te
DRAFT
seurse.: It sable thet the information used in davaloping the getdenee: wes
primartty ter. qutating. sites: of contamination and little real attention hes
been: paid te what new seems to be the primary usefulness of the guidance.
This: guidance hes been in preparation for about ten years and there have been changes. In policy in the EPA that should de considered before these numbers
are accepted.
A noteworthy example is the taik by Mr. Ruckelshags before the
Natiooal Academy of Sciences proclaiming the policy of the EPA to use the best
science avaitebie in providing their regulations.
We do not belteve that the
preseat limiting numbers represent a truly scientific approach to guearally
applicable standards.
Perhaps the results of the recently appointed
subcommittee of the EPA Sefentific Advisory Board will’ be applicable ta this
af
quideadca. ‘
We de Rave a number of objections to tris draft guidance.
The 00€
questions ithe wide range ef liaits in recently issued or proposed EPA
reguiations for the pretection ef the public from radiation.
This draft
guidance edds anether sat of values to the var tous anes accepted by the EPA,
In fact, the use of arade rather than mrems, as in the other standards, sets
- Qh?s ose apagt, from the ethers leading to tnconsistency tn units as well as in
risk values.
Earlier we referred te a shift in the prabable application of
this quidames from present sites to future accidents.
However, the background
studies leading te this guidance have paid little attention to thts aspect of
{ts 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 soi? have not been
addressed.
The current guidance is now about seven years old.
Much has
Ca