C

@:

in land areas for residential usc, specifying thet
238

.
Pu levels shall not exceed 2 dpm (0.91 pCi)

gram of surfac2 soil

1 cm depth of soil).

(i.e.,

per

averaged over the top

It is noteworthy that the

mee VD
.
eRe Sh
AEC
hasmee
net eScanlished
that
,

-- 4.
5
+
2
Ff
this
standard
is
unéuly
.

ok

consérvative and it is not apparent that the AEC

tp et

|

Sr pom be cy

has requested the ICRP or NCRP to make specific

Ope few

recommendations with respect to standards for Pu in

;

soils applicable to chronic exposure to the general

pe glee

pubiic, including children.

rie

~

i

.

I note that the DEIS recommends no remedial

action for soils containing
Pu/g,

« 40 pci or

averaged over the top 15 cm depth.

« 88 avn
This is

much morethan44tines the Colorado interim standard
(2 dpm per g in the top 1 cm) because for most
Enewetak soils the top cm contains substantially
higher levels of Pu per gram than the 15 cm depth
average.

Thus,

for example,

at location 101 on

Pearl, the top 1 cm depth shows 400 pci

Pu/g,

whereas the average over 15 cm depth is about 60.
Thus the recommended standard for Enewetak is about
100 to several hundred times that adopted in Colorado.
There are recent research developments which

are expected to lead to reductions in acceptable
organ burdens of Pu in man by a factor of 100 to

1000 or more.

In my opinion it is likely that a 16

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ae Pb

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wh

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