Institute fax - 1224 Executive Plaza North, Suite 530' Bethesda, MD 20892 Mr. Art Fraas Office of Management and Budget 202-395-3087 Room 10202 fax - 7285 New Executive Office Building Washington, DC 20503 Dr. Beverly Hartline (contact)
Office of Science and Technology Policy 202-456-6128 17th & Pennsylvania Avenue, NW fax - 6027 i
Washington, DC 20500 BHARTLINE@ostp.eop. gov Dr. Jill Lipoti, Assistant Director 609 984-5636 for Radiation Protection Programs Division of Environmental Safety,. Health fax - 7513 and Analytical P(ograms dpoti@dep. state.nj.us
, Department of Environmental Protection CN 415 Trenton, NJ 08625-0415
an
[
UNITED STATE j
L+
j NUCLEAR REGULATORY COMMISSION
-t WASHINGTON, D.C. 30806 0001 February 6, =1998 l
i-Mr. Richard Wilson i
l Acting Assistant Administrator l
for Air and Radiation L
. U.S. Environmental Protection Agency 401 M. Street, S.W.
935 WostTower(M6101) ~
Washington, D.C. 20460 l
Dear Mr. Wilson:
In my letter to you of February 4,1998, conceming EPA's Federal Guidance Report No.' 13, i
Health Risks from Low-Level Environmental Exposure to Radionuclides (FGR-13), I asked that the document be issued as a draft FGR for public comment rather than as an interim 'use and l
comment document. I also asked that NRC's brief (2-page) statement of its technical and
- policy views on the report, which was attached to my letter, accompany the document.
I have since teamed 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 l
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 concemed be forwarded to
. the printer for inclusion as en 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 Register 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 l
issued only for comment and not forinterim use. Because of the technical and policy differences that exists, no radiological standard setting use should occur until public 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,-
p i
g L.Tho'mpso Jr.
D y Executive ire r
for Regulatory Programs cc: See attached list kY
..?
Attached ec List for 0210s/98 Letter to Wilson US EPA Mr. D. Michael Schaeffer, Chairman '-
703-325-2407 Department of Defense fax-2951 Radiation Research and Policy Working Group a
Defense SpecialWeapons Agency 6801 Telegraph Road.
' Alexandria, VA -22310-3398 -
. 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, DC 20210 G
Mr. Alan Roberts 202-366-4469.
Associate Administrator for Hazardous Materials Safety
, fax - 5713 Department of Transportation, Room 8422 s
400 Seventh Street, SW Washington,DC 20590 Dr. Bruce Wachholz, Chief-301-496-9326
- Radiation Effects Branch fax - 1224 National Cancerinstitute 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 Bu!! ding
.Wasnington, DC 20503 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 CN 415 -
- Trenton, NJ 08625-0415 y
1 e
enclosure e DEPARTMEJ
,AR SAFETY yE 10 m:
SPR
%2704 Thomas W.Onciger Jim Edgar Director Govemor 2
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w January 8,1998 I
Mr. I.awrence Weinstock, Acting Director U.S. Environmental Protection Agency Office of Radiation and Indoor Air (660lJ) 401 M. Street, SW Washington, DC 20460 Re:
Nederal Guidance Report No.13, " Health Risks from Low-Ievel Envir w1 ental Exposure to Radionuclides"
Dear Mr. Weinstock:
The Illinois Department of Nuclear Safety (IDNS) is responsible for regulating the possession and use of sources of radiation in Illinois in order to ensure that Blinois residents have protection from the hazards from radiation. Without changes the U.S.
Environmental Protection Agency's (EPA) Federal Guidance Report No.13, " Health Risks from Low-Level Environmental Exposure to Radionuclides" is unacceptable.
Provided below are our recommendations to improve the quality of the guidance such that the guidance would be acceptable for use by this agency and other states' radiation regulatory programs.
The document should be published as a draft for review and comment by all interested persons, especially the EPA's Science Advisory Board and the International Commission on Radiation Protection (ICRP). Such review will provide opportunity for a check on the assumptions used to develop the risk coefficients and will allow the necessary time for EPA to analyze and publish the analysis of uncertainties in the risk coefficients. Knowledge of the uncertainties is important to ensure proper decision-making when using the guidance. Without knowledge of the uncertainties cleanup efforts would likely be delayed, reasonable cost estimates will be more difficult, and the potential exist to waste billious of dollars on unnecessary cleanup activities that would not result in significant reduction of risk.
r, Tp '.
e, EPA January 8,1998 Page 2-The IDNS agreciates the opportunity to work with the EPA ensuring that, as EPA' stated in the preface of the subject report, "the regulation of exposure to ionizing radiation is adequately protective, reflects the best available scientific information, and is carried out in a consistent manner." If you have any questions regarding these items, you may contact me at 217-785-6982 or collins @idns. state.il.us.
Sincerely, P
h, Steven C. Collins, Assistant Office Manager Office of Radiation Safety L_
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