-3-

T. OD. Pflaum

Therefore, until the technology is developed to perform TRU cleanups where
workers do not take substantially higher risks (which are real) to achieve
a condition where the risks (which are hypothetical) are substantially lower
than daily risks, guidance should be limited to reflect the greatest savings
of life.
The Enewetak cleanup, which was designed to conform with the proposed EPA
guidance is the epitome of the above discussion. According to risk analyses

published in the planning documents, the islands could have been turned over
to the people without a radiological TRU cleanupand saved lives.
Ultraconservatism costs more than just time and dollars, it can cost real

lives.
3.

Cost Versus Benefit

Reasonable alternatives should be evaluated when decisions are made
' affecting the expenditure of resources. The radiological cleanup at Enewetak
cost approximately $100 million and resulted in the potential of averting less
than one cancer death from radiation in 30 years in the Enewetak population.

How many premature deaths from disease and illness might have been averted in
the Enewetak population by directing £100 million into improving health care

knowledge, facilities, and capability? We may not have the information
available to answer this question, but it is not unreasonable to consider this

alternative.
cleanup.

Similar logic should be applied in considering any radiological

HPD: DLW
CC:

L. J. Deal, HO (EP-342) GTN

T. F. McCraw, HQ (EP-32) GTN
A, B. Siebert, Jr., HQ (DP-3.1) GTN
P. J. Mudra, Dir., OD, NV
Roger Ray, DPO, NV
J. D. Stewart, OD, NV

E. D. Campbell, NSD, NV
D. R. Martin, SHD, NV |

Bruce W. Church, Director —

Health Physics Division
|

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