DRAFT guidance applicable to present decontamination and cleanup work and would not overemphasize the transurantum elements. (3), \ The guidance should not be based on ALARA but rather on the EPA's | | version of a reasonable risk considering other risks. The use of. ALARA should be tn addition to meeting the standards and an ‘applicable lavel 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 “Agenctes 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 fs not needed; and (b) an action 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 studfes define the actiong needed in the tntermediate zone. (5) The DOE recommends that EPA take a conststent 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.