p.l2, lines 19-20.

The statement that 20% of that on the filter is usually

regarded as respirable raises the question of how this was included in the
calculations.

The definition of the AMAD of 0.5 um implies fractions deposited

and, therefore, the "respirable" fraction.
p.19, par. 2.

It should be noted that such a program is in progress at

Battelle and that numbers from their studies are not as extreme as those picked
from reviews or articles for another purpose (i.e., Larsen).

It would be well

to draw such conclusions from the published experiments rather than from an
interpretation.

The concentration ratios of vegetables seem low; probably should be
closer to 10.

]

2

and 10“.

Thus, actual observations are needed and not an

estimate from papaya and bananas.
More data are needed for CR values as well as more fish sampled to
validate the last sampling.
The estimates of Pu in cistern water is made using a Ka value (soil
to water in ml/g) of 5.9 x 10°.

This is a very high Ka value for Pu (VI)

thus it probably represents the K,

d

for Pu(IV) and not the K,

which will dominate when the water is chlorinated.
would probably be 102 to 10°.

d

for Pu({VI)

A more realistic Ky

Also what is the concentration of Pu in soil

particles that could be deposited on the roofs?

As one can observe a Ky

of 10° instead of 10° will make a great difference in the dose rate by
drinking chlorinated cistern water.

7 think a serious error is being made

here by using the assumptions stated in the report.
(Some recent work at Oak Ridge has shown that a gastrointestinal tract

coefficient of 6 x 10°73 is necessary to account for an observed lifetime
body burden of Th indicating that the 5 x 107? coefficient, as stated in their
report, may be more representative than the 3 x 10~

5

coefficient for Pu.)

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