DRAFT
‘happened in that time, including added experience fn the cleanup of areas
contaminated with transuranium elements.
draft as obsolescent.
Thus, we can only regard the present
Some of the later concepts and expertence should be
abaied with respect to this guidance.
In particular, the question of
flexibility tn application of the guidance should be considered.
Since DOE
will undoubtedly be a technical advisor to 000 or NASA in event of another
accident, we are concerned. that many options will be foreclosedby the present
“lack of flexibility,
in this respect, there are words. giving flexibility in
‘the document ; but not in the recommendat tons section.
in fact, this section
reflects the view that the guidance must be followed.
Since we do not know
what portion of this document «i be stoned by the President, if approved,
this lack of flexibility in the recommendations could lead to serious problems
in implementation.
Finally, a number of statements in the present (and past)
draft leads to belief that EPA was attempting to {ncorporate ALARA into their
considerations but appropriate analyses for the present use tn future
accidents are not included.
As a result of this review, the DOE has several recommendations for the
revision of this guidance and for development of future regulations and
guidance.
(1)
The EPA should issue generally applicable radiation standards fn the
form of a limiting-risk.
(2)
|
The scope of the generally applicable guidance should be broadened
to cover all radionuclides in the environment.
Thts would provide
O