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Department of Energy Enewetak Advisory Group Member In accordance with the requests for information made during the meetings of June 7 and 8, 1978, at LLL, 1 am enclosing for your use the following A. Package of eleven schedule 189's which identify DOE work in the B. Letter of December 9, 1974, from Dr. J. Liverman to W. Johnson, DNA, concerning the Draft Environmental Impact Statement on the Enewetak concerning the interpretation of ocean dumping regulations. D. Memorandum for Record of February 25, 1974, from A. Futral (DNA) on the interagency meeting of February 24, 1974, discussing disposal methods for the Enewetak cleanup operation. E. Summary of Bikini Whole Body Counting Results for 1977 and 1978. This is the raw data prepared by BNL. Surveillance Projects Branch Division of Operational and BEST COPY AVAILABLE
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ATOMIC ENERGY COMMISSION Lieutenant General, USAF Dnfcnoe Nuclear Agency Dear General Johnson: This is in response to your letter of September 3, 1974, transmitting to the U. S. Atomic Energy Commission (AEC) the Draft Environmental Impact Statement (DEIS) prepared under supervision of the Defense Nuclear Agency (DNA) for the proposed cleanup, rehabilitation, and resettlement of We have reviewed the Statement and are providing the following comments, and the enclosure of supporting consents for your consideration in preparing the Final Statement for this proposed action: In general, the DEIS reflects'a careful and thorough study of the possible cleanup of Enewetak Atoll and the future return of the people. We agree that the Case 3 approach, as presented in the DEIS, should be the preferred option for the cleanup project. This approach is based on successful past experience, appears to be feasible, and ensures the health and safety of the people insofar as "practicable. Further, the quantity of material requiring disposal is more manageable than in Cases 4 and 5, and the residual levels of contamination would not appear to be hazardous judging from present knowledge of contaminated levels in soils. The presentation of the AEC radiation exposure criteria is satisfactory; however, the term "standards," as used throughout the DEIS is inaccurate to describe the AEC criteria and should be' replaced by the word "guidelines." While those radiological criteria are based upon current national and international standards (see AEC Task Group Report, Volume II, Appendix R) we view them only as guides for the Enewetak cleanup project. The AEC Task Group report clearly indicates that ad hoc guidelines, derived from the existing recognized standards,were required and formu lated for the particular conditions existing at Enewetak Atoll and because future human habitation was planned for there. We further note that the plutonium guideline numbers, while having no particular scientific basis for establishing a standard, appear to be reasonable for the particular conditions existing at Enewetak Atoll.
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Dose estimates for use in the Section 5 matrix presentation (Volume I) ^should be those provided in the AEC Task Group report, not the estimates in ?IV-140 or estimates derived from equations presented in NV-140. The Task Croup report presents estimates of maximum annual exposures for individuals considcrinp, the most sensitive members of the population, and estimates of 30-year exposures for population groups living in various parts of the Atoll. The NV-140 survey report does not contain all of these estimates. It is recommended that Tables 5-11, 5-12, and 5-13 be deleted, that Sections 5.6.1.1, 5.6.1.2 and 5.6.1.3 and Tables 5-8, S-1! and 5-10 be revised using information from the Task Group report (Appendix IV, Section E, Volume II). It is also recommended.that doses for bone narrow, not bone, be used in all tables presenting maximum annual marrow criteria, and that AEC estimates of 30 year and maximum annual doses for Eelle, the island having the highest predicted doses, be used for Case 1 wherever this appears instead of exposure estimates for an average individual for the entire Atoll. Estimates of exposures averaged over the entire Atoll are not meaningful and should be deleted. Furtner detailed discussions on these points are presented in the enclosure. With regard to Section 5.3.1 on biological risk, the BEIR report estimates renresont upper limits of risk. The risk at low dose rates may be zero. (See paragraph IV, page 88, of the BEIR report.) It is recommended that esrimates of risk in Table 5-14 be presented as upper limits and a footnote added indicating that at low dose rates the risk may be zero. Th. risk estimates should be recalculated to account for revisions needed fc estimates presented in Table 5-8 in calculation of "30-year dose. Further, based upon the suggested revisions for the 30-year and maximum annual dose estimates, a revision of Table 5-16 is in order to reflect The arguments presented in the statement opposing ocean dumping of contaminated wastes are in our opinion weak and unconvincing. The "difficulty of obtaining a permit and certainty of international com plications," whether true or not, are insufficient"grounds for rejecting oclan dumping as a viable waste disposal optionv We note that the International Atomic Energy Agency (IAEA) Board of Governors' document, GOV/]685. of August 7, 1974, discusses in draft form the provisional definitions and recommendations concerning radioactive wastes ocean uu'-oing. Tills document is in relationship to the responsibilities entrusted to IAEA under the Convention on the Prevention of Marine Pollution by Pumping of Waste and Other Matter. For Case 3 in the
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DEIS, even if one assumed that 79,000 cubic yards of Atoll soil containing an average of 1 nCi/gra of Pu^-^ were dumped into the ocean, it would represent only about 75 Ci for this one time action. This is far below the opper disposal limit of 1010 Ci/year for alpha wastes Without necessarily advocating ocean dumping, we note that it is considered by some to be the best solution to this problem and one of the least costly. Indeed, the ocean water already has a certain access to the plutonium in Enewetak Atoll and disposal in the deep ocean would only represent removal of the plutonium to a safer marine location which, because of its remoteness, would minimize the chance of human exposure. We therefore recommend that the pertinent sections on the DEIS be rewritten to leave the ocean dumping option open. Furthermore, we believe that return of this debris to the United States for burial would be unacceptable and that burial on an island in a concrete-capped crater would require periodic followup that for practical purposes would last forever. Specific comments related to ocean dumping and encryptment are included in the enclosed Staff Comments. In the discussion of the "Impact of Blasting During Cleanup" (Section 8.16) it is not clear whether these blasting operations will open new channels that would pass completely through the reef from lagoon to ocean. If this is in fact planned, we would object in principle and would need to see much more information on the expected impact of new openings in the reef on the ecology of the Atoll. As a matter of policy beyond the scope of this Statement, we recommend that the last sentence (lines 18-20) on page 5-35 of the fourth recommended study be deleted, since it is not germane for any environmental statement to address detailed responsibilities of other agencies which have not been formally agreed upon. There appears to be some misunderstanding regarding Storage on Runit (Sections 5.5.2.5, page 5-48). As presented in the DEIS, it is indicated that as an intermediate step, contaminated soil will be stored on Runit pending a study and recommendation by AEC as to its ultimate disposal. AEC is not committed to provide any additional recommendation on the ultimate disposal of the contaminated soil. The disposal of debris is a DNA responsibility. The only open question is whether or not it may be feasible to reduce to some degree the amount of contaminated material
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to be disposed by removing some of the plutonium from the soil. Whether sur.h reduction ir; economically sound would depend on the final disposal I'cthod and its associated cost. Should deep ocean burial be the chosen method, the removal of plutonium from the soil would not be a cost effective action. In recognition of the above points, DNA should plan its cleanup and disposal actions as if no additional guidance from AEC may be forthcoming. Any results of a further AEC study to determine the possibility of reducing the volume of plutonium-contaminated material should be viewed as an added benefit. Our discussions with staff of the Department of the Interior during the Sept uiber 1974 visit to Enewetak Atoll indicated that a group of people from Ificl ..'g Atoll will be allowed to return to Japtan Island before cleanup operations begin. In a July IS, 1974 letter to the Department of the Interior, AEC presented its views on the safety aspects of any proposed early return of people to Japtan. We view an early return as a significant step that should be tianted in the DEIS. Biomedical and Environmental Research and Safety Programs cc: Council on Environmental Quality, w/encl. (5)
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to be disposed by removing some of the plutonium from the soil. Whether such reduction is economically sound would depend on the final disposal method and its associated cost. Should deep ocean burial be the chosen method, the removal of plutonium from the soil would not be a cost effective action. In recognition of the above points, DNA should plan ii.s cleanup and disposal actions as if no additional guidance from AEC may be forthcoming. Any. results of a further AEC study to determine the possibility of reducing the volume of plutonium-contaminated material should be viewed as an added benefit. Our di.-eussions with staff of the Department of the Interior during the Septerovr 1974 visit to Enewetak Atoll indicated that a group of people from Ujelang Atoll will be allowed to return to Japtan Island before cleanup operations begin. In a July 18, 1974 letter to the Department of the Interior, AEC presented its views on the safety aspects of any proposed early return of people to Japtan. We view an early return as a significant step that should be trc..:.ed in the DEIS. Biomedical and Environmental Research and Safety Programs cc: Council on Environmental Quality, w/encl. (5)
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Supporting AEC Comments on the Defense Nuclear Agency Draft Environmental Impact Statement on the Clean-up, Rehabilitation, Resettlement of Enewetak Atoll - Marshall Islands A severe deficiency in the DEIS concerns the dose estimateis presented in nacri>; 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 cue recommended radiation criteria were provided in the AEC Task Group report: 30-year whole body dose (for a population living in various parts of Maximum annual whole body 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 KV-140. The AEC Task Group rejected the concept of averaging annual doses over the 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-un options (cases) and presents maximum annual values for bone that were calculated using an equation in fiV-140 that is considered adequate only for determining 30-year doses. (Other models are now used in calculating maximum annual doses to bene and bone marrow that accommodate important changes that occur with time and with age of the individual.) The-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 DEIS Case 1 WB* 6 Rem in 30 years Bone= 60 Rera in 30 years These were determined for an average individual in the entire Atoll. AEC Case 1 VB= 31 Ren in 30 yeara Bone- 220 Rem in 30 years
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See AEC cctimates for a population living on Belle, Section B, Volume II, pager, 32-33, current condition, living pattern F. This example shows that important features of the radiological picture at Enewetak can be missed if dose estimates are averaged over the entire Atoll. DEIS Case 1 WE- 0.3 Rera in one year Bone= 2 Rera in one year (mineral bone) These were determined for an average individual in the Atoll. AEC Case 1 WB* 1.6 Rem in one year Bone marrow= 2 Rem in one year See data for an individual on Belle, Section B, Volume II, pages 3A-35, current condition, living pattern F. The significance of a bone marrow dose as high as the bone dose Is that, traditionally, the standard for bone marrow is one third that for bone. Annual dose for an average individual for the entire Atoll should not be used to develop ratios to indicate comparisions with AEC annual dose criteria. There are several problems with this approach. First, use of estimates for an average individual ignores the fact that children are thought to be more sensitive to radiation injury than adults. Maximum annual doses presented in the Task Croup report for use in the DEIS were derived through consideration of doses to the fetus and newborn, as well as to adults. Treatment of this innertant consideration seeras to be missing in the DEIS except in material provided in the Appendix. Second, there are no standards for doses to an average individual for a geographical area containing a wide range of dose races. The nearest category of Federal recommendations are guides for a population group where annual average doses arc to be determined giving due consideration to the most sensitive nerabers. By way of comparison, basic dose guides for such a group would be one-third of the guides for the individual. AEC criteria for annual exposures apply only to exposures of individuals using the condition specified by the Federal Radiation Council, namely, that this my be used when there is a sufficient level of radiological monitoring that exposures, including those of the most sensitive individuals, will be known. /•EC criteria for exposures at Enewetak do not apply to an average individual ca the entire Atoll or to a population group within which there would be a v.'ide range of doses that make up the average. TnDier, 5-11, ‘i-12 and 5-13, pages 5-54, 5-57, and 5-59 We hove not subscribed in the past to an approach that considers as alternative clean-up of islands to various external radiation isopleths such as F or K as
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defined by the EG&C aerial survey. Such an approach …
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