DRAFT 4 source. It sdhis thet the information used in daveloping the gu4danee' was origartiy fer. extat ing sites: of contamination and little real attention hes been: paid te what new seams to be the primary usefulness of the guidance.. This’ gaidance has been in preparation for about ten years and there have been . changes: In policy in the EPA that should be considered before these numbers are accepted. A noteworthy example 1s the taih by Mr, Ruckelshags before the National Academy of Sciences proclaiming the policy of the EPA to use the best science evailebte ta providing their requiations. We do not belleve that the - preseat limiting nymbers represent 4 truly sctentific approach to general ty ' applicable standards. Perhaps the results of the recently appointed subcommittee of the EPA Sctenttfic Advisory Board will be applicable te this if guideace. \ We de have a number of objections to this dreft guidance. The DE questions the wide range ef liaits in recently issued or proposed EPA requiations for the pretection of the public from radiation. This draft guidance edda anether sat of values to the var tous ones accepted by the EPA, In fact, the use of arade rather then mrems, as in the other standards, sets - thts ofe apart from the ethers leading to incanststency in units as well as in risk veluete Carlier we referred te a shift in the probable application of this quidapes from present sites to future accidents. However, the background studies leading te this guidance have paid little attention to this aspect of its use. There are, for example, no analyses of the cost and practicality of the values given. In particular, the potential political problems caused by these low values if the accident occurs on foreign $01] have not been addressed. The current guidance is now about seven years old. Much has