-?21As stated above, FRC, ICRP and NCRP have all-taken the position that there can be different guides with different numerical values for different circumstances; in other words, each situation is unique and must be considered in relation to its specific characteristics, Page 12, lines 15-20 - "...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 39pu/g, whereas the average over 15 cm depth is about 60." Comments: While Dr. Martell is correct that “for most Enewetak soils the top cover contains substantially higher levels of Pu per gram than the 15 cm depth average," there are also locations where higher plutonium concentrations are found below the top cover of soil (Janet, locations 135, 142, 143, 144, 901; Irene, 24, 27, 51, 100; Alice 24; Belle, 35, etc.). None of these islands are expected to be inhabited islands. Comparison with the Colorado guidelines, therefore, are grossly misleading. Furthermore, the recommendation of the Task Group clearly states that there should be, "Recovery of plutonium in soil at concentrations greater than 400 pCi/g 2392405, at_any depth these levels are found. Also, recovery of contaminated soil sufficient to reduce surface levels to a value well below 40 pCi/g 239,240), 0 (p. 5-80, Vol. I; emphasis added), Page 12, lines 23-26 - "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." Comments: There are no recent research developments of which we are aware that are expected by knowledgeable experts “to lead to reductions in of Pu : acceptable organ burdens/in man by a factor of 100 to 1000 or more.” If Dr. Martell is aware of research data which would justify such changes,