ek Fy ~Mecnriv ia) oi SIOSU0 403008 ENCLOSURE DISCUSSION ON TASK GROUP DRAFT REPORT March 6, 1974 tt Agency Views and Differences of Opinion - ~ ON/ EPA DNA Hold position that current radiation standards are "upper limits.' EPA will likely look only at risk of exposures rather than at the benefit-risk area. Expressed concern that restrictions for control of exposures may not be effective over the long term. Stated that use of 100% of the genetic criteria is not justifiable. Urged use of Federal standards (FRC) instead of ICRP guidance. Expressed concern that soil removal criteria for 439P.. may not be stringent enough. Cited need for more specific requirement for obtaining additional information on Pu levels in air. Had concern for verification of predicted doses an followup studies. Rejected use of DNA radiation criteria developed from consideration of past cleanup experience (the "precedent" approach). Support Task Group's approach to development of recommendations. Stated a strong preference for their own criteria and need for no other guidance. Feel that they are too far along in their planning and itis too late to change the approach taken last year. Support radiation criteria bascd upona review they have conducted of past AEC cleanup experience. Have selected numerical criteria taken primarily from Grand Junction uranium mill tailings experience. Reject Task Group ‘criteria based upon current radiation standards as being too low and too conservative. Support view that the cleanup ob- jective must be to reduce external radiation exposures toa specified value. Support alternatives that will clean all islands down to a specified external gamma level with no other cleanup or restrictions required. Support the concept of ''fallback positions" to be used if all necessary cleanup funds are not available. Hold that availability of mon2y will determine extent of cleanup. quirement. Reject the ‘as low as practicable" re- , BEST COPY AVAILABLE 967