million was not justified to save 1 life in 30 years. 14. If the expenditure of §16.4 million is not warranted to save 1 life in 30 years, then clearly the expenditure of $25 million would be even less justified. Based on the above discussion, it is apparent that regulation of DOE facilities as a source category of radionuclide emissions is not warranted since the health risks from emissions from such facilities currently are exceedingly small and would not be appreciably reduced by the costly proposed regulations. The risks from radionuclide emissions from DOE facilities to the most exposed individual and to the population as a whole are considerably lower than for the two benzene source categories EPA proposes to regulate and roughly similar to . the risks from the three benzene source categories that EPA has determined not to regulate. Consequently, it is this Department's position that EPA should withdraw the proposed emission standards for radionuclide emissions from DOE facilities in accordance with its announced prudent risk management policy under section 112 of the Clean Air Act. Sincerely, DONALD PAUL HODEL “DRAFT|4 wea ece we. = me eA Then nencen men me eo cpg a ee RO PS me ee ee _

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