CO C 14 MAY 1974 DDOA Dr. Martin B. Biles or that no harmful effects would result from the proposed action. Contrary to tnis, the recommendations of this AEC Report can be viewed as non-compliance with the needs that the Enewetak people have clearly stated, specifically to occuny Eniebi Isiind. Unfortunately, the justification for these ~estrictic:s seem to be an unduly restrictive application of criteria that are largely arbitrary and probably inapplicable. First let us consider the anplicability 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 or 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 III, but the present AEC Report numerically uses bone dose criteria to advise against the desired return of the Enewetak people to the island of Enjebi and to advise against full use of other islands. This particular case of Enjebi should instead be individually evaluated on such bases as relative risks or cost vs. oenefit 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 ror 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 restrict the Enewetak people. The Federal Radiation Council Report No. establishes an occupational dose criteria which has been reduced from the level at which biological damage occurs by a factor of 10. Both the Federal Radiation Council and the International Commission on Radiation Protection further reduce the dose levels for individuals in the population from the occupational level by a factor of 10. For 1 Enewetak, the AEC recommended exposure levels for individuals have 7 been arbitrarily reduced by another factor of 2. This reduction results in an overall reduction from the levels at which minor biological effects Further the 4 rems limit in 30 have been observed by a factor of 200. years for gonadal exposure, an 80% reduction from the recommended genetic exposure, does not seem to apply since the half lives of the isotopes of concern are approximately 30 years. ‘This then does not provide the recurrent genetic dose for future generations beyond the present generation which will return. “Corrected to 20% me ert ema oe ~~ . ™e, 7 cat wee wee mm . ~ Ty ’ 1 Dee. DORRETE wwe wa : ayn ome, aR Met eee — ' > . eet ge Lats + a ss 8 data. ‘ WO ae tf