-8point to recognize is that the AEC recommendations for cleanup
of plutonium in soil were derived from basic Federal standards
tritey le
and thererdrb tare” vortet ff to dose to man.
The criteria
selected for Enewetak while expressed as «-concentrations5
a
Ipee Ths
of radioactivity in soil = relatable to dose.
EPA criteria is
7
hey
“hn Ang
phe proposed
he
expressed in,Onde of dosex and gofl con-
centrations are to be devived from this doses using appropriate
- pathway models.
It is our view that if cleanup of islands at Enewetak is accom-
The Agdhe.Cendnals Comtees ith Mitest he S
plished according to the Task Group criteria,
Tia Opes,
vO transuranium elements will
criteria.
2
meet the proposed EPA
EPA is using conservative dose values in its pro-
posed recommendations.
Informally, EPA staff have indicated
that if predicted doses at Fnewetak associated Weeee, AEC
o~
soil_Ciegnup criteria are at or near their proposed, criteria,
the, project would meet the intent of their guidance.
The
published proposal mentions Enewetak cleanup but does not
make any recommendations specific to this project.
Comments on Iteme -
The statement that the Task Group's radio-
logical cleanup guidelines considered only
incorrect.
Pu-239, 240 is
The published scientific report that provided the
key information relating concentrations of radionuclides in
soil to dose to man, and~atilewing-recommended
oriteriate—be
expressedinusefulterns..Tanely-sonething-mersurapleat”Eneveteley
assumed a gistribution of transuranium elements
in the soil
that Coniehe expect’trom a nuclear weapon detonation.
In-
cluded in the ccnsiderations in this report were all of the
long lived transuranium element alpha emitters
residual to a nuclear detonation.
that would be
It was known that the ratios
of transiranium elements in Enewetak soils would vary from
place to place.
Even if the ratigs found in soil samples were