Martin B. Bilee — | -6- approved site and permit, are far more certain and implementable. There are no blind restrictions, no barriers or time consuming hearings, and decisions are to be made on the merits of the situation. This guidance in my view will lead to balanced judgements and actions, by otherparticipating nations, which are reasonable and beneficial toman. By contrast, the U.S. Act and EPA Regs. are biased and unreasonable and not necessarily in the best interest of the U.S. people. : ‘ The U.S. Act and EPA Regs. in my view are preventing the interested and responsible Federal agencies from considering the real issues and merits of the case for protecting the Enewetak people, and are forcing an arbitrary decision to bury contaminated materials on land at Enewetak Atoll when the best solution by far for the Enewetak people is burial in the nearby deep ocean. It appeare to me, that the one-time disposal of contaminated soil and acrap, at the levels we have found at Enewetak, is not really the kind of dumping the International Regulations were intended to control much less prevent. I make this final point to show how different the intent of International Regulations seems to be compared to what we have found in discussions with EPA. Part A of Enclosure II shows that IAEA has gelected 10 Ci/t for alpha wastes with a half life greater than 50 years, as the concentration above which such wastes would be considered unsuitable for dumping at sea. This concentration can be averaged over an amount of contaminated material not exceeding 100 tonnes. The dumping rate for such concentrations can be any amount up to 100, 000 tons per year at any one site. The highest level of 23954 in any soil sample analyzed from the island having the highest levels st Enewetak was about 3,000 pCi/g. The deat>, ' ‘ ett ee eee ee a et in NVO-140 on alpha emitters in soil.indicate that the ratio of 259= Lib / 23854 varies widely having values from about 2/1 to 50/1. The ratio of 239-240Py/24] Am has a value of about 10/1. Thus, it would not result in too great an error to leave 233Py and 241 Am alpise activity out of waste disposal estimates. If my arithmetic is correct, (see Enclosure VII) 3,000 pCi of 239Puina gram of soil is about 3, 0006 times less than the IAEA limit of 10 Ci/t averaged over 100 tonnes of soil. To carry this further, the 100,000 tonnes permiited to be dumped at One site in onc year at an average concentration of 10 curics per ton, would amount to 1,000,000 curies or 1 MCi. Since 1 curie of ae weighs|16 grams, 1 MCi would amount to 16, 000, 000 grams or 16, Co kg of 239Py, The total quantity of contaminated soil at Enewetak reorrices Jo . ccectntusasssicecannef esse seceaeesnvasinms sf sey vrsntnttntnsneie ee Lo. mama fe femaifstn vewncumnneneaf isin sin vo OATES Porm ANC.318 (Rev. 9-53) AECM 0240 VY U. 83 GOVERNMENT PRINTING OFFICE: IP7a-H26.106 .