Warren D. Johnson

- 2 <,

Dose estimates for use in the Section 5 matrix presentation (Volume I)
Should be those provided in the AEC Task Group report, not the estimates
in NV-140 or estimates derived from equations presented in NV-140. The
Task Group report presents estimates of maximum annual exposures for
individuals considering the most sensitive members of the population, and
estimates of 30-year exposures for population groups living in various
parts of the Atoll. The NV-140 survey report does not contain all of
these: estimates.
It is recommended that Tables 5-11, 5-12, and 5-13 be
deleted, that Sections 5.6.1.1, 5.6.1.2 and 5.6.1.3 and Tables 5-8,
5-9 and 5-10 be revised using information from the Task Group report
(Appendix IV, Section B, Volume II). It is also recommended that doses

estimates of risk in Table 5-14 be presented as upper limits and a

footnote added indicating that at low dose rates the risk may be zero.
The risk estimates should be recalculated to account for revisions needed
for estimates presented in Table 5-8 in calculation of 30-year dose.
Further, based upon the suggested revisions for the 30-year and maximum
annual dose estimates, a revision of Table 5-16 is in order to reflect
these changes.
The arguments presented in the statement opposing ocean dumping of

contaminated wastes are in our opinion weak and unconvincing. The
“difficulty of obtaining a permit and certainty of international com-

on
|

With regard to Section 5.3.1 on biological risk, the BEIR report estimates
represent upper limits of risk. The risk at low dose rates may be zero.
(See paragraph IV, page 88, of the BEIR report.) It is recommended that’

- mm mre

for bone marrow, not bone, be used in all tables presenting maximum

annual marrow criteria, and that AEC estimates of 30 year and maximum
annual doses for Belle, the island having the highest predicted doses,
be used for Case 1 wherever this appears instead of exposure estimates
for an average individual for the entire Atoll. Estimates of exposures
averaged over the entire Atoll are not meaningful and should be deleted.
Further detailed discussions on these points are presented in the enclosure.

plications," whether true or not, are insufficient grounds for rejecting

ocean dumping as a viable waste disposal option, We note that the
International Atomic Energy Agency (IAEA) Board‘of Governors' document,
GOV/1688, of August 7, 1974, discusses in draft form the provisional

definitions and recommendations concerning radioactive wastes ocean
dumping. This document is in relationship to the-responsibilities
entrusted to IAEA under the Convention on the Prevention of Marine
Pollution by Dumping of Waste and Other Matter. For Case 3 in the

Qi

Select target paragraph3