19-0
0
WE ARC PROVIDING BELOW SUBSTANTIVE COMMENTS ON THE PROPOSED REGULATIONS AND DOE IMPACT:
A COMMENT SHOULD BE MADE ON TIE HAZARD STATEMENT ON PAGE 9, THAT "INHALATION OF
“RANSURANICM CLEMCNTS MAY CAUSE LUNG CANCERS, AND INGESTION MAY CAUSE BONE AND LIVER
CANCEKS,"
WHILE THIS 18 NO DOUBT TRUE FOR HUMANS, IT HAS ONLY BEEN ACTUALLY DEMONSTRATED
FOR LABORATORY ANIMALS, AND THE ONE-IN-A-MILLION RISK FOR HUMANS IS ONLY CALCULATED.
THIS WAZARD STATLMENT SHOULD ALSO STATE THAT THE PURPOSE OF THE STANDARD IS TO PREVENT
FUTURE CANCERS IN HUMANS FROM TRANSPLUTONIUM ELEMENTS, SINCE WE EXPECT THE SAME EFIECT
FROM TULSEC ELEMENTS AS WE WAVE EXPERIENCED FROM RADIUM.
WE SHOULD NOT GIVE THE FALSE
*MPRESSION TO LAY PERSONS TILAT WE BELIEVE PRESENT AND PAST ENVIRONMENTAL PLUTONIUM
LEVELS ART A CAUSE OF NUMAN CANCERS,
TUT DOSE LIMITS ARE INTENDED TO BE BASED ON A CANCER RISK OF 10(E-6) PER YEAR.
STATEMENTS
IN THI. DOCUMENT (f.C., PACE 3, PARAGRAPH 2) SUCH AS "LESS THAN ONE ADDITIONAL DEATH PER
MILLTON...'' ARE NOT DEFINITE.
THIS SHOULD BE CHANGED TO "NOT TO EXCEED ONE...", SINCE
LESS THAN OND COULD MEAN 10(F-7) OR LOWER, AND IS OPEN AT ONE END.
DOSE LIMITS BASED
ON A RISK OF 10(l~G) PER YEAR ARE GENERALLY ACCEPTABLE BY MOST MEMBERS OF SOCIETY, AND
COUT. BE. ACCRUTANLE. TA DOE. 2. een. eee ee eee
THC PRINCIPAL PROBLEM IS TO ESTABLISH THAT THE DOSE CORRESPONDING TO THIS RISK IS
NOT CXCHENUD AT A SPECIFIC CONTAMINATED SITE.
THE CONCEPT OF SCREENING LEVELS PROPOSED
IN THE DOCUMENT 1S VERY USEFUL AND SHOULD BE SUPPORTED AND ACCEPTED.
THR SOIL SCREENING
LEVEL IS 0,2 uCI/sQq. M FOR THE TOP ONE INCH OF SOIL. FOR PARTICLES SMALLFR THAN 2M.
PRESUMABLY If TIF TOTAL SURFACE ACTIVITY WERE LESS THAN 02, uCI/SQ. M PARTICLE SIZING
WOULD NOT SM NICLSSARY, BUT THIS SHOULD BE CONFIRMED.
ABOUT 4PCT/G OF SOIL.
AN EVALUATION IF THIS LEVEL CAN BE MEASURED BY READILY AVAILABLF
FIELD INSTRUMENTS SHOULD BE MADE.
BO PON.
THE SCREENING LEVEL EQUATES TO
OTHERWISE, SAMPLING AND LABORATORY ANALYSIS MUST
JUN ATR PARTICULATE SCREENING LEVEL, 1 FCI/CU. M, WILL REQUIRE SAMPLING AND