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Exposed to Transuraniun Blezents in the Ceneral Environsent
MERCER
Proposed Eovironcents! Protection Agency (£PA) Dose Limits for Persons
1/10/84
As requested by your mesorandum of Novenber 23, 1983, we and our contractors have reviewed the msteriale provided concerning the subject
wPE
regulation and offer the folioving comsnte;
SODEN
(1)
Phe dose limite fin the proposed regulation (1 wfllired per
year to the pulmonary lung, or 3 pillired per year to the bone,
1/ (84
or 49 wiliirad per year to the bone surfaces) appear to be unreasonably conservative.
OSD -
limite on guidance provided in ICRP report 26 concerning a¢-
MILLER
The EPA purports to base the proposed
ceptable risk limites to the public.
ZL wuld tlerefere seen
deena, LI”
appropr fete for the EPA to use the risk, quality and weighting
factors and general uethodology aleo presented in ICRP 26,
Although we were not given their sethodology or essuaptions,
4t appears that EPA errived at their liafts through a more
ecouservative approach then {¢ presented in ICRP 26 without an
obvious justificetion for ao doing.
(2)
From the guidance presented, the fepact upon current AL eites
and operations ate expected to be ainiasl. Based upon prelie-
1) {Bs
osp
1] (a!
dnsry ftnforaation, the eof] acreening levels are exceeded only
on @ enall erea near LANL in Actdé Oanyon where average traneurasic
levele are about 60 pCi/g. However, in this particular dnstance,
@ pathvay analysia would indoubtably ehow the levels frow the
site to be less than the dose linits in the proposed regulation.
Of more sericus concert to AL would be the reguletion's (epact
wpon future accident situations wherefin the guidance froa EPA
seeng ftuadequate.
(3)
Ve are alse concerned ebout the potential applications of the
soil screening level,
Ic would he costly if, through {uappro-
priate use, the soil ecreening level were ultinstely to becone
@ soil cleanup level. The origins of Appendix B of 10 CFR 20 ere
2 case in point, wherein ICRP guidance wae eventually promulgated
ae tegulatfon.
We fear that other Vederal and/or State regulatory
agencies may adopt the screening level a8 8 regulation to provide
eet
FMET ameont.
oa Se8et
WOH: DDM
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JAN 39 1004