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verified in practice. What DOI needs is practical advice based
on realistic assumptions, advice that supports decisions in a
way that no retraction is needed later. DOE not only needs to
answer questions that DOI asks, but also needs to answer
important questions not asked. We must avoid answering
questions in a way that DOI does not comprehend the whole
problem.
I must express particular concern when I observe that both of
the conservative elements described above have been dropped in
DOE’s current dose assessments/evaluations . The lower radioactivity intake levels inherent in the MM diet lead to dose
assessments that are not~s conservative as in the past, and
evaluating such dose as~essments against standards using 500
mrem/year and 5,000 mrem\30 year, and not the 250 mrem/year
and 4,000 mrem\30 year developed for the Enewetak cleanup and
rehab project, leaves no room for error. In the face of the
important decisions that will be based upon LLNL’s report
(and particularly when we cannot know what uses and misuses
may be made of the report) , it is not enough to state that
dietary assumptions are “critical” or “extremelv important” and
that doses fo~ some individuals may be higher tfian~redicted.
Since the primary concern is health and safety of people, one cannot base go-no go resettlement decisions only on average dose to
the average population.
This only has meaning for the dose
standard for 30 years. One must also limit doses to individuals, even those individuals who for one reason or another
get doses much higher than the average.
If one looks at the draft objectively, one sees that we are
using assumed living patterns, an average diet based upon a
questionnaire and not upon any measurements or observations,
and average levels of radioactivity in foods that are predicted, not measured.
With all these uncertainties, good
practice would say predict on the high side and state that
doses may be lower. We should be able to state that this report
contains conservative estimates of dose, that there are uncertainties

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