pretty well been identified: a) How realistic is a mass loading of 100 wg/m?, especially if used as a yearly average? b) It seems extremely conservative to assume that ALL of the resuspended material is of respirable size, or to assume that the AMAD is 0.5 um. c) Is it realistic to assume a Pu/Am ratio identical to that in soil for al? respirable particles? It seems to me that at least some of the mass loading would be due to particles from ocean/lagoon spray which probably have little or no Pu content. d) Can one assume that inhaled material is high-fired oxide? It may be misleading or misinterpreted to retain tables for average soil concentrations up to 400 pCi/gm. Even 40 pCi/gm probably is unreasonably high as an island average. The use of average soil concentrations is a delicate one. are NOT used, presumably ALL island areas must be measured. If averages If island averages ARE used, individual values may exceed the average (almost by definition). moral. There probably are two aspects to this issue: para-legal and In terms of what regulatory guidance is available, the use of averages probably is okay assuming that reasonable statistics are used--soil/island averages, annual inhalation/ingestion averages, occupancy averages, etc. Without the use of averages, the habits and location and exposure of each individual presumably would need to be estimated. difficult: The moral aspect is more should anyone need to accept a higher risk than the "average"? Considering all of the uncertainties, it is felt that averages are acceptable as long as maximums similarly are defined (e.g., a residence island might have an average of 6-8 pCi/gm with no area of the island to exceed, say, 30 pCi/gm).