- 20 0.004 to 0.31.

Even ifthe total quantity of plutonium in this sample

were concentrated in the top 1 cm of soil (a most unlikely situation),
the concentration would be 1.5 pCi/gm,

quite comparable to the Colorado

guidelines.

The recommendations for Enewetak are based upon reasonable constraints
to the living patterns and the diet of the people after their return.
Colorado criteria did not consider such factors,

Furthermore, the Colorado

values are not based upon any demonstrated health hazard to man, but rather

are based upon an arbitrary factor times the plutonium concentration in
Colorado soils resulting from world-wide fallout.

Page 12, Lines 4-6 - "It is noteworthy that the AEC has not established
that this standard is unduly conservative..."
Comment:

ERDA (AEC) has never recognized the interim plutonium

concentration in soil guidelines of the State of Colorado, nor are we
aware that any other Federal agency has recognized this guideline; such
guidance is not applicable to Federal property.

However, we do not dispute

the right of the sovreign State of Colorado to establish whatever guidelines
it wishes for applicability elsewhere within the state.

The lack of any

challenge on this issue should not be interpreted as tacit acceptance of
the guidelines, however.

Page 12, lines6-10 - ",.,it is not apparent that the AEC has requested

the ICRP or NCRP to make specific recommendations with respect to standards
for Pu in soils applicable to chronic exposure to the general public,
including children,"

Comments:

Contrary to the impressions of Dr. Martell, the ICRP and

the NCRP consistently have avoided giving guidance with respect to plutonium

contaminated soil.

Whether or not this response may change in the future is

a matter for speculation.

To date, however, no guidance has been forthcoming.

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