and between 56 and 920 in 10,000 for high-arsenic copper smelters) would remain considerably above the EPA estimated maximum individual lifetime risk of less than 2 in 10,000 from current radionuclide emissions from DOE facilities. Seetd. Further, the maximum individual lifetime risk from current emissions at DOE facilities are roughly equivalent to those estimated for four sources of inorganic arsenic that EPA determined should not be regulated (i.e., zinc oxide plants, between 1.7 and 28 in 10,000; arsenic chemical manufacturing, between 0.4 and 6.4 in 10,000; cotton gins, between 0.17 and 2.83; and secondary lead smelters, between 2.0 and 3.2 in 10,000). Seeid. The other measure of risk that EPA considers important for sensible risk management is “total population impact®. Background Paper, supra. EPA This risk estimate which takes account of all persons exposed provides a measure of the "overall impact on public health® and is expressed in terms of the annual number of cancer fatalities. See id. The annual increased total population impact from current radionuclide emissions from DOE facilities is estimated by EPA to be about 1 cancer death in 15 years or 0.07 per year. 48 FR 15080 (April 6, 1983). This is considerably less than the annual population impact from benzene emissions from the two benzene sources proposed to be regulated even after the imposition of the proposed regulations (i.e., 0.14 for fugitive benzene and .23 for coke by-product recovery

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