in the root zone? I would guess that in undisturbed areas it would be less and in disturbed areas {it could be greater. The potential impact of plowing should be considered, P. 5, line 4. A reference should be given to the work of Stuart. The coefficient Listed appears high to me, but I will have a review available in the next week or So, P. 5, lines 16-17. It should also be noted that the EPA made no attempt to justify their numbers and they appear to be assumed. In particular, there seems to be no justification for using a higher uptake for 238pu, except, possibly, with ““"PuOy particles. In fact, Weeks, et al. in 1956 reported on uptake from nitrate solution over a range of 0.019 to 140 ug intake with no difference in uptake. used to obtain the low mass feedings. P, 6, lines 1 and 2. Plutonium-238 was The three orders of magnitude should not be taken as a result of experimental work by Larsen. I suspect that it will be lower but must finish the review. 8, P. 6, lines 13-14. Justification should be given for the 1073 uptake by americium., While data are scarce, what we have indicates a somewhat lower value. <Aqain, this will be in the review, The discussion on the uptake is unsatisfactory in that the liver is not ineluded and many of the values quoted included the urine component so that they are not strictly comparable. 10, P. 6, line 21. It sould be helpful to provide a better derivation for the plant uptake factors in Table II including the actual data used, This would enable the reader to better assess the validity of the values. Was americium assumad to have the same plant concentration ratio as plutonium? Wa. jl2. P, 7, par. 1. It would be useful to the reader if the data for the birds and bird eggs were included. In particular, the concentration ratios that were used in the calculations should be included. In the dose calculations throughout it would be useful if the exact paramaters (bone weight, energy of alpha, etc.) along with the calculation methods ware given, It is not clear, for example, whether the decay of 24. am and 238py over the 70-year period is included. 13, P, 12, lines 6-7, justification, Tha mass Loading of 100 jiq/m? needs greater For example, the time period of sampling and the activities in progress for the 80 ug/m3 mentioned Later