Document emkVXjEJGa9BjZLkq12KGYNk9

% f\ . But Ruckelshaus said the "downside" of using conservative risk assumptions is that "we sometimes, I think, unnecessarily frighten people." Ruckelshaus suggests the agency needs to "start describing these risks in a broader array of terms. . .We tried that in the radionuclides decision." Ruckelshaus said he feels the biggest challenge facing EPA administrator-designate LeeThomas is "managing the total agency." Ruckelshaus added, "that means not just managing the programs, but managing all the environmental constituencies he deals with whether it's the Congress, the whole Ad ministrative apparatus, the Office of Management & Budget, the White House, other agencies he has to interrelate with. . .environmentalists or the press. . .That's the overall challenge of running this agency." Ruckelshaus said he is leaving an agency he feels is "in good shape" in terms of management systems, morale and leadership. Ruckelshaus said the transition of the agency to Thomas' leadership has been "about as simple as any EPA has ever had." Thomas was named to the post at Ruckelshaus' behest. Ruckelshaus has accepted what he describes as "office space" at the Washington, D.C. Urban In stitute, where he was chairman of the board, while he mulls his future. He leans toward accepting a posi tion in the private sector, though "that doesn't mean I'll never come back" to government, he said. Yet he says he "doubts" that he will again pursue elected politics, his career of the 1960's. Ruckelshaus said he is clearly most at home in the sort of crisis situation that existed when he returned to a demoralized EPA 18 months ago. The former administrator said he was looking for a "challenge. Just going in and quietly managing an institution is not that gripping," he said. WARNS EPA USE OF NEW VINYUDENE CHLORIDE DATA MAY SPUR OSHA DISCORD EPA's Science Advisory Board last week warned then-administrator William Ruckelshaus that EPA may find itself at odds with the Occupational Safety & Health Administration if it places much credence on Italian data showing vinylidene chloride causes cancer in mice -- data that OSHA did not consider in setting its workplace exposure standard. EPA in its draft health assessment document on vinylidine chloride concluded there is currently "no evidence" the substance causes cancer in humans -- a conclu sion supported by the SAB -- but nevertheless used the Italian data (collected by Maltoni) in discussing the potential effects of the substance. EPA has temporarily delayed plans to announce a decision not to list vinylidene chloride as a Clean Air Act hazardous air pollutant because of the Maltoni data. In a Jan. 4 letter to Ruckelshaus, SAB warns that if EPA "continues to use" the Maltoni data, "the two agencies may have conflicting scientific assessments on vinylidene chloride." OSHA did not use the Maltoni data in setting its 1 part per million workplace exposure standard. EPA's risk estimate from animal data implies that 1 part per million lifetime exposure to vinylidene chloride will lead to an in cremental risk of approximately one in six for humans. SAB points out that EPA's "one in six" risk estimate seems inconsistent with results of an epidemiological study in which a population of 138 persons were exposed to an approximate average of 43 ppm of vinylidene chloride in which no statistically signifi cant increase in cancer occurred. SAB asks EPA to "compare" its quantitative estimates of risk based on human data to those based on animal data. The 1980 bioassay by Maltoni and coworkers cited by EPA showed a statistically significant evidence of kidney carcinomas in mice. SAB recommends that EPA "attempt to verify the tentative results" of the study because "several factors for which no evidence exists either way could lead to conclusions other than those reached by EPA." OMB SITTING ON RCRA CODIFICATION RULE FEARING 'LEGISLATION BY REGULATION' The Office of Management & Budget is sitting on EPA's rulemaking codifying the provisions of the recent Resource Conservation & Recovery Act, sources say, in the belief that EPA's interpretive language and regulation preamble are undue attempts to limit flexibility granted by Congress in the new RCRA law. Sources say OMB fears EPA may be attempting to "legislate through regulation," and is considering forcing EPA to go through the extended proposal and public comment period required by most agency action. EPA, insisting that the codification rule is merely an attempt to transfer Congress's wishes into the body of current RCRA law, reportedly may simply drop the codification rule if OMB insists on the drawn-out formal process. Sources say OMB concerns may have been prompted in part by industry complaints about the codification rule. The steel tank coalition late last year wrote OMB voicing the concern that EPA may be "over-interpreting" RCRA'provisions related to leaking underground storage tanks, sources say. The group requested that OMB force a formal rulemaking procedure for the codification. OMB was from the start of the review process aggravated by EPA activity on the issue, sources explain, because Congress was given copies of the codification rule before OMB. "Breaches of procedure like that really tick them {OMB] off," said one source. EPA and environmentalists are dismayed at the impasse, believing the codification rule can only help INSIDE E.P.A. -- January 11. 1985 SL 068307 3