an f af A mw 4 © 1959 T. 9. Pflaum, YO, Chief of Envir., Safety & Health (NP-275.1) STN ATTY: Q. H. Hank, HO (MP=226.1) Tl! COMMENTS OM EPA-PRMPOSED "ROSE LIMITS FR PERSONS EYPOSED TO TRANSURANTUM ELEMENTS IN THE GENERAL ENVIROMMENT" The Nevada Operations Office (NV), Healt> Physics Division (HPN), has obtained comments from the scientific laboratories, annropriate contractors, and staff on the subiect document. A brief summary of those comments is provided helow. Poacansa tha maximum measured Pu concentration outside of the Aellis Bombing and Gunnery Range (observed during samptina anoroxinately 19 voars aqn) is less than a hal? of the screening level, we beliaya the recommendations of the report probably will not impact significantly on “TS activities. Even so, the racormandations are not considered reasonable. 'lnwever, because thers is qreat vartability between Incations of samples and aliquots af the same sot] sample (i.8., the hot particle problen), it is conceivable that someone could find atf-sit? locations which would exceed the screening level, In addition, we nave substantial areas contaminated above those limits on the flellis rangs, hun aff tie ETS, as well as substantial areas ahove the limits an the NTS, It appaars chat the real hasis for these recommendations is “as Inw as can he talorated without heavily consuming agency hudgets," and is nor based on any cost-hennfit analysis. Any number of. approaches cnuld he used to assiqn a valuo to a life and thereby calculate a dollar v3iue for dose reduction which canld ha balanced against claanup costs. Instead, the reoort lists an absolute risk of 10 uf 197° deaths:ser yoar as,(reasonable and then turns arnuni and selects 160° (not 5 x 10” or 3x 10° *y without cansidering cost or henetit. , ° The auidanea lavels of 1 m8/yr to the pulmonary tine, 3 mm/yr to hone, or 49 mR/ yr ta the bane surface are not directly measurable quantities and theretore are of Vittle eractical use. Complex and auestionable calculations would he required ta transvorm mnasuroad contamination levels to doses. ‘Inv such calculations contain jwiqmantal factors cancerning dietary habits and personal praferancas weich could fe challenced and the rasnansibla adency could find itself in ondlass court Sattles renardina compliance. The enly certain way to assnre compliance woul-l ba oronidsitive far rautingop rations. SO pet, Gacts of cloanup, if in should Se poquipnd, aro osrimatad in the FPA document at unwards oF SAA UN ner acre, which excaeds tne intrinsic land value around Tho “TS two enpa than taq times, Tris ind of cost rabative to the estimated mateatial nenatit ar ach less than one anneniltionth af a "health atfeet” Spems arassly exe-ssiyve.