, 4 Rorigelap and Utirik Residents - 1954 to 1980”, adds to this worry. This report indicates that while the maximum deviation from ‘the average value of the daily activity ingestion rate for members of an age subgroup was no greater than a factor of 3, the population distributions illustrated a activity ingestion rate. The factor of 5 times the mean greatest variation in intake was observed to occur in infants, and of 5 times the mean activity ingestion rate. Infants, children, and adults 20 to 40 years of age, ingested more activity each day than adolescents and persons over 40. It is therefore very important to know what ages subgroups will receive the highestiexposure. I am not at all certain we know which group this i-s. It may not be adult males or females. It may be infants born several years after return. How do we explain if doses to infants are greatly underpredicted? My advice is that LLNL’s use of averages or mean values, and conversion factors ~’here there is no data, in calculations of dose to individuals is OK so long as a factor or factors are introduced to give some assurance that these doses are not underpredicted for age groups receiving the highest exposure and that standards are conservatively applied. My feeling is that the uncertainties in our dose estimates are larger than we have admitted, and there may be important factors influencing dose we have not yet taken into account. I find no comfort in the fact that some of the most important foods dose-wise, foods that are known to be a significant part of the diet, are still not yet growing at Enewetak and the radioactivity values used were averages derived from radioactivity concentration ratios involving average plant and soil data that come prir,arily from experience at Bikini. With these concerns in mind I urge that the dose predictions for population groups in this draft be considered the low end report Of a range of possible estimates, and that LLNLtS should give an indication of the high end of the range as well. This could be done by updating the diet used in their 1977 report using Naidu’s food intake levels. Naidu claims these needed, i.e., may represent maxi,mum intake, which is what is the maximum intake for a population group. I think the Naidu numbers can be defended as a conservative “no imports” diet for such a group. Also, I urge that the 250 mrem~year and 4,000 mrem/30 years be recommended to DOI for use in comparing the dose to the highest individuals and to the population with Federal standards in the interest of providing some degree of assurance that the standards will not be exceeded.