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Years of experience have dencnstrated the good faith of the {1dustr

{primar{ly (QE) {in conservative application of existing guides in the
bpirit of ALARA. In fact when {it can be easily and economically

jusftifed {at cons{derable expense in most cases), activity fs removed
o "nondetectable” levels to avoid public concern.

€.

Reducing
the limits to levels approaching background and/or minimum
detectable, alaces the odustry under unnecessary pressure which in
addition destroys the flexibility to affectively work ALARA programs.
The current Himits are s> low that the limit of detection sensitivity

is reached.

Sampling and analyses require extended time and detailed

Chenical separation and counting tectnology.

The limits

placed at

these low levels multiply the number af the extensive analyses.

The minimum cost ($500 p2r acre) assumed for estimating the total costs
for bringing contaminates areas {nto compifance with the

whrealistically low.

guidance 1s

It Is a generally accepted fact that the costs

associated nith decontamination rapicly escalate when the des‘red

incremental reduction 1s small.

In eddition, the costs attritutable to

decoitanination efforts Include planning and engfieering; Vabcr;
equipment use and decont mination; weste packaging, hand{ing, transport,
and disposal; and radiation monitoring.

when dealing with very low annual dose rates,

the assunptions and/or

models used when computing doses have a significant impact on the dose

rate estimates resulting

from a given set of data points.

Corsideration

should be given to standardizing the dose computa‘ ion and pathways
analysis methodologies and to referencing specific methodologies in
the proposed guidance.

The "screening levels" d'qcussed in the proposed guidance should be
removed. Quantifying these levels may corstitute establishment of a
separate set of dose lim’ts. That is, each site has urfque environmental
and demographic parameters which may result fin different screening
levels than those proposed, but stil} correspond ta the annual dose

rates specified in the gufdance.

We would sup zest & more appropriate approach for the FRC function to

take would
1.

fh the following options:

First endPreferred Cption
Establish technically based limits which are cansistent with trose
recommended by ICRP end NCRP with eB strong ALARA requirement.

2.

Second Option
List the limits/guides fn tables with two columns, the first with

the technically based lim‘ts and :he second with the ALARA based
guides a; goals to be used with discretion and judgment.
,

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[his

Select target paragraph3