* U8, GOVERNMENT PRINTING OF FICH:
Mrs. Ruth Van Cleve
the gonadal dose.
1978-RE 2-897
- 2 -
This averaces out to 170 millirem per year.
However,
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the FRC also recognized that if the “...probable benefits..." to be
derived from exceeding these guides were greater than "...the potentfal
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having jurisdiction over the matter has carefully considered the reason
for doing so in light of the recommendations...".
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risk...” involved, exposures greater than these values could be justified }-------——
"The...radiation dose...should not be exceeded without careful consideration of the reasons for doing so; every effort should be made to encourag@wcverscthe maintenance of radiation doses as far below this gufde as practicable]
And further, "The Guides may be exceeded only after the Federal agency
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Because of the uncertainties inherent in predicting the radiation exposur¢arcivne—
levels to which the Enewetak people may be subject upon their return to
Enewetak Atoll, the Atomic Energy Commissfon (AEC) Task Group Report
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included in the Enewetak Environmental Impact Statement (EIS) recommended
that exposure limits for the Enewetak people be lower than FRC radiation fw
exposure guidance in order to provide a reasonable margin of safety.
For planning purposes, in place of the 500 millirem per year value for
[erecevssor
the individual, 250 millfrem per year was recommended; and in place of
the genetic dose of 5000 milltrem over 30 years, 4000 millfrem over 30
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years was reconmended.
Regarding radiation exposure limits for the Enewetak people, Dr. William
Mills of the Environmental Protection Agency stated in a letter to the
AEC dated February 28, 1974, that: "These Trust Territory people are
entitled to as much protection as that afforded residents of the U.S.
by the Federal Radfation Protection Guides." With respect to the recommended exposure limits stated in the EIS, the Region IX EPA comments on
the EIS dated December 12, 1974, Stated that they considered them to be
",..upper limits...". However, in a meeting held in your office on
August 2, 1979, Mr. Todd Joseph of EPA's Office of General Counsel and
Dr. Mills of EPA both stated that the 1974 EPA letters expressed public
health views and not legal views.
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It also should be noted that the FRC recommended that occupational}
exposure of the whole body be limited to an average of 5000 milltrem
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per year beyond 18 years of age (ji.e., "...five times the number of
years beyond age 18"). The previously quoted FRC statement pertaining
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to the possible need for exceeding the guidance and for the desirability
of limiting exposures to levels betow the guidance is pertinent here
DATE
also (i.e., "The...radiation dose...should not be exceeded without careful
consideration of the reasons for doing so; every effort should be made to] rte. symcot
encourage the maintenance of radiation doses as far below this guide as
practicable.").
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DATE
DOE FORM AD-9 (12-77)
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