- 16 - 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