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ENERGY RESEARCH AND DEVELOPMENT ADMINISTRATION Enclosedfor your reviewand commentare the commentsof Ted Mitchell, Legal Counselfor the Micronesians,on the DEIS for the Cleanup, in Hawaiion March 17, pleaseprovideyour commentsto him by close for Environmentand Safety
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People of Enewetak issued by the Defense Nuclear Agency, Washington, Counsel for the People Micronesia Legal Services Corp.
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The impetus for ~evelopm”ent of this program comes from to their homeland. Although resigned to “their nearly thirty . returning to Enewetak, if but only “if,.it is radio.logicalll’ s~fe for them to do so. They are aware of the substantial social and economic problems which necessarily attend the r~’lo”cationand resett~ement of their more than 400 personsl but the difficulty. of assessing the risk “from the extensi%*e radioactivity present at the Atoll as a result of the nuclear weapons testing program there is”by far the most troublesome. . . It is difficult enough for the layman to comprehend what the. akcut the effects of radioactivity, but that difficulty 1s compounded many times over the differences of opinion fouild “among the experts, by the realization that even the experts agree that the long term effects of some of the more dangerous radionuclides are not known by anyone at this time and may not become known for many years to come, and it is unsettling to learn that the standards used for the kinds and amounts of to be tolerated in the environment and in man are reputable experts as unreliable and inadequately .Their individual and collective desire to return to their ancestral homeland is difficult for Americans to fully appreciate. To them land is not a commodity, a thing apart, to bc
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environment of the atoll axe fully integrated with the human , members of the soc’iety. It is an economic resource and more. To be sure, their society h~s undergtine and contin’uousiy is undergoing change as a result of forces both within and without, but the extraordinary signifi cance of th~ir being able to resettle to the atoll discovered by their ancestors remains Thus, the People of Enewetak are both the prime beneficiaries and the prime risk-takers in this resettlemerit program. And it is in the assessment and, if possi”~le, elimination of the Ya~iobiological health risk that they are the most dependent upon the United States government. The Defense Nuclear Agency and the Atomic Energy Commission have already devoted great amounts of time and money to assessment and remedy of radiological problems presented by this program, but more will have to be done and it will kava to be done over a long period of time.f, And throughout, the People of Ene%;et.akwifll rely upon the responsible agencies of the United States government to do everything possible to assess and minimize the risk d’ue to the residual radioactivity in the Ene;uetak biosphere. Nothing said in these comments, for example, should ever be taken as an assumption of riskby the people c>f Enewetak. When they left the Atoll in 1947 at the insistence of the United States government it was radiologically safe. That is the state in ~ihich it should be for their return.
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- -that must be the assumed objective in order that remedial measures can more likely fall within the ~afest possible limits, and so. will be made to continually add to thethat on-going “effcrts Ynowledge 01 radiological coriditions at Eiie-wetakand refine an~ Improve both risk assessment and r~il~edialmeasures as the various - relevant sciences develop over the year=. \ Not only.is the United States trustee for these people, but it has an especial humanitarian obligation to them because of the uniqueiy dangerous potentiai effects due to the use to which the trustee put the Atoll. It is an absolute kind of rf3SpOllSibility to both return the people to their home and eliminate the. . likelihood of sc much as a single radiation induced illness or . A full measure of gratitude is due and hereby given, however, 4 to the considerable efforts which the United States has made thus “ far. The planning for resettlement, the planning for the clean-up, all represent to the ultimate success of the program... . And we do not wish to dampen the enthusiasm and interest of the many persons in and out of the go\*ernment whn have given devoted effort thus far. The comments made here are offered in the spirit of cooperation, with the realization that they will be received in that same spirit. 2. Social and Economic Problems Associated with Resettlement Further consideration of the social and economic. . associated with the “resettlement must be given. This
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short and 1ong range economic be found.. that the shared . c -suffici en Cy can be. achi eved. We onof this compl exether aspect up to now, this was not intenti ally underemphasiszed . But as the program moves into its clea,n-up phase do re attent ion mus t be given to meeting the future economi needs Oi the people. Thisc become known. that adverse rad iological Cond in th = i~orthern par t of the Atoll do not permi.t zehabitation of Engebi islet . ,- if not northernand severely completely restrict the use the Planning Council relicon . to make the final val ue jud gments upon one proposal “or another and upon the deve 1,opment of the economy as a WY.G1e so that it will be consona .nt withr thei own capabil ,ities and values, but one or ;hould engaged th government and mademare spec e avai labl in an .s,ory capacity. They mu St be ,ly selec te d both in terms of expert ,ise in the field and suit ab ility to this kind of cross -Cul tural task and to the max imurn feasible ex terlt the Planni ng Council should partic ipate in the selection l Resettl emen t to Enewetak A,to from Ujelang will invo an Unus”ual amount of str~ss for individual member ‘s of the group and for the groupas a whole. Physical stress wi.11, if all goec as
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This matter is not addressed at all by the DEIS. Ultimately, of course, it is for the people to manage the. . t~--~nsit<onweli ar.d to aciapt with their society intact, but. -. should be used to increase the likelj-hood of successful resettlement. The pepple themselves can benefit from greater awareness of the stresses they will experience and those outsiders involved in planning and ~:orking with the’r,must have the same understanding. Dr. Thayer Scudder of the California Institute of Technology, a recognized authority on the s-tibjectand an experienced consultant,. should be considered fcr this e.ssignment and if the Planning Council agrees, he should be engaged in this capacity. Dr. s~~dder . has taken a quick look at the DEIS at our request. His comiients attached hereto as Appendix I provide valuable insights and his contribution to planning and execution of the program would appear to be necessary. (The article which he enclosed is also useful. . It is “The Impact of Human Activities on the Physical and Social Montgomery, J. W. Bennett and T. Scudder, 2 Annual Review of Participation of another anthropologist ‘rersed in ~~arsha~lese culture is also in order, to assist both .th~ Enewetak people and the outsiders involved in the program. Workingin conjunction with sc.mcone like Dr. Scudder, the total contribution would be invaluable. Dr. Robert Kiste at the Uni”.’ersityof Minnesota has be~i)
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~ Short of involving so many advisors and planners that ,. :, decision-makers. To some extent this ic what has “been done during planning to d~te, b~ut for ttle remainder of the program, the relevant disciplines should be identified as such, appropriate representatives engaged anti ocganized into a more or less formai 1972 under the auspices of the Atomic Energy Commission is; we . c believe exceptionally good as far as it goes, but we have been advised by capable experts in the field that more work remains to be done and that the qualifications of the four-member Task Group is also apparent that as “detailed and elaborate as follow-~p gathering of data and careful assessment that survey was, of that data is the risk to
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<1 - Group, but in a field involving so many specialties and where equally expert opinions difier markedly, it is imperative that the Task Group for follow-up studies be.— —— enlarged to include scicntj_s~;sknowrl to take the most conservaUniversity of-Minnesota. Their presence in the Task Group, or their participation in some ‘other direct w=~ in designing methods to be useci for the gathering of ‘. lnfor.mation and its evaluation is strongly recommended. The 1972 radiological survey (NVO-140) must be regarded as an impressive beginning of long-range radiological assessment and monitoring cf the EneYletak envirorunent with appropriate enphasis placed upon not only the marine and terrestrial environments but upon the radionuclide pathways to man. As we shall discuss more fully below, more information is needed about the presence of hot particles... The long range effects of Strontium-90 and Cesium-137 and other nuclides in the food ~tiebcannot be known without experi-. examples. And as time goes on, scientific knowledge of the nature and effect of radioactivity is bound to improve and new techniques for remedial measures will be found. These scientific advancements will be lost to the Enewetak people unless the United States assumes a long-range commitme~it of the kind we suggest in so doing it is highly probable that important contrithe de~’elopment of gxea%er understanding of radioactivity
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3.2. The Hot Particle ”Problem C.:Z comments here concerning this urique radiological hazard. . Drs. Tamplin and Cochran submitted fcrmal comments upon this DEIS to the Defense Nuclear Agency under date of September 24, 1974, and we fully accept and”endorse what they have said there. Their c3sEr-v-GtiGEsErx? corlceriisare erlti~ely consistent with those of Marten and Geesaman, expressed to us in personal communications. For a discussion of the seriousness the hot particles problem we attach as Appendix II, E. A. Marten, “Basic Considerations in the Assessment of the Cancer Risks and Standards for Internal, i.-p’l:dEmLittcrs,” (Scateirientpresented at the public hearings on. P1-~tonium standards sponsored by the United States Environmental “Protection Agency, Denver, Colorado, January 10, 197S.) To further emphasize our grave concern about this problem, v;e attach co,miner~ts and materials provided to us by.Dr. Donald P. Geesaman as Appendix III. We subscribe fully t; the views they express and we insist t}lat they he dealt with fully in the final impact statement. It is beycnd question that the presence of Plutonium-239, Enewetak Atoll constitutes one of the most serious health risks for the returning population. It is highly likely that inhalation of very small amounts of plutonium ”gives.rise to a high risk of lung cancer. And the DE’IS completely fails to address the recent
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‘=‘be a causative factor in a number of other disorders. See r~-endicas II and III. The DEIS” deals cnly with inhalation risk, yet Americium is kilo’;~nto present a risk for the liver, spleen Concerning the adequacy of the radiological survey with respect to internai alpha emitters, Dr. Marten had this to say: It is noted that the survey results for the Enewetak Lagoon sediments .s~~; an average of 463 the Am concentrations range up to 8.2 pCi/g averaged over the top 15 cm depth of soils, with Am/ .Pu vol. 1, p 507). Due to further radioactive decay of Pu , the AIn activity concentrations can be expected . to double over the next 50 years. In addition, densely vegetated soils on each island show the highest radioThe DEIS limits consideration of Pu to ,, inhalation risks. However significant uptake of Pu (lJI ~ from the gastrointestinal tract has been observed in Z?& young mammals and similar uptake may occur,in young children. In addition the uptake “of americium in soils by vcgetati~a “is substantially higher than plutonium
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.. uptake. Simil;rly americium is readily taken up from tne gastrointestinal tract and accumulated in the liver~ spleen and b~ne of mammals, and thus undoubtedly in man. . Based on these cGnsider?tions it is possible that uptake of americium in the food chain and its accumulation in the liver and skeletal tissue of . . man may be the critical path for exposure to internal alpha emitters in the Enewetak Atoll area. The radiological survey is seriously inadequate with respect to americium distribution in both vegetation and in edible marine life to assess .,.,.,.- consequent body burdens and heald consequences future atoll ~IIhG:ltz:::t5.(1’erscnal Cormnunication.) ,, Dr. Geesaman independently identifies the same inadequacy ,. ,.,., ,, in the DEIS and also finds a need for further study of the mechanisms ..... by which plutonium contamination in tile soil may find its way int”o. . The resuspension measurements and calculations . which relate the air contamination to the soil.’ contamination are not immediately compelling, and deserve a much more careful analysis than I have,; given them. I would be surprised if the analysis is meaningful to factor of 100, when used to determine. . pu”blic health guidelines. Resuspension is poorly understood, it is sensitive “to windspeed, soil
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characteristics, vegetation, humidity, rainfall, mechanical distrubance, physical and chemical history. of plutonium particles in soil. How then does one large fluctuations about the iz-lplici.texposure levels, which, even for the limiting soil contamination \ guidelines and predicted air concentrations associated with these guidelines, will be approximately a Each of the questions raised here and in the related appendices must be addressed fully and carefully prior to resettlement of the people of Enewetak Atoll. Concerning the standard employed by the 12EIS for maximum . permissible plutonium contamination of soils at Enewetak, Dr. Marten points out that “There are no ICRP standards for soil levels of Pu and the actinides or for lifetime exposures to internal alpha cxitique of the standards adopted by the AEC Task Group for Enel~’c2a}:: The recommendation that pluto,~ium contaminated soils, with levels not exceeding 40 pCi Pu/g of soil averaged over 15 cm”depth, is suitable for human “ habitation, can be very seriously questioned. The St~.te of Colcrado Bor~rd of Health has adopted interim standa~xis for Pu contafiination limits in soils
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in land areas for residential USC,’ specifying t.hc.t Pu levels shall not exceed 2 dpm (0’.91pCi) per gram of surface scil (i.e. , avevagcd over the top 1 cm depthof soil). It is noteworthy that the conservative and it is not apparent that the AEC has requested the ICRII or NCP.P to make specif}-c recommendations h;ith respect to”standards for Pu in soils applicable to chronic exposure to the general I note that the DEIS recommends no remedial Pu/g, averaged over the top 15 cm depth. This is Colcradn interim standard (2 dpm per g in the top 1 cm) because for most . Enewetak soils the top cm contains substantially higher levels of Pu per gram than the 15 cm depth average. Thus, for examplef at location 101 on whereas the average over 15 cm depth is about 60. Thus the recommended standard for Enewetak is about to several hundred timez that adopted in Colorado. There are recent research developments which expected to lead to reductions in acceptable organ burdens …
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