-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

Select target paragraph3