o i R fi F a I 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. , -2- [his