om re c Dose estimates for use in the Section 5 matrix presentation (Volume I) Shoula be those provided in the AEC Task Group report, not the estimates in "W-140 or estimates derived from equations presented in NV-140. Tass Croup report presents cstimates of maximum annual exposures for The individuals considering the most sensitive members of the population, and estimates of 30-year exposures for population groups living in various parts of the Atoll. ‘The NV~140 survey report does not contain all of these estimates. Jt is recommended that Tables 5-11, 5-12, and 5-13 be deleted, that Sections 5.6.1.1, 5.6.1.2 and 5.6.1.3 and Tables 5-8, 9-4 and 5-10 be revised using information from the Task Group report (Appendix IV, Section B, Volume II). It is also recommended that doses for bone inarrow, not bone, be used in all tables presenting maximum annual marrow criteria, and that AEC estimates of 30 year and maxinum annual doses for Bellic, the island having the highest predicted doses, be used for Case 1 wherever this appears instead of exposure estimates for an average individual for the entire Atoll. Estimates of exposures averaged over the entire Atoll aré not meaningful and should be deleted. Furtner detailed discussions on these points are presented in the enclosure. With regard to Section 5.3.1 on biological risk, the BEIR report estimates represent upper limits of risk. The risk at low dose rates may be zero. (See paragraph IV, pase 88, of the BEIR report.) It is recommended that estimates of risk in Table 5-14 be presented as upper limits and a foormnote added indicating that at low dose rates the risk may be zero. Th. risk estimates should be recalculated to account for revisions needed fc. estimates presented in Table 5-8 in calculation of 30-year dose. Furciher, based upon the suggested revisions for the 30-year and maximum annual duse estimates, a revision of Table 5-16 is in order to reflect these changes. The arguments presented in the statement opposing ocean dumping of contaminated wastes are in our opinion weak and unconvincing. The “difficulty of obtaining a permit and certainty of international com- plications," whether true or not, are insufficient grounds for rejecting ocv.in cusping as a viable waste disposal option. We note that the lnternational Atomic Energy Agency (IAEA) Board ‘of Governors! document, GOV/168S, of August 7, 1974, discusses in draft form the provisional definitiens and recommendations concerning radioactive wastes ocean ducping., This document is in relationship to the responsibilities entrusted ca TARA under the Convention on the Prevention of Marine Pollution by Pumping of Waste and Other Matter. For Case 3 in the cm -2-., 7 Warren D. Johnson