ML20134D657

Responds to to Chairman Jackson,Commissioners Rogers,Dicus,Diaz & Mcgaffigan Which Provided Comments on 951122 Draft, Epa/Nrc Risk Harmonization White Paper

ML20134D657
Person / Time
Issue date:	01/30/1997
From:	Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Mobley M TENNESSEE, STATE OF
Shared Package
ML20134D661	List: ML20134D657
References
NUDOCS 9702050293
Download: ML20134D657 (4)

Text

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' jdAN 3 0.13373 -

Mr. Michael H. Mobley, Director "  ;

Division of Radiologics1 Health ~  ;

Tennessee Department of Environment ,

and Conservation 3rd Floor, L & C Annex ,

Nashville, TN 37243-1532

Dear Mr. Mobley:

This replies to your December 31, 1996',' letters to Chairman Jackson and Commissioners Rogers, Dicus, Diaz and McGaffigan which provided comments on  ;

the November 22, 1995 draft " EPA /NRC Risk Harmonization White Paper." i We agree with you that EPA's air emissions standard is not more protective than NRC's air emissions standard. The section you quote on page 15 of the White Paper is entitled, "Different exposure scenarios are used in some programs." As one example, the paper says that, under National Emissions  !

Standards for Hazardous Air Pollutants, "the scenarios addressed by EPA are i more extensive." While one could infer that this means that EPA's standard is -

more stringent, we agree with you that such an inference would be incorrect.

Such an inference was not intended. Elsewhere in the paper, it is made clear  ;

that, "The agencies usually achieve similar levels of protection, despite >

fundamental differences in approaches." t We also agree that it is inaccurate to describe EPA's drinking water standard as being simply 4 mres/ year. The paper repeats this common error on page 22. t As you stated, the standard actually corresponds to a range of dose limits ,

that vary by radionuclide, and there is no standard for some radionuclides.

Thank you for your interest in risk harmonization. We will forward both of  !

your comments to the ISCORS Risk Harmonization Subcommittee. For your information, Robert Nelson, at (301) 415-7298, is NRC's risk harmonization i technical contact.  ;

i Sincerely, j Odginalsigned by CarlJ. Paperie!)o l Carl J. Paperiello, Director  !

Office of Nuclear Material Safety  !

and Safeguards Distribution: r E00 RF (G970023, G970028)

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%*****/ January 30, 1997 Mr. Michael H. Mobley, Director Division of Radiological Health Tennessee Department of Environment and Conservation 3rd Floor, L & C Annex Nashville, TN 37243-1532

Dear Mr. Mobley:

This replies to your December 31, 1996, letters to Chairman Jackson and Commissioners Rogers, Dicus, Diaz and McGaffigan which provided comments on the November 22, 1995 I draft " EPA /NRC Risk Harmonization White Paper." i We agree with you that EPA's air emissions standard is not more protective l than NRC's air emissions standard.

White Paper programs." is entitled, "Different exposure scenarios are used in someThe As one example, the paper says that, under National Emissions Standards for more extensive." Hazardous Air Pollutants, "the scenarios addressed by EPA are While one could infer that this means that EPA's standard is more stringent, we agree with you that such an inference would be incorrect.

Such an inference was not intended. Elsewhere in the paper, it is made clear that, "The agencies usually achieve similar levels of protection, despite fundamental differences in approaches."

We also agree that it is inaccurate to describe EPA's drinking water standard l as being simply 4 mrem / year. The paper repeats this common error on page 22.

As you stated, the standard actually corresponds to a range of dose limits that vary by radionuclide, and there is no standard for some radionuclides.

Thank you for your interest in risk harmonization. We will forward both of your comments to the ISCORS Risk Harmonization Subcommittee. For your information, Robert Nelson, at (301) 415-7298, is NRC's risk harmonization technical contact.

Sincerely,

' s -

& mz Carl J. Paperie lo, Director j Office of Nuclear Material Safety and Safeguards 4

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EDO Principal Correspondence Control s

[EOMs DUE: / / EDO CONTROL: G970023 DOC DT: 12/31/96 -

FINAL REPLY:

ich2Ol H. Mobley, State of Tennessee St Chairman ER SIGNATURE OF : ** GRN **

CRC NO: 97-0017 ESC ROUTING:

COMMENTS ON EPA /NRC RISK HARMONIZATION WHITE PAPER Callan BEING REVIEWED BY ISCORS Jordan Thompson Norry Blaha Bangart, SP QTE: 01/10/97 Morrison, RES

@ SIGNED TO: CONTACT:

NMSS Paperiello

@ECIAL INSTRUCTIONS OR REMARKS:

For Appropriate Action Kathaleen:

SP please acknowledge per King. Mobley wrote i a letter to the Chairman and each Commissioner, so please reference all of them. Thanks.

Margo 1

hos

. a

, OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET PAPER NUMBER: CRC-97-0017 LOGGING DATE: Jan 6 97 ACTION OFFICE: EDO AUTHOR: MICHAEL MOBLEY AFFILIATION: TENNESSEE ADDRESSEE: CHAIRMAN JACKSON LETTER DATE: Dec 31 96 FILE CODE:

SUBJECT:

COMMENTS TO A NOV. 22, 1995 EPA /NRC RISK HARMONIZATION WHITE PAPER ACTION: Appropriate DISTRIBUTION: CHAIRMAN, COMRS.

SPECIAL HANDLING: NONE

/ CONSTITUENT:

1 MOTES: i DATE DUE:

1 SIGNATURE:

• DATE SIGNED-AFFILIATION:

• l I

I EDO -- G970023