"EPA
Hold position that current radiation standards are ‘upper limits'. EPA will
likely look only at risk of exposures rather than at the benefit-risk area.
Expressed concern that restrictions for control of exposures may not be
effective over the long term. Stated that use of 100% of the genetic
criteria is not justifiable. Urged use of Federal standards (FRC) instead, of
ICRP guidance. Expressed concern that soil removal criteria for
Pu
may not be stringent enough. Cited need for more specific requirement
for obtaining additional information on Pu levels in air. Had concern for
verification of predicted doses and followup studies. Rejected use of DNA
radiation criteria developed from consideration of past cleanup experience
(the 'preeedent' approach). Support Task Group's approach to development
of recommendations.
"DNA
Stated a strong preference for their own criteria and need for no other
guidance. Feel that they are too far along in their planning andit is too
late to change the approach taken last year. Support radiation criteria
based upon a review they have conducted of past AEC cleanup
experience. Have selected numerical criteria taken primarily from Grand
Junction uranium mill tailings experience. Reject Task Group criteria
based upon current radiation standards as being too low and too
conservative. Support view that the cleanup objective must be to reduce
external ga™ima level with no other cleanup or restrictions required.
Support the concept of ‘fallback positions' to be used if all necessary
cleanup funds are not available. Hold that availability of money will
determine extent of cleanup. Reject the ‘as low as practicabie'
requirement.
"DOI
"HEW
Have concern that Janet may not be returned.
Support the Task Group's
approach to development of recommendations. Are hopeful of actions
leading to return of people to Janet. Question when Janet can be returned
if not now. Hold position that people will eventually return to Janet.
See need for more air sampling and investigation of exposure from inhaled
Pu. Cited need for information on
I exposure of the thyroid. Found
the Task Group draft a very satisfactory report.
"TASK Supports use of current radiation standards and philosophy recommended
GROUP by FRC and ICRP. Cannot support DNA approachto criteria development
using cleanup experience such as current effort for removal of mill
tailings under and near structures in Grand Junction. Cannot support
recommendation of cleanup alternatives wherein basic Federal radiation
exposure standards would not be met. Supports position that both internal
and external exposures must be evaluated in considering cleanup
alternatives. Cannot support concept of fall-back positions to be used if
necessary funds for cleanup to acceptable criteria are not available. Hold
to position that recommended actions are only those known to be feasible
and effective. Cannot support DNA recommendation of use of 'clean beds'
of soil for growing food on a contaminated island since this action involves
many uncertainties and is unproven as to effectiveness. View of remedial
(cleanup) action is that once it is taken, the objective is to make
substantial reduction in radioactivity levels, not to reduce levels to some
specified value. Support approach of studying all alternatives for cleanup,
but to recommendonly a preferred set of actions that in the judgement of
the Task Group will comply with the ‘as low as practicable' requirement.
Believe
that
DNA has
misinterpreted and
is
misusing
AEC cleanup
experience in citing this as a basis for choosing radiation exposure
criteria. Observes that DNA uses a 'worst case' approach to cleanup based
upon AEC exposure estimates that are actually average exposures.
Believe that DNA recommendations cannot be successfully defended
against criticism from those who are familiar with current Federal
regulations and standards."
59