- 33 inte a Page 17, lines 11-13 - "Thus the Colorado/soil standard is hardly a safe or acceptable standard unless it can be shown that such levels of plutonium have no serious long term health effects." Comments: Assuming thepreceding assumptions to be fact, the author now states that, "Thus..." This conclusion is no more valid than the assumptions upon which it rests, for which no evidence is presented, Page Li, line 20-25 - "Thus the high tumor risk for the hot 238pu09 particles can be variously attributed to (a) the mobility of the smaller particles (b) the recoil ablation and/or dissolution rates which increase with specific activity and with surface area of hot particles and (c) the irradiation or Larger numbers of cells with scattered protons (an effect that may be significant for very hot particles). Comments: The reference to "the hot 238 Pud, particles (1D is misleading. As was stated previously (see author's page 8, lines 9-11), the material used was neither 238510 2 sn 2 385y, to be "monomeric" nor in particulate form, but was considered : . Furthermore, the author's definition of "hot...particles" here is not clear. It is the "monomeric" 238pu, with its consequent exposure of more’ target' epithelial cells" which reference ll attributes as the cause of the higher tumor incidence. Recoil ablation, scattered protons, etc. are not discussed in reference 11. ; . Page 18, lines 1-4 - "For these reasons, the insoluble alpha emitting smoke particle, uranium oxide, thorium oxide and other alpha emitting particles of moderate to low specific activity may be expected to give rise to a higher tumor risk per alpha disintegration or for a given cumulative dese."