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%

Select target paragraph3