OGYS a ghew specific Comments: 1) To what extent, if any, is the assumed diet realistic or conservative? After what period of time is {tianticipated that this diet will, in fact, be available as the primary, if not sole, source of food? For example, are the people now to some extent dependent upon imported food, and would this continue? 2) How do LLL soil surface (0-3 cm) recommendations (0-1 cm)? measurements compare with EPA (Perhaps info related to this could be obtained from the Rockwell comparative soil sampling program at Rocky Flats.) How reliable and consistent fs the Pu:Am ratio of 2:1? Is 4% justifiable to assume a 2:1 ratio for both the surface soil (0-3 cia) | and the root zone (0-30 cm)? How realistic are the occupancy| factors stated? for women and children? Are these valid also for example, children might be expected to eS tan 4) estimated dose be decreased because of avoidance of agricultural islands, increased because they|might be expected to play in the dirt, sand or coral, or would the dosé adult? 5) = spend more time on a village or!picnic {sland, but would their be essentially the same as for an | A gut transfer factor of 3.0 x jo-5 may not be conservative. EPA recommends 10-4 for Pu-239, 240 oxide, 1073 for oxides and non-oxides of other isotopes of Pu, Am andiCm, and 5 x 10°3 for biologically “a q incorporated material. Use of o73 for Am is okay, but Pu-239, to say nothing of jPu-238, absorption factors may have been underestimated, Perici i 3)