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Years of experience have dencnstrated the good faith of the {1dustr
{primar{ly (QE) {in conservative application of existing guides in the
bpirit of ALARA. In fact when {it can be easily and economically
jusftifed {at cons{derable expense in most cases), activity fs removed
o "nondetectable” levels to avoid public concern.
€.
Reducing
the limits to levels approaching background and/or minimum
detectable, alaces the odustry under unnecessary pressure which in
addition destroys the flexibility to affectively work ALARA programs.
The current Himits are s> low that the limit of detection sensitivity
is reached.
Sampling and analyses require extended time and detailed
Chenical separation and counting tectnology.
The limits
placed at
these low levels multiply the number af the extensive analyses.
The minimum cost ($500 p2r acre) assumed for estimating the total costs
for bringing contaminates areas {nto compifance with the
whrealistically low.
guidance 1s
It Is a generally accepted fact that the costs
associated nith decontamination rapicly escalate when the des‘red
incremental reduction 1s small.
In eddition, the costs attritutable to
decoitanination efforts Include planning and engfieering; Vabcr;
equipment use and decont mination; weste packaging, hand{ing, transport,
and disposal; and radiation monitoring.
when dealing with very low annual dose rates,
the assunptions and/or
models used when computing doses have a significant impact on the dose
rate estimates resulting
from a given set of data points.
Corsideration
should be given to standardizing the dose computa‘ ion and pathways
analysis methodologies and to referencing specific methodologies in
the proposed guidance.
The "screening levels" d'qcussed in the proposed guidance should be
removed. Quantifying these levels may corstitute establishment of a
separate set of dose lim’ts. That is, each site has urfque environmental
and demographic parameters which may result fin different screening
levels than those proposed, but stil} correspond ta the annual dose
rates specified in the gufdance.
We would sup zest & more appropriate approach for the FRC function to
take would
1.
fh the following options:
First endPreferred Cption
Establish technically based limits which are cansistent with trose
recommended by ICRP end NCRP with eB strong ALARA requirement.
2.
Second Option
List the limits/guides fn tables with two columns, the first with
the technically based lim‘ts and :he second with the ALARA based
guides a; goals to be used with discretion and judgment.
,
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