million was not justified to save 1 life in 30 years.
14.
If the expenditure of §16.4 million is not warranted to save 1
life in 30 years, then clearly the expenditure of $25 million
would be even less justified.
Based on the above discussion, it is apparent that regulation
of DOE facilities as a source category of radionuclide emissions
is not warranted since the health risks from emissions from
such facilities currently are exceedingly small and would
not be appreciably reduced by the costly proposed regulations.
The risks from radionuclide emissions from DOE facilities to
the most exposed individual and to the population as a whole
are considerably lower than for the two benzene source
categories EPA proposes to regulate and roughly similar to .
the risks from the three benzene source categories that EPA
has determined not to regulate.
Consequently, it is this
Department's position that EPA should withdraw the proposed
emission standards for radionuclide emissions from DOE
facilities in accordance with its announced prudent risk
management policy under section 112 of the Clean Air Act.
Sincerely,
DONALD PAUL HODEL
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