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
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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

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