-7especially in the absence of a proven need for such application. Pages 8-11 - The Hot Particle Problem - The comments of NRDC, Geesaman and Martell are addressed separately following their respective comments. Page 8, lines 12-17 - "For a discussion of the seriousness the hot particles problem we attach as Appendix II, E. A. Martell, "Basic Considerations in the Assessment of the Cancer Risks and Standards for Internal Alpha Emitters," (Statement presented at the public hearings on plutonium standards sponsored by the United States Environmental Protection Agency, Denver, Colorado, January 10, 1975)." Comments: Martell's conclusions are reached quite independent of those who advocate the "hot particle" hypothesis, Although he reaches similar conclusions the logic by which he justifies his position cannot be considered suportive of the "hot particle" argument (see Martell's comments, page 8, lines 11-22). Page 8, lines 25-27 - "It is highly likely that inhalation of very small amounts of plutonium gives rise to a high risk of lung cancer." Comments: There is no question that inhalation of sufficient quantities of plutonium will lead to lung cancer. “very small amounts. It is not clear what is meant by Research to determine the levels below which lung cancer is not seen is currently in progress. Page 8, line 27 to Page 9, line 2 ~ "And the DEIS completely fails to address the recent findings of Martell and others that hot particles may very well be a causative factor in a number of other disorders." Comments: The "...recent findings of Martell..." were presented at public hearings in Denver, Colorado, on January 10, 1975, as stated on page 8, lines 15-17, and were appended as Appendix II. These "...findings of Martell..." are reviewed separately (see "Comments on Appendix II: ‘Basic Considerations in the Assessment of the Cancer Risks and Standards for Internal Alpha Emitters'"). Page 9, lines 12-16 - "In addition, the 241an concentratiops ran e up to 8.2 pCi/g averaged over the tope 15 cm depth of soils, with Am/ 32py ratios varying widely and ranging up to 3.5 (NVO-140, Vol. 1, p. 507)."