There may be as many as 38 veterans who were mistakenly listed as dead and whose names were carved on the Vietnam Veterans Memorial, the man who compiled the list for the memorial says.

Robert W. Doubek, former project director for the Vietnam Veterans Memorial Fund, said he included the 38 names to be put on the V-shaped, black granite memorial even though he could not be certain many of them were dead because their records were incomplete.

Doubek, himself a Vietnam veteran, said he wanted to "err on the side of inclusivity instead of exclusivity," and at the time was unsure whether more names could be added to the memorial after its dedication in November 1982.

"It was not a clerical error, it was a deliberate decision," Doubek said. "I thought that was going to be it, for history."

About 250 names have been added since the dedication, and the wall now contains the names of 58,175 veterans.

It would be impossible to remove names from the wall without disfiguring it, although the names could be easily removed from the official register, Doubek said.

The Associated Press reported this week that 14 Army veterans whose names are on the wall are alive. Doubek read the story and contacted the AP reporter to tell him there could be as many as 24 more.

Compiling the list of the dead and missing from the war was an exhaustive research project conducted by Doubek and other memorial fund members.

Doubek said he obtained a list of Vietnam War casualties from the Defense Department and cross-checked it against lists compiled by various military branches.

The Army had a computer tape of casualty lists, Doubek said. A computer check of the Army's list against the one compiled by the Defense Department came up with about 1,000 names that apparently were not on the list compiled by Defense, Doubek said.

With the help of the Gold Stars, a group of mothers whose children have died in military service, all but 53 of those discrepancies were explained as the result of slight variations in the spelling of names or differences in the listing of home towns, Doubek said.

By checking the daily telephone logs of casualties phoned from Southeast Asia to Washington, Doubek determined that 15 of the 53 soldiers listed received "light wounds" that were not life-threatening.

In reviewing military records, Doubek found that the remaining 38 soldiers were listed as apparently having suffered mortal wounds, or there was no indication of any injuries. Yesterday, Doubek said he does not know whether all 38 survived the war.Doubek said. "In hindsight, it is close to impossible to compile a list of that magnitude that would be 100 percent accurate."END NOTES

One veteran whose name was mistakenly listed on the memorial took the error in stride. Eugene J. Toni, of Alexandria, who was an Army sergeant in Vietnam, said he saw his name on the wall when he and his wife visited the memorial for the first time last spring. "We both kind of laughed," said Toni, who is a double amputee as a result of war injuries. "She knew I wasn't dead."