In this regard, I would like to call to your attention a
proposed EPA rulemaking of interest to this Department
(DOE) which on its face appears inconsistent with your
announced policy.
I am referring to EPA's proposed National
Emission Standards for Radionuclides, in particular the
proposed standards for radionuclide emissions from DOE
facilities. 48 FR 15076 (April 6, 1983). 1/ As discussed
below, the maximum lifetime individual risk and the annual
increased incidence of cancer from current radionuclide
emissions from DOE facilities are similar to the risk values
for the three sources of benzene for which EPA has announced
its intent to withdraw proposed regulations.
It is, therefore,
recommended that the proposed rulemaking for radionuclide
emissions be reviewed under the criteria announced for the
benzene decision.
I am confident that based upon this
review, EPA will decide to withdraw the proposed indirect
emission standards for DOE facilities.
7
DOE provided written comments on the proposed rulemaking
na letter dated July 14, 1983 to Charles L. Elkins. In
addition, DOE provided oral comments at the public hearing
held in Washington, D.C. on April 28, 1983.
WUT eeeye
sna -
ee re
.
.
a
ee ewe