fiants are advised by their counsel that ERDA-AEC
representatives attributed the contents of Table 2 to the
Enawetak Survey at meetings at Livermore, California on
Rsgust 12, 1975 and in private conversations between Allen
and Gudiksen and Ray in the Marshalls in September, 1975.
Affiants can state flatly that Table 2 bears no
resemblance to any probable life-style of future Bikini
residents.

The estimates of time to be spent in the interior

of the island are far too low and the estimates for time
to be spent on the beaches and lagoon are far too high.
AZfiants understand clearly that these estimates have been
used for computer analysis of probable external gamma
radiation dose estimates and that the integrity of the conclusions in the document rests entirely on the validity of
Table 2.

In the judgment of affiants, Table 2 is utterly

lacking in validity.

It contemplates a life-style with

an unrealistically high amount of time to be spent on the
beach and lagoon, where external gamma radiation is apparently

low and with an unrealistically low amount of time to be
‘spent in the interior of Bikini Island, where radiation is
extremely high.
Because we understand representatives of ERDA-AEC
bese Table 2 on Enewetak data (see footnote 1, page six,
English version, specifically attributing the data to the
Erewetak Survey), we compared Table 2 to the comparable
vaterial in the Enewetak Survey,

set forth at page 33 of

Volume I.
“Ne find no valid resemblance between Table 2 and the
contents of Table 4 at Volume I, page 33 of the Enewetak Survey.
= photocopy of that Table is attached for comparison.with
Tasle 2, a copy of which is also attached.

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