Mr. Tom McCraw
September 22, 1976

Page 4.

It is clear that averaging plutonium concentrations will tend to reduce
the apparent health risk since the peak concentrations get averaged in with
the lower concentrations. This is not, however, a justification for averaging. What we need to know is what average or metric is the best indicator
of future health risk to persons inhabiting the area. Guidance from resus~
pension and radionuclide cycling studies is needed here.

Question 2:

To what areas should the Pu cleanup criteria, 40 pCi/g and
400 pCi/g, be applied?

This seems to be a restatement of Question 1. Again, the answer depends on
how concentrations for the various size areas are related to health. If
this were known and we had some idea of trends and variability over space,
we would be in a better position to answer this question.
Question 3: Looking at past survey results compared with the cleanup
~~~criteria, which islands need cleanup? What levels of
assurance that the criteria are met without cleanup are
reasonable and attainable?

A.

There are a number of probability statements that can be made based on

survey data.

These include (1) a one-sided upper confidence limit on the

true (unknown) average Pu concentration, and (2) a one-sided upper confidence

limit on a percentile of the population. For this latter case, using the
95th percentile for a = .0] as an example, we could construct, e.g., an upper
100(1-a) = 99% confidence limit on the concentration level below which 95%
of the soil concentrations on the island lie. A third type of interval that
appears particularly useful is a one-sided upper confidence limit on the
roportion of soil concentrations that fall below the cleanup specification
Tevel (this level is denoted here by L). These three kinds of limits are
illustrated in an attached supplement to this letter using the 239-240py
data collected on Janet during the 1972 Enewetak survey. We might say at
this point, however, that confidence limits on average values (number 1

above) are usually computed on the assumption the data are themselves

normally distributed or that the estimated mean is normally distributed.

Since Pu concentrations tend to have skewed distributions similar to the
lognormal, the usual procedures are sometimes modified by first transforming
the data to logs, computing the limits in Jog scale, then transforming the
limits back to the original scale. Alternatively, nonparametric or "distribution-free" limits can be computed These latter limits are valid no matter
what the underlying statistical distribution, but the one-sided limits wil]
be higher (or wider for 2-sided limits) than if a specific distribution such
as the normal or lognormal is assumed. We note, however, that limits on
percentiles and proportions (items 2 and 3 above) do not require any assump-

tions about the underlying statistical distribution.
mentioned above are illustrated in the Supplement.

The several approaches

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