- 22 it would be expected -v be distributed to the scientii.c community so that the ICRP and NCRP might consider the implications, Page 12, line 26 to Page 13, line 3 - "In my opinion it is likely that a 10 pCi lung burden of insoluble alpha emitting particles will give rise to significant adverse health effects for lifetime exposures." Comments: Similarly, if Dr. Martell has evidence that "a 10 pCi lung burden of insoluble alpha emitting particles will give rise to Significant adverse health effects for lifetime exposures," we would expect to have such data presented scientifically. Until such time as evidence is available, these conclusions remain as stated by Dr. Martell as "my opinion." Page 13, lines 14 to Page 14, line 6 - "Drs. Cochran, Tamplin and Geesaman all raise the same or similar cbjections to the DEIS plutonium standards, "Further explanation of the plutonium cleanup criteria developed by the AEC Task Group is necessary. (DEIS, Vol. II, Tab B, pp. ILI-8 to III-l1.) We have already mentioned the questionable wisdom of the 40 pCi/g standard. For any concentrations exceeding 400 pCi/g the Task Group recom- mendations require removal of the soil. But in the range between 40 and 400 pCi/g, the DEIS standards call for 'corrective action ..... on a caseby-case basis.' (Vol. II, Tab B, p, III-9.) Certain criteria are offered for guidance in the exercise of this judgment, but they appear to be entirely too unspecific and subjective. Once a decision is made to take corrective action, the objective is to achieve a substantial reduction in plutonium soil concentrations, and further, to reduce concentrations to the lowest practicable level, not to reduce them to some prescribed numerical value. (Ibid. Emphasis added.)" Comments: As stated in the DEIS, decisions regarding corrective action . : . . . 239,240 for plutonium concentrations in soil between 40 and 400 pCi/gm Pu will be on a case-by-case basis. Many specific factors enter into such a decision for which definite statements and numbers are inappropriate: location, environmental factors (e.g., wind and wave action); soil matrix; soil use; frequency and duration of human, animal or crop contact; risk/benefit balance; significance of removal, etc. To establish predetermined criteria for those and other variables is unrealistic. Judgment must be used to determine what can be done without doing more harm than good. LEO EY CEO ENTETOS: SONI MARYFERRY Aanimaom