4. We have difficulty in reconciling the statements on page 4 abput using 50 percent of the ICRP dose limits; then at the bottom of the page, it is stated that the ICRP limit of the 5 rems in 30 years is proposed to be used the guideline for genetic or gonadal exposure. This is contrary to the guidance given in paragraphs 86 and 87 of ICRP Report No. 9, as well as applicable Federal guidances as expressed by the FRC. 5. It should be understood and stated that any proposed guidelines or numerical values for the dose limits are only preliminary guidance and that a cost-benefit analysis must be undertaken, to determine whether the projected doses are really as low as readily achievable and practical before proceeding with the relocation project. On the basis of such analysis it may be prudent to lower dose guidelines for this operation. 6. Children are the critical segment of the native population and we cannot determine from the report to what extent they were considered either in calculating the dose estimates, or in the development of the guidance on pages 4 and 5. 7. %It is not clear in the guidance (page 5) or the text what criteria will be used to decide if areas below 400 pCi/gm of soil should receive corrective action. More information and criteria should be included in the next draft to indicate how the cost of removal is to be balanced against risk reduction. In addition, the Task Group may want to reconsider whether the guide for plutonium in soil is conservative enough. It is obvious that insufficient data on the dust load in Enewetok air was available for the prediction of lung doses; nor does the "lung burden approach" presented in the appendix agree with the tast group recommendation of 400 pCi per gram of soil. At the very least, recommendation 15 on page 9 should be revised to insure sufficient data is available in the future to settle this point. 8. Our final major comment relates to a deficiency in the recommendations sectian in recard to needed verification of expected doses. It would appear most desirable that the Task Group recommend procedures and actions that will provide assurance that cleanup activities have been completed and that the natives can return to the islands and live without meaningless restrictions. ; ! This should be institutionalized by setting provisions and procedures to monitor the population exposure at reoccupation and in future years. It is our understanding that such arrangements were made after the Bikini cleanup, and a similar operation with regard to the repopulation of Enewetok would appear to be in order. ammCtg ig: |