-
37
-
of complex processes serve to make this procedure an almost
useless exercise."
Comments:
While we agree that there are uncertainties in the procedures
which the author describes, we do not agree with the author's opinion
that such calculations are useless exercises.
Where uncertainties
exist conservative factors are utilized, thereby overestimating any
potential hazard.
Because of this procedure, any errors are likely
to be in the direction of conservatism.
Page 17, lines 5-8 - "For this reason, surface soils with one
picocurie of plutonium per gram (the Colorado interim soil standard)
should contain an estimated 10 to 100 pCi of plutonium per gram of
insoluble soil particles of respirable size."
Comments:
The conclusion again is a supposition of the author for which
no evidence is presented, as is suggested by the word "should."
and justification of
Furthermore, the evidence for/the relationship between plutonium
per gram of soil and plutonium per gram of insoluble soil particles
of respirable size is not clear,
Page 17,
lines 8-11 - "Such a soil level should lead to plutonium Lung
burdens of 5 to 50 picocuries by age 20, or 15 to 150 picocuries by age
60, with correspondingly higher concentrations in the lymph nodes,
liver and bone."
Comments:
Again, the sentence is speculation ("should") by the author.
It
would be of interest to know how this conclusion was arrived at without
using the surface soil concentration, applicable resuspension factors,
inhalation exposure patterns, particle size distributions, etc., etc.
which the author described on page 16, lines 14-21, as being "almost
useless,"