DRAFT —
CUMMENTS ON THE PRO?QSED EPA DOSE LIMITS FOR PERSONS
EXPOSED TO TRANSURANIUM ELEMENTS IN THE GENERAL ENVIRONMENT
A.
The conservatism associaced with the numerical Vnfts are far too
great. .
1.
The population dose limit of 500 mrem per
yea to a target organ
2.
There are multiple assumptions necessary in the uptake pathways
to man. Each has been conservatively estimatad which procuces an
Was established by the advisory bodies (ICRP, WCRP, etc.) wit
significant safety factors applied.
unrealistic total conservative overestimate.
39.
Linear dose response curves have now been demonstrated to be
overly conservative. In addition, the internal organ dose
response curves are (4s$ well defined fron exposure to internal
uptake/dose.
4.
§.
6.
The assunption of io°@ acceptable risk 1s dn itself unrealistically
conservative consider ng the cumulative conservatism enumerated
above.
:
The size and location of the population at risk {fs unrealistically.
estimated.
The availability of the radfoactive contaninants after 100 years or
so (the loss of federal reserve protection) hat been assumed at
levels rofiective of aarlier times. It has been snown that plutoniun
availability decreases with time.
The explanatory text repeatedly emphasizes that these guides are just
that and that technical judgment must be exercised. However, these
will be the only guidance available and will be applied by regulators
and interpre:ed by the public as strict limits. ‘Sifte specific application
will be impractical since the uninformed end those with ulterior social
motives will point to apparent discresancy between sites as a cavalier
approach.
The general piblic will be led to believe that levels
exceeding the published limits are injury-producing levels.
the “fine print."
Few read
It {is important to recognize the obviogs conflict fn the statenents
dfrectin rpitament by
the Implementing agencies” and in the same
paragraph (#4, page if pcinting out that exemptiors must be granted
only by the President of the United S:etes on the basis of "nations)
security or paramount {nterest of the §.5S."
The reasons listed for lowering the recommended dcse limits (gsides?)
by a factor of 25 (in reference to the proposed average annua! dose
rate to the pulmonary tissue of I mradfyear) are sctentif{cally baseless.
The reasons {paragraph #1, page 95) are stated as “deemed unnecessarily
high and capable of being reduced."