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Department of Energy Ginsburg, Feldman, Weil and Bress Mr. Hollister requested that I respond to your letters of October 16, 1980, and of November 3, 1980. Please excuse the unusual delay in responding. As you know, the information we presented at Kili Island in the book, “The Meaning of Radiation at Bikini Atoll,” indicated that the people could return to Eneu Island with the expectation that the resulting radiation doses would be within the United States Federal standards if (a) residence was restricted to Eneu Island, (b) at least 50% of their diet would consist of food from outside the atoll (imported food), (c) that time spent on Bikini Island would be controlled and minimized (10%), and (d) that no food from Bikini Island would be eaten. (Since these estimates were based upon the averaged values of a number of parameters, the individual with unusual personal habits and lifestyles may vary -- in either direction -- from these estimates.) It also was stated at Kili that without imported food :Ltwould be about 20-25 years before the people could return with the expectation of living within United States radiation exposure limits. This information is consistent with the information provided by the Department of Energy (DOE) to the Department of the Interior (DOI) in a letter dated May 1S, 1979, from Ruth C. Clusen, Department of Energy Assistant Secretary for Environment, to Mr. James Joseph, under SecretarY of the Department of the Interior. That letter contains the following “If the guidance of the Federal Radiation Council (FRC) 30 yrs to a population) is to be complied with, the people could return to Eneu only if it is assured that adequate imported food would be available to and used by the people for approximately 20 years, that food grown on Bikini Island is not a part of the diet, that residence is restricted to Eneu Island, and that visitation to Bikini 1s1 nd is DOCUMENT DOES NOT CONTAINEC[
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The information therefore contained in the letter of May, 1979, was identical to the information given on Kili in October, 1980. The letter of May 15, 1979, then proceeds to explain, however, that if the radiation exposure criteria recommended by the Atomic Energy Commission in the Environmental Impact Statement for the cleanup, rehabilitation and resettlement of Enewetak Atoll (2S0 millirem per year to the individual and 4,000 millirem over 30 years) were to be applied also to resettlement at the Bikini Atoll (i.e<, Eneu Island), the situation would warrant deferral of resettlement at Eneu for some years. This was stated in the following paragraph from that letter, which YOU also quoted: “The degree of uncertainty in estimating doses on Eneu Island is similar to that for Enewetak Atoll. Assuming, therefore, that Enewetak criteria are applicable to other similar situations in the northern Marshall Islands, the dose estimates for return of the Bikini people to Eneu Island would be compared to the Enewetak criteria as described above rather than to the FRC guidance. When this is done, it is found that even with imported food the radiation doses to the people on Eneu wculd not be expected to be in compliance with the Enewetak criteria for about 20-25 years.” The content of this paragraph remains valid. However, since the Enewetak criteria (which were conservative values based upon uncertainties with respect to data and to personal living habits) were recommendations by a Task Group of the Atomic Energy Commission to the Department of the Interior with respect to Enewetak Atoll resettlement, and since these recommendations were not based upon any regulatory authority, they were included in the letter as a point of information to the Department of the Interior so that, if they consider it appropriate, a consistent policy could be established. Furthermore, the implications of such a policy also were identified. Because the recommendations carry no regulatory authority, however, the comparison of dose estimates for the return of the Bikini people to Eneu or Bikini Islanclswith the recommended criteria for Enewetak was omitted from the book, ‘The Meaning of Radiation at Bikini Atoll,” as it was omitted from the book, “The Enewetak Atoll Today,” prepared in The paragraph in Mrs. Ruth Van Cleve’s letter of June 1, 1979, to Magistrate Tomaki Juda, to which you make reference in your letter of November 3, 1980, presumably was based upon the assumption that it would be unrealistic to anticipate that the four conditions referred to above (i.e., in our letter of May 1S, 1979) could be assured for the next 20-25 years, particularly in light of the immediate past experiences at
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With respect to the testimony presented by the Department of Energy in May and June, 1978, we are unable to confirm that the Department of I were aware of the subject being discussed at the hearings in question, we were not aware of the above statement being made. Even if such a statement had been made at that time, however, presumably the additional information and analyses which have become available during the past 2 1/2 years would permit revision of ofiinionexpressed on the basis of information available at that time. The Department of Energy did testify that the cesium concentration in coconut on Eneu Island was 5-6 times higher than was anticipated from the very limited amount of relevant information that was available prior to 1978. The data repcrted at the hearing was the first “new” data which had just become available in early May, 1978; this limited “new” information raised questions as to the suitability of Eneu Island as a site of residence. The Department of Energy also testified that some of the water wells may have been in excess of Environmental Protection Agency standards. This statement was based on the fact that during different years the radionuclide content of the water varied from being above Environmental Protection Agency standards to being below Environmental Protection Agency standards. The implication of this was unknown at the time, but since then has been determined to be a relatively minor contributing factor with respect tc)the overall potential radiation doses. To my knowledge, the above is the extent to which the Department of Energy testified. However, given the facts as known in mid-1978 that (a] the cesium levels in coconuts were higher than expected, (b) an imported food supply :systemhad just demonstrated its lack of effectiveness, and (c) subsistence foods were available on Bikini Island but, except for coconut trees, not on Eneu Island, it seems a reasonable assumption for the Department of the Interior to have made at that time that relocation from Bikini Island to Eneu Island was not advisable. The more recent dose estimates include a considerably expanded data base compared to that which was available in past years. These data have resulted from the continuing Department of Energy environmental studies at the Bikini Atoll, and in part from information obtained through the Northern Marshall Islands Radiological Survey. Nevertheless, our recent radiation dose estimates confirm the above conclusions in showing that without a diet consisting of approximately 50% imported foods, plus other restrictions as identified above, United States radiation standards would be exceeded by residents on Eneu Island for approximately 20 years.
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I hope that the above is responsive to inquiries by you and by Office of Health and Environmental Research, Office of Environment