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16

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solubility, optimal size particles for deep lung deposition; furthermore,
cases for both surface soil concentrations of plutonium and average soil
plutonium concentratims are calculated.
is apparent in that:

The conservatism of these factors

the average person is not likely to be constantly

exposed to an air dust loading of 100 we/m>s the plutonium content of the

air is not likely to continually be the same as that in the soil; all
resuspending particles of plutonium will never be of an identical and
optimal respirable size; particles of low solubility are considered to be
the more hazardous of the chemical forms of plutonium,
In view of the author's stated uncertainties it is not clear what
the basis is for the conclusions stated, or their derivation or justification.
In the absence of any of these it must be regarded as opinion.
Page 11, lines 15-20 - "Concerning the standard employed by the DEIS

for maximum permissible plutonium contamination of soils at Enewetak,

Dr. Martell points out that ‘There are no ICRP standards for soil Levels
of Pu and the actinides or for lifetime exposures to internal alpha
emitters.' (Personal Communication.) And he provides the following
critique of the standards adopted by the AEC Task Group for Enewetak:"
Comments:

Numerical values of radiation exposure and concentrations

of plutonium in soil were recommended by the Task Group as guides for use
in evaluating radiological conditions at Enewetak Atoll only.
were not intended as and are not to be considered as standards.

Such guides
These guides

were used as limits in evaluating remedial action options in order to recommend actions and restrictions that will ensure that exposures of people when
they return will not exceed the basic FRC, ICRP, and NCRP standards.

These

considerations are the basis for actions and restrictions recommended in the
DEIS.

While there is no national or international standard for plutonium

expressed as a concentration in soil, the guides recommended, 40 and 400 pCi/g,
were derived using the best current information relating such soil concentrations
to possible exposure to man.

The guidance for cleanup of contaminated soil

Select target paragraph3