Supporting AEC Comments on the Defense Nuclear Agency Draft Environmental Impact Statement on the Clean-up, Rehabilitation, Resettlement of Enewetak Atoll - Marshall Islands 1. Dose Estimates A severe deficiency in the DEIS concerns the dose estimates presented in matrix form in Tables 5-8, 5-9, 5-10, 5-12, 5-13, and 5-16 and the associated material in Sections 5.6.1.1, 5.6.1.2 and 5.6.1.3. The following estimates of radiation dose and an evaluation of these estimates using the recommended radiation criteria were provided in the AEC Task Group report: 30-year whole body dose (for a population living in various parts of the Atoll). 30-year bone dose (mineral bone). Maximum annual whole body dose (considering the most sensitive individual). Maximum annual bone marrow dose (considering the -most sensitive individual). These estimates appear in Section B, Volume II of the DEIS. We have anticipated that the dose most likely to be exceeded at Enewetak is the annual dose to bone marrow. Thus, bone marrow dose for the most sensitive individuals in the population is the critical dose for comparison with cleanup radiological criteria. Estimates of bone marrow dose were developed during Task Group deliberations and do not appear in NV-140. The AEC Task Group rejected the concept of averaging annual doses over the Ce entire Atoll or over the entire population. This is of particular importance for the case where it was assumed that there was no clean-up with islands used for permanent residence without regard to radiation and radioactivity levels * (Case 1). The DEIS matrix presents no information on annual bone marrow doses, presents doses for an “average individual on entire Atoll" for some clean-up options (cases) and presents maximum annual values for bone that were calculated using an equation in NV-140 that is considered adequate only for determining 30-year doses. (Other models are now used in calculating maximum annual doses to bone and bone marrow that accommodate important changes that occur with time and with aze of the individual.) Thé-following examples show reasons why we cannot agree with the DEIS presentation of doses in Section 5, “Cleanup and Habitation Alternatives," unless the presentation is appropriately modified. Table 5-8, page 5-50 DEIS Case 1 WB= 6 Rem in 30 years Bone= 60 Rem in 30 years These were determined for an average individual in the entire Atoll. wan ay AEC Case 1 WB= 31 Rem in 30 years -Bone= 220 Rem in 30 years