DRAFT “happened in that time, including added experience in the cleanup of areas contaminated with transurantum elements. draft as obsolescent. Thus, we can only regard the present Some of the later concepts and expertence should be | e@isied with respect to this guidance. In particular, the question of flexib{iity in application of the guidance should be consfdered. Since DOE | will undoubtedly be a technical advisor to DOO or NASA in event of another. accident, we are concerned that many options will be foreclosedby the present “Yack of flexibility, In this respect, there are words giving flexibility in the document ; but not in the reconmendat fons section. In fact, this sectton 4 | . reflects the view that the gut dance must be followed. Since we do‘not know what portion of this document “i be signed by the President, if approved, this tack 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 incorporate ALARA into their considerations but appropriate analyses for the present use in 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 tn the form of a limiting-risk. (2) | The scope of the generally applicable guidance should be broadened to cover al] radionuclides tn the environment. This would provide @)