Using the linear dose response model 2/ and EPA's own estimates
of exposures, 3/ the lifetime risk to the maximally exposed
individual from current radionuclide emissions from DOR
facilities is less than 2 in 10,000. 48 FR 15080 (April 6,
1983).
For comparison, the maximun lifetime individual risks
from exposure to benzene from the two sources proposed to be
regulated by EPA currently are estimated to be 15 in 10,000
and 83 in 10,000; the maximum individual risks from the
benzene sources which EPA proposes not to regulate are 1.4
in 10,000 (ethylbenzene and styrene plants), .76 in 10,000
(maleic anhydride plants), and .36 in 10,000 (benzene storage
2/7
While appreciating the need for conservatism in rulemaking,
DOE questions EPA's reliance on the linear dose response
estimates for radionuclides recommended by the Committee on
Biological Effects of Ionizing Radiation (BEIR) 1972 rather
than utilizing the more current dose response estimates of
BEIR 1980.
The BEIR 1980 report, prepared by a group of experts
in the National Academy of Sciences, is the most recent
compilation of data on the biological effects of ionizing
radiation and yet is not even cited in the Preamble to
proposed 40 CFR Part 61.
See Testimony of Warren K. Sinclair,
President, National Councilon Radiation Protection and
Measurements at EPA hearings on proposed 40 CFR Part 61,
April 29, 1983.
I£ this more current scientifically accepted
Gose response data were used, the risk figures for radionuclide
emissions from DOE facilities would be even lower.
3/
A recalculation of the maximum individual lifetime risk
By the Oak Ridge National Laboratory (ORNL) using EPA
prescribed models determined that the EPA estimate of 2 in
10,000 is too high and that the maximum lifetime risk from
DOE facilities is approximately .3 in 10,000. This risk
estimate is equivalent to the extremely low maximum lifetime
individual risk estimated for benzene storage vessels (i.e.,
the lowest maximum lifetime individual risk from those
benzene sources that EPA has decided not to regulate) and
substantially less than the maximum lifetime individual risk
from those benzene sources EPA proposes to regulate.
ORAFT:
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