75 Statement to “Preliminary Report, Rongelap Reassessment Project", April] 15, 1988 April 15, 1988 page 3 of 4 According to the model used by LLNL, about 6 people would be exp sed to doses above the 500 millirem per year limit quoted by the DOE. Second, the DOE declared Rongelap Island to be unconditionally safe. However, the dietary assumptions used in the dose estimates show a high degrep of imported (non-radioactive) food, thus lowering the intake of local food. (radioactive? The degree of imported food in the diet is not a natural constant but debends, among phased out. other things, on the existence the of U.S. food program which is being If habitability is defined as “possibility of full usage of Rongelap Isfands natural resources for food", the Island is not habitable even by DOE’s dose standards. If Rongelap people would live on local food only, for whatever reason,| doses would exceed DOE’s dose limits. What is the radiation dose? Suppose that the amount of local food consumed is kept at the What is the radiation dose for the Rongelap people? I agree with Dr. 4978/82 level. Hohn that the direct measurement of radioactivity in the human body is the preferred |method. However, Dr. Kohn’s assessment of the average dose with 1.25 rem cdmmitted dose equivalent ("whole-body dose") over 30 years represents only one posgible scenario and has two major deficiencies: ® It is based on extrapolation from the 1979 average body burdan of 175,000 picocuries of cesium-137. In 1982, the average body burden] was 240,000 picocuries (see Fig. 4.3#1), probably due to increased uptake Taking 1982 as the baseline, the cesium-137 dose estimate would ® df local food. wicrease from 0.62 to 0.85 rem (see Table 4.5#1). Kohn’s estimate of plutonium dose is premature and scientifically questionable. For an accurate estimate of plutonium doses from urine data, afi urine data has to be interpreted (including the data on children) and the length of residence has to be taken into account. Kohn’s assumption of a 20 year continuous daily intake is not substantiated by the data ahd leads to underestimates of body burdens. Furthermore, at interest is thelaverage and the maximum, not just the median dose which is referenced by Kolin. An alternative dose estimate can be derived from the estimate of plujonium doses for the Bikini population where urine data was interpreted for a subgroup of 16 individuals which had plutonium levels above the detection limit. In thdse 16 cases, individual residence time was accounted for, whereas this was not the case with the Rongelap urine data. According to Dr. Lessard from BrookhaYen National Laboratories, the average annual committed effective dose due to plutbnium-239 is estimated with 0.25 rem. Since on Rongelap, average soil concentrations are 3.4 lower than on Bikini (see Table p.83), I would extrapolate an average plgtonium dose for Rongelap people with 0.075 rem annual committed effective dbse due to Plutonium-239. The dose from plutonium-240 and americium-241 would We about the same. The total dose due toe transuranics could well be 0.15 rem annus] committed effective dose or 4.5 rem over 30 years. ® My alternative dose estimate would thus be 0.85 rem (cesium-1 7), 4.5 rem {transuranics), 0.021 rem (strontium-90), and 0.59 rem (external), 2 total of SR rem. This dose would then be above the DOE limit of 5 rem in 30 years. S°9