DRAFT
a
guidance applicable to present decontamination and cleanup work and
would not overemphasize the transuranium elements.
oi
;
The guidance should not be based on ALARA but rather on the EPA's
| version ofa reasonable risk considering other risks.’ The use of.
ALARA should be in addttion to meeting the standards and an
‘applicable level of ALARA should be defined by the responsible
agency that has knowledge of the details of the given situation.
(4) DOE has changed their former position on having EPA provide a
screening level.
We now believe -that the EPA should provide the
generally applicable guidance and that DOE, 00D, NASA, and other
“Agencies as needed, cooperate to produce any screening level
required.
be defined:
As we now envision it, there are two levels that need to
(a) a screening level below which action is not needed;
and (b) an actton level above which cleanup could be started without
further studies.
This would satisfy the need of the operator who
needs a number to work with while other studies define the actiond
needed in the {ntermediate zone.
(5)
The DOE recommends that EPA take a consistent approach to the
setting of environmental standards and guidance so that these
standards represent a coherent whole rather than a fragmented group
of inconsistent standards.