DRAFT
guidance applicable to present decontamination and cleanup work and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.

Select target paragraph3