,.. ,

US. DEPARTMENT OF ENERC
DATE

REPLY TO
ATTN OF

SUBJECT

To

December 9, 1980

13M?morandun

EV-30 GTN
rmSPS
Review of “Reevaluation of the Potential Radinlnaieal
for Residents Resettling Enewetak Atoll”, Draft, UCRL-53966

Bruce W. Wachholz, EV-30 GTN
I kno~’ this draft report on doses at Enewetak Atoll and the new
LLNL estimates of doses for Bikini and Eneu Islands at Bikini
Atoll represent a lot of work, but I have numerous reservations
regarding assumptions that are common to both sets of these
estimates. These reservations may be identified as follows:
1. I cannot support ti~e of dietary information commonly
referred to as the “Mitchell Coke Can Diet” (the MLS diet), as
an “average” diet for use in predicting average exposures which
are then used to estimate maximum exposures.
At every opportunity I have spoken against such use in any planning
estimates produced by DOE. The survey that produced this diet
was conducted on a portion of the population on Ujelang Atoll,
which was not a resettled population.
This survey produced new
and lower estimates of food intake (for most of the important
foods) than that used in the past. This survey was initiated
and conducted by Micronesia
Legal Services (!4LS),legal
representatives of the Enewetak people, with the assistance of
the school teacher on Ujelang Island. The procedure used in
this survey
was to ask Ujelang residents to fill out a
questionnaire in which estimates were made of how many 12 ounce
beverage cans of food (a volume equivalent to this) and liquids
each person was consuming.
To my knowledge this survey was not
based in any way on actual observations of use of food. Using
conversion factors, LLNL converted these volume estimates into
grams, and also into grams per day intake. This is certainly
a tortuous path to get at such important information.
So far
as
I know, no technical report has yet
been published on the MLS
diet and may never be, nor has there been any independent review of these critical new data or of their impact on dose
asses-sments and risks.
2. The MLS diet has two categories for coconut intake; fluid
and meat. Naidu’s diet (a diet based in part on actual
observation of food use by Jan Naidu, BNL, living with a group
of Marshallese) has six; milk, meat, water, flesh, husk,
embryo, and sap. The total “no imports” coconut intake level
for adult males (fluid and meat) has a mean value of 293 grams
per day in the MLS diet. The equivalent for all six items in
the Naidu diet (see his letter to Robison dated January 22,
1.980) is 929 grams per day. This is the low end of the range
of values obtained from Naidu’s study which applies to the case
of no imported food. Naidu’s dietary information was

Select target paragraph3