Need for guidance on use of 3 x 10°~ 5 or 1073 as GT coefficient for 239 240py, 4(a), line 1. Why is it assumed that plowing will reduce the surface soil concs by a factor of 2. If the Pu is on the surface only, than the reduction for inhalation purposes will be much more than 2. p.2, line 9. The statement that the transuranics are "...readily available ...tO man..." iS wrong. Generally, there are a number of discriminations against them. p.3, line 6. The value of 2 liters of drinking water per day seems high as compared to the ICRP reference man. p.3, lines 13-14. Is there evidence to support it? Here a plutonium to americium ratio of 2 to 1 is assumed. Surely with the number of measurements that have been made, a better value could be chosen from the data. The ratio chosen appears to give much more americium than I would have expected. p.3, lines 16-18. Is there a basis for the assumption that one-half of the surface transuranic concentrations will be in the root zone? I would guess that in undisturbed areas it would be less and in disturbed areas it could be greater. p.5, line 4. The potential impact of plowing should be considered. A reference should be given to the work of Stuart. The co- efficient 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 FPA made no attemntto. justify their numbers and they appear to be assumed. In particular, there seems to be no justification for using a higher uptake for *38Pu, except, possibly, with 238Pu0, particles. In fact, Weeks, et al., in 1956 reported on uptake from nitrate solution over a range of 0.019 to 140 yg intake with no difference in uptake. Plutonium-238 was used to obtain the low mass feedings.