* U8, GOVERNMENT PRINTING OF FICH: Mrs. Ruth Van Cleve the gonadal dose. 1978-RE 2-897 - 2 - This averaces out to 170 millirem per year. However, CONCURAENCES tr RIG. SYMBOL the FRC also recognized that if the “...probable benefits..." to be derived from exceeding these guides were greater than "...the potentfal [ZL f°"" having jurisdiction over the matter has carefully considered the reason for doing so in light of the recommendations...". megegri risk...” involved, exposures greater than these values could be justified }-------—— "The...radiation dose...should not be exceeded without careful consideration of the reasons for doing so; every effort should be made to encourag@wcverscthe maintenance of radiation doses as far below this gufde as practicable] And further, "The Guides may be exceeded only after the Federal agency faeen Because of the uncertainties inherent in predicting the radiation exposur¢arcivne— levels to which the Enewetak people may be subject upon their return to Enewetak Atoll, the Atomic Energy Commissfon (AEC) Task Group Report PRCTOTe included in the Enewetak Environmental Impact Statement (EIS) recommended that exposure limits for the Enewetak people be lower than FRC radiation fw exposure guidance in order to provide a reasonable margin of safety. For planning purposes, in place of the 500 millirem per year value for [erecevssor the individual, 250 millfrem per year was recommended; and in place of the genetic dose of 5000 milltrem over 30 years, 4000 millfrem over 30 TRIS TACST STE years was reconmended. Regarding radiation exposure limits for the Enewetak people, Dr. William Mills of the Environmental Protection Agency stated in a letter to the AEC dated February 28, 1974, that: "These Trust Territory people are entitled to as much protection as that afforded residents of the U.S. by the Federal Radfation Protection Guides." With respect to the recommended exposure limits stated in the EIS, the Region IX EPA comments on the EIS dated December 12, 1974, Stated that they considered them to be ",..upper limits...". However, in a meeting held in your office on August 2, 1979, Mr. Todd Joseph of EPA's Office of General Counsel and Dr. Mills of EPA both stated that the 1974 EPA letters expressed public health views and not legal views. ire,syMoou TaiTiAcsy wee fsste77--— Tare.svuuou [vnmacrsie7 ae DATE It also should be noted that the FRC recommended that occupational} exposure of the whole body be limited to an average of 5000 milltrem Daye.s¥mpou per year beyond 18 years of age (ji.e., "...five times the number of years beyond age 18"). The previously quoted FRC statement pertaining pawTiALs)sia. to the possible need for exceeding the guidance and for the desirability of limiting exposures to levels betow the guidance is pertinent here DATE also (i.e., "The...radiation dose...should not be exceeded without careful consideration of the reasons for doing so; every effort should be made to] rte. symcot encourage the maintenance of radiation doses as far below this guide as practicable."). [ INITIALS) S16 ae een DATE DOE FORM AD-9 (12-77) 50 5 9 h | OFFICIAL FILE COPY