7 — wre e . een ewe <- Ws: dl§ Exposed to Transuraniun Blezents in the Ceneral Environsent MERCER Proposed Eovironcents! Protection Agency (£PA) Dose Limits for Persons 1/10/84 As requested by your mesorandum of Novenber 23, 1983, we and our contractors have reviewed the msteriale provided concerning the subject wPE regulation and offer the folioving comsnte; SODEN (1) Phe dose limite fin the proposed regulation (1 wfllired per year to the pulmonary lung, or 3 pillired per year to the bone, 1/ (84 or 49 wiliirad per year to the bone surfaces) appear to be unreasonably conservative. OSD - limite on guidance provided in ICRP report 26 concerning a¢- MILLER The EPA purports to base the proposed ceptable risk limites to the public. ZL wuld tlerefere seen deena, LI” appropr fete for the EPA to use the risk, quality and weighting factors and general uethodology aleo presented in ICRP 26, Although we were not given their sethodology or essuaptions, 4t appears that EPA errived at their liafts through a more ecouservative approach then {¢ presented in ICRP 26 without an obvious justificetion for ao doing. (2) From the guidance presented, the fepact upon current AL eites and operations ate expected to be ainiasl. Based upon prelie- 1) {Bs osp 1] (a! dnsry ftnforaation, the eof] acreening levels are exceeded only on @ enall erea near LANL in Actdé Oanyon where average traneurasic levele are about 60 pCi/g. However, in this particular dnstance, @ pathvay analysia would indoubtably ehow the levels frow the site to be less than the dose linits in the proposed regulation. Of more sericus concert to AL would be the reguletion's (epact wpon future accident situations wherefin the guidance froa EPA seeng ftuadequate. (3) Ve are alse concerned ebout the potential applications of the soil screening level, Ic would he costly if, through {uappro- priate use, the soil ecreening level were ultinstely to becone @ soil cleanup level. The origins of Appendix B of 10 CFR 20 ere 2 case in point, wherein ICRP guidance wae eventually promulgated ae tegulatfon. We fear that other Vederal and/or State regulatory agencies may adopt the screening level a8 8 regulation to provide eet FMET ameont. oa Se8et WOH: DDM -% wwe cee ee Bee JAN 39 1004