- 17 - was selected such that exposures of people are expected to be well within the basic standard. This guidance has been approved by EPA for use at Enewetak. The statement that, "There are no ICRP standards...for lifetime exposures to internal alpha emitters," is in error. All ICRP standards for internal emitters are based upon the assumption of lifetime exposure. Page 11, line 21 to Page 12, line 4 - "The recommendation that plutonium contaminated soils, with levels not exceeding 40 pCi 239+240pu/g of soil averaged over 15 cm depth, is suitable for human habitation, can be very seriously questioned, "The State of Colorado Board of Health has adopted interim standards for Pu contamination limits in soils in land areas for residential use, specifying that 238pu levels shall not exceed 2 dpm (0.91 pCi) per gram of surface soil (i.e., averaged over the top 1 em depth of soil)." caer: Comments: The information quoted from Dr. Martell's "personal communication" relative to an interim standard for plutonium in soil adopted by the State of Colorado Board of Health is grossly misleading. The guidance referred to does not apply to cleanup or removal of soil containing plutonium or to restrictionson use of plutonium contaminated lam as Dr. Martell's communication implies. After conduct of an appropriate hearing, the Colorado Board accepted 2 dpm/g or 1 pCi/g of plutonium in soil as requiring special techniques of construction upon such property. These special techniques are intended to minimize plutonium resuspension by construction activities. This guidance is irrelevant to development of plutonium cleanup guidance for Enewetak Atoll. PPO MACON FS RYHMEREM KPO ROE INE 0SNER MR ORT Fn OO TT