Department of Energy Nevada Operations Office P. O. Box 14100 Las Vegas, NV 89114-4100 JAN 13 1984 T. D. Pflaum, HQ, Chief of Envir., Safety & Health (DP-226.1) GTN COMMENTS ON EPA-PROPOSED "DOSE LIMITS FOR PERSONS EXPOSED TO TRANSURANIUM ELEMENTS IN THE GENERAL ENVIRONMENT" The Nevada Operations Office (NV) submitted comments on the subject dose limits via our letter, Church to Pflaum, dated October 19, 1983. convenience a copy is enclosed. For Although much can be said on this subject I wish to take this opportunity to discuss the following points. ‘ 1, EPA Objective of Reducing Risk to 10° 6 Ultra Conservative EPA states that they believe it appropriate to limit the risk for a cancer fatality from a single radiation source to a person in the population to 10 per year. We contend that the proposed standards in reality impose a risk limit much more conservative and could be as low as 10°, There is considerable uncertainty in developing risk estimates from observable health effect data, and there is considerable uncertainty in estimating environmental organ doses through pathway modeling because of the assumptions made and variability of individuals (i.e., lifestyles, ingestion, uptake and growth rates, etc.). If the maximizing assumptions are always taken, the predicted risk to a population for leaving a contaminated area undisturbed could be several orders of magnitude less than the real risk encountered during cleanup operations. One risk not considered by EPA is _fhe risk benefit to personnel involved in the cleanup which approximates 10 ". The criteria and consideration for cleanups should include the risk of death and injury resulting from the cleanup itself. During the course of the Enewetak cleanup, two men died in work-related accidents; six otners died from a variety of causes. It is well documented that construction activities have higher fray rate Dok st industries. | gehae Pathan) é py