In terms of what regulatory guidance {is available, tiie
use of averages probably 1s okay assuming that reasonable statistics are
used--soll/island averages, annual inhalation/ingestion averages,
occupancy averages, etc,
Without the use of averages, the habits and
Vocation and exposure of each individual presumably would need to be
estimated.
The moral aspect is |nore difficult:
should anyone need to
accept a higher risk than the "average’?
Considering all of the uncertainties, my own feeling 1s that avcrages
are acceptable as long as maxius, similarly are defined (e.g., a residence
{sland might have an average of (6-8 pCi/gm with no area of the island
3)
!
k
to exceed, say, 30 pCi/gm).
The above becomes tied into the japplicability of the EPA Guidance
to the Enewetak return,
This has literally forced O£S to consider
dose projections from transurantcs, something that heretofore had been
either not considered or snr to be insignificant.
both “considereds" were in error.
ine RS
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and moral.
There probably are two aspects to this issue:
Obvioussry
1 feel that the EPA Guidance should
be considered to be what it is--guidance.
The closer we can get to
or below it, the better off DOE land the Enewetak people will be.
However, it is doubtful that EPA will insist on the use of their
Guidance as an upper exposure lavel and have indicated that {f it
can be met we should by all means do so, but if it cannot be met the
reasons are understandable because of the uniqueness of the situation
and because the benefits, whtle iintangible, no doubt exceed the
wee ey
definition).
Seabee cept
averages ARDC used, individual velues may exceed the average (almost by
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