-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