Leo M. Krulitz October 30, 1970 Page Four clearly pointed out to the AEC thgt 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 on, "seems wholly inadequate in such evaluations." Letter, J. W. McEnery to Martin B. Biles, May 14, 1974. I would have had General McEnery make the related point that the RPGs do not apply at all. quite sound all the same. He did not, but his advice was 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 . . W. D. Rowe to Martin B. Biles, USAEC, May 17, . "Letter, 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 basis of the modified RPGs. (We pointed out in "Radiation 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. p. 5-51. EIS, Vol. I, Table 5-13, 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 low. EIS, Vol. II, Tab B, p. III-12 to III-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 project. That is a matter of record. I will not trouble 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 ALAP: ms ALARA