-

15

-

Vegetation

Over 400 vegetation samples were analyzed during the Enewetak
survey.

There were only 3 samples where both 241a and

were detected.

The average values for these 3 samples were 0.44 pCi/g

239,240), and 0.053 pCi/g
0.82 pCi/g.

239 ,240
Pu

241

Am.

The 24154 concentration is 1.85 (0.44) =

The maximum 24]an activity resulting from this level of

241puy is 0.026 (0.82) = 0.021 pCi/g 2
present 24lam concentrations.

Al

Am which is a 40% increase above

The total

241

Am activity is 0.053 + 0.021

0.074 pCi/g which is 0.074 pCi/g/0.44 pCi/g = 0.168 or 17% of the 739>74%py
concentration.
Page 10,line 19 to Page 11, line 10 - "The resuspension measurements

and calculations which relate the air contamination to the soil contamination
are not immediately compelling, and deserve a much more careful analysis than
I have given them. I would be surprised if the analysis is meaningful to
factor of 100, when used to determine public health guidelines. Resuspension
is poorly understood, it is sensitive to windspeed, soil characteristics,
vegetation, humidity, rainfall, mechanical disturbance, physical and chemical

history of plutonium particles in soil. How then does one@nsider the
exposure of children throwing dry sand on a windy day at the beach? I
would anticipate large fluctuations about the implicity exposure levels,

which, even for the Limiting soil contamination guidelines and predicted

air concentrations associated with these guidelines, will be approximately
a maximum permissible lung burden."
Comments:

The issues raised by Dr. Geesaman are not new.

We are weil

aware that all of the variables which are identified have not been analyzed

with respect to their individual or combined . influence upon resuspension
- factors.

For that reason additional air sampling studies will be carried

out for a period of twelve months, as described in the DEIS,
Even though measurements made primarily reflect airborne plutonium
from worldwide fallout levels and cosmic ray activity, because of the
uncertainties identified the assumptions made in deriving the various
organ doses due to the inhalation of plutonium are quite conservative.
consisting of low
A constant air concentration of plutonium is assumed,

Select target paragraph3