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Leo M. Krulitz
October 30, 1970
Page Four

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clearly pointed out to the AEC that the PAGs applied and
that the “particular case of Enjebi should be . . .
individually evaluated on such bases as relative risks or
cost v. benefit . . .“ “The present AEC Report,” he went
Letter,
on, “seems wholly inadequate in such evaluations.”
I
would
J. W. McEnery to Martin B. Biles, May 14, 1974.
have had General McEnery make the related point that the
RPGs do not apply at all. He did not, but his advice was
quite sound all the same.
The Environmental Protection Agency gave the AEC essentially
the same counsel,, saying that “numerical values for the
dose limits are only preliminary guidance and . . . a
cost-benefit analysis must be undertaken . . .“ Letter,
W. D. Rowe to Martin B. Biles, USAEC, May 17, 1974.
The facts essential to a relative risk or cost-benefit
analysis were all there, but despite the unanimous advice
it was given, the AEC chose to decide the matter on the
(We pointed out in “Radiation
basis of the modified RPGs.
Protection at Enewetak Atoll” that neither AEC or EpA has
any authority to modify radiation protection standards.
Only the ‘President can do that.) When the modified standards
were applied to Enjebi, the AEC found that the projected
doses would be “near or slightly above the radiation
criteria” and on that basis rejected that alternative.
EIS, vol.
II, Tab V, p. 23. Under Case 4, residence on
Enjebi was expected to increase the 30 year cancer risk
from 0.3 cases to 0.8 cases. EIS, Vol. I, Table 5-13,
p. 5-51. The Task Group Report did not make this kind of
comparison, but it did recognize explicitly that at the
dose levels of concern the risk of harm was comparatively
16W . EIS, Vol. II, Tab B, p. 111-12 to 111-13. Nonetheless,
the AEC clung to the security of the RPGs.
Now , in light of the foregoing, what does the National
Environmental Policy Act of 1969 require of us? We were
the first to suggest that NEPA is applicable here and that
an environmental impact statement was required for this
I will not trouble
project.
That is a matter of record.
you with the details, but simply mention that we insisted
that the NEPA requirement of an impact statement for every
“major federal action significantly affecting the quality of

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