DDOA Dr. Martin B. 14 MAY 1974 Biles or that no harmful effects would result from the proposed action. Contrary to this, the recommendations of this AEC Report can be viewed as non-compliance with the needs that the Enewetak people have clearly stated, specifically to occupy Enjebi Island. Unfortunately, the justification for these restrictions seem to be an unduly restrictive application of criteria that are largely arbitrary and probably inapplicable. First let us consider the applicability of criteria. With the radioactive contamination being beyond our ability to turn off or wholly eliminate, it is an uncontrolled localized contamination event , in the definition of the Federal Radiation Council (FRC). Being the release of radioactive material from nuclear explosions of many years ~~ ago, the Enewetak situation is Category III of p. 30 of FRC Staff Report No. 7. For this category, protective action is to be considered on a case-by-case basis (p. 38). Any situation resulting in a bonemarrow dose greater than 0.5 rad per year is to be appropriately evaluated. FRC Report No. 7 does not include any criterion for bone dose for this Category II1, but the present AEC Report numerically uses bone dose criteria to advise against the desired return of.the Enewetak people to use of other islands. the island of Enjebi and to advise against full This particular case of Enjebi should instead be individually evaluated on such bases as relative risks or cost vs. benefit that are recurrently requested in FRC reports. The present AEC Report seems wholly inadequate in such evaluations. Leaving aside this genuine question of whether quantitative application of criteria are grounds for decisions, one can review the bases of the numerical values of the radiological criteria on p. 5 of the present AEC Report. These are later used in the AEC Report to [he Federal Radiation Council Report No. 1 restrict the Enewetak people. establishes an occupational dose criteria which has been reduced from Both the level at which biological damage occurs vy a factor of 10. the Federal Radiation Council and the International Commission on Radiation Protection further reduce the dose levels for individuals ror in the population from the occupational level by a factor of 10. Enewetak, the AEC recommended exposure ieveis for individuals have been arbitrarily reduced by another factor of 2. This reduction resuits in an overall reduction from the levels at wnich minor biological effects Further the 4 rems limit in 30 have been observed by a factor of 200. from the recommended genetic reduction 80% an exposure, years for gonadal lives of the isotopes ot half the since apply to exposure, does not seem not provide the does then This years. concern are approximately 50 recurrent genetic dose for future generations beyond the present to generation which will return. “Corrected to 20%