Prepared for 

DEFENSE NUCLEAR AGENCY 

Washington, D. C. 20305 

Under 

Contract No. DNA 001-73 C-155 

HOLMES &NARVER,INC. 

---.•~=== A Resource ScJences company 

Advanced TechnoloVl/Englneering/Construcllon/Management/Melntenance & Opetallona 

400 EAST ORANGETHORPE AVENUE •ANAHEM. CALFORNA 92801 

TABLE OF CONTENTS 

VOLUME IV - COMMENTS ON DEIS 

TAB 

1 LETTER FROM ENVIRONMENTAL PROTECTION BOARD, 

DEPARTMENT OF HEALTH SERVICES, TRUST TERRITORY 

OF THE PACIFIC ISLANDS (TTPI), OCTOBER IS, 1974. 

2 LETTER FROM OFFICE OF ENVIRONMENTAL AFFAIRS, 

DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE 

(HEW), OFFICE OF THE SECRETARY, NOVEMBER 15, 1974. 

3 LETTER FROM OFFICE OF MARINE ENVIRONMENT AND 

SYSTEMS, UNITED STATES COAST GUARD (USCG) 

DEPARTMENT OF TRANSPORTATION, DECEMBER 13, 1974. 

4 LETTERS FROM DIVISION OF BIOMEDICAL AND ENVIRONMENTAL RESEARCH AND SAFETY PROGRAMS, U. S. 

ATOMIC ENERGY COMMISSION (AEC), DECEMBER 9, 1974 

AND DECEMBER 23, 1974. 

5 LETTER FROM DIRECTOR CATEGORICAL PROGRAMS, 

OFFICE OF THE ASSISTANT SECRETARY OF DEFENSE, 

(HEALTH AND ENVIRONMENT), NOVEMBER 13, 1974. 

6 LETTER FROM REGION IX, U. S. ENVIRONMENTAL 

PROTECTION AGENCY {EPA}, DECEMBER 12, 1974. 

7 LETTERS FROM NATURAL RESOURCES DEFENSE 

COUNCIL, INC., SEPTEMBER 24, 1974 AND 

NOVEMBER 14, 1974. 

8 LETTER FROM MICRONESIAN LEGAL SERVICES 

CORPORA TION, FEBRUARY 1, 1975. 

9 LETTER FROM OFFICE OF REVIEW AND COMPLIANCE, 

ADVISORY COUNCIL ON HISTORIC PRESERVATION, 

NOVEMBER 19, 1974. 

10 SUMMARY OF COMMENTS ON DEIS. 

11 

Masao Kumangal. M.O. ENVIRONMENTAL PROTECTION BOARD r Chalrmlln Division ofEnvironmental Health 

Gilbert C. Ada Department ofHealth Services 

Vice Chairman Trust Territory of the pacific Islands I Saipan, Mariana Islands 96950 

Klkuo Apls I Cable Address TTEPB Salpan John lou 

Oemlll O. Otobed 

_.. i'iiigh-t Pollution­ Tawn Paul 

The island you Eusebio E. RlIChucher 

save may be your oum" Moses Samuel 

Jllmes R. Wheeler 

October 15, 1974 

Warren D. Johnson 

Lieutenant General, USAF 

Director 

Defense Nuclear Agency 

Washington, D.C. 20305 

Dear Sir: 

Enclosed are comments prepared by the Trust Territory Environmental 

Protection Board's Technical advisors in response to the Draft 

Environmental Impact Statement - Clean up, Rehabilitation, Resettlement of Enewetak. Atoll, Marshall Islands - prepared by Holmes and 

Narver, Inc. for the Defense Nuclear Agency. 

I was pleased to have one of our Board members and a representative 

of our technical staff in attendance at the hearing on Enewetak. Atoll. 

I sincerely hope our comments and technical recommendations will assist 

in the drafting of the Final Environmental Impact Statement and speed 

the safe return of the dri-Enjebi and dri-Enewetak. to their traditional 

homeland. 

Sincerely, 

//7""dJ Masao Ktunangai, £:NU'l"" M.0.7 

Chairman, 'I"l'EPB 

enclosure 

cc: High Commissioner 

Special Assistant for District Affairs, TTPI 

Micronesian Legal Services Corp., Saipan 

Micronesian Legal Services Corp., Majuro 

District Director of Health Services, ~ajuro 

Stanley Carpenter, Office of Territorial Affairs, 

Dept. of Interior, Wash. D.C. 

MilSao Kumanpl. M.O. ENVIRONMENTAL PROTECTION BOARD 

Chairman Division ofEnvircmmental Healtll 

Gilbert C. Ada Department ofHealth Services 

Vlc;e Chalrm.an Trust Territory oftile Pacific Islands 

Saipan, Mariana Islands 96950 K1k~oApll 

Cable Address TTEPB Salpan John lou 

Qamal o. Otobed 

ttFight Pollution­ Tawn P.aul 

The island you Eusebio E. Rechuc:her 

save may be your own" MOMs Samuel 

.lama R. Wheeler COMMENTS TO THE 

CLEAN-UP, REHABILITATION, RESETTLEMENT OF ENEWETAK ATOLL 

MARSHALL ISLANDS 

DR.AF'r ENVIRONMENTAL IMPACT STATEMENT 

The Trust Territory Enviror...mental Protection Board has re'fie-..ed the 

Draft Environmental Impact Statement on the "Clean-up, Reha.bilitation, 

Resettlement of Enewetak Atoll-Marshall Islands," prepared by Holmes 

and Narver, Inc. 

The Draft Statement satisfactorily addressed most of the various environmental, social, cultural and political aspects of the return of Enewetak 

Atoll to the dl'i-En.1ebi and the dri-Enewetak reople. The partici~atior. 

and support of the Enewetek Planning Council in prepari~g the I~pact 

Statement and Master Plan has p!"oduced a document which addresses itself 

to the particular needs and requirements of returning these people to 

their traditional homeland. 

In the opinion of the Board's technical staff, Case III represents the 

most practical and realistic e.pproach to the proposed clean-up, rehabilitation and resettlement program. Specific technical comments will be 

addressed ill Section 2. 

Section 1. The need for an Envirolwent~/Health EdUcation Program. 

Two areas that are of primary concern to the Board do not appear to be 

adequately addressed in the Draft Environmental Impa~t Statement or the 

sununary, nor does the Board feel they were adequately discussed during 

the hearing on Enewetak Atoll. They involve the full wlderstanding and 

education of the dri-Enjebi and dri-Enewetak with respect to the concept 

of radiation poisonins and the real or potential effects of somatic ar.d 

genetic injury as Q. consequence of long-term exposure to excessive radiation 

levels. 

Tne Board's concern or doubt is based upon the overall concept of radiation 

and the vocabulary and terndnology associated with isotopes, dosages, 

occurrence in food chains, etc. We question whether or not the Marshallese 

translation presented at the Hearing (and summarized in the DEIS) provided 

a complete and thorough enough understanding of the potential hazards involved 

here t with respect to the various living, food-gathering and agricultural 

restrictions which will have to be imposed, should Case III be elected. 
The Board does not question the competency of the translation during the 

hearing; rather it addresses itself to the concern over words and phrases 

not translatable into Marshallese. The delegation from Ujelang indicated 

it understood the imposed restrictions and the ration~ behind those 

restrictions. However, the subject matters of nuclear physics and radiation 

biology are extremely complex. 

Poisons of various types are not unknown in the Trust Territory. In early 

times poisons were used during inter-island warfare. Even today, poison is 

occasionally used to "settle" disputes in cases of land ownership, jE'alousy, 

sibling rivalry and inter-clan disagreements. ~ne use of traditional poisons 

in the taking of fish and other marine resources is still common in many 

districts of the Trust Territory. It would be logical for a given cultural 

group to associate radiation poisoning with their traditional poisons; 

however, the effects of low level radiation doses· spanning a period of 

ma~' years are fa~ less obvious or understandable than the overt ( and 

traditionally known) systemic responses to traditional poisons. 

The Board strongly recommends that a comprehensive training program be 

administered to the dri-Enjebi and the dri-Enewetak, their Marshallese 

legal council, Health Servict:!s and other governmental offidaIs. ~.1ovies, 

slides and educational booklets should be developed (in the ve:,:,nac~.ar) 

to adeqautely explain the concept of radiation and radiation poisoning, 

radiation induced genetic mutati.on, "normal" backgrour..d radiation, etc. 

Documentation of the radia.tion exposures or injuries suffered in Rongelap, 

Uritik and other atolls in the ~1arshall Islands duri ng th~ nucJ.<,e.r ·":E'~·PQns 

testing period 3hould also be d.epicted as factually as possible. The 

objective should not be to frighten, but to inform. 

The Board stro~gly feels that only through a comprehensive educational 

program could the dri-Enjebi and the dri-Enewetak safel:r return to Ene,o{etak 

Atoll. Fuller and !Core complete understanding of these concepts should 

engender in the people voluntary cooparation regarding restrictions on 

their life-style i-rhich the Board feels would be far more successful thnn 

enfo:rcement by outside agencies such as the Atomic Energy Commission or 

the military. 

Sec cion 2: 

1. Disposal of non-radioactive scrHp and delly-j8 (Section 5.5, pae.:: 5-)16.) 

a • CombtwLi ble rna +;cri E~l s 

The BOUJ'd does not fo:rsee envirom:tnntsl Yl"oblemi' reBultinG in thC' 

bu:rni.ng of non-rndioe.cti ve (:o::lbustibl e scrap and ne1.n'is. The B0:Jrd 

tokes the p()~i tion that the E.sh :rE.:pr(sc:nts H substant:i.!:.tl minl~r::-LJ. 

rc:source: ulld rccOr,l"l('!lds that thc aslles be utilized as a soil comlitioner in n.reaf; luc1:ing adD(}l~Q t·; soil and/or used as e soil comlitioncr in rrrC'!).s t.hat have [)(;E.'11 cove:rcd Hi th co~crete or aspl1ul t 

for lllll.ny yea:rs 1,nd m:.iy lack ce:rtain minerals or trace cl emcntfl 

that \muld nOl'.:;:--;lly be prc!;ent ill the l!um1istu:rbed" state. The 

-2-
proportionally small cost of this ~xtra effort could conceivably 

be balanced by increased soil fertility and faster recovery of 

of natural flora and/or agricultural crops. 

b. Non-Combustible materials (Section 5.5, page 5-46.) 

The Board suggests that the non-radioactive scrap and debris 

(concrete, steel etc.) represents another potential resource 

to the' Enewetak people, if utilized properly. In this regard the 

Board suggests that with proper research a~d planning the scrap 

and debris could be effectively utilized to create artificial 

reefs within the lagoon. These materials might be used most 

e:f:fectively if introduced in areas deficient of natural "reef" 

environments, in expanses of unconsolidated sand or in areas 

where entire ree:f ecosystems were destroyed as a result o:f 

nuclear testing. The creation of artificial ree:fs :from materials 

that mightothel""tlise be indiscriminately dumped into the lagoon could 

provide a stable substrate :for the development of new reef environments and the flora and fauna associated with such environments. 

Thus, if properly marked and located, these areas at some point 

in the future could potentially yield commercially valuable marine 

resources. To this end, we recommend that appropriate agencies 

be contacted and studies performed to explore the feasibility 

of establishing of artificial reefs within the Enewetak Lagoon. 

These lnvestigations should include measurements of current flow. 

in the lagoon, productivity determinations, ecological succession 

patterns, potential for ciguatera poisoning, and habitat requirements for reef :fish and invertebrates and commercially valuable 

marine resources. 

2. Disposal of radioactive soil, scrap and debris - discussion of 

alternatives (Section 5.5.2, subsections 1-4.) 

1. The packaging of radioactive soil, scrap and debris for shipment 

to the United States :for disposal would reflect the expressed 

interests of the dri-Enjebi and the dri-Enewetak.. However, aside 

from the cost (and assuming the required Congressional appropriation) 

the legal ramifications would preclude this alternative from being 

practical. The time involved in lengthly legal proceeding would 

not to be in the best interests of the Enewetak. people. 

2. Deep ocean dumping might be practical from a cost standpoint, but 

could potentially result in unpredictable ecological consequences 

of illltoid magnitude. 

3. Utilizing one or both craters on the north side of Runit Island 

for disposal o:f radioactive materials is the favored means for 

disposal, as presented in the Draft E.I.S. However, the D.E.I.S. 

does not discuss any supportive data which would describe the 

feasibility of the proposal :from an engineering or geological 

-3-
standpoint. The Board expresses concern on the justification 

of this alternative on the basis of no reported feasibility 

studies having first been conducted. Can these craters actually 

be "Pumped out" and tllined" with concrete? In the final E.I.S., 

attention should be directed toward engineering design as a 

function of the geological history of Enewetak Atoll, impact 

of typhoon or tsunami, structural integrity of concrete versus 

other lining materials, porosity of ancient corals, a..."ld environmentai consequences and remedial or clean-up procedures in the 

event of a crack or leak in the craters or-their linings. 
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE 

OFFICE OF THE SECRETARY 

WASHINGTON. D.C. :20201 

NOV 15 1974 

Lt. Gen. Warren D. Johnson, USAF 

Defense Nuclear Agency 

Washington, D. C. 20305 

Dear Sir: 

We appreciate the opportunity to review the draft Environmental 

Impact Statement for the proposed Cleanup, Rehabilitation, and 

Resettlement of the Enewetak Atoll - Marshall Islands. On the 

basis of our review, we offer the following comments: 

5.3.3.1 Control of Food Sources 

The results of a radiological survey show high levels of 

contamination on the northern islands and low levels of 

contamination on tre soutern islands. This high level of 

contamination is of significance both from the standpoint 

of external exposure and from the uptake of the radionuclides by plants as well as by indigenous fauna which 

if eaten would result in internal dose and deposition of 

radionuclides. Radiological surveys on Enewetak have 

found evidence of uptake of cesium-137 and strontium-90, 

among other radionuclides, in indigenous plants used for 

food including coconuts, pandanus, breadfruit, and tacca 

(arrowroot). The surveys also report radionuclies in 

flesh and organs of indigenous fauna such as terns, rats, 

and land crabs. Presumably domestic animals such as 

poultry and swine would, if they foraged on indigenous 

radioactive plants, also show uptake of these radionuclides. 

If the driEnjebi faction of the Atoll popUlation are to live 

on the northern islands and particularly the island of 

Enjebi, care would need to be taken that the pandanus and 

breadfruit are grown in non-radioactive soil, either on the 

southern islands or imported from elsewhere. The alternative 

would be to provide farm plots for pandanus and breadfruit 

by removing existing soil and replacing it with non-radioactive soil in sufficient volume to contain the roots of 

these plants. The removal and replacement of soil to 

create these farm plots is of questionable and unproven 

value, since sustained land removal and replacement operations 

could result in serious ecological damage of unknown proportions. 

Also, there is no guarantee that sufficient soil could be 

removed and replaced to assure radiological safety of residents 

who would be eating plants grown on these plots. 
Page " 

5.6.1 Dose Estimates 

It is unclear as to whether the dosage estimates include 

contribution of potential ground water supplies such as 

brackish or fresh water wells. While it is clear that 

the use of grossly contaminated supplies would be precluded, 

estimates of potential added dosage from these sources 

in the southern quadrant should be made. 

As noted in the statement, the implications of concentrations of cesium and strontium in bone marrow by ingestion 

routes is an item of considerable concern. However, it 

is unclear from the draft statement if the mortality rate 

shown in Table 5.14 (page 5-60) includes the effect of 

doses to the bone marrow. 

6.1 Selection of Cleanup Case 3 

As stated, the selection of Case 3 is preferred as the 

most favorable mode of resettlement. Inherent in this 

choice is the restriction of the inhabitants to residence 

in the lower half of the Atoll, with limited use of the 

islands in the northern quadrant. This implies as a 

minimum self-discipline on the part of the inhabitants 

with respect to public health and safety, i.e., exposure 

to the on-site hazards in the northern islands. The 

proposed plan should delineate control or quarantine 

measures to be implemented and enforced over a specified 

period of years. 

7.2.4 Community Center Development 

We found very little information contained in the statement 

addressing the long-term, on-going, health services following 

the initial phases of the resettlement. Continuing health 

services should be included in the preliminary planning in 

order to receive maximum benefit from the facilities and to 

establish, insofar as possible, some patterns of health 

service delivery early in the process. There is no 

indication as to whether the TTPI will have a medical officer 

on the Atoll. If so, would he have the responsibility for 

health education, particularly radiology? We note that the 

TTPI currently has a significant health manpower shortage: 

MDls, nurses, medics, etc. 
Page 3 

Remote communities in other districts of the Trust 

Territory are generally served by a sub-professional 

health aide with training similar to that of a U.S. 

Navy Hospital Corpsman serving a small ship or outpost. 

Ideally, this aide should have at his disposal a supply 

of drugs with a very simple numbering system. Reliable 

radio contact with the District Hospital is essential 

so that the aide can communicate with physicians in 

case of an emergency. Periodic visits by a physician 

and other health professionals are important in order 

to update the aide's training and to replenish his 

supplies. 

Prior to relocation, all persons should receive physical 

examinations, necessary immunizations, and have their 

individual health records prepared or updated. 

Should radiation sickness cases develop, is the Majoro 

Hospital (or Kwaplain Base) prepared to treat them? 

In addition, the statement indicates that two small 

dispensaries (2 room-2 bed) with health aid quarters 

will be located on Enjebi and Enewetak. However, it 

is also stated on page 7-10 that "Since development 

of the Master Plan, it has been shown that it is 

impractical to ••• develop Enjebi until such time as it 

can be shown to be safe." will the dispensary serving 

Enewetak be enlarged to adequately care for the people, 

and/or will an additional dispensary be located in the 

southern quadrant? In general, much more attention needs 

to be given to addressing the provision of health services, 

particularly long-term requirements of the population of the 

Atoll. 

7.2.5 utilities 

With regard to water supply, the statement indicates 

rain catchment-cistern utilization as the primary potable 

water source. The statement also projects potential 

curtailed water availability at the end of the "dry season". 

The inventory of Atoll resources includes a 43,000 galJ6ay 

disti.llation plant which may be put to limited use. Could 

this resource be made available for use to augment the 

Atoll's potable water supply? Further, the use of brackish 

wells as a limited water source is suggested in the statement. 
Page 4 

The feasibility of using ion-exchange, reverse osmosis 

or other presently available techniques should be investigated 

for water supply augmentation. 

The housing and community development plans project the 

use of privie-septic tank-drain field installation for 

disposal of domestic wastes. While placement of such 

installations will be carefully considered, the possibility 

exists that effluents may enter the usable water table, 

posing potential for contamination of the existing water 

lens. Therefore, we suggest that a definitive sanitation 

program be implemented for continued monitoring of the 

usable water supplies and maintenance of disposal installations. 

A recently developed small scale aerobic digestion unit 

may be a possible alternative to the septic-drain field 

concept. We recommend that the feasibility of utilizing 

this concept be studied. 

With regard to 7.2.4 and 7.2.5 mentioned above, the 

Health, Sanitation, Education, and Social Service section 

of the 1973 HEW/Interior Task Force Report on the Trust 

Territory of the Pacific Islands should prove a useful 

reference item. 

8.6 Impact of Base Camp Sewage Disposal on Human Health 

Sewage outfall lines would best be located to flow into 

ocean waters rather than the lagoon, because of the 

possibility of disease transmission through consumption 

of raw or partially cooked shellfish or other marine 

organisms contained by partially treated raw sewage. 

The assumption that raw sewage will be flushed out of the 

lagoon by ocean currents is apparently based on speculation 

and observations of the dispelling of solid wastes from 

the lagoon by this method. Isolations of pathogenic 

organisms from similar lagoons in the Trust Territory 

suggest that these waters may become contaiminated even 

under low volume dumping. 

8.11 Impapt of Pesticides in Base Camp on Human Health 

It is stated that chlorinated hydrocarbons will not be 

used for pesticide control, but organic phosphates would 

be used only in the required quantities. The concerns 

seem to be focused on the environmental residuals. However, 

some concern should also be focused on the toxic effects 

to the workers applying the pesticides and to people in 

the general area. EPA, NIOSH, and USDA are establishing 

some feasible standards and/or work practices for persons 

using pesticides. 
Page 5 

8.16 Impact of Blasting During Cleanup - Human Health 

The draft statement indicates that all kinds of shellfish 

may be consumed by the people populating the islands. 

It appears the best shellfish growing site in the lagoon 

is the blast area. Because shellfish tend to concentrate 

pollutants, including radionuclides, we believe extensive 

sampling and testing (for fission and activation products) 

should be undertaken before any shellfish growing areas 

are harvested. 

8.22 Impact of Toxic Materials Encountered During Cleanup 

We note that beryllium contaminated materials will be 

disposed of along with the radioactive material. However, 

no mention is made concerning the safeguards needed for 

the workers conducting the cleanup. Occupational health 

experience dictates that some degree of expertise is 

needed in controlling the exposure of workers to beryllium. 

NIOSH has put out a criteria document which deals in part 

with control of worker exposure to beryllium and the USAF 

has had extensive experience with decontamination of buildings 

where beryllium was being machined. . 

8.26 Impact of Noise During Rehabilitation and Resettlement 

We found no mention in the draft statement concerning 

the impact of noise levels effecting workers and people 

on the Atoll during the rehabilitation and resettlement 

activities. 

Summary 

Based on information contained in the draft statement, Ujeland 

has a total land area of 429 acres and Enewetak 1760 acres. 

Enjebi has a land area of 290 acres. The islands of Enewetak, 

Medren, and Japtan have areas of 32~ 220, and 79 acres respectively 

for a total 611 acres. This latter area would appear to be 

ample and certainly an improvement over the current conditions 

on Ujeland for the resident areas for all of the Enewetakese. 

The southern islands which have very low residual radioactivity 

have a total area of 804.68 acres. This makes an additional 

193 acres available over and above the resident islands acreage 

which could be devoted to unrestricted agriculture use. In 
Page 6 

addition, there are 524.31 acres in the northern islands 

which have intermediate levels of residual radioactivity 

that are judged to be suitable for raising coconuts. 

Based on all of these considerations, it appears that from 

a cost-benefit standpoint the use of Case 3 would be the 

optimum solution to the question of resettling the Enewetakese. 

On the other hand, if the driEnjebi would be extremely 

dissatisfied under these conditions, political and social 

indications may be such that they should be allowed to resettle 

on Enjebi, thus necessitating the use of Case 4. In this 

instance, the annual dose to individuals would exceed the 

AEC limits, but would be below tho~e set by the FRC (whole 

body 0.35 rem/year vs. 0.5; bone 0.975 rem/year vs. 1.5; 

and bone marrow 0.3 rem/year vs. 0.5). It would leave a 

residual of approximately 140,000 cubic yards of contaminated 

soil and/or soil and radioactive debris to be disposed of 

other than that which could be achieved through crater dumping 

or crater containment. It would very likely require indefinite 

storage of soil on the island of Runit until suitable methods 

of disposal could be developed and agreed upon. 

If the technique of crater containment is finally judged to 

be feasible, it should provide a reasonable degree of protection 

from the stored radioactive materials. One then might consider 

utilizing an additional crater to contain the residue of 

radioactive scrap and soil as mentioned above. This would 

require a cube approximately 73 feet on a side and 73 feet 

deep. With the apparent relative insolubility of the residual 

plutonium and fission products in this material, relatively 

small leaks into and out of a structure of this sort as well 

as that from sealed craters would appear to present a minimal 

hazard. 

Thank you for the opportunity to review this draft statement. 

Sincerely, 

f~(;~ Charles Custard 

Director 

Office of Environmental Affairs 
DEPARTMENT OF TRANSPORTATION 

UNITED STATES COAST GUARD 

MAILING ADDRESS:( G-WS/73) U.S. COAST GUARD 

400 SEVENTH STREET SW. 

WASHINt,;XqN. D.C. 2OSIiIO 

PHONE:4:tb-2262 

. J." Ut.e IH/4 

• 

Director 

Defense Nuclear Agency 

Washington, D. C. 20305 

Dear Sir: 

This is in response to your letter dated 3 September 1974 addressed to 

Office of Marine Environment and Systems U. S. Coast Guard. 

The concerned operating administrations and staff of the Department of 

Transportation have reviewed the material submitted. The Coast Guard 

commented as follows: 

liThe U. S. Coast Guard will be required to maintain a LORAN Station 

on Eniwetok Island until at least 31 December 1977. The DNA contractor 

is currently providing the Coast Guard with sleeping quarters, all meals 

medical services, electrical power, communications services, fuel and 

vehicles. Should any or all of these services be terminated, it will 

be necessary for the Coast Guard to replace them with some probable adverse 

impacts on the environment. Among these impacts will be: 

(1) An increase in personnel assigned from 10 to approximately 

16 to 20. 

(2) Construction of sleeping quarters with cooking and dining 

facilities. 

(3) Installation of diesel powered generators and fuel tanks 

with 180,000 gallon capacity. Enlargement of the present power 

building will also be required. 

(4) Installation of additional communication equipment and 

associated antennas. 

While these are contingency items and their environmental effect would 

be small in comparison with the overall project, they should be addressed 

in the final E1S. Mention of the LORAN Station should be made in the 

'Enewetak' (Eniwetok) section, page 15 of the summary, and appropriately 

in the text of the E1S. 

liThe basis for calling the atoll and the island 'Enewetak' vice 

'Eniwetok' should be reviewed . • 
II In the sl.Ullffiary, the th ird sentence of 'Phase 3 - Resettlement' on 

page 3 contains a phrase 'that the living patterns of the people conform 

to the limitations recommended •... ' Out of context this phrase could be 

offensive, i.e., natives are being asked to change their culture to adapt 

to recommendations of the American Government. It is recommended that the 

phrase be reworded to avoid any tUgly American' connotation. 

TIThe elements of sewage disposal and ocean/lagoon water quality should 

appropriately be commented on by the EPA. (NPDES) 

"Section 8-23, DEIS text, states tstandard radiological safety 

procedures will be practiced during the cleanup operation.' Undoubtedly 

AEC will govern this aspect. It should be mentioned in this section, 

however, that the transportation of radioactive material by vessel, such 

as to a remote disposal site, will be so accomplished in compliance with 

current regulations (46 CPR 146.19). 

!TIn a telephone conversation on 12 December 1974 between Mr. M. E. 

Stevens of your office and Commander L. Y. Wald of my office, the impact 

of the termination of the contract was further discussed. The point of the 

discussion was that it should be emphasized that a possible two year lead 

time would be required to obtain the equipment necessary to duplicate the 

services now being supplied by contract. It is the Coast Guard's grave 

concern that should the services to the Loran Station on Eniwetok Island 

be terminated, the outage of this station would affect the entire Pacific 

Ocean Loran net.!! 

The Department of Transportation has no other comments to offer. The final 

environmental impact statement, however, should address the concern of the 

Coast Guard. 

The opportunity to review this draft statement is appreciated. 

Sincerely, 

W. E. CALDWELL 

Captain, U. S. Coast Guard 

ActnJ Chief, Office of Marine 

Envlror:"lciit and Systems 

2 
UNITED STATES 

ATOMIC ENERGY COMMISSION 

WASHINGTON. D.C. 20545 

DEC 9 •• 

Warren D. Johnson 

Lieutenant General, USAF 

Director 

Defense Nuclear Agency 

Washington, D. C. 20305 

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 

Enewetak Atoll. 

We have reviewed the Statement and are providing the following comments, 

and the enclosure of supporting comments 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 these radiological criteria are based upon current 

national and international standards (see AEC Task Group Report, Volume II, 

Appendix B) 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 formulated 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. 
Warren D. Johnson - 2 -

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 NV-140 or estimates derived from equations presented in NV-140. The 

Task Group report presents estimates of maximum annual exposures for 

individuals considering 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, 

5-9 and 5-10 be revised using information from the Task Group report 

(Appendix IV, Section B, Volume II). It is also recommended that doses 

for bone marrow, not bone, be used in all tables presenting maximum 

annual marrow criteria, and that AEC estimates of 30 year and maximum 

annual doses for Belle, 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. 

Further detailed discussions on these points are presented in the enclosure. 

With regard to Section 5.3.1 on biological risk, the BEIR report estimates 

represent 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 

estimates 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. 

The risk estimates should be recalculated to account for revisions needed 

for 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 

these changes. 

The arguments presented in the statement opposing ocean dumping of 

contaminated wastes are in our opinion weak and unconvincing. The 

IIdifficulty of obtaining a permit and certainty of international complications," whether true or not, are insufficient grounds for rejecting 

ocean dumping as a viable waste disposal option. We note that the 

International Atomic Energy Agency (IAEA) Board of Governors' document, 

GOV/1688, of August 7, 1974, discusses in draft form the provisional 

definitions and recommendations concerning radioactive wastes ocean 

dumoing. This document is in relationship to the responsibilities 

entrusted to lAEA under the Convention on the Prevention of Marine 

Pollution by Dumping of Waste and Other Matter. For Case 3 in the 
Warren D. Johnson - 3 -

DEIS, even if one assumed that 79,000 cubic yards of Atoll soil 

containing an average of 1 nCi/gm of Pu239 were dumped into the ocean, 

it would represent only about 75 Ci for this one time action. This is 

far below the ypper disposal limit of 1010 Ci/year for alpha wastes 

(based on Pu23~) in GOV/1688. 

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 fo110wup 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 
• 

Warren D. Johnson - 4 -

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 

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 

September 1974 visit to Enewetak Atoll indicated that a group of people from 

Uje1ang 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 treated in the DEIS. 

Sincerely, 

mes L. 

A sistant General Manager for 

Biomedical and Environmental 

Research and Safety Programs 

Enclosure: 

Staff Report 

cc: Council on Environmental Quality, w/enc1. (5) 
Supporting AEC Comments on the Defense Nuclear Agency 

Draft Environmental Impact Statement on the 

Clean-up, Rehabilitation, Resettlement of 

Enewetak Atoll - Marshall Islands 

1. Dose Estimates 

.A severe deficiency in the DEIS concerns the dose estimates presented in 

macrix 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 the recommended 

radiation criteria were provided in the AEC Task Group report: 

3O-year whole body dose (for a population living in various parts of 

the Atoll). 

3O-year bone dose (mineral bone). 

Maximum annual whole body dose (considering the most sensitive individual). 

Maximum annual bone marrow 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 NV-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-up 

options (cases) and presents maximum annual values for bone that were calculated 

using an equation in NV-140 that is considered adequate only for determining 

30-year doses. (Other models are now used in calculating maximum annual doses 

to bone and bone marrow that accommodate important changes that occur with 

time and with aae of the individual.) The following examples show reasons 

why we cannot agree with the DElS presentation of doses in Section 5, 

lIC1eanup and Habitation Alternatives," unless the presentation is appropriately 

modified. 

Table 5-8, page 5-50 

DEIS Case 1 WB- 6 Rem in 30 years 

Bone= 60 Rem in 30 years 

These were determined for an average individual in the entire Atoll. 

AEC Case 1 WB= 31 Rem in 30 years 

Bone= 220 Rem in 30 years 
- 2 -

See AEC estimates for a population living on Belle, Section B, Volume II, 

pages 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. 

Table 5-9, page 5-51 

DEIS Case 1 WB- 0.3 Rem in one year 

Bone= 2 Rem 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 34-35, 

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. 

Table 5-10, page 5-53 

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 Group 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 

important consideration seems 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 

rates. The nearest category of Federal recommendations are guides for a 

population group where annual average doses are to be determined giving due 

consideration to the most sensitive nembers. 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 

may be used when there is a sufficient level of radiological monitoring that 

exposures, including those of the most sensitive individuals, will be known. 

AEC criteria for exposures at Enewetak do not apply to an average individual 

on the entire Atoll or to a population group within which there would be a 

wide range of doses that make up the average. 

Tables 5-11, 5-12 and 5-13, pages 5-54, 5-57, and 5-59 

We have not subscribed in the past to an approach that considers as alternatives, 

clean-up of islands to various external radiation isopleths such as F or K as 
- 3 -

defined by the EG&G aerial survey. Such an approach is deficient in that 

it does not adequately treat the reduction, if any, of the more significant 

exposures that are expected to occur from internal emitters coming through 

the food chain for crops grown on the islands. Sections 5.6.1.1 and 

5.6.1.2 and tables 5-11 and 5-12 are not consistent with the Task Group report. 

2. Debris and Soil Disposal 

Four other alternatives are mentioned, consisting of crater dumping (5.5.2.2), 

crater containment (5.5.2.3), return to the continental United States (5.5.2.4), 

and storage on Runit (5.5.2.5). Although a few advantages and disadvantages 

are mentioned for some of these alternatives, the specific environmental 

impacts of each are not discussed nor can the reader find which alternatives 

are proposed for which wastes. 

In the section on returning radioactive debris to the continental U.S. (5.5.2.4), 

Richland, Washington is cited as an example of "one of the low-grade disposal 

areas in the western part of the United States." There are two radioactive 

waste burial areas which can be identified as being near Richland, Washington. 

One is operated by the AEC and ordinarily does not compete with private industry 

by accepting offsite-generated waste, either from private firms or from other 

Federal activities. The other is operated by a private firm which could or 

could not accept such wastes. 

The statement that ocean dumping was rejected (5.5.2.1) is in contradiction to 

the later statement that "Pu contaminated surface soils would be removed from 

five" islands and disposed of at sea" (first indented item, page 11-1). The 

quantities of radioactivity to be disposed of are not quantified, nor is the 

environmental impact discussed, in the remaining text of Section 11 

(irreversible or irretrievable commitments of resources). Sea dumping is 

not mentioned in the description of the "proposed (preferred) cleanup operation" 

(Section 6) nor the discussion of adverse environmental impacts which cannot 

be avoided (Section 9). Radioactive sea dumping is not discussed in the 

section on environmental impacts, which is a conspicuous omission since 

Section 8.18 discusses the impact of dumping noncontaminated materials at sea. 

Section 6.2.3 discusses the placement of plutonium-contaminated soil and scrap 

within a concrete matrix in LaCrosse crater. Section 8.19.1 states "maintenance 

of the crypt is a continuing problem" in referring to this plan, but neither 

section gives an indication of intent as to the responsibility for long-term 

surveillance and maintenance of this rather special case of transuranium waste 

storage. 

The proposed method of disposal of Pu contaminated scrap and soil assumes that 

LaCrosse crater can be pumped out. Has it been clearly established that this 

can be done? The reef is often porous and cracks may have been caused by the 

detonation. We would suggest that DNA should consider whether the craters can 

and/or need to be pumped out for this particular option. 
- 4 -

Page 2-1, Lines 14-15 - Should also include the fact that removal and disposal 

of plutonium-bearing soil in the 40-400 picocuries per gram range will be 

decided on a case-by-case basis. Suggest also include the following change: 

"Removal and disposal of plutonium-bearing soil which exceeds 400 picocuries 

per gram at all locations and 40 picocuries per gram on islands where housing 

may someday be located. 

Page 2-2, lines 9-10 - the conclusion that plutonium debris will be encrypted 

in the LaCrosse crater seems premature at this point in the DEIS. Recommend 

deletion of this sentence. 

Page 6-4, lines 10-11 - Recommend substitution of the words "appropriate 

disposal" in place of entombment with the radioactive scrap in LaCrosse center" 

and recommend deletion of the rest of the page. The text, as written, assumes 

that the entombment disposal action will be adopted. 

Page 6-8, lines 10-11 - Recommend substitution of the words "and stored for 

eventual disposal" in place of "encapsulated in concrete in one or both of the 

craters on Runit." 

Pages 8-29 and 8-30, Sections 8.18 and 8.19. Recommend that the ocean dumping 

option be left open as another possibility for disposal. 

Page 11-1, lines 4-5. In referring to disposal at sea, this sentence is 

inconsistent with previous discussions in the DEIS concerning Pu contamination 

disposal. However, recommend that this ocean dumping option be retained as a 

possibility for disposal. 

3. Miscellaneous Remarks 

Page 3-10, last line on page - Delete the word "light." 

Page 3-12, 6th line from the top - Delete "of water." 

Page 3-15, Section 3.2.5, line 10 - Change "devastaged" to "devastated." 

Page 3-44, 1st line - Change "life" to "live." 

Page 3-46, Section 3.3.4.2, line 10 - Change "Engebi" to Enj ebi. " 

Page 3-49, Section 3.5.1, 3rd paragraph - Change "patrilineal" to "ideally 

matrilineal" as per Tobin's paper "Land Tenure in the Marshall Islands, 1956." 

Essentially the iroij power comes from land holdings and land is owned by the 

women. 

Page 3-52, Section 3.5.3, line 11 - Change "as island" to "an island." 
- 5 -

Page 3-57, 2nd paragraph, line 3 - Change "Enewakese" to "Enewetakese," 

or better yet "people." 

Page 3-62, last sentence in Section 3.8.1.1.1 and 3.8.1.1.2 - Breadfruit 

should be included with pandanus. (This would be consistent with the 

statement in NVO-140, that in predicting 137 and 90 concentrations in Cs Sr breadfruit, it is assumed that breadfruit and pandanus fruit will experience 

the same uptake from soil.) 

Page 3-63, Section 3.8.1.1.3, lines 1, 2 and 3 - This sentence should be 

changed to reflect the lack of completeness of conclusive data on this sUbject. 

Change to, "The available data indicates that the body's uptake and retention 

of Pu through the gastrointestinal tract is a small percentage of the Pu 

ingested. This pathway is therefore less significant than other potential 

means of ingress to the body." 

Page 3-63,Section 3.8.1.2, last sentence: As presented the statement is not 

correct. Sentence should read: After 15 years of wind action on Enewetak 

Atoll, much of the dispersion of surface contamination has already occurred. 

Further significant redistribution due to wind action seems unlikely, although 

test related radioactivity is found in surface air at detectable levels. 

The dust raised by resident activities is expected to increase airborne 

concentrations with further redistribution of the radioactivity." 

Page 3-84, Section 3.8.2 - The fourth sentence indicates that all the Be has 

been removed, but the sixth sentence indicates that there is still some Be that 

needs to be cleaned up. Suggest the paragraph be consistent. 

Page 5-3, line 1 - Change "as" to "has." 

Page 5-13, Option 2 - This should be clarified since it does not appear 

consistent with Table 5-6 in that it states " ••• may use food grown on Enjebi 

other than pandanus and breadfruit." Whereas table indicates these are the 

two that can be grown on Enjebi with the appropriate restrictions. 

Page 5-21/5-22. Section 5.4.1.1, first line - Change "islanders" to "people 

of Enewetak" or "Enewetak people." 

Page 5-25, Section 5.4.2.2 - This doesn't agree with Figure 5-2 in that 

5.4.2.2 implies that the southern islands are Jinedrol through Kidrenen 

and limits inter-island visitation, agriculture, as well as collection of 

birds and eggs to these islands whereas the figure extends the allowable 

islands for these activities to include Boko, Munjor, Inedral, and Van, 

all of which are north of Jinedrol. 

Page 5-32 and 5-33 - Figure 5-3 is not consistent with text for Case 3 in 

that: Text states that residence would be restricted to Jinedrol through 

Kidrenen yet the figure shows Boko, Munjor, Inedral and Van also as living 

islands; both the figure (which show Enjebi as only a picnic island) and 

text (page 5-34) agree that there will be no cultivation on Enjebi yet the 
- 6 -

case summary on figure 5-3 shows "subsistance agriculture limited to 

southern islands plus Enjebi." It it is.not clear what islands ~re included 

in the "southern islands." 

Page 5-40, Section 5.4.4.3 .- Change "does" to "dose." 

Page 5-45, Section 5.4.5.3, next to last line - "solid replacement" should be 

"soil replacement." 

Page 5-47, Section 5.5.2.1 - This section should be revised and updated to 

show that the possibility of ocean dumping is again being discussed. 

Page 5-78, paragraph 2.h. - "pvoide" should be "provide." 
UNITED STATES 

ATOMIC ENERGY COMMISSION 

WASHINGTON, D.C. 20545 

December 23, 1974 

Warren D. J ohnSOJl 

Lieutenant General, USAF 

Director 

Defense Nuclear Agency 

WashiRgton, D. C. 20305 

Dear General Johnson: 

Please refer to my letter of December 9, 1974, transmitting AEC 

comments on the Draft Environmental Impact Statement for Clean Up, 

Rehabilitation, Resettlement of Enewetak Atoll - Marshall Islands. 

It is requested that our comments be revised to include the following additional information: 

During the last 8 years the Nuclear Energy Agency (NEA), 

formerly the European Nuclear Energy Agency (ENEA), has 

managed an ocean disposal program for radioactive wastes 

from the member countries. The following, by years, is 

a listing of the curies (Ci) of alpha activity in the 

materials so disposed. The alpha activity is assumed to 

be Pu 239. 

1974 - 416 1970 - 233 

1973 - 773 1969 - 390 

1972 - 674 1968 - 721 

1971 - 324 1967 - 92 

Total 3633 Ci - alpha 

Other operations from 1949 to 1967, such as U.S. and U.K., 

disposed of wastes containing similar quantities of longlived alpha active materials. Thus, a total of at least 

7,000 alpha Ci have been disposed of into the ocean. If 

we assume 15 grams of Pu per Ci alpha activity, the total 

is at least 100 kilograms of Pu. Thus, it is evident the 

disposal of a few hundred grams of Pu from Enewetak Atoll 

would not materially add to the alpha activity already 

disposed in the deep ocean. 

cc: H&N,Mr. Woo1fenden) _ 1/8/75 

AFRRI, Hr. Slaback) 
Warren D. Johnson -2- December 23, 1974 

Reference is also made to paragraph 2, section 2, page 3, of the 

supporting AEC comments. Please delete the final sentence of that 

paragraph and replace with the following: 

The other is operated by a private firm licensed by the 

State of Washington. Under proposed regulations, this 

latter burial ground may not be permitted to accept 

plutonium-contaminated waste. 

Sincerely, 

J es L. Liverman 

A sistant General Manager 

for Biomedical &Environmental 

Research &Safety Programs 
OFFICE OF THE ASSISTANT SECRETARY OF DEFENSE 

WASHINGTON. O. C. 20301 

HEALTH AND 

ENVIRONMENT 1 a ~L!V 1974 

MEMORANDUM FOR Director, Defense Nuclear Agency 

SUBJECT: DEIS, "Clean-Up, Rehabilitation, Resettlement of 

Eniwetok Atoll-Marshall Islands!! 

The Draft Environmental Impact Statement for the Clean-up of Eniwetok 

Atoll has been reviewed and is generally found to be satisfactory. The 

following items should be addressed to provide a more complete understanding of the program: 

1. The estimated time frame of the various phases of the operation noted 

on pages 2 and 3 of the summary should be specified, especially the anticipated completion of phases 3 and 4 since this is a question of vital importance to the people concerned. 

2. The relative hazard level to personnel relocated to the islands compared 

with presently accepted AEC standards for human health should be tabulated 

rather than the generalizations presented in the summary. 

3. Some controls on movement of the relocated personnel must be established. There is no question that some personnel will test the system and 

attempt to visit or even settle on some of the forbidden northern islands. 

Since the hazard is a long-term phenomena and no immediate consequences 

of such an action would be evident, a comprehensive education program to 

insure that the relocated personnel understand the hazard and the consequences of such visits is a necessity. 

4. A long-term continuous monitoring program of the conditions at all 

locations is believed to be a firm requirement until all hazard is removed. 

5. Assuming more adequate disposal techniques become available in the 

future, consideration should be provided for implementation of such methods 

at some future date rather than permanent entombment on Runit. 

I a'I:It,J ~< }t., 

/ /C.-(/fatt.ohn P. Meade 

tit Colonel, USAF BSC 

Dir ector for 

Categorical Programs 

Pa 

R gional Administrator 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

100 CALIFORNIA STREET 

SAN FRANCISCO. CALIFORNIA 94111 

DEC 12 1974 

Warren D. Johnson, Director 

Defense Nuclear Agency 

Washington, D.C. 

Dear Mr. Johnson: 

The Environmental Protection Agency has received and 

reviewed the draft environmental statement for the following 

proposed action, Clean Q£, Rehabilitation, Resettlement of 

Enewetak Atoll, Marshall Islands. 

EPA's comments on the draft environmental statement 

have been classified as Category ER-2, specifically environmental 

reservations pending the resolution of comments noted in the 

attachment to this letter. Definitions of the categories 

are provided on the enclosure. The classification and the 

date of EPA's comments will be published in the Federal 

Register in accordance with our responsibility to inform the 

public of our views on proposed Federal actions under Section 

309 of the Clean Air Act. Our procedure is to categorize 

our comments on both the environmental consequences of the 

proposed action and the adequacy of the environmental statement. 

EPA appreciates the opportunity to comment on this 

draft environmental statement and requests one copy of the 

final environmental statement when available. 

ly, 

Ivc;//£1f1t 

Enclosure 

cc: Council on Environmental Quality, Wash., DC 20460 
COMMENTS ON DRAFT EIS 

CLEAN-UP, REHABILITATION, RESETTLEMENT 

OF ENEWETAK ATOLL - MARSHALL ISLANDS 

The analysis of this proposed action is divided into two 

sections: (1) Radiological Aspects; and (2) Other Environmental Aspects. 

Radiological Aspects 

Current Sampling Needs 

A great amount of sampling and analysis has been done and 

the magnitude of the radioactive contamination has been 

relatively well defined. However, there are two areas in 

which more information is needed to aid in decision making: 

(a) The water quality of the brackish water lens needs to 

be determined for those islands to be inhabited before 

a decision is made to use the water. Radiological, 

bacteriological, and chemical quality should be determined for a period of at least 12 months. 

(b) Airborne radioactivity, especially plutonium, needs to 

be determined over a period of at least a year on all 

islands to be inhabited and on other heavily contaminated islands after chean-up and before lifting of 

quarantine. Due to the large amount of plutonium on 

the atoll and the uncertainties in predicting resuspension factors it is very important that the actual 

conditions be determined rather than calculated. 

It is surprising that uranium isotopes were not detectable 

in air filter samples. Were analysis made for uranium? 

Future Sampling 

It is apparent (and recognized in the Draft EIS) that 

regular monitoring will be necessary for many years after 

resettlement and should include air, water, food, and body 

burdens of the Enewetakese. This requires some agency to 

accept the responsibility and obtain the funding for this 

necessary follow through. 
-2-

Recommended Clean-Up and Disposal Plan 

It is agreed that soil significantly contaminated with plutonium should be removed from islands in the atoll. EPA 

(letter of May 17, 1974) has previously accepted, in general, 

the radiation protection criteria and clean-up criteria prepared by AEC. However, these criteria should be considered 

as upper limits and the clean-up levels and population doses 

should be maintained as low as practicable. The Draft EIS 

appears to recognize this concept but there is uncertainty 

on how it is to be applied. For example, the Statement is 

vague on when a 40 pCi/gm limit will be applicable and when 

400 pCi/gm will be satisfactory. This uncertainty should be 

clarified in the Final EIS. 

The choice of crater entombment for disposal of contaminated 

soil appears to be the most feasible alternative and provides 

some degree of retrievability. The fact that this is only a 

semi-permanent solution should be recognized. Several other 

points that should be addressed in the Final EIS are: (1) 

more discussion on the technical advantages and disadvantages 

of ocean disposal rather than a rejection based on purely 

legal and international difficulties: (~) the remedial 

action that will be taken if the volume of Cactus and 

La Crosse craters is insufficient to contain all the contaminated soil: and (3) the action that will be taken if the 

Enewetakese reject the entombment option. 

Recommended Rehabilitation and Resettlement Plan 

The recommendation that habitation be limited to the Southern 

Islands is sound and the Statement quite properly does not 

promise an early end to restrictions on use of the Northern 

Islands. However, there are several aspects of the plan 

that have not been adequately explained. 

The decision to permit subsistence coconut production on the 

northeastern islands is not justified in the EIS. Virtually 

all of the predicted dose received by the Enewetakese under 

the proposed plan is due to this decision. When using an 

"As Low as Practicable" concept a dose should be accepted 

only if it cannot be avoided by practicable means, regardless of whether the total dose is still under the RCG being 

used. This use should be deferred unless it can be shown 

that there is no practicable alternative to providing an 

adequate diet or that radionuclide contamination is actually 

much lower than predicted. 
-3-

The possible marketing of copra produced on the atoll needs 

to be evaluated in an "As Low as Practicable" context prior 

to decision making in order to determine if the economic 

benefits to the Enewetakese outweigh the r~diological cost 

of the population dose delivered to off-island populations. 

The total quantity of plutonium and strontium radionuclides 

estimated to be present in lagoon sediments are somewhat 

greater than are present on the islands of the atoll. 

Apparently, the majority of the contamination is in the 

northwest portion of the lagoon. The Draft EIS does not 

discuss the short and long range implications of this 

source, nor does it indicate whether any consideration was 

given to the feasibility of minimizing the future radiation 

dose that will be obtained from the seafood pathway. 

There is no discussion of the decision to permit fishing in 

all of the lagoon. Apparently, this recommendation came 

from the conclusion on page 11-43 that there was "no statistically significant difference for dose estimation purposes 

between samples taken in different parts of the lagoon." 

The data depicted in Figures 160-161 suggests that l37Cs, 

90Sr, 239Pu concentrations in convict sturgeon may be somewhat higher near Belle and Irene, where bottom sediment 

concentrations are also highest. 

The recommendation to ban coconut crab collection in the 

Northern Islands is perhaps prudent but was reached without actually sampling any crabs in that part of the atoll. 

Also, the possibility of this restriction being observed is 

uncertain because it is a delicacy, in short supply, and the 

islands would be open for picnicing and fishing. 

Clean-Up Operation 

We have no specific comments to make about this phase except 

to note that there will be significant possibilities for 

inhalation exposures to workers and transport of radioactive 

material from greater to lesser contaminated portions of the 

atoll. Constant health physics support will be needed. 
-4-

Other Environmental Aspects 

Sewage Disposal During Clean-Up 

The proposed discharge of raw sewage is of serious concern 

to EPA. The Trust Territory standards of water quality do 

not permit raw sewage discharges into surface waters. 

Although the discharge may not be subject to TTPI jurisdiction, it would be inappropriate for a Federal agency to 

carry out a discharge contrary to TTPI policy. In addition, 

the raw sewage may result in public health hazards to any 

users of these waters. 

It is possible that these crude sanitary facilities may 

continue to be used for years. The later stages of clean-up 

may well occur after many of the Enewetakese have returned. 

There is a possibility that some tourism will develop and 

the environmental statement mentions that these existing 

facilities could be used. 

EPA recommends that some form of sewage treatment be provided 

for the wastewaters generated by the clean-up personnel and 

subsequent visitors to the atoll. 

Garbage and Trash Disposal During Clean-Up 

Garbage and trash residue should not be dumped off the end 

of the island for the same reasons noted above. Burial may 

be an appropriate method of disposal provided it does not 

interfer with the brackish water lens that may be used for 

water supply. 

water Supply and waste Disposal 

The plan to extensively use roof catchment with large cisterns at individua1 residences and community bui1dings is 

good. However, it is probable that supplemental supp1ies 

will be needed. Plans to use septic tank leach fields and 

to bury garbage must be evaluated with great care due to the 

potential to contaminate the brackish water lenses which may 

serve as the source of supp1emental water supply. 

The environmental statement should discuss this serious 

potential conflict and present evidence that wastewater and 

garbage disposition will not degrade the drinking water 

supply. The Department of Health Services, Environmental 

Health Division of the Trust Territories should have a fundamental role in deciding on the water supply and waste 

disposal systems that are selected. 
Cll\PT£R 3 

PREPA~\TIO~, APPROVAL, A~D 

;)ISTRIBUTIO~" OF C0i-1HE:GS ,):, .?'::'/ZS':i or FEDeRAL ACTIONS 

EWIRON~U:::NTAL IitPACT S:'.\?.t::[':NTS ::::·!P';;C':'ING TilE ES'lrRONilE~;T 

Enviro~ental Impact of the Action 

LO--Lack of Objections 

EPA has no objeccions to the proposed actio~ as described 

in the draft impact state~ent; or sugg~s~s only minor changes 

in the proposed action. 

ER--Enviro~~ental Reservations 

EPA has reservations concerning the envi!:onrn.ental effe::ts of 

certain aspects of the proposed action. ::!'A !:>elieves that 

further study of suggested alternatives or r.:odEications is 

required and has asked the originating ?ederal" agency to reassess these aspects. 

EU--Enviro~entally Unsatisfactory 

EPA believes that the proposed action is unsatisfactory 

because of its potentially harmful eff~ct on the envirolli~ent. 

Furthermore, the Agency believes that t~e potential safeguards which might be utilized may not adequa~ely protect 

the environment from hazards arising fro~ this action. The 

Agency reco~~ends that alternatives to the action be analyzed 

further (including the possibility of no action at all) • 

Adequacy of the Irn2act Statement 

Category l--;\dequate 

The draft i:;-.pa-::t statement adequately set::s forth the 

environmental i~pact of the proposed ?=oject'or action as well as alternat'hoes reasonably available to t~.::;! ,;l!:'oject or action. 

Category 2--Insufficient Information 

EP,\ belie,-:s that the draft impact sta-:s:cen:: d':)-:;!s not contain 

sufficient information to assess fully -:h.:;: e~'.riron..-:H?nt.::tl 

impact of t:"lS ?roj?osed p!:'oject or actio:1. :i?,...'ev~:::, frow the 

information s~b~itted, th: Agency is a~le to ~a~e a 

prelil!!ina.r:,- ceterrnination of t~e impact o~ t:-,e e;:'!Viron::~ent. 

EPA has requested that the originator !=!:O'lide ens information that was not included in the drai~ st~te~e~~. 

Category 3--Inadequate 

BPA believes that the draft impact state:cent joss not 

adequately assess the envi::::oIL'!lental L--:pac-: of t:-;.::! ?roposed 

project or actio;1, or that the state:-te:1-:' _;1ads~t,;.:.teli· 

analyzes reaso:1ably avai lable al t:.ern:l~':'·:es _ ?~e :\g0ncy hilS 

requested !::ore inEor!:lation and a:1alysis c:>:;c€:r::ing t::he 

potenti:ll environrn.ental hazards and naS as%e:! ::~,:l.'; substantial revision be ~aje to the impact s::a';e~ent. 

If a draft i~pact statement is assigned a Categ?ry 3, no rating will ~e ~ade of the project or :l=::i:>!l, si:1ce n 

basis does .r,ot .:;ener:::tlly exist on whi::~ to !":!a:c<! s\.:.ch a 

deterr:lination. 

CHAP 3 :'~.; 1640 .. 1 Fi~~~e 3-1. A~tac~.ent 

11- J:) ,72 Pa:;.? 2 of 2 

') 
SUMMARY SHEET 

DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR CLEANUP, 

REHABILITATION, AND RESETTLEMENT OF ENEWETAK ATOLL, 

MARSHALL ISLANDS 

1. This is a Draft Environmental Impact Statement for the proposed 

cleanup, rehabilitation, and resettlement of Enewetak Atoll, the Marshall 

Islands. The statement is an administrative action in compliance with 

the National Environmental Policy Act (NEPA), (47USC4332). 

2. This statement addres ses a proposed project to remove and dispose 

of debris, structures, and soils which pose physical or radiation hazards 

or which pose obstructions to human habitation or the productive use of 

the land. The Department of Defense has been assigned responsibility 

to plan the cleanup phase of the proposed project. This statement also 

addresses the problem of the economic and social measures required to 

resettle the Enewetak people in the Atoll after 25-30 years of absence. 

The Department of the Interior, through the Trust Territory of the 

Pacific Islands, is responsible for this latter aspect of the proposed 

project. 

3. During the post World War II period, the Atoll was used as a 

proving grounds for development testing of modern weapons and weapons 

systems, particularly nuclear weapons. This resulted in the relocation 

of the inhabitants from the Atoll, the creation of hazards, both physical 

and radiological, and the consequent loss of much of the productive 

capacity of the Atoll. The intent of this project is to remove or reduce 

those existing conditions which would be a bar to safe habitation of the 

Atoll and to return the Enewetak people to the Atoll. The effects of this 

proposed action are expected to be permanent settlement of the people in 

a safe and productive environment. As the population grows from approximately 400 at present, the problems associated with a growing population 

xvii 
on a small isolated land area may be expected to be magnified. The 

effects of the engineering operation to produce the results desired will 

of course create some adverse effects such as fish kill, loss of habitat 

for fauna, soil erosion and other like effects. These latter effects are 

expected to be minimal and temporary when compared to the overall 

improvement which will result. 

4. The Engineering Survey Report prepared for the Defense Nuclear 

Agency and the Enewetak Radiological Survey (NVO-140) prepared by the 

Atomic Energy Commission are essentially are essentially condition 

surveys which show the hazardous debris and structures and the radiological conditions of the Atoll. From these two source documents and 

the AEC Task Group Report, as well as from a Master Plan for the 

resettlement of the Atoll prepared for the Trust Territory of the Pacific 

Islands, it is pos sible to visualize many alternatives which can be 

addressed in the evaluation of the many human, physical, and cost 

variables which are present. In order to obtain an overview of the many 

possible solutions, a tabulation of twelve illustrative solutions has been 

made. These involve three separate cleanup procedures for each of four 

different habitation control plans. The consequences of all these combinations are tabulated. Factors involved in structuring these solutions 

are radiological conditions, living patterns, physical hazards, and the 

disposal of hazardous and radioactive materials and scrap. The tabular 

analyses presented for these twelve particular solutions include possible 

radiation doses and cost-benefit comparisons. Based on this orientation, 

five solutions hereafter referred to as Cases 1 through 5, are selected 

for detailed discussion. Of these, two are considered to be the bounding 

outside limits but three are considered to illustrate the nature of the 

most likely solutions. 

Case 3 is considered to be the most responsive to the human, 

physical, and cost parameters presented in the three most likely solutions. 

xviii 
The estimated radiological dose is well below the radiation protection 

standards and guides recommended by the AEC Task Group; all hazards 

resulting from past construction and testing are to be removed; the cost 

is below the midpoint between Cases Z and 4. 

5. Under the conditions of Case 3, the Enjebi People would not be 

able to return to their ancestral residence island of Enjebi at an early 

time. This would require both the Enjebi and Enewetak People to live 

on the land formerly occupied only by the Enewetak People. Thus for 

some period of time, as yet undetermined, there would be less land 

available for agriculture; therefore, some supplement to their diet by 

importing food may be needed. 

6. The Draft Environment Impact Statement was made available to 

the Council on Environmental Quality, concerned federal agencies and 

the public on September 9, 1974. 

xvix 

Natural Resources Defense Council, Inc. 

1710 N STREET, N.W. 

WASHINGTON, D.C. 20036 

New York Office 

202 783-5710 S6 WEST 44TH STREET BOARD OF TRUSTEES 

NEW YORK, N.Y. 10036 Stephen P. Duggan. Esq. 

Chairman 24 September 1974 1Il~ 986-8310 

Dr. Dean E. Abrahamaon 

Mrs. Louis Auchlndoas West Coost Office Boris I. Blttker. Esq. 

Jobn T. Booth. Esq. 664 HAMILTON AVENUE 

Frederick. A. Collins. Jr.. Esq. TO: Lt. General Warren D. Johnson PALO ALTO, CALIF. 94S01 

Dr. Rene J. Dubos Director

James B. Frankel. Esq. 4 15 3~7-1080 

Robert W. Gilmore Defense Nuclear Agency 

Dr. Joshua Lederberg 

James Marsball, Esq. 

Ruby G. Martin. Esq. FROM: Dr. Thomas B. Cochran 

Anthony Mazzocchi Staff Scientist 

Michael McIntoSb 

JohnB.Oaka 

Dr. Gifford B. Plnchot RE: Draft Environmental Impact Statement -- Enewetak 

John R. Robinson, Esq. 

Laurance Rockefeller 

J. Willard ROOIIeVelt ENCLOSURE : "Radiation Standards for Hot Particles," 

David Sive, Esq. A. R. Tamplin and T. B. Cochran, NRDC, Dr. George M. Woodwell 

Edwin M. Zimmerman, Esq. 14 February, 1974 

1. NRDC finds the "Draft Environmental Impact Statement, Clean Up, 

Rehabilitation, Resettlement of Enewetak Atoll -- Marshall Islands," 

to be incomplete and inadequate. Furthermore, the proposed (preferred) 

clean up operation is totally inadequate to protect the health of the 

Enewetak people from exposure to hot particles of plutonium which carry 

a high risk of producing lung cancer. The basis for these conclusions 

is presented in the report, "Radiation Standards for Hot Particles,1I 

by Drs. Arthur R. Tamplin and myself (enclosure). This report is 

intended to be an integral part of these comments. 

2. "Radiation Standards for Hot Particles," was written in support 

of a petition by the Natural Resources Defense Council to the 

Environmental Protection Agency and the Atomic Energy Commission requesting (1) a reduction of the existing radiation protection standards 

applicable to the internal exposure of man to insoluble alpha-emitting 

hot particles and (2) the establishment, with respect to such materials, 

of standards governing the maximum permissible concentrations in air and 

maximum permissible surface contamination levels in unrestricted areas. 

3. The petition was filed with the AEC on February 14, 1974. It is 

totally irresponsible for the AEC Task Group on Recommendations for 

Clean Up and Rehabilitation of Enewetak Atoll to issue its report on 

June 19, 1974, without acknowledging the serious implications of hot 

particles as detailed in our report. 

4. It is NRDC'S~position that the clean up of Enewetak should meet the 

standards summarized on pages 51-52 of our report (enclosure). 

h

D (: 

c-..., 

Q ......~--
Document IIRadiation Standards for Hot Particles IT 

not included at this time but will be included in 

final distribution. 
RADIATION STANDARDS FOR HOT PARTICLES 

A REPORT ON THE INADEQUACY OF 

EXISTING RADIATION PROTECTION STANDARDS 

RELATED TO INTERNAL EXPOSURE OF MAN TO INSOLUBLE PARTICLES 

OF PLUTONIUM AND OTHER ALPHA-EMITTING HOT PARTICLES. 

FEBRUARY 14, 1974 

ARTHUR R. TAMPLIN 

mOMAS B. COCHRAN 

Natural Resources Defense Council 

t 710 N Street, N.W. 

Washington, D. C. 

20036 

TABLE OF CONTENTS 

I Introduction . . . . . . . . . . . . . . . . 1 

II Plutonium Use and Public Health • . . . . 3 

III Existing Standards for Plutonium Exposure . . . . . . 6 

IV Calculating the Dose Due to Insoluble Alpha-Emitters •• 11 

A The Dose Equivalent. • . . . . . . . . . . . . • 11 

B Modifying Factors . . . . . . . . . • 13 

C The Hot Particle Problem • • • • 18 

V Biological Data Related to the Cancer Risk from 

Insoluble Plutonium Exposure • • . • •• •••••• 21 

A The Geesaman Hypothesis . . . . · 22 

B Related Human Experience • . • • 26 

C Related Lung Experiments • • •.• 29 

VI Critical Particle Activity • 32 

A Exposure at Rocky Flats . . . . . • 34 

B Manhattan Project Workers . . . . 38 

C Weapons Test Fallout. . • • • 41 

VII Exposure Standards for Hot Particles . . . . • • 41 

A Occupational Exposure . . . . . . . . . . . · • 42 

B Exposure of the General Public · 44 

C Exposure from Accidental Releases • • 46 

D Surface Contamination . . . . . . • 48 

E As Low as Practicable Hearings . . . • • 50 

VIII Summary of Recommendations . . . . . . . . . . . · 51 

Appendix A Radiation Standards Setting Organizations and 

Their Roles 

Appendix B Statement Submitted to Attorneys for Mr. Edward Gleason 

Glossary 

I. Introduction 

This report is written in support of a petition by 

the Natural Resources Defense Council to the Environmental 

Protection Agency (EPA) and the Atomic Energy Commission 

(AEC) requesting (I) a reduction of the existing radiation 

protection standards applicable to the internal exposure of 

man to insoluble alpha-emitting hot particles and (2) the 

establishment, with respect to such materials, of standards 

governing the maximum permissible concentrations in air and 

maximum permissible surface contamination levels in unrestricted areas. 

Before proposing modifications to existing radiation 

l protection standards related to plutonium exposure , we 

review in the followinq section the qravity of the public 

health concern as plutonium becomes a principal article of 

commerce in the nuclear power industry. 

~/ While much of this report focuses narrowly on plutonium-239, 

the discussion is, nevertheless, germaine to all radionuclides 

in insoluble particles with a high specific activity. (The 

definition of specific activity and other technical terms 

in this report are given in the Glossary). The justification 

for focusing on plutonium has been aptly stated by the International Commission on Radiological Protection (ICRP): 

"the emphasis on plutonium is clearly a reflection of the general consensus that, in terms of amount available, projected 

usage, extent of anticipated accidental human exposure, and 

radiotoxicity, plutonium is the most formidable radionuclide 

in the periodic table." [ICRP Publication 19, liThe Metabolism 

of Compounds of Plutonium and Other Actnides," Pergamon Press, 

1972, p.l.] 
- 2 -

This is followed in Section III by a review of the 

specific radiation protection regulations that are in force 

in the United States today and which are at issue. This 

section focuses on the existing guidelines for Pu-239, but it 

is to be understood that, in this and subsequent sections, 

it should be applied to all alpha-emitting radionuclides that 

meet the hot particle criteria developed in this report. 

Before reading Section III, those unfamiliar with the 

national and international organizations which have primary 

responsibility for recommending or establishing radiation 

protection standards, may find it useful to read Appendix 

A, where these organizations and their authority are reviewed. 

Section IV presents assumptions inherent in the existing 

radiation protection standards and identifies those assumptions that are inappropriate when applied to insoluble 

alpha-emitting particulates. The biological data which 

demonstrate that these assumptions are inappropriate when applied 

to hot particles are discussed in Section V. 

Utilizinq the data presented in Section V, the 

criteria that define a hot particle are developed in Section 

VI. Recommendations for exposure standards for hot particles 

are then developed in Section VII and summarized in 

Section VIII. 
- 3 -

II. Plutonium Use and Public Health 

Plutonium occurs in nature, although in such small 

amounts that it does not constitute a practical source of the 

2 element. Plutonium is bred in nuclear reactors by the 

capture of neutrons in uranium-238. To date, the nuclear 

weapons program has been the principal source of plutonium. 

However, it is anticipated that the commercial nuclear power 

industry will become the principal source of this material 

within the next two decades. In today's commercial reactors 

plutonium is produced as a by-product in the production of 

electricity. 

As a result of the growth of the nuclear power industry, 

the AEC estimates that the total cumulative production of 

plutonium in the commercial sector of the United States will 

3 be some 4.5 million kilograms by the year 2000 • Since 

plutonium, like uranium, can serve as a reactor fuel, both 

are recovered from spent reactor fuel in anticipation that 

they will be recycled. The reactor together with the variety 

~ The ratio of the concentrations of plutonium-239 to 

uranium in ores varies from 4xlO-13 to 1.5xlO-ll• Katz, J.J., 

Chapter VI, The Chemistry of Actinide Elements, Methuen and 

Co., Ltd., London, 1957, pp. 239-330. 

~/ Environmental Statement, Liquid Metal Fast Breeder Reactor 

Demonstration Plant, USAEC, WASH-1509, April 1972, p. 149. 
- 4 -

of support activities required both to provide raw fuel and 

to recover and recycle the uranium and plutonium make up 

what is known as the nuclear fuel cycle. The AEC has 

projected that over 4 million megawatts of nuclear capacity 

4 will be installed between 1970 and 2020. Over the lifetimes 

of these plants this installed capacity could result in a 

cumulative flow of approximately 200 million kilograms of 

plutonium through the nuclear fuel cycle. 

In today's commercial reactors the plutonium is in 

5 oxide form, Pu02' At various facilities in the nuclear fuel 

cycle, aerosols of Pu0 2 are released to the environment on 

a routine basis. In addition, there are numerous points in 

the fuel cycle where accidents, particularly those associated 

with fire or explosions, can release significant amounts of 

Pu02 as aerosols that can be inhaled by man. 

These small aerosol particles of Pu02 are highly radioactive. An appreciable fraction of the inhaled Pu02 

particles are trapped in the deep respiratory tissue of the 

lung, where, because they are insoluble in human tissue, 

!/ Updated (1970) Cost-Benefit Analysis of the U. S. Breeder 

Reactor Program, USAEC, WASH-1184, January 1972, p. 34. Four 

million megawatts (Mw) corresponds to 4000 nominal-size 

nuclear reactors -- 1000 Mw each. 

~ Some advanced reactors of the future may use fuel in 

carbide and nitride, rather than oxide, form. 
- 5 -

they can remain for long periods of time and deliver a very 

intense radiation dose to the surrounding lung tissue. 

Plutonium is one of the most potent cancer producing 

agents known to man. A machinist of plutonium metal carried 

0.08 micrograms of plutonium-239 imbedded at the site of 

the puncture wound in the palm of his hand. Within the four 

year period before it was excized, it produced a nodule which 

6 displayed precancerous changes. There is little doubt from 

experimental animal studies that inhaled plutonium is one of 

the most potent respiratory carcinogens known. There is 

experimental and observed evidence that plutonium concentrations in the lungs of dogs as low as 0.2 microcuries (3 micro~ 

grams of plutonium-239) produce cancer 

7 

• Hence, the flow of 

200 million kilograms of plutonium represents a flow of over 

10 17 cancer doses, a staggering number which, as will be 

demonstrated subsequently, may be an underestimate of the 

cancer doses by several orders of magnitude. 

The persistance of this toxic material, once lost to 

the environment, is measured in terms of thousands of years. 

Roughly two-thirds of the plutonium flowing in the nuclear 

~ Lushbauch, c.c. and J. Langham, "A Dermal Lesion from 

Implanted Plutonium," Archives of Dermatology, ~, October 

1962, pp. 121-124. 

ZI There are 0.061 curies per gram of plutonium-239. 

Two-tenths of a microcurie of plutonium-238 would have a 

mass of only 0.01 micrograms since plutonium-238 has a 

much higher specific activity, 17.47 curies per gram. 
- 6 -

fuel cycle will be plutonium-239 which has a 24,400 year halflife. In other words, in 240,000 years the inventory of this 

hazardous material would be reduced by only a factor of 1000 

due to natural radioactive decay. This material must be 

isolated from the environment in perpetuity. 

III. Existing Standards for Plutonium Exposure 

Radiation exposure standards have been established 

because radiation is known to produce cancer and genetic 

mutations in individuals irradiated. The mutations can 

in turn cause genetic defects in subsequent generations. 

The intent of the exposure standards is to limit this biological 

damage. The magnitude of the biological effect has been 

shown to be related to the radiation dose. The higher the 

dose the greater the effect. Therefore, the primary radiation exposure standard is one that limits the radiation 

dose. This primary standard is generally referred to as the 

maximum permissible dose and is given in units of rem/yr. 

We shall discuss the nature of this unit subsequently. 

An individual can be exposed to radiation from sources 

that are external to his body as, for example, an X-ray 

machine or from radionuclides which emit X-ray like radiation 

deposited on the ground (this occurred with fallout from 

nuclear weapon tests). Alternately, an individual can be 
- 7 -

irradiated by internal sourceSj that is, by radionuclides 

incorporated in body tissues. These radionuclides gain 

entrance into the body through inhalation or through contaminated food or water. Once inside they behave like their 

non-radioactive counterparts. Radioactive iodine, for example, 

accumulates in the thyroid gland in the same fashion as 

stable iodine, and radioactive strontium or calcium accumulate 

in the bone similar to their naturally occurring non-radioactive counterparts. The radioactive iodine will thus deliver 

a dosage to the thyroid qland that is many times larger than 

that to the other organs or to the whole body, and the 

radioactive strontium and calcium will mainly irradiate the 

bone. 

Because of the uneven distribution of radionuclides 

in the body organs, radiation exposure standards have been 

developed not just for the whole body, but also for individual 

organs. In this report we will be referring to the maximum 

permissible whole body and lunq doses. 

Largely as a matter of convenience, secondary or derived 

radiation standards have been developed. These secondary 

standards, which limit radionuclide concentrations or organ 

burdens, are often more easily employed than the primary dose 

standards. We shall examine two secondary standards in this 
- 8 -

report; the maxim~~ permissible lung burden (MPLB) and the 

maximum permissible concentration in air (MPCa ). The MPLB 

is the total amount of a given radionuclide in the lung of 

an average size man that will result in the lung being 

irradiated at the maximum permissible lung dose (MPLD). 

The MPCa is the concentration in air that will result in 

an average adult male obtaining a MPLB and hence a MPLD by 

breathing the air. 

It is important to recognize that the MPLD is the 

primary standard; it applies to all radionuclides and 

radiation sources. The MPLB and the MPCa are derived standards 

and are specific for a radionuclide. These derived standards 

are related to the biological properties of a radionuclide 

and to the form of radiation it emits. 

Table I lists the existing exposure standards for employees of the nuclear industry that apply to Pu-239 in insoluble 

form. The MPLD of 15 rem/yr is included in the recommendations 

of the International Commission on Radiological Protection 

(ICRP)~ the National Council on Radiation Protection and 

Measurements (NCRP) 9 , and the Federal Radiation Council 

~/ ICRP Publication 9, Recommendations of the International 

Commission on Radiological Protection (Adopted September 17, 1966), 

Pergamon Press, New York, 1966, p. 14. 

9/ NCRP Report No. 39, Basic Radiation Protection Criteria, 

NCRP Publications, Washington, D. C., Jan. 15, 1971, p. 106. 
- 9 -

(FRC) 10. The MPC is included in the ICRP recommendationsll 

a 

and is also an AEC radiation standard12 • Of the standards 

in Table I only the MPCa is desiqnated in the AEC regulations. 

However, this MPCa corresponds to that tabulated in ICRP 

Publication 213 which is derived on the basis of the MPLD 

listed in Table I. The MPLB is also derived on the basis of 

the MPLD14 • The MPLB is not included in either the recommendations of ICRP, NCRP, the guidelines of FRC, or the AEC 

regulations. In summary, in Table I the MPCa (designated 

in AEC regulations) is consistant with the MPLD and MPLB. In 

Table I the MPLD applies to all forms of ionizing radiation. 

The MPLB and MPCa apply specifically to Pu-239 in insoluble 

form15 • 

10/ FRC Report No.1, 2£. cit., p. 38. The FRC has been 

abolished and its duties transferred to EPA. 

11/ ICRP Publication 2, Report of Committee II on Permissible 

Dose for Internal Radiation, Pergamon Press, New York, 1960. 

[Appeared in Health Physics, Vol. 3, Pergamon Press, June 1960.] 

12/ 10 CFR 20, Appendix B. 

13 ICRP Publication 2,2£. cit. 

14/ Mann, J.R. and A.R. Kirchner, IIEvaluation of Lung Burden 

Following Acute Inhalation of Highly Insoluble PU02," Health 

Physics, Vol. 13, 1967, pp. 877-882. 

15 The MPLB could apply to most other alpha-emitting 

radionuclides with long half-lives, since the alpha particle 

energies do not differ appreciably from the Pu-239 alpha 

energy. 
- 10 -

TABLE I 

Existing Occupational Exposure Guidelines 

that APply to Pu-239 in Insoluble Form* 

MPLD (ICRP, NCRP, FRC) 15 rem/yr 

MPLB 0.016 uCi 

MPCa (ICRP, AEC) 4xlO-ll uCi/ml 

*Note: See Glossary for definitions of symbols. 

The exposure guidelines for Pu-239 that apply to nonoccupational exposure of the general public are tabulated in 

Table II. Two guidelines are applied here. One is for the 

limiting exposure to an individual and the other is for the 

average exposure of a population sample. These two guidelines 

differ by a factor of 3. The ICRP recommendations include only 

the guidelines for individuals. The MPLD values within the 

parentheses in Table II correspond to the latest recommendation 

16 of the NCRP • These latest recommendations of the NCRP 

have not, at this time, been incorporated into either the 

AEC or EPA regulations. 

16 NCRP Report No. 39, QE. cit., p. 95. 
- 11 -

TABLE II 

Existing Exposure Guidelines for Non-Occupational Exposure 

that Apply to Pu-239 in Insoluble Form* 

Individual Population Average 

MPLD 1.5 (0.5) rem/yr 0.5 (0.17) rem/yr 

(ICRP , NCRP , FRC) 

MPLB 0.0016 (0.0005) uCi 0.0005 (0.00017) uCi 

MPC 10-12 (3x10-13 ) uCi/m1 3x10-13 (10-13 ) uCi/m1 a 

(ICRP, AEC) 

* The MPLD values in parentheses refer to the latest 

recommendations of the NCRP. The MPLB and MPCa values in 

parentheses correspond to the new NCRP dose recommendations. 

IV. Ca1cu1atinq the Dose Due to Insoluble Alpha-Emitters 

The purpose of this section is to examine the assumptions 

in the radiation standards above that are inappropriate when 

applied to insoluble alpha-emitting particulates such as 

aerosols of Pu02. The assumptions are introduced through a 

review of basic definitions of radiation dose and the factors 

used to calculate the dose. 

A. The Dose Equivalent 

When an X-ray or the radiation emitted by a radionuc1ide 

passes through tissue it transfers energy to the cells in 
- 12 -

these tissues. This energy produces chemical changes in 

the molecule of the cells; for example, such a chemical 

change could be a mutation in a gene. The radiation dose 

is actually a measure of the energy transferred to or 

absorbed by the tissue. The basic unit of dose is the 

rad (one rad represents the absorption of 100 ergs of 

energy per gram of material) • 

In addition to X-rays, radionuclides emit gamma rays 

(high energy X-rays), beta particles (electrons), and alpha 

particles (helium nuclei). In radiobiological experiments, 

it was determined that, while these various types of radiation 

produced the same biological effects, such as cancer, the 

magnitude of the effect was not the same per rad. For 

example, it was found that 100 rad of alpha radiation would 

produce roughly 10 times as many cancers as 100 rad of 

X-rays. Moreover, it was found that because of the special 

way in which Pu-239 deposits in the bone, its alpha particles 

were 5 times more effective in producing bone cancer than the 

alpha particles from radium17 . To account for these differences 

in the magnitude of the observed effects at the same absorbed 

dose in rad, the maximum permissible dose limits are given 

in rem rather than rad. 

The MPLD is given in rem in Tables I and II. The 

17/ ICRP Publication 11, "A Review of the Radiosensitivity of 

the Tissues in Bone," Pergamon Press, New York, N. Y., 1967, p. 21. 
- 13 -

18 

rem is the unit of Dose Equivalent (DE) The DE is obtained 

by multiplying the absorbed dose in rad by modifying factors 

to correct for these observed differences in the magnitude 

of the effect. As a consequence, the magnitude of the 

effect will be the same for a given DE regardless of the 

nature of the radiation or the manner of radiation. 

B. Modifying Factors 

At the present time, two modifying factors are employed. 

One is the Quality Factor (QF) which accounts for differences 

in producing bioloqical effects among various forms of 

radiation. The other is the Distribution Factor (DF) 

which accounts for the modification of the biological effects 

when a radionuclide is nonuniformly distributed in an organ. 

For example, the DE for X-ray to bone tissue is determined 

by using QF=l and DF=l,while that for Pu-239 in the bone is 

determined by using a QF=lO (to account for the greater 

effectiveness of alpha particle irradiation) and a DF=5 

19 (to account for the peculiar distribution of Pu in the bone) • 

A DE=50 rem from X-rays or Pu-239 would thus induce the same 

number of cancers in bone but the absorbed dose from the X-rays 

would be 50 rad while that from Pu-239 would be only 1 rad. 

18 NCRP Report No. 39, ~. cit., p. 81. 

19/ ICRP Publication 11, Op. cit., p. 21. 
- 14 -

In obtaining the derived values in Tables I and II, 

MPLB and MPCa for Pu-239, a QF=lO was employed. This QF 

implies, as mentioned above, that the particles of Pu-239, 

which emit alpha particle radiation, are 10 times more effective 

in inducing cancer than X-rays. Although the irradiation of 

tissue by insoluble plutonium particles is highly nonuniform, 

no DF value has been assigned to these particles and hence, a 

DF=l was employed in determining the derived values in Tables 

and II. Ideally, the DF should be determined by the ratio 

of the observed effects in an organ following uniform and 

nonuniform radiation of the tissue with the same radionuclide; 

for example: 

DF = Number of cancers (nonuniform irradiation) 

Number of cancers (uniform irradiation) 

Since direct experimental data are not available, it is 

necessary to derive the DF for insoluble Pu-239 particles from 

collateral data. In a subsequent section, we shall present 

the biological evidence that strongly suggests that a DF=l 

grossly underestimates the DE for insoluble particulates of 

Pu-239 and, consequently, that the derived standards, MPLB 

20 and MPCa for this radionuclide, are greatly in error. 

In fact, it will be shown that the biological data strongly 

suggests that for such particles one should use a DF=115,000. 

20/ This applies as well to other alpha-emitting actinides 

in insoluble particulate form. 

I 
- 15 -

Before turning to the biological data it is appropriate to 

discuss first the radiation field around a particle of Pu02 

and thereby define the fundamental ques.tions that need to be 

answered by the collateral data from radiobiological studies. 

The unique form of tissue irradiation displayed by 

insoluble particles of Pu-239 occurs because, when Pu-239 

decays, it emits an alpha particle with an energy of 5.1 MeV. 

This particle has a range (produces biological damage) of only 

some 40-45 u (0.004 cm) in human tissue. In other words, 

a Pu-239 particle in tissue will only irradiate a volume of 

tissue enclosed in a sphere of 45 u radius. As one moves inward from the surface of this sphere, the radiation intensity 

increases geometrically. About half of the alpha particle 

energy is dissipated at 20 u (that is, with a volume that 

is 1/8 the total volume). This means that the average dose 

delivered in the first 20 u is 8 times that delivered in the 

remaining 20 u. The first column of Table III describes 

the radiation field around such a particle in soft tissue: 

e.g., the skin. Since the lung is a spongy tissue with a large 

air volume, the range of alpha particles is longer in the 

lung and consequently the mass of irradiated tissue is larger. 

Professor Donald Geesaman made a detailed analysis of plutonium 
- 16 -

2l particle irradiation of deep respiratory tissue . The 

last two columns in Table III describe the radiation field 

around such a particle in the lung using Geesaman's lung 

22 model • The dose rate to the entire organ is given in 

column 2 of Table III for comparison. From Table III it is 

significant to note that with an assumed DF=l, the lung 

dose from the same particle varies by more than 8 orders of 

magnitude depending on whether one averages the dose over 

the entire lung or calculates it on the basis of the tissue 

exposed. 

TABLE III 

Radiation Dose Rate Due to a Pu-239 Particle 

23 (1 u in diameter, 0.28 pCi ) 

Soft Lung 

Tissue 24 Entire Tissue 25 Closest 26 

Irradiated Organ Irradiated 20 Alveoli 

Mass of 

Tissue 0.4 ug 1000 g27 65 ug 19 ug 

Dose Rate 

(rem/yr) 730,000 0.0003 4000 11,000 

21/ Geesaman, Donald P., An Analysis of the Carcinogenic Risk 

from an Insoluble Alpha-Emitting Aerosol Deposited in Deep 

Respiratory Tissue, UCRL-S0387 and UCRL-S0387 Addendum, 

Lawrence Livermore Laboratory, Livermore, Calif., 1968. 
- 17 -

It would take 53,000 particles of the size illustrated 

in Table III to reach the MPLB of 0.016 uCi which results 

in 15 rem/yr to the entire (1000 g) lung. However, as 

Table III indicates, these particles would irradiate only 

3.4 g of this 1000 g to the lung, but at a dose rate of 

28 4000 rem/yr • Thus, as Table III indicates, these particles 

result in an intense but highly localized irradiation. A 

fundamental question is, then: is this intense but localized 

irradiation more or less carcinogenic than uniform 

irradiation? Alternatively, is the DF for this particular form 

of irradiation equal to, greater than, or less than one? In 

the remainder of this section, we review the guidance, or 

more appropriately lack of quidance, for dealing with this 

hot particle problem. 

22/ Geesaman, Donald P., UCRL-50387, pp. 8, 15. 

23/ Langham, Wright H., The Problem of Large Area Plutonium 

Contamination, U. S. Dept. of H. E. w., Public Health 

Services, Seminar Paper No. 002, Dec. 6, 1968, p. 7. 

24/ Long, A.B., "Plutonium Inhalation: The Burden of 

Neqliqible Consequence,lI Nuclear News, June 1971, p. 71. 

25/ Geesaman, Donald P., UCRL-50387, pp. 8, 15. Based on 

Geesaman's model for a lung at one-half maximum inflation. 

Geesaman estimates a total of 68 alveoli at risk, each 

8xlO-6 cm3 in volume, and deep respiratory zone tissue density 

of 0.12 g/cm3 • 

26/ See footnote 23. 

~ Based on a lung mass of a standard man = 1000 g. 

28/ This assumes that the radiation field of the 53,000 

particles do not overlap. 
- 18 -

C. The Hot Particle Problem 

It is important to recognize that the ICRP has given 

no guidance with respect to nonuniform irradiation of the lung 

by insoluble alpha-emitters such as insoluble plutonium 

particles. In its Publication 9, the ICRP states: 

...In the meantime there is no clear evidence to show 

whether, with a given mean absorbed dose, the biological 

risk associated with a non-homogeneous distribution is 

greater or less than the risk resulting from a more 

diffuse distribution of that dose in the lung. 29 

In effect, the ICRP is saying that there is no guidance as 

to the risk for non-homoqeneous exposure in the lung, hence 

the MPCa and the MPLB are meaningless for insoluble plutonium 

particles. 

The NCRP offers the following and similar statement 

with respect to these particles: 

(210) The NCRP has arbitrarily used 10 percent of 

the volume of the organ as the significant volume for 

irradiation of the gonads. There are some cases in 

which choice of a significant volume or area is 

virtually meaningless. For example, if a single 

particle of radioactive material fixed in either lung 

or lymph node may be carcinogenic, the averaging 

of dose either over the lung or even OVer one cubic 

centimeter may have little to do with this case. 30 

This hot particle problem is also well recognized in 

the blological community. The following is extracted from a 

29/ ICRP Publication 9, ~. cit., p. 4. 

30/ NCRP Report No. 39, Ope cit., pp. 79-80. 
- 19 -

paper by Professor Donald P. Geesaman: 

So there is a hot particle problem with plutonium in the lung, and the hot particle problem is not 

understood, and there is no guidance as to the risk. 

I don't think there is any controversy about that. 

Let me quote to you from Dr. K. Z. Morgan's testimony 

in January of this year before the Joint Committee on 

Atomic Energy, U.S. Congress. [a] Dr. K. Z. Morgan 

is one of the United States' two members to the main 

Committee of the International Commission on Radiological Protection; he has been a member of the committee longer than anyone; and he is director of 

Health Physics Division at Oak Ridge National Laboratory. I quote: "There are many things about radiation 

exposure we do not understand, and there will continue 

to be uncertainties until health physics can provide 

a coherent theory of radiation damage. This is why 

some of the basic research studies of the USAEC are so 

important. D. P. Geesaman and Tamplin have pointed 

out recently the problems of plutonium-239 particles 

and the uncertainty of the risk to a man who carries 

such a particle of high specific activity in his lungs." 

At the same hearing, in response to the committee's 

inquiry about priorities in basic research on the biological effects of radiation, Dr. M. Eisenbud, then 

Director of the New York City Environmental Protection 

Administration, in part replied, "For some reason or 

other the particle problem has not corne upon us in 

quite a little while, but it probably will one of these 

days. We are not much further along on the basic 

question of whether a given amount of energy delivered 

to a progressively smaller and smaller volume of tissue 

is better or worse for the recipient. This is another 

way of asking the question of how you calculate the dose 

when you inhale a single particle." [b] He was 

correct; the problem has corne up aqain. 

faJ Morgan, K. Z., "Radiation Standards for Reactor Siting," 

in Environmental Effects of Producing Electrical Power 

Phase 2. Testimony presented at Hearings before the Joint 

Committee on Atomic Energy, 91st Congress, 1970. 

Washington, D. C., U. S. Government Printing Office. 

[b] Eisenbud, M. Panel Discussion. In: Environmental Effects 

of Producing Electrical Power, Phase 2. Testimony presented 

at Hearings before the Joint Committee on Atomic Energy, 

91st Congress, 1970. Washington, D. C., U. S. Government 

Printing Office. 
- 20 -

In the context of his comment it is interesting to 

refer to the National Academy of Sciences, National 

Research Council report of 1961 on the Effects of 

Inhaled Radioactive Particles. [c] The first 

sentence reads, liThe potential hazard due to airborne radioactive ticu1ates is probably the least 

understood of the hazards associated with atomic 

weapons tests, production of radioe1ements, and the 

expanding use of nuclear energy for power production." 

A decade later that statement is still valid. Fin 1y 

let me quote Drs. Sanders, Thompson, and Bair from a 

paper given by them last October. [d] Dr. Bair and 

his colleagues have done the most relevant plutonium 

oxide inhalation experiments. "Nonuniform irradiation 

of the lung from deposited radioactive particulates is 

clearly more carcinogenic than uniform exposure (on a 

total-lung dose basis), and alpha-irradiation is more 

carcinogenic than beta-irradiation. The doses required 

for a substantial tumor incidence, are very high, however, if measured in proximity to the particle; and, 

again, there are no data to establish the low-incidence 

end of a dose-effect curve. And there is no general 

theory, or data on which to base a theory, which would 

permit extrapolation of the high incidence portion of 

the curve into the low incidence region. 1I I agree and 

I suggest that in such a circumstance it is appropriate 

to view the standards with extreme caution. 31 

[c] u. S. NAS-NRC Subcommittee, Effects of Inhaled Radioactive 

Particles. Report of the Subcommittee on Inhalation 

Haz Committee on Pathologic Effects of Atomic 

Radiation. National Academy of Sciences - National 

Research Council, ~vashington, D. C. 1961. Publication 

848. NAS-NRC/PUB-848, 1961. 

[d) Sanders, C.L., R.C. Thompson, and W.J. Bair, "Lung 

Cancer: Dose Response Studies with Radionuc1ides. 1I 

In: Inhalation Carcinogenesis. Proceedings of a Biology 

Division, Oak Ridge National Laboratory, conference held 

in Gatlinburg, Tennessee, October 8-11, 1969. M.G. 

Hanna, Jr., P. Nettesheim, and J.R. Gilbert, eds., 

U. S. Atomic Energy Commission Symposium Series 18, 1970. 

pp. 285-303. (CONF-691001). 

31 Geesaman, Donald P., "Plutonium and Public Health," 

Lawrence Livermore Laboratory, Calif., GT-121-70, April 19, 1970, 

reproduced in Underground Uses of Nuclear Energy, Part 2, Hearings 

before the Subcommittee on Air and Water Pollution of the 

Committee on Public Works, U. S. Senate, 91st Congress, 2nd Session, 

August 5, 1970, pp. 1530-1532. 
- 21 -

To these comments, referenced by Geesaman, can be added 

the comments of Dr. A. B. Long: 

" there is an urgent need to dispell the sense of 

security and certainty that the present limits for 

the maximum permissible lung burden and the maximum 

permissible air concentration bring. . the public 

should be informed of the uncertainties that exist 

in these limits."32 

v. Biological Data Related to Cancer Risk from Insoluble 

Plutonium Particles 

We have shown that insoluble alpha-emitting particles 

result in intense but localized radiation. They can irradiate 

at very high doses without being organism- or organ fatal. 

We said that the available biological data strongly suggests 

that a DF=l grossly underestimates the DE for insoluble 

particulates of Pu-239, and consequently, the derived standards 

MPLB and MPCa for this radionuclide are greatly in error. 

We now turn to the experin~nts involving cancer induction 

by intense local exposure, since these are especially 

relevant in judging whether or not insoluble alpha-emitting 

particles constitute a unique risk. Geesaman collected 

and analyzed the pertinent experiments, and what follows 

32/ Long, A.B., Ope cit., p. 73. 
- 22 -

~s . essent~a . 11 . f' l' 33 y a rev~ew 0 h~s ana ys~s which has become 

known as the "Geesaman hypothesis." 

A The Geesaman Hypothesis 

Dr. Roy E. Albert and co-workers performed a number of 

experiments on the induction of cancer in rat skin34 - 36 • 

Albert's study of radiation-induced carcinoma in rat skin 

gives some quantitative description of a high-dose carcinogenic situation. A skin area of 24 cm2 was exposed 

to electron radiation with various depths of maximum penetration. The dose response curves are reproduced in Figure 1. 

In all cases the response at sufficiently high doses (1000-

3000 rem) was large, """'1-5 tumors per rat by 80 weeks post 

exposure. It was noted by Albert that when the dose was 

normalized to a skin depth of 0.27 milimeters, the three 

response curves became continuous (See Figure 2). Since this 

~ Geesaman, D.P., UCRL-50387 Addendum, ~. cit. 

34/ Albert, R.E., F.J. Burns, and R.D. Heimbach, "The 

effect of penetration depth of electron radiation on skin 

tumor formation in the rat," Radiation Res . .!Q., 1967, pp. 515-524. 

35/ Albert, R.E., F.J. Burns, and R.D. Heimbach, "Skin damage 

and tu~or formation from grid and sieve patterns of electron 

and beta radiation in the rat," Radiation Res . .!Q., 1967, pp. 525-540. 

36/ Albert, R.E., F.J. Burns, and R.D. Heimbach, "The 

association between chronic radiation damage of the hair 

follicles and tumor formation in the rat," Radiation Res. 30, 

1967, pp. 590-599. 
- 23 -

depth is near the base of the hair follicle which comprises 

the deepest reservoir of epithelial cells of the germinal 

layer, it was suggestive that this might be a critical 

region in the observed carcinogenesis. The suggestion gained 

significance from the observations that most of the tumors 

are similar to hair follicles, and that in the non-ulcerogenic 

dose range the number of tumors per rat was in nearly constant 

ratio (1/2000-1/4000) with the number of atrophied hair 

follicles. Thus the carcinogenesis in this experiment 

was remarkably correlated with the dose to and specific 

damage of a particular skin structure. When exposures were 

made with stripe and sieve patterns of roughly 1 rom scale, 

geometrical effects were observed: most notably the cancer 

induction in the sieve geometry was suppressed at doses of 

1700 rad but not at doses of 2300 rad. The reduction, however, 

was again consistent with the reduction in damage as characterized 

by atrophied hair follicles. 

To summarize this important experiment, a high incidence 

of cancer was observed after intense local doses of radiation, 

and the carcinogenesis was proportional to the damage or 

disordering of a critical architectural unit of the tissue, 

the hair follicles. 
__ __ 

- 24 -

o 2 3 4 5 6 ]. 8 

Dose at 0.27 mm - krod 

Fig. 2. Tumor Incidence with l'esocct to 

the dose at a depth of 0.2i mm in 

the skin at 80 weeks for three 

penetration depths of electrons. 

Source of Figures: Albert, R. E., et al., Radiation Res. 30, 

QE. cit., pp. SlS-S24, Figures Sand 7; reproduced in 

Geesaman, UeRL-S0387 Addendum, QE. cit., p. 2. 

A 0.36 mm 7 

• 0.75 mm 

_ 1.40 mm 6 

o 1.65 mm (suppl. data) 

.... 5 o... 

lii 4 a.. 

.,. 

(; 3 

E 

:::> 

.... 2 

..-/' OIL~~JI_A_------~I o 2345678 

~I ~~__~~I_~~ Surface dose - krod 

Fig. 1. Tumor incidence with respect to 

surface dose at 80 weeks for three 

penetration depths of electrons. 

8 

7 

6 

4- 5 ~ 

... 

CIl 

a.. 4 .,. 

t.-

o 

E 

:::> 3 t2 

A 0.36 mm 

• 0.75 mm 

- 1.40 mm 

o 1 .65 mm (suppl • data) 

• 

~ ------. 
- 25 -

Others have observed carcinomas and sarcomas in rats 

and mice after intense exposure of the skin to ionizing radia-

' 37-43 t lon. • Cancer induction is generally a frequent event 

in these experiments. Even at elevated doses, such as 

12,000 rad of 1 MeV electrons, Boag and G1ucksmann induced 

' t 37 ..-5 sarcomas/100 cm2 ln ra s • 

A few results for rabbits, sheep, and swine were 

obtained at Hanford38- 41 • Despite the small number of animals 

~ Withers, H.R., "The dose-survival relationship for 

irradiation of epithelial cells of mouse skin," Brit. J. 

Radio1. 40, 1967, pp' 187-194. 

38/ Hulse, E.V., "Tumours of the skin of mice and other 

delayed effects of external beta irradiation of mice using 

90Sr and 32p," Brit. J. Cancer 16, 1962, pp. 72-86. 

~ Boag, J.W. and A. G1ucksmann, "Production of cancers in 

rats by the local application of Beta-rays and of chemical 

carcinogens," Progress in Radiobiology, J.S. Mitchell, 

B.E. Holmes, and C.L. Smith, eds. Proceedings of the Fourth 

International Conference on Radiobiology held in Cambridge, 

14-17 August 1955. Edinburgh, Oliver and Boyd, 1956, pp. 476-479. 

40/ George, L.A. and L.K. Bustad, "Gross effects of beta rays 

on the skin," Hanford Atomic Products Operation, Biology 

Research Annual Report for 1956, HW-47500, 1957, pp. 135-141. 

41/ George, L.A. II, R.L. Pershinq, S. Marks, and L.K. 

Bustad, "Cutaneous fibrosarcoma in a rabbit following beta 

irradiation," Hanford Atomic Products Operation, Biology 

Research Annual Report for 1959, HW-65500, 1960, pp. 68-69. 

42/ Ragan, H.A., W.J. Clarke and L.K. Bustad, "Late effects 

of skin irradiation," Battelle-Northwest Laboratory Annual 

Report for 1965 in the Biological Sciences, BNWL-280, 1956,pp. 13-14. 

43 Karagianes, M.T., E'B' Howard and J.L. Pa1otay, Batte11eNorthwest Laboratory Annual Report for 1967 to the USAEC Division 

of Biology and Medicine, Vol. I, Biological Sciences, BNWL-714, 

1968, pp. 1.10-1.11 
- 26 -

involved, surface doses of 16,000 rad from a p32 plaque 

induced an average of 1 cancer/animal which is indicative 

that larger mammals are similarly susceptible to skin cancer 

after intense radiation insult. Again, these gross observations demonstrate that enhanced tumor incidence does occur 

after very high doses. 

Intense localized radiation of the subcutaneous and 

intraperitoneal tissue of animals by Pu-239 has also been 

shown to cause a high frequency of cancer induction43- 45 • 

Now what are these experiments trying to tell us? 

Certainly a reasonable interpretation of these experimental 

results is: when a critical architectural unit of a tissue 

(e.g., a hair follicle) is irradiated at a sufficiently high 

dosage, the chance of it becoming cancerous is approximately 

10-3 to 10-4 • This has become known as the "Geesaman 

hypothesis. II 

B Related Human Experience 

Since the above experiments relate to cancer induction 

in animals, it is pertinent to ask whether man is more or less 

44/ Sanders, C.L. and T.A. Jackson, "Induction of Mesotheliomas 

and Sarcomas From 'Hot spots' of Pu02 Activity,lI Health Physics, 

Vol. 22, No.6, June 1972, pp. 755-759. 

45/ Lisco, Herman, et al, IICarcinogenic Properties of 

Radioactive Fission Products and of Plutonium,lI Radiology, 

Vol. 49, No.3, Sept. 1947, pp. 361-363. 
- 27 -

sensitive to such intense localized radiation. C. C. 

Lushbaugh reported on a lesion that developed as the result 

46 of residual Pu-239 from a puncture wound • The particle 

contained 0.08 ug (0.005 uCi) of Pu-239. Commenting on 

the histological examination of the lesion, the authors 

state, "The autoradiographs showed precise confinement of 

alpha-tracks to the area of maximum damage and their 

penetration into the basal areas of the epidermis, where 

epithelial changes typical of ionizing radiation exposure were 

present. The cause and effect relationship of these findings, 

therefore, seemed obvious. Although the lesion was minute, 

the changes in it were severe. Their similarity to known 

precancerous epidermal cytologic changes, of course, raised 

the question of the ultimate fate of such a lesion should it 

be allowed to exist without surqical intervention .•. " In 

this case, less than 0.1 uq of Pu-239 produced precancerous 

changes in human tissue. The dose to the surrounding tissue 

was very intense. There is every reason to believe that a 

smaller quantity of Pu-239 would have produced similar changes. 

This precancerous lesion indicates that a single Pu-239 

particle irradiates a significant (critical) volume of tissue 

and is capable of inducing cancer. The Lushbaugh study was 

46/ Lushbaugh, C.C. and J. Langham, Ope cit., pp. 461-464. 
- 28 -

published in 1962. At that time the total number of puncture 

wounds in man was less than 1,000 47 • The treatment of such 

wounds was excision so that the total number of wounds displaying residual contamination by plutonium particles was 

certainly less than 1,000. Therefore, this wound data would 

suggest that insoluble plutonium particles could offer a risk 

of cancer induction in man that is even qreater than 1/1000 

per particle. In other words, when a critical unit of tissue 

is irradiated, man may be more susceptible to cancer than the 

Albert data as analyzed by Geesaman would suggest. 

A second case of plutonium particle induced cancer is 

that of Mr. Edward Gleason. He was not associated with 

the nuclear industry but was a freight handler who unloaded, 

rotated and reloaded a crate that was contaminated by the 

leaking carboy of Pu-239 solution which it contained. He 

subsequently developed an infiltratinq soft tissue sarcoma 

on the left palm which eventually resulted in his death. 

Although this case is not as clear cut as the case of the 

plutonium worker, there is an overwhelming medical probability 

that his cancer was induced by olutonium. Mr. Gleason's 

unfortunate contact with Pu-239 lead to a lawsuit, 

~I Vanderbeck, J.W., "PlutoniU:::I in Puncture Wounds," HW-66l72, 

Hanford Laboratories Operation, July 25, 1960. 
- 29 -

Edward Gleason, et al v. NUMEC. This suit was eventually 

settled out-of-court. A discussion of the evidence in this 

case by one of the authors is presented in the Appendix B 

of this report. 

These two cases, drawn from the relatively small number 

of individuals so contaminated, strongly suggest that Pu-239 

particles offer a unique carcinogenic risk. They indicate 

that a single particle is capable of delivering an intense 

radiation dose to a critical volume of tissue and that this 

disruptively irradiated tissue, like an atrophied hair follicle, 

has a hiqh probability (maybe as high as 1/1000) of becoming 

cancerous. 

C . Related Lung Experiments 

The skin experiments with animals are remarkable in that 

a highly disruptive dose of radiation to a small portion of 

repairable mammalian tissue produced frequent carcinogenesis. 

The chance of producing one cancer per animal is essentially 

unity. It is reasonable to expect that a comparable 

development could occur in lung tissue. While a number of 

radioactive substances have been used to induce lung cancers 

48 in mice and rats , it is difficult to derive any characterization of carcinogenesis from these experiments. 

48/ Cember, H., "Radiogenic lung cancer," Progress in 

Experimental Tumor Research, F. Homburger, ed. New York, 

Hafner Publishing Company, Inc., Vol. 4, 1964, pp. 251-303. 
- 30 -

The work of Laskin, et aI, though not specifically 

involving deep respiratory tissue, does demonstrate a source 

1n . t . t enS1 y-response curve fl' or unq t1ssue 49 . A Ru-l06 

cylindrical source was implanted in the bronchi of rats, and 

cancers were observed to arise from the bronchial epithelium. 

The response curve indicates a substantial response (7 percent) 

even at 0.008 uCi burden, and a slow, approximately logarithmic 

increase of tumor incidence over three orders of magnitude 

in the source intensity. Corresponding first-year doses to 

adjacent bronchial epithelium varied from 10 3 rad to 10 6 rad50• 

Animals were followed until death and it was observed that 

the tumor incidence generally increased with the dose accumulated 

at death. The lowest accumulated dose associated with a 

cancer was 1400 rad. For an accumulated dose of the order of 

10 6 rad the incidence was approximately two-thirds. Cember 

fortified glass beads (0.3 u diameter) with several microcuries 

of Sr-90, and single beads were implanted in the lungs of 

rats. Tumors were observed in 7 of 23 animals. In a second 

experiment Cember exposed rat lungs to Ce-144 particles. For 

49/ Laskin, S., M. Kuschner, N. Nelson, B. Altshuler, J.H. 

Harley and M. Daniels, "Carcinoma of the lung in rats exposed 

to the beta-radiation of intra-bronchial rutheniuml06 pellets. 

1. Dose response relationships," J. Natl. Cancer Inst. 31, 

1963, pp. 219-231. 

50/ Altshuler, B., "Dosimetry from a Ru l06 -coated platinum 

pellet I" Radiation Res. ~I 1958, pp. 626-632.
- 31 -

a burden range of 0.5 uCi to 50 uCi the observed tumor incidence 

51 fluctuated between 0.04 and 0.3 • 

All of these lung experiments involved intense exposures 

and a significant level of carcinogenesis. Severe damage 

and disruption of tissue were associated with the exposures. 

The most relevant lung experiment is Bair's Pu23902 

inhalation study wiL~ beagles52 - 54 • Exposure was to 

particulates of 0.25 u or 0.5 u median diameter; burdens were 

in the uCi range. Twenty of the 21 dogs that survived more 

than 1600 days post exposure had lung cancer. Many of these 

cancers were multicentric in origin. The cancers again 

appeared in conjunction with severe lung injury. Since the 

natural incidence of the disease is small, it appears that 

at this level of exposure the induction of lung cancer is a 

certainty during the normal beagle life span. At the same 

51/ Cernber, H., QE. cit. 

52/ Bair, W.J., J.F. Park, and W.J. Clarke, IILong-term 

study of inhaled plutonium in dogs," Battelle Memorial Institute 

(Richland), AFWL-TR-65-214, 1966 (AD-631 690). 

53/ Park, J.F., W.J. Clarke and W.J. Bair, IIChronic effects 

of inhaled 239pu02 in beagles," Battelle-Northwest Laboratory 

Annual Report for 1967 to the USAEC Division of Biology and 

Medicine, Vol. I, Biological Sciences, BNWL-714, 1968, 

pp. 3.3-3.4. 

54/ Park, J.F., et aI, If Progress in Beagle Dog Studies with 

Transuranium Elements at Battelle-Northwest," Health Physics, 

Vol. 22, No.6, June 1972, pp. 803-810. 
- 32 -

time, since the pathological response is saturated in this 

experiment, it is inappropriate to draw any inference about 

the magnitude of the response at smaller burdens. The smallest 

burden (at death) in a dog showing lung cancer was 0.2 uCi. 

Presumably this would correspond to a particle burden of 

about 10 7 particles. Burdens which are smaller by orders of 

magnitude may still induce a substantial incidence of cancer. 

Indeed, the cancer risk may, as for skin and soft tissues, 

correspond to a risk per particle in the neighborhood of 

1/1000 to 1/10,000. 

VI. Critical Particle'Activity 

Not all particles would be expected to result in these 

high cancer probabilities. As the particle size or specific 

activity per particle is reduced so is the dosage to the 

surrounding tissue. Indeed, at sufficiently small particle 

size or specific activity, one would expect the radiation 

insult to behave similar to uniform irradiation. The study 

of Albert on induction of cancer in rat skin indicates a 

precipitous change in the dose response curve as the dosage 

55 exceeds 1,000 rem . (See Figure 2). This suggests that a 

particular level of tissue damage must occur before this 

unique carcinogenic response occurs. The experiments of 

55/ Albert, R.E., et aI, Radiation Res. ~, ~. cit., pp. 515-524, 

Figure 7; reproduced in Geesaman, UCRL-50387 Addendum, ~. cit., 

p. 2. 
- 33 -

Laskin, et al, indicate a significant carcinogenic response 

in the lung at 1400 rem, suggesting a comparable sensitivity 

of lunq tl.'ssue56. Geesaman l.n'd'l.cat es tha t the t'l.ssue repal.r, 

57 time in the lung is of the order of one year • It therefore 

seems appropriate, but not necessarily conservative, to accept 

as guidance that this enhanced cancer risk occurs when particles 

irradiate the surroundinq lung tissue at a dose rate of 1000 

rem/yr or more. 

TABLE IV 

Particle Activity and Size to Give a Dose of 

58 1000 rem/year to the Surrounding Lung Tissue 

Particle Particle Diameter (u~59 

Activity 239 p 0 (pCi) u 2 238pu02 

3/4 max inflated (138 alveoli) 0.14 0.8 0.12 

1/2 max inflated 68 alveoli) 0.07 0.6 0.09 

Closest 20 alveoli 0.02 0.4 0.06 

?...§I Laskin, et al, Q.E.. cit. 

57/ Geesaman, Donald P., UCRL-50387, Q.E.. cit., p. 11. 

58/ Ibid 

~/ Based upon specific activity given by Lanqham, W.H., 

Q.E.. cit., p. 7. 
- 34 -

As seen from Table IV, using Geesaman's lung model, a 

particle with an alpha activity between 0.02 pCi and 0.14 pCi 

is required to give a dose of 1000 rem/yr to irradiated lung 

tissue. For purposes of establishing a maximum permissible 

lung particle burden we will use 0.07 pCi from long halflived (greater than one year) isotopes as the limiting 

alpha activity to qualify as a hot particle. Thus, throughout 

the remainder of this report, hot particle will imply a particle 

with at least this limiting alpha activity which is insoluble 

in lung tissue. 

A Exposures at Rocky Flats 

The AEC has a plutonium facility associated with its 

nuclear weapons program at Rocky Flats, Colorado. This 

facility is operated under contract to the AEC by the Dow 

Chemical Company. The employees, the environment and undoubtedly 

the surrounding population have been contaminated with plutonium 

60-62 particles as a result of the operation of this plant. 

It is, therefore, pertinent here to examine the information 

60/ Mann, J.R. and A.R. Kirchnev, 2£. cit. 

61/ Poet, S.E. and E.A. Martell, "Plutonium-239 and 

Americium-24l in the Denver Area,1I Health Physics, Vol. 23, 

1972, pp. 537-549. 

62/ Richmond, Chet, Transcript of Plutonium Information 

Meeting of the Advisory Committee on Reactor Safeguards, 

Los Alamos, N. Mex., 5 January 1974, pp. 319-320. 
- 35 -

available on the exposure of employees of the Rocky Flats 

facility and to relate 'this to the hot particle problem. 

J. R. Mann and R. A. Kirchner discuss the exposures that 

resulted from a plutonium fire at Rocky Flats on 15 October 

63 1965. Some 400 employees were working in the room at the 

time the fire occurred. These employees were subsequently 

placed in a whole body counter to determine their lung burdens 

of Pu-239. However, Mann and Kirchner reported only on those 

25 employees who were exposed above the MPLB of 0.016 uCi. 

Table V presents the information on the exposure of 

these 25 employees. Utilizing the other information presented 

by Mann and Kirchner, we have also estimated in Table V 

the fraction of the lung burden activity (uCi) associated 

with hot particles and the number of hot particles that this 

represents. 

63/ Mann, J.R. and R.A. Kirchner, QE. cit. 
- 36 -

TABLE V 

Rocky Flats Exposure* 

Number of Total Lung Hot Particles Number of 

Cases Burden (uCi) Lung Burden (uCi) Hot Particles 

1 0.272 0.033 137,000 

1 0.160 0.019 79,000 

1 0.111 0.013 54,000 

3 0.064 0.008 33,000 

19 0.024 0.003 12,500 

* Mann and Kirchner presented the lung burdens as number 

of MPLB. These have been converted to uCi in column two 

using MPLB=0.016 uCi. (For the groups with 3 and 19 cases, 

we selected the midpoint of the reported range.) The hot 

particle burden in column three was estimated by mUltiplying 

the total burden by 0.17, the fraction of the activity on 

particles above 0.6 u, and 0.70, the fraction of initial 

deposited activity that was involved in long term retention in 

the lung. Based on particle size data reported by Mann and 

Kirchner, we estimate the average hot particle activity is 

about 0.24 pCi. The numbers of hot particles in the last column 

were obtained by dividing the hot particle burdens in column 

three by the average hot particle activity (0.24 pCi). 

Allowing a risk of cancer equal to 1/2000 per hot 

particle, suggests that the individuals whose exposures are 

presented in Table V stand a very high chance of developing 

lung cancer -- the probability is essentially unity. In 

this respect, it is significant to note that in the experiments 
- 37 -

reported by Park, et al, the beagle dog with the smallest 

64 lung burden, i.e., 0.2 uCi, developed lung cancer. The 

highest burden in Table V is comparable to the lowest 

beagle exposure; the lowest exposure in Table V, the 19 

cases with lung burdens in the 0.024 uCi range are only an 

order of magnitude less than the lowest beagle exposure. 

We would suggest that this is potentially a serious situation. 

As of this time, none of these individuals has developed 

65 lung cancer. However, it is only 9 years since the exposure 

and there is qood reason to suggest that the latent period 

(the time between exposure and the development of cancer) 

is much lonqer than this. In the beagle dog experiments, 

the lowest lunq burden was associated with a latent period 

of 11 years. The latent period may be longer in man and 

particularly at these lower dosaqes and the small number of 

cases involved. Therefore, while these exposed individuals 

will be expected to supply pertinent data relative to this 

hot particle cancer risk over the next 10 to 20 years, 

these exposures give us no information at this time that would 

warrant modifyinq the risk per particle or the critical 

particle activity. 

~/ Park, J.F., et al, Health Physics, 2£. cit. p. 805. 

65/ Richmond, Chet, Op. cit., p. 320. 
- 38 -

B . Manhattan Project Workers 

Another study of human respiratory exposure to plutonium 

relates to 25 young men exposed to plutonium during the 

. 66 Manh attan ProJect. The latest examination of this group 

found them to be free of lung cancer although the report 

states, "The bronchial cells of several subjects showed 

moderate to marked metaplastic changes, but the significance 

of these changes is not clear." Such metaplastic changes are 

a possible indicator for detecting incipient or actual lung 

cancer. In one case the report indicates that the subject 

was a heavy smoker (3 packs/day) and undoubtedly this contributed to the changes. Nevertheless, these findings 

suggest that lung cancer may become manifest in some of 

these subjects in the future. Indeed, one would not be 

surprised to find one lung cancer even in such a group of 

non-exposed subjects. Daring the latest examination of these 

workers, in vivo measurement of the plutonium lung burdens 

were conducted with these results: 

An average MDA for a 2000-sec counting time is \ 

about 7 nCi if one uses the 95% confidence level. 67 

For the 68% confidence level and a similar counting 

time, the comparable value is about 3.5 nCi. 

~/ Hemplemann, L.H., et aI, "Manhattan Project Plutonium 

Workers; A Twenty-Seven Year Follow-Up Study of Selected Cases." 

67/ MDA refers to the minimum detectable amount. 
- 39 -

Positive counts were obtained for 14 of 21 persons 

measured. These counts suggested chest burdens ranging 

from 3 to about 10 nCi. However, in no case did the 

estimated chest burden exceed the MDA at the 95% confidence level. Seven of the 14 subjects with positive 

chest counts had estimated chest burdens of 7 nCi or 

greater and may be considered (at the 68% level of 

confidence) to have statistically significant chest 

burdens of from 7 to 10 nCi. 68 

Since the plutonium is still in the lung cavity, 27 years 

post-exposure, it is correct to assume that it was initially 

in the insoluble form and hence pertinent here. 69 At the time 

of this measurement, however, most of the material would be 

expected to be in the lymph nodes. Nevertheless, we could 

estimate the initial particle burden in these subjects from 

these data if we knew the initial particle size at the time 

of contamination. This particle size data is unavailable. 

The nature of the contaminating events suggest that the 

particle size miqht have been somewhat larger than those that 

result from plutonium fires where most of the respirable 

activity resides on particles in the size range of 0.1 u to 

. d' 70 O. 5 u ln lameter. Much pf the contamination of the 

68/ Hemplemann, L.H., Ope cit., p. 474. 

69/ ICRP Publication 19, The Metabolism of Compounds of 

Plutonium and Other Actnides, Pergamon Press, New York, 1972, p. 7. 

70 Mann, J.R. and A.R. Kirchner, QE. cit., p. 880. 
- 40 -

Manhattan workers resulted from aspiration of droplets of 

liquid solutions of plutonium into the air wherein much larger 

particle sizes would result. At the same time, the activity 

of the plutonium in the particle would be considerably less 

than that for a particle of Pu02' For example, it is stated 

that 14 of the 25 subjects with measurable body burdens of 

plutonium worked in the recovery operation and that this 

occurred when working with solutions containing 1-40 g/liter 

of plutonyl nitrate to which H202 was being added with 

vigorous stirring in an open hood. This resulted in con~ 

siderable fizzing and the discharge of droplets into the 

air outside the hood. A droplet 1 u in diameter (0.5 u 3) 

from the solution with the highest concentration (40 g/liter) 

would therefore contain only 6xlO- 4 pci compared with a 

0.07 pCi particle of Pu02 71 (a specific activity that is 

lower by a factor of 100) .72 In other words, the particles 

involved in this study do not qualify as hot particles. 

They are delivering dosages lower than 1000 rem/yr to the 

71/ Recall from Table IV that a 0.07 pCi, the limiting 

activity for a hot particle, would give a dose of 1000 rem/yr 

to thB surrounding tissue in a lung inflated to 1/2 maximum. 

72/ Of the particles of an inhaled aerosol that are deposited 

in the deep respiratory zone of the lung, virtually all are 

less than 5 u in diameter [Geesaman, UCRL-S0387, 2£. cit., p. 3]. 

A 5 u droplet from the 40 q/liter solution would correspond 

roughly to the limiting activity of a hot particle. 
C 

- 41 -

surrounding tissue (roughly 10 rem/yr). 

Weapons Test Fallout 

Another source of human contamination that is suggested 

as being pertinent to this problem is the plutonium in the 

fallout from nuclear weapon tests. The plutonium from 

weapon tests is incorporated in or deposited on particles 

that contain other materials and, like that for the Manhattan 

workers, the specific activity in these particles is much 

smaller than that in hot particles. 

VII Exposure Standards for Hot Particles 

Thus the existing biological evidence strongly suggests 

that an insoluble particle of Pu-239 deposited in deep 

respiratory tissue represents a risk of cancer induction 

between 1/1000 and 1/10,000. Prudent public health practices 

should assess the risk associated with environmental plutonium and establish exposure guidelines on the basis of 

these probabilities. 

The existing standards for uniform radiation exposure 

of the whole body or lung can be used as the basis for 

establishing particle exposure standards by equating the 

risk of cancer induction between the two types of exposure 

(uniform vs. qrossly non-uniform). The most recent 

assessment of the risk associated with uniform irradiation of 
- 42 -

man was performed by the NAS-MRC Advisory Committee on the 

Biological Effects of Radiation. Their report, published in 

73 1972, is referred to as the BEIR Report. 

A. Occupational Exposure 

The existing occupational exposure standard for uniform 

whole body irradiation is 5 rem/yr and for the lung, 15 rem/yr. 

the BEIR Report estimates that exposure of the whole body 

of an individual to 5 rem/yr would lead to a cancer risk 

-4 -3 74 between 4.5x10 and 2.3x10 /yr. Their best estimate is 

-3 75 

10 /yr. Their estimate of the risk of cancer to the 

-5 76 individual from a lung exposure of the 15 rem/yr is 3x10 /yr. 

Allowing a risk of cancer induction between 1/1000 and 

1/10,000 per particle, Table V presents the maximim permissible 

lung particle burdens (r~LPB) that result in risks comparable 

to these uniform radiation standards for occupational exposure. 

The MPLPB values in Table V represent a very substantial 

reduction in the MPLB. A hot particle of Pu-239 at the lower 

limit activity contains only 0.07 pCi while the MPLB for 

occupational exposure is 1.6x104 pCi. Thus the 

73/ NAS-NRC, liThe Effects on Populations of Exposure to 

Low Levels of Ionizing Radiation," (BEIR Report), NAS-NRC, 

Washington, D. C. , Nov. 1972. 

2!/ Ibid, p. 91. 

75/ Ibid, p. 91. 

76/ Ibid, p. 156. 
- 43 -

TABLE V 

occupational Exposure Guidance for Insoluble Alpha Emitters, 

Maximum Permissible Lung Particle Burden (MPLPB)77 

Cancer risk due to 5 

whole body exposure 

rem/yr 

78 

Assumed 

1/1000 

Risk in Particle 

1/2000 1/10,000 

4.5xlO- 4 0.45 0.9 4.5 

10- 3 (best estimate) 1. 2. 10. 

2.3xlO- 3 2.3 4.6 23. 

largest MPLPB in Table V, 23 particles, represent a 

reduction of the existing MPLB and MPCa by a factor of 

10,000. It is recommended here that the best estimate of 

the effects of uniform exposure by the BEIR Committee be used 

together with a risk of cancer induction of 1/2000 per hot 

particle in determining the MPLPB for insoluble alphaemitting radionuclides in hot particles. This is a somewhat 

arbitrary compromise and is not the most conservative value 

that could be recommended. Thus, the recommended MPLPB 

for occupational exposure from hot particles of alpha77/ The number of particles required to give a cancer risk 

equal to that from uniform radiation. 

78/ Source: BEIR Report, QE. cit., p. 91. The MPLPB 

corresponding to a lung cancer risk of 3xlO-5 due to 15 rem/yr 

lunq dose [BEIR Report, ~. cit., p. 156] are 0.03,0.06 

and 0.3 for assumed particle risks of 1/1000, 1/2000 and 

1/10,000 respectively. 
- 44 -

emitting radionuclides in the deep respiratory zone is 2 

particles. This corresponds to a MPLB of 0.14 pCi and represents a reduction of 115,000 in the existing MPLB. This 

implies that the DF for hot particles is 115,000. Moreover, 

it requires a reduction of the MPCa for Pu-239 by 115,000 to 

a value of 3.5xlO-16 uCi/ml unless it is determined that 

the plutonium is not in hot particles. 

B. Exposure of the General Public 

As indicated in Table II, the MPLB for non-occupational 

exposure (members of the public) is tenfold less than that 

for occupational 8x~0sure. Such an exposure limit for a hot 

particle would be 0.2 particles. Exposure at this level 

implies that on the average one out of five individuals 

would be contaminated by a particle and the other four would 

not. Obviously the exposed invididuals would be assuming a 

disproportionate fraction of the risk. In fact, since an 

individual is exposed to whole particles, any non-occupational 

exposure to hot particles would be an overexposure. This 

condition does not meet the recommendations and admonitions 

of the FRC, ICRP and NCRP. 

Onder certain conditions, s~ch as widespread radioactive 

contamination of the environment, the only data available may be related to average contamination or exposure 

levels. Under these circumstances, it is necessary to 

make assumptions concerning the relationship between 
- 45 -

average and maximum doses. The Federal Radiation 

Council suggests the use of the arbitrary assumption 

that the majority of individuals do not vary from the 

average by a factor greater than three. Thus, we 

recommend the use of 0.17 rem for yearly whole-body 

exposure of average population groups. (It is noted 

that this guide is also in essential agreement with 

current recommendations of the NCRP and the ICRP.) 

It is critical that this guide be applied with reason 

and judgment. Especially, it is noted that the use 

of the average figure, as a substitute for evidence 

concerning the dose to individuals, is permissible 

only when there is a probability of appreciable homogeneity concerning the distribution of ~~e dose within 

the population included in the average. 

Strict adherence to these guidelines implies that 

the ambient air standard should be zero particles. 80 

While a variety of suggestions could be proposed, we recommend 

a slight deviation from these guidelines and the acceptance 

of the disproportionate risk implicit in the 0.2 particle 

standard. This is a workable solution since best estimates 

of lung burdens can be fractional quantities. Thus, we 

recommend that the MPLPB for members of the public be 0.2 

hot particles, and the average lung burden for members of the 

public be 0.07 hot particles, a factor of 3 less than the 

maximum. 

~/ FRC Report No.1, 2£. cit., p. 27. 

80/ Had we based the standard on a 1/10,000 risk per 

particle (See Table V), the MPLPB would have been one 

particle and this problem would not exist. 
- 46 -

The MPLPB=0.2 particles implies that the existing MPCa 

for non-occupational exposure to Pu-239 should also be reduced 

by a factor of 115,000 to a value of 9xlO- 18 uCi/ml unless it 

is determined that the plutonium is not in hot particles. 

C. Exposure from Accidental Releases 

There are no direct statements by standard-setting organizations regarding an "acceptable" exposure associated with 

release of radioactivity in an accident. 8l For purposes of 

evaluating sites for nuclear reactors, establishing site 

boundaries, and preparing safety analysis reports, however, 

the AEC has adopted specific criteria. The reactor site 

boundary (surrounding the exclusion area) must meet the following 

criteria (10 CFR 100.11(a) (1»: 

(1) An exclusion area of such size that an 

individual located at any point on its boundary 

for two hours immediately following onset of the 

postulated fission product release would not 

receive a total radiation dose to the whole body 

in excess of 25 rem2 or a total radiation dose 

in excess of 300 rem2 to the thyroid from iodine 

exposure. 

81/ Fish, B.R., G.W. Keilhalte, W.S. Snyder, and S.D. Swisher, 

Chapter 7 of early draft version of B.R. Fish, et aI, IICalculation of Doses Due to Accidental Released Plutonium from an 

LMFBR," ORNL-NSIC-74 (Nov. 1972), p. 128. This chapter was 

deleted from the final version at the direction of AEC-Division 

of Reactor Development and Technology because it was judged to 

be not directly applicable to the objective of the study, and 

the information base from which it was developed was already 

available in other documents. AEC-DRDT further stated that it 

was not removed because of the quality of the work. 
- 47 -

2

The whole body dose of 25 rem referred to 

above corresponds numerically to the once in a 

lifetime accidental or emergency dose for radiation workers which, according to NCRP recommendations may be disregarded in the determination of 

their radiation exposure status (see NBS Handbook 

69 dated June 5, 1959). However, neither its use 

nor that of the 300 rem value for thyroid exposure 

as set forth in these site criteria guides are 

intended to imply that these numbers constitute 

acceptable limits for emergency doses to the public 

under accident conditions. Rather, this 25 rem 

whole body value and the 300 rem thyroid value 

have been set forth in these guides as reference 

values, which can be used in the evaluation of 

reactor sites with respect to potential reactor 

accidents of exceedingly low probability of 

occurrence, and low risk of public exposure to 

radiation. 

Fish, et aI, made the following comments regarding the 

applicability of these criteria to the case of plutonium 

release. These comments are also applicable to hot particle 

case. 

First, the wording of sections 100.11(a) (1) 

clearly limits the application to the irradiation of 

the whole body and the thyroid; no other organ or tissue 

is mentioned or implied. Furthermore, only fission 

products in general and iodine in particular are 

identified as reference substances. Finally, footnote (2) 

states unequivocally that the guides are not to be 

considered as acceptable limits for emergency doses 

to the public under accident conditions. 82 

without addressing whether the guideline values, 

25 rem to the whole body and 300 rem to the thyroid, should 

82/ Ibid, p. 129. 
- 48 -

be considered as acceptable limits, or whether design basis 

accidents that are currently evaluated under these criteria 

are "of exceedingly low probability of occurrence," we 

recommend that 10 CFR 100.11(a) (1) be modified as follows in 

order to establish a hot particle standard that is equivalent 

to the risk associated with 25 rem whole body irradiation: 

(1) An exclusion area of such size that an 

individual located at any point on its boundary 

for two hours immediately following onset of the 

postulated fission product or other radionuclide 

release would not receive a total radiation dose 

to the whole body in excess of 25 rem2 or a total 

radiation dose in excess of 300 rem2 to the 

thyroid from iodine exposure, or receive a lung 

particle burden in excess of 10 hot particles. 3 

2 (Unchanged from original text) 

3A hot particle is a particle that contains 

sufficient activity to deliver at least 1000 rem/yr 

to the surrounding lung tissue. For isotopes 

having half-lives greater than one year, this would 

correspond to particles containing at least 0.07 

pCi of alpha activity. 

We also recommend that similar criteria be established 

limiting hot particle releases for nuclear facilities not 

now covered under 10 CFR 100. 

D. Surface Contamination 

Hot particles deposited on land surfaces can be 

resuspended into the air by any number of means, including 

wind, automobile traffic, human or animal movements, Following 
- 49 -

an accident wherein surfaces are contaminated with hot 

particles, it is necessary to have a standard to apply to 

decontamination measures. 

The number of particles that can be resuspended from 

surfaces has been the subject of a number of experiments. 

These experiments have usually resulted in the determination 

of a resuspension factor (RF). The RF is defined by: 

concentration in air (uCi/m3 ) 

concentration on surface (uCi/m2) 

R. L. Kathren has reviewed the data obtained on RF 

values. 83 He indicates that, "reported [RF] values for plutohium 

and its compounds range over 11 orders of magnitude." This 

11 orders corresponds to values between 10-1 to 10-11 m- l • 

Kathren indicates that, "an RF of 10- 4 m- l , although 

conservative is appropriate. H84 Langham indicates that a 

member of the Danish scientific team used an RF=10-3 m- l 

during the Thule deliberation. 85 Vie would recommend that 

83/ Kathren, R.L., "Towards interim acceptable surface contamination levels for environmental PU02," BNWL-SA-1510, Battelle 

Northwest Laboratory, Richland, Washington, April 1968, pp. 3-4. 

84 Ibid, p. 4. 

85/ Langham, Wright H., Q£. cit., p. 5. The Thule Deliberations refer to the deliberations following the accidental 

crash of a B-52 bomber carrying nuclear weapons near Thule 

Air Force Base in Greenland. The high explosives in the 

weapons detonated and dispersed the plutonium. 
- 50 -

the value selected by Kathren be used when the RF is unknown 

to determine the ambient ground contamination standard. 

Applying an RF=10-4 m- l to the ambient MPCa standard 

recommended in the previous section, we obtain a maximum permissible surface contamination (MPSC) level for hot particles 

of 9xlO- 8 uCi/m2 • 

86 This is roughly 1 hot particle/m2 • 

In areas where an RF greater or less than 10-4 m- l could 

be shown to apply, the MPSC could be altered appropriately. 

E. As Low as Practicable Hearings 

It is to be understood that the above recommendations 

do not represent endorsement on our part of the risk 

inherent in the existing radiation protection guidelines 

upon which these recommendations are based. Rather, we off~r 

the admonition that the exposures should be kept as far 

below these guidelines as is practicable. Therefore, we 

further recommend that these guidelines be incorporated 

into the existing regUlations without delay and that the 

appropriate agency or agencies convene hearings to determine 

for the regulations what constitutes as low as practicable 

limits for exposure to hot particles. 

~/ This value is derived as follows: The recommended MPCa 

for hot particles is 9xlO-18 uCi/ml which corresponds to 

9xlO-12 uCi/m3 • The maximum ground contamination level, using 

RF=10-4 m- l , is 9xlO- 12 /l0- 4 = 9xlO- 8 uCi/m2. 
- 51 -

VIII Summary of Recommendations 

The following recommendations apply to alpha-emitting 

hot particles where a hot particle is defined as a particle 

that contains sufficient activity to deliver at least 1000 

rem/yr to the surrounding lung tissue. For isotopes having 

half-lives greater than one year, this would correspond to 

particles containing at least 0.07 pCi of alpha activity.87 

It is recommended that: 

1. For occupational exposure 

MPLPB = 2 hot particles 

MPCa for Pu-239 = 3.5xlO-16 uCi/m1 88 

2. For non-occupational exposure 

MPLPB = 0.2 hot particles 

MPCa for Pu-239 = 9xlO-18 uCi/m1 89 

87/ These particulates would consist of compounds of Pu and 

the other actnides which fall into Class Y material in the ICRP 

Task Group Lung Model. These materials would be retained for 

years in the lung. See for example, ICRP Publication 19,2£. cit., 

p. 6. Since only particles in the size range of 5 u and below in 

diameter would be deposited in the deep respiratory tissue, this 

in effect sets an upper limit for the particle size of interest 

here. If the half-life is less than or close to 1 year the limit 

of 0.07 pCi can be adjusted upward through appropriate calculations. 

~/ This MPCa applies for particles containing 0.07 pCi of 

Pu-239. For particles containing more than 0.07 pCi the 

MPCa could be increased proportionately. For particles 

containing less than 0.07 pCi the existing MPCa=4xlO-ll pCi/ml 

would apply. The MPCa for hot particles of other isotopes 

and mixtures of isotopes should be established on a similar 

basis with consideration given to the half-life of the isotope. 

89/ Ibid. 
- 52 -

3. For accidental releases exposure (10 CFR 100.11(a) (1» 

MPLPB (2 hours exposure) = 10 hot particles 

4. For unrestricted areas 

MPSC = 1 hot particle/m2 90 

5. Hearings should be convened to determine as low as 

practicable regulations. 

901 This value is meant for guidance with respect to 

decontamination of an unrestricted area that has been contaminated with hot particles. In areas where an RF greater or 

less than 10-4 m-l could be shown to apply, the MPSC could be 

altered appropriately. 
APPENDIX A 

Radiation Standards Setting Organizations 

and Their Roles 

The organization which recommends basic radiation criteria and standards at the international level is the 

International Commission on Radiological Protection (ICRP). 

It was established in 1928 under the auspices of the Second 

International Congress of Radiology. During the early 

period and until 1950, the ICRP was concerned primarily with 

recommendations designed to provide protection to members 

of the medical profession in their diagnostic and therapeutic use of X-rays and gamma radiation from radium. 

However, since the advent of atomic energy, and radiation 

uses on a large scale, it has extended its efforts to include 

studies of radiation protection matters covering the whole 

gamut of radiation applications. It works together with its 

sister commission, the International Commission on Radiation 

Units Measurements (ICRU), and relies on the ICRU for background knowledge on radiation measurements. 

The National Council on Radiation Protection and 

Measurements (NCRP) was organized in 1929, a year after the 

ICRP, as a combined effort of several radiation protection 

committees in the United States to consolidate their 

scattered efforts and to present a unified voice at meetings 

of the ICRP.l The ICRP and NCRP are private groups whose 

recommendations are purely advisory. 

In 1934 the NCRP adopted the simple level of 0.1 

roentgen per day, measured in air as the tolerance dose. In 

1940, it recommended a permissible body burden of 0.1 microgram for ingested radium. The latter standard, still in 

effect today, corresponds to an average dose to the skeleton 

of about 30 rem/yr or a dose to the critical endosteal tissue 

out to a distance of 5-10 microns of about 10 rem/yr. 

1/ Initially the NCRP was known as the Advisory Committee 

on X-rays and Radium Protection: in 1946 the name was changed 

to the National Committee on Radiation Protection and Measurements, and in 1964 it received a Federal charter and took 

its present name. 
- A2 -

In 1949, the maximum permissible dose for radiation 

was lowered to 0.3 roentgen per week. It was lowered again 

in 1957 to 5 rem/yr as the permissible dose for radiation 

workers. This standard is still in effect. 

The AEC has also played a significant role in setting 

radiation standards. However, the AEC's regulatory authority 

over materials was, and still is, limited by the Atomic Energy 

Act of 1954, as amended, to source, by-product, and special 

nuclear material. Before the Federal Radiation Council 

(FRC) was formed, the AEC, when setting radiation standards, 

generally followed closely the recommendations of the NCRP, 

which in turn paralleled the ICRP recommendations. 

In 1959, after the advent of the atomic age had aroused 

public fears over fallout from nuclear weapons, the U. S. 

government, because of uncertainty of government influence 

over radiation protection standards, organized the FRC. 

It was authorized by Congress to " ..• advise the President 

with respect to radiation matters directly or indirectly 

affecting health, including guidance for all federal agencies 

in the formulation of radiation standards and in establishment' 

and execution of programs in cooperation with the states ••• "2 

The final authority with respect to radiation standards rested 

not with the FRC but with the President. Such a subordinate 

agency as the AEC, for example, had to make its rules, e.g., 

those governing licensed reactors, compatible with the overall 

guides developed by the FRC. 

Tnrouqhout the 1950's the ICRP and NCRP continued to 

revise an~ refine th2 basic recommendations concerning 

permissible radiation exposure standards. Standards were 

recommended for some non-occupational groups and for the whole 

population. Maximum permissible body burdens and maximum 

permissible concentrations of radionuclides in the air and in 

water were recommended as secondary standards. Most of these 

recommendations were incorporated by the FRC and the AEC. 

In 1970 the FRC was abolished and its duties were transferct"j 

to the EPA. Since that time, the setting of population 

exposure standards has resided in EPA. Population standards, 

~/ FRC Report No. I, Background Material for the Development 

of Radiation Protection Standards, Government Printing Office, 

Washington, D. C., May 13, 1960, p. 1. 
- A3 -

in this case, mean exposure to persons "outside the fence" 

of an AEC (or AEC-licensed) facility. Criteria, required 

to meet these standards, for plant operation and design 

remained with the AEC. Hence, present responsibility for 

assessment of health effects resides in EPA, while the 

responsibility for developing technology to control emissions 

resides in AEC. The Office of Management and Budget (OMB) 

in a recent letter to EPA and AEC clarified the delegation 

of responsibility between these agencies for promulgating 

regulations to limit the radioactivity that may be emitted 

from facilities in the nuclear power industry. OMB stated: 

AEC should proceed with its plans for 

issuing uranium fuel cycle standards, taking 

into account the comments received from all 

sources, including EPAi that EPA should discontinue its preparations for issuing, now 

or in the future, any standards for types of 

facilities; and that EPA should continue, 

under its current authority, to have responsibility for setting standards for the total 

amount of radiation in the general environment 

from all facilities combined in the uranium 

fuel cycle, i.e., an ambient standard which 

would have to reflect AEC's findings as to 

the practicability of emission controls. 3 

There are other agencies and groups which are concerned 

with radiation standards and in some cases have regulatory 

authority. These incluue, but are not limited to, the 

Department of Health, Education and Welfare, Department of 

Labor, Bureau of Mines, the American National Standards 

Institute, and state agencies. The radiation standards of 

these organizations are not at issue here. For the most part 

they playa secondary role, or where applicable, follow the 

guidance of the NCRP, EPA and AEC. 

3/ Memorandum for Administrator Train and Chairman Ray 

from Roy L. Ash, Dec. 7, 1973. 

APPENDIX B 

statement Submitted to Attorneys for Mr. Edward Gleason 

Re: Edward Gleason, et al vs. NUMEC 

by: Arthur R. Tamplin 

The following is my analysis of the origin of Mr. Edward 

Gleason's soft tissue sarcoma that ultimately resulted in his 

death and of the Consultation Report, submitted by Dr. Niel 

Wald, dated Jan. 29, 1973. 

Mr. Gleason unloaded, rotated, and loaded a crate containing a aking carbov of plutonium-239 (Pu-239) solution. 

This could not have occured without contaminating the palmar 

surface of his left hand, which was bare. The question is: 

did this Pu-239 contamination cause Mr. Gleason to develop a 

sarcoma? Since radiation induced cancers are identical with 

those that occur spontaneously, it is necessary to consider 

the relative chances that the cancer was spontaneous or Pu-239 

induced. 

The united States Vital Statistics, record a death rate 

for malignant neoplasms (other than melanoma) of the skin in 

the upper extremity of less than one per million per year. Since 

synovial sarcoma is a rare form that often metastasizes and 

hence has a poor proqnosis, its occurrence rate is certainly 

less than the total skin cancer death rate of one per million 

per year. Thus it is highly unlikely that anyone who handled 

this crate would spontaneously develop this sarcoma on the 

contaminated hand (less than one chance in a million) . 

Now t us consider what the chances are of the development of cancer as a result of plutonium contamination of the 

skin. Experimental data from plutonium contaminated animals 

demonstrate that injection of 1 microgram of Pu-239 into the skin 

of rats promptly produced cancer in up to 5% of the animals 

(Exhibit 1). The particular tumors are fibrosarcomas. 

Now the analysis done by LASL indicated that the Pu-239 

concentration was about 160 micrograms per milliliter. This 

is reason to suspect, since the volume of liquid was reduced, 

the Pu was actually more concentrated in 1963. But setting that 

aside, one drop would be expected to cont n between 8 and 

16 micrograms of Pu-239. One-one hundredth of a milliliter 

(a very small amount of liquid) would have been sufficient to 
- B2 -

produce sarcomas in animals. There is little reason to doubt 

that this small amount of liquid (0.01 milliliter) or even more 

found its way below the surface of Mr. Gleason's palm. In this 

event, his chance of developing cancer would be one in twenty. 

This is at least 50,000 times higher than his chances of developing 

the cancer spontaneously. In other words, the evidence is overwhelming in favor of the tumor resulting from Pu-239 contamination. 

The above relative probability is based upon data from 

animals. It is quite possible that man is more sensitive than 

animals to cancer induction by P~-239. In fact, the biological 

evidence strongly suggests that man is more sensitive. Exhibit 2 

is a case report of a nodule removed from a man. This nodule 

contained only 0.08 ug of Pu-239. COMmenting on the histological 

examination of the sion, the authors states,"The autoradiographs ahowed precise confinement of ~-tracks to the area of 

maximum damage and their penetration into the basal areas of 

the epidermis, where epithelial changes typical of ionizing 

radiation exposure were present. The cause,and effect relationship of these findings, therefore, seemed obvious. Although the 

lesion was minute, the changes in it were severe. Their 

similarity to known precancerous epidermal cytologic changes, 

of course, raised the question of the ultimate fate of such a 

lesion should it be allowed to exist without surgical intervention .•. " In this case, less than 0.1 ug of Pu-239 produced 

precancerous changes in human tissue. The dose to the surrounding 

tissue was very intense. There is every reason to believe 

that a smaller quantity of Pu-239 would have produced similar 

changes. 

When I consider the above human and animal data together with 

the relative probability of 50,000, I can corne to no other 

conclusion than that this sarcoma was a direct result of the 

contamination of Mr. Gleason's left oalm by Pu-239. 

Turning now to Dr. Wald's Consultation Report, it can be 

stated that he has presented no evidence to disprove the claim 

that this sarcoma was caused by Pu-239 contamination. I shall 

discuss Dr. Wald's report in the order that it was written. 

According to the Division of Inspection Report submitted 

by Anson M. Bartlett on April 11, 1963, pages 29-30, the 

January 19 examination was conducted not on Mr. Gleason, but on 

his horne, clothing and automobile. The single urine and feces 
- B3 -

samples collected subsequent to January 20 gave negative 

results. The only thing that this demonstrates is that no 

detectable level of Pu-239 was found. Even following the injection of large volumes of Pu-239 solution into the skin and 

muscle of animals, the Pu-239 is slowly absorbed and appreciable 

fractions, up to 70%, remain at the s of injection. Moreover, of the quantity absorbed only a small fraction appears 

in the urine or feces (see page 3, Exhibit 3 and Exhibit 4). 

In Mr. Gleason's case we are concerned with only a very small 

volume of solution and hence we should not be surprised if we 

obtain negative results in an individual urine or feces 

sample. (See also Exhibit 5) 

The physical examination performed by Dr. Roy E. Albert 

on January 23, 1963, has no relevance. One would expect no 

overt signs of radiation injury at this early date from the 

small quantity of Pu-239 which is at issue here. We are concerned 

here with the long term effects, not the acute effects. 

The medical history of Mr. Gleason as recorded by Dr. Wald 

a?pears to be accurate, however, he omitted the conclusions 

of the Pathology Report of the Hospital for Special Surgery 

wherein the unanimous opinion of the pathologists was stated 

to be that this lesion was a synovial sarcoma. 

The negative findings in the feces and urine in April of 

1970 are of no more relevance than the similar findings in the 

January 1963 samples. The whole body counter has a detection 

limit of 0.3 u Ci of Pu-239. At issue here are quantities 

below 0.06 u Ci and, hence, well below the detectable limit. 

There are three reasons for setting aside the negative 

findings in the initial tissue removed from Mr. Gleason. First, 

since the pathologist report indicated "no evidence of atypical 

or malignant changes," it is quite possible that this mass was 

unrelated to the sarcoma. Recall here that the histology of 

the small nodule in Exhibit 2 showed severe changes that resembled 

precancerous changes. Third, the site of contamination was 

not necessarily removed with the mass or it could have trimmed 

from the mass prior to production of the paraffin blocks and 

slides. Consider here that the nodule in Exhib 2 was only 

1/10 of a millimeter in diameter. Since Mr. Gleason eventually 

developed an infiltrating soft tissue sarcoma, and this original 

tissue removed showed no atypical change, there is no basis for 
- B4 -

assuming that the origin of the sarcoma was included in this 

tissue mass. 

The negative results on the clavicle specimen are also 

equivocal. The issue here is a small quantity of Pu-239 

that remained localized in the palmar area of the left hand. 

This bone specimen indicates only that the amount of systemically absorbed Pu-239 was too small to be detected in this bone 

specimen. 

None of these clinical findings are able to set aside the 

strong possibility that Mr. Gleason's sarcoma was a direct 

result of the plutonium contamination. The most likely course 

of events is that a small quantity of the Pu-239 solution 

(less the 0.01 milliliter) was deposited in the tissue below 

Mr. Gleason's palm. This may have occured through a small cut 

or via a sliver. The body then reacted to this material as a 

foreign body, and encapsulated it. Eventually, a lesion 

similar to that discussed in Exhibit 2 developed. This nodule 

progressed beyond the precancerous stage to become an infiltrating soft tissue sarcoma. The chances are some 50,000 

times greater that the sarcoma developed in this fashion than 

that it occured spontaneously. 

I think that it is important to point out that all of the 

information relevant to this case was available in 1963. 

Had Mr. Gleason been informed of the potential cancer risk 

subsequent to the incident, he could have informed his physicians. 

As a result they would probably have treated him more cautiously 

and the tradegy could have been substantially mitigated. 
- BS -

Exhibits 

1 Lisco, Herman, et al, Radiology, Vol. 49, No.3, 

Sept. 1947, pp. 361-363. 

2 Lushbaugh, C.C., et al, Arch. of Dermatology, Vol. 86, 

Oct. 1962, pp. 461-464. 

3 Vanderbeck, J. W., HW-66172, Hanford Laboratories 

Operation, July 25, 1960. 

4 Matsuoka, Mr., et al, Health Physics, Vol. 22, June 1972, 

pp. 713-722. 

5 Lisco, Herman and Walter E. Kesiekeski, American J. 

of Pathology, Vol. 29, No.1, Jan. - Feb. 1953, pp. 305-

321. 

Absorbed Dose: 

AEC: 

Ci: 

Curie: 

D: 

DE: 

DF: 

Dose Distribution 

Factor: 

Dose Equivalent: 

EPA: 

FRC: 

g: 

Half-life: 

GLOSSARY 

The absorbed dose of any ionizing radiation is the energy imparted to matter 

by ionizing radiation per unit mass of 

irradiated material at the place of 

interest. The unit of absorbed dose is 

the rad. One rad is 100 ergs/gram. 

Atomic Energy Commission. 

Abbreviation for curie. 

The quantity of a radioactive nuclide 

disintegrating at the rate of 3.7xlOlO 

atoms per second. 

Abbreviation for Absorbed Dose. 

Abbreviation for Dose Equivalent. 

Abbreviation for Dose Distribution Factor. 

A modifying factor used in calculating 

dose equivalent which accounts for nonuniform distribution of radiation. 

The product of absorbed dose D, quality 

factor (QF) , dose distribution factor (DF) , 

and other necessary modifying factors (The 

dose equivalent is numerically equal to 

the absorbed dose in rads multiplied by 

the appropriate modifying factors). The 

unit of dose equivalent is the 'rem.' 

Environmental Protection Agency. 

Federal Radiation Council. The FRC has 

been abolished, and its functions taken over 

by EPA. 

Abbreviation for gram. 

Time required for a radioactive substance to 

lose 50 percent of its activity by radioactive 

decay. Each radionuclide has a unique halflife. 
ICRP: 

m: 

micron: 

ml: 

MPCa : 

MPCw: 

MPLB: 

MPLD: 

NCRP: 

nCi: 

pCi: 

QF: 

Rad: 

Radionuclide: 

- G2 -

International Commission on Radiological 

Protection. 

Abbreviation for meter. 

One-millionth of a meter. 

Milliliter = 0.001 liters. 

Maximum permissible concentration (of a 

radionuclide) in air. The average concentration above background of a specific 

radionuclide to which an individual can 

be exposed without exceeding the guidelines. 

Maximum permissible concentration (of a 

radionuclide) in water. (See definition 

above. ) 

Maximum permissible lung burden. 

Maximum permissible lung dose. 

National Council on Radiation Protection 

and Measurements. 

Abbreviation for nanocurie, which is onebillionth of a curie, or 10-9 curie. 

Abbreviation for picocurie, which is onemillionth of a microcurie, or 10-12 curies. 

Abbreviation for Quality Factor, which is 

assigned on the basis of a number of considerations. A quality factor is a 

modifying factor used in calculation of 

dose equivalent which accounts for differences 

in producing biological effects among 

various forms of radiation {e.g., alpha, 

and X-radiation}. 

Unit of absorbed dose (D), which is 100 

ergs/gram. The rad is a measure of the 

energy imparted to matter by ionizing 

radiation per unit mass of irradiated 

material at the place of interest. 

A nuclide of an element that is radioactive. 
- G3 -

Rem: 

Roentgen: 

Specific activity: 

u: 

uCi: 

ug: 

Unit of dose equivalent. When the 

appropriate modifying factors are used to 

calculate dose equivalent one rem is the 

quantity of any type of ionizing radiation 

which when absorbed in man produces an 

effect equivalent to the absorbtion of 

one rad of X- or gamma-radiation at the 

place of interest. 

The quantity of X- or gamma-radiation such 

that the associated corpuscular emission 

per 0.001293 grams of air produces, in 

air ions carrying one electrostatic unit 

of electricity of either sign. For the 

purposes here, the roentgen is roughly 

equivalent to the rad. 

Total radioactivity of a given material 

(isotope, element, or compound) per gram 

of the material -- curies/gram. 

Abbreviation for micron, which is onemillionth of a meter. 

Abbreviation for microcurie, which is 

one-millionth of a curie. 

Abbreviation for microgram, which is onemillionth of a gram. 

Natural Resources Defense Council, Inc. 

1710 N STREET, N.W. 

WASHINGTON. D.c. 20036 

BOARD OF TRUSTEES Nffl' York OJfiCt 

Stephen P. Duggan. E'q. 202 783-5710 15 WEST 44th STREET 

Chai"""" 

Dr. Dean E. Abl.hamson 

Mrs. Louis Auchincloss 

14 November 1974 NEW YORK. N.Y. 10036 

212 869-0150 

Bor;s 1. Bittker. Esq. 

John T. Booth. Esq. 

Frederick A. Collins. Jr.. Esq. Palo Alto Office 

Dr. Rene J. Dubos 664 HAMILTON AVENUE 

James B. Funkel. Esq. 

Robert W. Gilmore PALO ALTO. CALIF. 94301 

Dr. Joshua Lcderberg 415 327-1080 

James Marshall, Esq. 

Ruby G. Martin. Esq. 

Anthony Mazzocchi 

Michael McIntosh 

John B. Oakes 

Dr. Gifford B. Pincho! 

Lt. General Warren D. 

Director 

Johnson 

John R. Robinson. Esq. 

Laurance RockefeUer Operations & Administration 

J. Willard Roosevelt 

David Sivc. Esq. 

Dr. George M. Woodwcll 

Headquarters, Defense Nuclear Agency 

Washington, D. C. 20305 

Edwin M. Zimmerman. Esq. 

RE: Environmental Impact statement -- Enewetak 

Dear Lt. General Johnson: 

Enclosed is a copy of "The Hot Particle Issue: 

A Critique of WASH-1320 as it Relates to the Hot Particle Hypothesis," by Dr. Arthur Tamplin and me. 

NRDC requests that this critique by included in 

any subsequent versions of the Environmental Impact Statement on 

Enewetak. 

Sincerely, 

Thomas B. Cochran 
Document "The Hot Particle Issue: A Critique of 

WASH 1320 as it Relates to the Hot Particle 

Hypothesis" not included at this time but will be 

included in final distribution. 
Natural Res9urces Defense Coun~il, Inc. 

1710 N STREET, N.W. 

BOARD OF TRUSTEES 

Stephen P. DlIilsan. Esq. 

CIJ"i,1I>A• 

Dr. Dean E. Abrahamson 

MIS. Loui. Auchinclo$S 

Boris I. Biuker. E'q. 

John T. Booth. fl'!. 

Frtderick A. Cotlins, Jr.. Esq. 

Dr. Rtn. J. DuOOs 

Jamet B. Frankel. Esq. 

Robert \V. Gilmore 

Dr. Jenhu2 Lcderberg 

Jama Marshall, Esq. 

J.ub., G. Mmin. E'q. 

Anthony Ma.uoccru 

Michael McIntosh 

John B. O.kH 

Dr. Gillord B. Pinchot 

John R. Robinson. Esq. 

Laurance Rockcltll~r 

J. Willard Roost.'vdr 

David Sive. Esq. 

Dr. GrorS. M. Woodwel1 

Edwin M. ZimmeftlWl. Esq. 

WASHINGTON, D. C. 20036 

202 783-5710 

The Hot Particle Issue: 

A Critique of WASH 1326* 

as it Relates to the 

Hot Particle Hypothesis 

by 

Arthur R. Tamplin 

Thomas B. Cochran 

November 1974 

Nrw y".,f Offin 

II WEST 44th STREET 

NEW YORK. N.Y. 10036 

212869-0150 

PII/# .Alto Offin 

664 HAMILTON AVENUE 

PALO ALTO. CALIF. 94301 

4ll 327-1080 

WA Radiobiological Assessment of the Spatial Distribution 

of Radiation Dose from Inhaled Plutonium, II WASH 1320, 

U. S. Atomic Energy Commission [September 1974]. 

I. Background 

On February 14, 1974, the Natural Resources Defense Council 

(NRDC) petitioned the Atomic Energy Commission (AEC) and the 

Environmental Protection Agency (EPA) to amend their radiation 

protection standards applicable to "hot particles" of plutonium 

and other actinides where hot particles were defined more fully 

1 in an accompanying report. The report (referred to herein as 

the Tamplin-Cochran Report) concluded that the existing radiation 

protection standards are grossly inadequate to protect workers 

and the public from the high cancer risk posed by exposure to 

the atmospheric release'of plutonium particulates from the 

nuclear power and weapons industries. The report recommended 

(and the 'petition requested) that the current standards be 

made more restrictive by a factor of 115,000. In the petition 

NRDC indicated that matters of importance to the public health 

and safety such as this require prompt action. Allowing a 

reasonable period for public comment NRDC recommended that the 

proposed standards be set within six months (by August 14, 1974). 

On March 15, 1974, the AEC released its Draft of the Liquid 

Metal Fast Breeder Reactor Program Environmental Impact Statement (DRAFT LMFBR EIS). This statement contained a IS-page 

discussion of the hot particle problem. 2 This discussion, based 

1/ Tamplin, A. R. and T. B. Cochran, "Radiation Standards for 

Hot Particles," Natural Resources Defense Council, Washington, 

D. C., 14 February, 1974. 

2/ DRAFT LMFBR EIS, Vol. II, Part 2, Section 4.G.S, pp. 4.G-89 

to 4.G-lOS, March 1974. 
- 2 -

on an earlier report by John W. Healy (referred to herein as 

the Healy Report) of Los Alamos Scientific Laboratory,3 was 

used as justification for ignoring the approach taken in the 

Tamplin-Cochran Report for estimating the lung cancer incidence 

associated with the inhalation of plutonium particulates (hot 

particles) and using instead the assumption of uniform lung 

exposure even where hot particles are concerned. 

On March 28, 1974, the AEC gave notice in the Federal 

Register (39 Fed. Reg. 11450) of NRDC's filing of its petition 

and requested public comments by May 28, 1974. 

On April 16, 1974,. NRDC submitted to the AEC a critique 

of the hot particle discussion in the DRAFT LMFBR EIS.4 Since 

the hot "particle discussion in the DRAFT LMFBR EIS drew heavily 

from the Healy Report (much of it reproduced verbatim), the 

NRDC comments were a critique of the Healy Report itself. 

On August 5, 1974, the AEC announced that it was releasing 

a draft Generic Environmental Statement on Mixed Oxide Fuel 

(DRAFT GESMO), i.e., recycled plutonium in light water reactors. 

NRDC in a letter of February 21, 1974, had requested that the 

AEC give in this generic environmental statement a full and candid 

Y Healy, J. W., "Contamination Limits for Real and Personal 

Property," Los Alamos Scientific Laboratory, Los Alamos, New 

Mexico, LA-5482-PR, January 1974. 

4/ NRDC Comments on WASH 1535, Draft Environmental Impact 

Statement, Liquid Metal Fast Breeder Reactor Program, Re: Volume 

II, Part 2, section 4.G.5, Particle Lung Dose Effects, pp. 4.G-89 

to 4.G-105, 6 May 1974. 
- 3 -

discussion of the recommendations and supporting evidence presented 

in the NRDC petition and accompanying report. 

In the DRAFT GESMO, just as in the DRAFT LMFBR EIS, the 

uniform exposure assumption was used to calculate the lung 

cancer risk from hot particle exposures. The first paragraph 

of the following quote from the DRAFT GESMO gives the justification for. this assumption. The two remaining paragraphs describe 

the AEC's treatment of the NRDC petition and the Tamplin-Cochran 

Report in the DRAFT GESMO. 

Over the past 30 years concern has arisen from time to 

time about the possibility that radioactivity concentrated 

in discrete particles might be more potent when in contact 

with living tissue. than the same activity diffusely 

distributed through the same tissue (hot particle 

hypothesis). Numerous studies to investigate this 

hypothesis provide evidence that present standards 

have been established on a sound basis. 2 The standards 

setting bodies have not set different limits for these 

two types of exposure to radioactivity. Diffuse radiation 

of tissues is used to calculate dose. Hence this approach, 

.that is diffuse irradiation of tissues, has been used 

in the preparation of this statement. 

The AEC has been asked by the Natural Resources Defense 

Council, Inc. {NRDC) to consider the "hot particle" 

hypothesis in this generic environmental statement on 

the use of mixed oxide fuel. Appendix D presents key 

elements of a report by Arthur R. Tamplin and Thomas B. 

Cochran3 submitted by NRDC as well as selections from 

a report by J. W. Healy.2 The Healy study is a broad 

review of investigations on this subject and generally 

supports the prevailing position of the standards setting 

bodies. 

The Natural Resources Defense Council, Inc. has raised 

again the question of the effect of IIhot particles" 

in a petition filed with the Atomic Energy Commission, 

requesting that a reduced limit"be imposed upon the 

concentration of plutonium in air for particles of a 

specified high activity. This matter is being Siven 

careful consideration in a separate proceeding • 

. E.I DRAFT GESMO,p. IV J-7. 
- 4 -

NRDC filed its petition requesting the reduction in the 

plutonium standards with the agencies charged with the responsibility. In its first official statement on this issue subsequent to the NRDC petition, the AEC presented in the DRAFT 

LMFBR EIS an argument based on the Healy Report. NRDC responded 

with a critique (NRDC's comments on the DRAFT LMFBR EIS), setting 

aside the Healy Report by rebutting each of the points raised 

in the DRAFT LMFBR EIS and showing why the references cited do 

not support the hypothesis that hot particles can be analyzed 

in the same manner as uniform organ exposures, either for purposes of estimating carcinogenic risks or for establishing 

radiation standards. Four months after submitting those comments, 

we were presented with the second AEC pronouncement on the hot 

particle issue (DRAFT GESMO). Here, the AEC used as justification 

the original Healy Report and made no reference to NRDC's 

comments. There was absolutely no justification for this 

aberrant behavior by the AEC. 

We are now presented with the third pronouncement on this 

subject py the AEC in the report by Bair, Richmond and Wachholz 

{referred to herein as the BRW Report).6 As we shall show in 

our critique, it is for the most part an elaboration on the Healy 

report. Moreover, this report also fails to acknowledge and 

discuss our comments on the Healy Report submitted some six months 

~ Bair, W. J., C. R. Richmond and B. W. Wachholz, A Radiobiological Assessment of the Spatial Distribution of Radiation 

Dose from Inhaled Plutonium, WASH-1320, USAEC, September 1974. 
- 5 -

ago on April 16, 1974, relative to the DRAFT LMFBR EIS. In 

this respect, it is also significant to note that on May 22-24, 

1974, the AEC sponsored a symposium on the biological effects 

of plutonium at Los Alamos, New Mexico. Attendance was by 

invitation. The authors, Bair, Richmond and Wachholz were 

invited but we were not invited. When we submitted our report 

and petition to the AEC, we had hoped that this would lead to 

a dialogue that would serve to resolve this important issue. 

However, it appears that the AEC refuses to engage in this 

dialogue either face-to-face or in writing. It appears to us 

that the simplest elements of professional responsibility would 

require that they respond to our refutation of their arguments 

rather than continually raising the same arguments in successive 

publicat~ons. To this end, we again respond to their arguments. 

We begin by reviewing the principal elements of the hot particle 

hypothesis. 

lIe The Hot Particle Hypothesis 

The "hot particle hypothesis" is relatively simple. 

With respect to alpha-emitting particles in the lung, it is: 

If a particle deposited in the deep respiratory tissue 

is of such activity as to expose the surrounding 

lung tissue to a dose of at least 1000 rem in 1 year, 

this particle represents a-unique carcinogenic risk. 

The biological data suggest that such a particle may 

have a cancer risk equal to 1/2000. 

This hypothesis implies that if"a particle exposes the 

surrounding lung tissue to a dosage greater than 1000 rem in 1 

year, the cancer risk is still 1/2000. (This of course causes 

a larger particle to be less effective on a per pCi basis, 
- 6 -

but not on a per particle basis.} The hypothesis implies nothing 

about particles that expose the tissue to less than 1000 rem 

in one year. 

The basic support for the hypothesis derives from a number 

of experiments wherein a small volume of tissue was exposed to 

high dosage. In these experiments cancer was the almost inevitable 

result. Although it is not explicitly stated, these experiments 

are relevant to the following NCRP criteria: 

(206) Simplifications in practice hinge largely on 

reporting a single representative protection dose for a 

limiting organ system even when the actual irradiation 

is grossly non-uniform. The representative dose is 

taken as the highest that can be obtained by averaging 

over a prescribed significant volume. The implication 

of this concept, or at least the convention that is 

followed, is that any redistribution of a given dose 

within such a volume does not materially alter the 

radiation response. It is usually assumed that the "significant volume" should be of the order of one cubic 

centimeter. This will be grossly conservative. 

(207) There will be some cases in which selection of 

a significant volume is inappropriate. Most notably 

these will include cases where the radiation agent is 

an alpha particle emitter deposited in thin sheets. As 

an example, the deposition of radon daughter products 

on the bronchioepithe1ia1 lining of the lungs is a 

case in which the effective radiation field is virtually 

two-dimensional only. In such cases, one may plausibly 

consider a significant area of tissue surface, perhaps equally arbitrarily taken as one square centimeter. 

Realistic modeling of such cases suggests a much smaller 

region as the reasonable effective target. 7 

The hypothesis is essentially an extension of these criteria. 

The quantitative parameters in the hypothesis are derived from 

a series of experiments conducted by Dr. Roy C. Albert on rat 

11 NCRP Report No. 39, Basic Radiation Protection Criteria, 

NeRP Publications, Washington, D. C., January 1S, 1971. 
- 7 -

skin. 8- lO In these experiments, Dr. Albert observed that the 

radiation induced cancers were remarkably correlated with the 

disruption of a critical architectural unit of the skin, the 

hair follicle. The cancers were induced in the rough proportion 

of 1 cancer per 2000 atrophied hair follicles when the dosages 

exceeded some 1000 rem. 

The hot particle hypothesis thus suggests that if these 

skin experiments were performed with small particles, each 

capable of disrupting a single hair follicle, the observed cancer 

induction would correspond to one cancer per 2000 particles. 

So far as the lung is concerned, the hypothesis contains 

the corollary that the lung also has such a critical architectural 

unit that can be disrupted by a single particle and that this 

also presents a cancer risk of 1/2000. 

The potential hazard of a single hot particle embedded 

in the tissue of humans is illustrated by the observation of 

11 Lushbaugh and Langham. They excised a nodule that developed 

8/ Albert, R. E., F. J. Burns, and R. D. Heimbach, "The effect 

of penetration depth of electron radiation on skin tumor formation in the rat," Radiation Res. ~, 1967, pp. 515-524. 

9/ Albert, R. E., F. J. Burns, and R. D. Heimbach, "Skin damage 

and tumor formation from grid and sieve patterns of electron 

and beta radiation in the rat," Radiation Res. ~, 1967, pp. 525-

540. 

10/ Albert, R. E., F. J. Burns, and R. D. Heimbach, "The 

association between chronic radiation damage of the hair follicles 

and tumor formation in the rat," Radiation Res. 30, 1967, 

pp. 590-599. 

11/ Lushbaugh, C. C. and J. Langham, "A dermal lesion from 

implanted plutonium," Archives of Dermatology ~, October 1962, 

pp. 121-124. 
- 8 -

around a Pu-239 particle imbedded in the palm of a machinist. 

Commenting on the histological examination of the lesion, the 

authors state: 

The autoradiographs showed precise confinement 

of alpha-tracks to the area of maximum damage 

and their penetration into the basal areas of the 

epidermis, where epithelial changes typical of 

ionizing radiation exposure were present. The 

cause and effect relationship of these findings, 

therefore, seemed obvious. Although the lesion 

was minute, the changes in it were severe. Their 

similarity to known precancerous epidermal cytologic changes, of course, raised the question of 

the ultimate fate of such a lesion should it be 

allowed to exist without surgical intervention•••• 12 

Considering the above observations, it would be surprising 

indeed if a physician would not suggest surgical intervention 

in a case where a patient had a few such imbedded particles. 

We feel that this lesion alone should cause one to be very 

cautious in estimating the hazard of hot particles. 

That such lesions can develop in lung tissue is supported 

by the observations of Richmond, et al., on the lesions induced 

in experiments wherein hot particles were introduced into blood 

vessels of the lungs of rats: 

Such a lesion with collagenous degeneration and 

subsequent liquefaction, due to the large local dose 

of radiation at a high dose rate, has been reported 

by Lushbaugh et al.,(9) whose description of a plutonium 

lesion found In the dermis is very similar to that 

observed for plutonium in the lung. 13 

12/ Ibid., p. 463. 

13/ Richmond, C. R., et al., "Biological response to small 

discrete highly radioactive sources,lI Health Physics 18, 1970, 

p. 406. 
- 9 -

The above represents the distilled essences of the TamplinCochran Report which was an extension of some earlier publica14 tions of Professor Donald Geesaman. It is important to 

restate that the hypothesis suggests that the disruption of 

a critical architectural unit of a tissue is a significant 

carcinogenic event. 

The actual killing of cells and the development of a 

fibrotic ,lesion surrounding the hot particle is the suggested 

mechanism of carcinogenesis. As Geesaman stated: 

Summing up, intense radiation exposure of mammalian 

skin and lung tissue commonly results in cancers. 

Tissue injury and disturbance are a primary consequence of intense radiation insult, and are observed 

in association with carcinogenesis. Albert has 

exhibited a simple proportionality between skin 

carcinomas and atrophied hair follicles. No general 

description of precarcinogenic injury exists, but 

in a crude sense the available observations are 

compatible with the idea of an injury-mediated 

carcinogenesis. Cancer is a frequent instability 

of tissue~ Since tissue is more than an aggregate 

of cells, and has a structural and functional unity 

of its own, it would not be surprising if some 

disrupted local integrity, a disturbed ordering, 

comprises a primary pathway of carcinogenesis. The 

induction of sarcomas with inert discs of Mylar 

cellophane, Teflon and Millipore (Brues, et al. 17 ) 

is indicative that such a mechanism exists. Presumably mitotic sterilization is an important factor 

in any carcinogenesis mediated by radiation-induced 

tissue injury. The functional relation of this factor 

in the carcinogenic response may be quite different 

from a linearity in the surviving mitotic fraction. 

14/ Geesaman, D. P., An Analysis of the Carcinogenic Risk 

from an Insoluble Alpha-Emitting Aerosol Deposited in Deep 

Respiratory Tissue, UCRL-50387 and UCRL-50387 Addendum, 

Lawrence Livermore Laboratory, Livermore, California, 1968. 
- 10 -

While regrettably unquantitative, the hypothesis of 

an injury-mediated carcinogenesis is suggestively 

descriptive. If the respiratory zone of the lung 

contains a structure analogous to the rat hair 

follicle, and if a radioactive particulate deposited 

in the respiratory zone has the capacity to disrupt 

one or more of these structures and create a precancerous lesion, then cancer risks of the Qrder of 

10-3 to 10-4 per particle can be expected. lS ,16 

The lesion excised by Lusbaugh and Langham17 from human 

palmar tissue and the observation by Richmond, et al •. ,18 that 

similar lesions are produced in the lung by hot particles 

strongly argue that a comparable sensitive structure is present 

in the lung and other tissues. Thus, the uncertainties in the 

hot particle hypothesis involve these quantitative parameters: 

a) Is the risk of cancer per disrupted tissue mass 

comparable to that per disrupted hair follicle? 

b) Is a particle capable of irradiating the surrounding 

tissue mass at the rate of 1000 rem/year sufficient 

to produce such a lesion? 

The thrust of the NRDC petition to modify the plutonium 

exposure standards is that, until these uncertainties are 

resolved, the prudent public health principle is to accept the 

hot particle hypothesis rather than the less conservative 

hypothesis that average organ dose from hot particles provides 

15/ Geesaman, D. P., UCRL-50387 Addendum, ~ cit., pp. 6-7. 

16/ Brues, et al. 17 , refers to Brues, A. M., H. Auerbach, 

G. M. De Roche, and D. Brube, "Mechanisms of carcinogenesis," 

Argonne National Laboratory, Biological and Medical Research 

Division Annual Report for 1967, ANL-7409, 1967, pp. 151-155. 

17/ Lushbaugh, C. R. and J. Langham, ~ cit. 

18/ Richmond, C. R., et al., ~ cit. 
- 11 -

. a reasonable basis for protection. The implication is, of course, 

that while the evidence discussed in the Tamplin-Cochran Report 

supports the hot particle hypothesis there is no substantial 

body of scientific evidence that can reject the hypothesis. The 

purpose of this report is to demonstrate that the evidence is 

also not to be found in the BRW Report. 

III. Points of Analytical Confusion 

Before reviewing the BRW Report in detail the following 

general observations are presented in order to draw clear 

distinctions among several analytical approaches or concepts 

that appear to be the source of some confusion to analysts 

addressing the hot particle issue. These approaches are: 

(1) The assignment of a risk per hot particle, independent over 

a range of particle sizes and activities; (2) the comparison 

of the risk associated with a fixed amount of activity (or 

absorbed dose) when spread uniformly over tissue with the risk 

when the same activity (or absorbed dose) is spread non-uniformly 

over tne same tissue; (3) the concept of "wasted radiation" 

and/or "overkill." It is essential that these three approaches 

or concepts and their relationships (or distinguishing features) 

be clearly understood before judging the relevance of experimental 

da~a to the hot particle issue. We begin by reviewing each 

approach or concept and then examine their relationships of (2) 

and (3) to (1). 
- 12 -

(1) Risk Per Hot Particle -- The assignment of a risk 

per hot particle is based on a hypothesis that when the radiation 

dose to the irradiated tissue mass surrounding a radioactive particle is sufficient to disturb a critical architectural unit of 

the tissue, such a disrupted tissue mass poses a unique carcinogenic risk. A value is assigned for the tumor risk associated 

with the disrupted tissue. Since for small particles there is 

a one to one correspondence between the disrupted architectural 

unit and the associated radioactive particle, this tumor risk 

is the risk per particle. In the Tamplin-Cochran Report, a lower 

limit on the radiation dose (and therefore alpha activity) to ~ 

disrupt the architecture was assigned (1000 rem to the irradiated 

tissue) and used to define a hot particle. No opinion was 

offered with respect to the appropriate risk function for doses 

(or activities) below this cutoff value. In the lung there is 

an upper limit on the size of particles that aLe deposited in 

the deep respiratory tissue. Hence, in the lung there is a 

·window" on the hot particle size and activity. In analyzing 

experi~ental data vis-a-vis the hot particle hypothesis the 

relevant parameter is the tumor risk per hot particle. 

(2) Uniform Versus Non-Uniform Exposure -- Present radiation standards are based on (i.e., establish limiting values 

for) the concept of radiation dose equivalent (units of rem) to 

the whole body and certain crit~cal 0rgans. In the calculation 

of the rem dose a "dose distribution factor" is assigned in order 

that the risk associated with a non-uniform distribution of a 

given type of radiation exposure to the critical organ is 
- 13 -

consistent with uniform exposure by the same type of radiation. 

Consistent with this approach experiments have been designed 

and analyzed to assess the difference between uniform and nonuniform distributions of dose to critical organs. For internal 

alpha-emitters the absorbed dose (in rads) to a critical organ 

is proportional to the total activity in the organ. 19 Hence, 

tumors per microcurie has been the primary parameter used 

when comparing tumor risk for uniform versus non-uniform dose 

distributions. 

(3) Wasted Radiation -- The concept of "wasted radiation" 

or "overkill" has been invoked to describe that fraction of the 

radiation which kills cells, where these dead cells are assumed 

not to contribute to tumor production. For example, the dose rate 

in the immediate vicinity of a single alpha-emitting particle 

in the lung (or other tissue) can be high enough (given a 

sufficient particle activity) such that even a limited residence 

time in the tissue \'1ill result in the death of cells within 

a given radius. Since such cells can not reproduce it has 

20 been hypothesized that they would not lead to cancer. An 

alternative hypothesis, consistant with the hot particle 

hypothesis, is that the presence of dead cells, cellular products or fibrosis may be required for tumor production. 

19/ This is also generally true for-beta-emitters. 

20/ The concept of "wasted radiation" also has been invoked 

to describe the radiation dose during the period from the inception of initial malignancy until detection or death. The . concepts of overkill and wasted radiation have been used interchangeably. 
- 14 -

In order to demonstrate the relationships among the three 

approaches and concepts described above it is useful to analyze 

some hypothetical experiments. We do this below: 

Tumors/pCi or Tumors/Particle -- Suppose one ran a series 

of related experiments involving hot particles in tissue where 

the tissue mass and the total activity were held constant across 

experiments (e.g., the same number of lungs exposed to 12 nanocuries total activity in each experiment), and the experiments 

differed only in the number of particles and the activity per particle. Consistent with the hot particle hypothesis (one tumor per 

2000 hot particles) suppose one observed a tumor incidence given 

below in the second column from the right. 

ExperimentNumber 

of Hot 

Particles 

Activity per 

Particle (pCi) 

Number of 

Tumors 

Observed 

Tumors 

per nCi 

1 

2 

3 

4 

6000 

4000 

2000 

200 

2 

3 

6 

60 

3 

2 

1 

0 

0.25 

0.17 

0.08 

0.00 

From the observed number of tumors and the total activity (12. 

nCi) , the tumors per nanocurie are calculated in the last column. 

Holding the total activity and tissue mass as constant while 

increasing the number of particles tends to make the exposure more 

uniform. Hence the results, when analyzed on a tumor per 

nanocurie basis (the last column), appear consistent with the 

view that uniform exposure carries a higher risk than non-uniform 

exposure. But these same experimental results are exactly 

consistent with the hot particle hypothesis. What does this 

tell us? First, it clearly demonstrates that an analysis of 
- 15 -

an experiment, or series of experiments, on a tumor per nanocurie 

or microcurie basis, the results of which appear consistent 

with the concept. that uniform exposure carries a higher tumor 

risk than non-uniform exposure, is not in itself a refutation 

of the hot particle hypothesis. In fact, if the hot particle 

hypothesis is correct, ~n analysis based on tumor per microcurie 

is irrelevant. One can just as easily design a series of 

experim~nts consistent with the hot particle hypothesis, which 

when analyzed on a tumor per microcurie basis suggests the 

opposite, that is, uniform exposure carries a smaller risk than 

non-uniform exposure, as is the case with respect to the two 

experiments below. 

\ Total Number of 

Number of Activity Tumors Tumors 

Experiment Particles (nCi) Observed per nCi 

1 6000 12 3 0.25 

2 4000 6 2 0.33 

Again, if the hot particle hypothesis is correct, the analysis 

based on tumors per microcurie would be irrelevant. If tumor 

production depends on the number of disrupted architectural 

units independent of particle activity (over a range of activities), 

analyzing the data on a tumor per microcurie basis clearly 

makes no sense. One would not expect, a priori, a correlation 

between tumors per microcurie and numbers of particles (uniformity 

. of dose). To the contrary one should not be surprised to see 

conflicting experimental results (i.e., some experiments suggestiny 

uniform exposure carries a higher risk and other experiments . 
- 16 -

suggesting the opposite). The relevant parameter to judge the 

hot particle hypothesis is tumors per hot particle, not tumors 

per microcurie. 

At this point we might add that in addressing the hot 

particle issue, an analysis based on tumors per microcurie 

(or tumors per rad), where the radiation exposure is from other 

than hot particles (and therefore a different carcinogenic response mechanism may be controlling), is also irrelevant and is 

simply a compounding of mistakes. 

We do not imply that comparisons of the risks associated 

with uniform and non-uniform exposure serves no useful purpose. 

Consider, for example, radium-226 and plutonium-239 which are 

- both alpha-emitters and both bone seekers, that is both are 

preferentially deposited in the skeleton. The cancer risk per 

microcurie deposited in the skeleton (or per rad) is about 

five times,higher for plutonium than radium. This suggests 

that plutonium is preferentially deposited in tissue more 

sensitive to the development of bone cancer, and that in calculating the dose equivalent (rem) to the skeleton due to plutonium the use of a dose distribution factor of 5 is appropriate. 

However, this clearly has no relevance to the hot particle 

hypothesis which is an entirely different effect, aside from 

the fact that the distribution factor for plutonium in the bone 

is based on soluble plutonium and not hot particles. 

Hot Particles and Wasted Radiation -- Turning next to the 

concept of wasted radiation, suppose one were to implant one hot 

particle of alpha activity in a critical organ such as the lung. 

Under the hot particle hypothesis it would carry a tumor risk 
- 17 -

equal to the assigned risk per particle, one in 2000. As long as 

the particle activity remained above the cutoff limit defining a 

hot particle, changing the activity, for example doubling it, 

would not change the lung tumor risk. If the a9tivity and therefore the radiation dose were doubled without a c.hange in the tumor 

risk, one could invoke the concept of "wasted radiation" or "overkill." At least one-half the activit"y (more than one-half if 

the particle activity were greater than twice the minimum defining 

a hot particle) would be "wasted." The hot particle hypothesis is 

consistent with the concept of "wasted radiation." But more 

important, the concept of "wasted radiation" is clearly irrelevant in judging the validity of the hot particle hypothesis. 

What is important, is the assessment of the risk per particle 

over the range of particle sizes defining hot particles. The 

relevant parameter in this assessment is again, the tumor risk. 

Eer hot particle. 

IV. Page by Page Critique of the BRW Report 

In this section we will present a page by page critique 

of the BRW Report. To avoid confusion we will use their method 

for bibliographic. citation. Their bibliography is reproduced 

at the end of this section. 

Page 1. "Summary and Conclusions." We will comment on 

the conclusions in this section as we review the related material 

in the main text of the report, only noting here that the conclusions are without merit. 
- 18 -

Page 3. "I. Statement of the Problem." We generally 

agree with this statement of the problem, noting only that the 

hot particle hypothesis is based on damage to a critical 

architectural unit as opposed to individual cells. The 

discussion here is essentially the same as the discussion 

on pp. 15-17 of the Tamplin-Cochran Report and Table I in 

the BRW Report is comparable to Table III in the TamplinCochran Report. 

Pages 5-7. "II. Background. II This is a general discussion 

of consideration of irradiation from radioactive materials in 

parti9ulate form by several organizations concerned with radiation 

P!otection, including the ICRP, NCRP and National Academy of 

Sciences--National Research Council (NAS-NRC). The thrust of 

this discussion is that (1) non-uniformity of dose has been 

. recognized, been of interest, and periodically reviewed since 

the early days of the Manhattan Project, and (2) organizations 

with responsibility for recommending radiation standards, such 

as ICRP, NCRP and NAS-NRC, have never recommended a change 

from the current practice of basing radiation standards on the 

mean dose to organ. While the hot particle problem is well 

recognized in the biological community, and while we agree with 

the observations above, we do not believe the conclusion reached 

on page 7 by the authors of the BRW Report is appropriate, 

namely: 

The fact that these organizations have not changed or 

recommended changes in the procedures used for calculating dose to the lung as the result of their deliberations is an implication of implicit guidance on 

this particular problem. 
- 19 -

To the contrary, had these organizations intended that this 

conclusion be drawn, they would have made it explicit. In 

its Publication'9, the ICRP (1966) states (p. 4): 

•.• In the meantime there is no clear evidence to 

show whether, with a given mean absorbed dose, the 

biological risk associated with a non-homogeneous 

distribution is greater or less than the risk resulting from a more diffuse distribution of that 

dose in the lung. 

And the NCRP (197l) offers the similar statement (pp. 79-80): 

(210) The NCRP has arbitrarily used 10 percent 

of the volume of the organ as the significant volume 

for irradiation of the gonads. There are some 

cases in which choice of a significant volume or 

area is virtually meaningless. For example, if a 

single particle of radioactive material fixed in 

either lung or lymph node may be carcinogenic, the 

averaging of dose either over the lung or even over 

one cubic centimeter may have little to do with this 

pase. 

The appropriate interpretation of these remarks by the ICRP 

and NCRP is that there is no guidance as to the risk for 

non-homogeneous exposure in the lung. The intent of these 

remarks is to call attention to exceptions to the general rule, 

rather than to implicitly advocate averaging the dose over the 

critical organ when the dose is grossly non-uniform. 

Page 7. With regard to the quotation from the ICRP Task 

Group in Publication 14 (ICRP 1969), it is not at all clear that 

the Task Group reviewed Geesaman's work before preparing 

this ICRP report. Moreover, while the opinion of the Task 

Group may be worth noting, it is important to note that it is 

only an opinion and is totally unsupported in ICRP Publication 

14. Considering this in 1974, it is significant that in the 

intervening 5 years since the issuance of Publication 14, 
I 

- 20 -

adequate support for that opinion has not been forthcoming and 

as we demonstrate here is not to be found in the BRW Report. 

Quite the contrar~, the analysis of Geesaman and the TamplinCochran Report have emerged to support the opposite. The BRW 

Report states that new data tend to support the ICRP Task Group's 

opinion. With this, as we show in this critique, we totally 

disagre~.· 

Pages 9-23. "III. Animal Studies." 

Pages 9,10. "A. Retention of Plutonium in Lung" 

This section discusses the long retention time of PuO 

2 

in human lung. There is no controversy here. 

Pages 10-12. "B. Spatial Distribution of Plutonium 1'7ithin Lung" 

This section, while attempting to indicate that Pu particles 

in the lower respiratory region are not static, does admit on 

page 12 that autoradiographic evidence demonstrates that such 

particles are immobilized in scar tissue and possibly in Type 

alveolar epithelial cells. The long residence time of Pu 

particles in the lung suggests that such immobilization must 

occur. 

Pages 12-23. "C. Pulmonary Neoplasia" 

These pages present the animal data on Pu induced lung 

cancers. The data on both soluble and insoluble Pu compounds 

are presented. It is only those experiments that involve insoluble alpha-emitting hot particles-that are of interest here. 

Of those experiments discussed here, it is only those involving 

Pu02 that are pertinent. Since these experiments are recanted - . 

in the subsequent section of the BRW Report, we will briefly 

discuss only a few of them here. 
- 21 -

Page 13. Mention is made here of an experiment (Bair, 

et al., 1962) wherein 800 mice were subjected to inhalation 

of 0.1 to 2 nCi per' gram of lung. At time of death, these 

animals had retained only 0.1 to 10 pCi in their lung. Moreover, 

the report states that since so few autopsies were performed, 

the lung tumor incidence is unknown. In other words, this 

experiment is of little value to the hot particle problem. 

The beagle dog experiment (Park, et al., 1972) (Park 

and Bair, 1974) did involve Pu hot particles. However, as we 

indicated in the Tamplin-Cochran Report, since the tumor incidence was essentially 100%, this experiment does little to 

resolve the uncertainties in the hot particle hypothesis. 

Page 15. The Pu-238 experiment by Sanders (1973) involved Pu02 derived from crushed microspheres. However, Sanders 

indicates that this material was nsolublen in his experiment and 

that the irradiation was uniform. The observed rapid clearance 

from the lungs supports this contention. 

The baboon studies (Metivier, et al., 1972) relates to 

hot particles but at quite large particle concentrations which, 

as in the beagle experiment, makes it difficult to draw inference relative to lower concentrations. 

Pages 16-23. "0. Experiments of Special Relevance to NonUniform Dose Distribution" 

Page 16. This page is a confusing discussion of nwasted 

radiation" and "overkill." As we stated in the previous section 

of-this critique, the hot particle hypothesis designates a 
- 22 -

minimum particle activity--one that delivers a dose of 1000 rem/year 

to the irradiated tissue. Such a particle is suggested to have 

a chance of producing cancer equal to 1/2000. Particles with 

greater activity have the same chance, hence the concept of 

"overkill" or "wasted radiation" is included in the hot particle 

hypothesis. 

This page also contains the following sentence and footnote: 

For a single radioactive particle of 239 PuO in the 

lung (or other tissue), the dose rate near t~e particle 

can be high enough to cause the death of all cells within 

a given radius even if the residence time of the particle 

is short. Such cells will not be able to reproduce and 

subsequently result in cancer.* 

*The presence of dead cells, cellular products or 

fibrosis may be required before a cellular transformation can express itself as a cancer. However, 

this concept has not been generally accepted. 

This same statement and footnote appeared in both the 

Healy Report and the Draft EIS for the LMFBR with the significant 

exception of the last sentence in the footnote. Even if this last 

sentence were true, which we doubt, it is irrelevant because 

matters of science are not determined by public opinion polls. 

Nevertheless, we are curious concerning the method employed 

by the authors of the BRW Report to establish this conclusion. 

We have previously indicated that the hot particle hypothesis implies an injury-mediated mechanism of carcinogenesis 

as the footnote suggests (see pp. 9-10). There is no need to 

repeat that discussion here. However, we submit that lesion 

discussed by Lushbaugh and Langham (1962) is by itself so 
- 23 -

incriminating of hot particles that we are amazed that the 

authors of the BRW Report are so reluctant to acknowledge the 

potential hazard of'such particles. 

It is, however, obvious that this reluctance led to confusion 

on their part. For example, the paragraph, from which the 

above quote was extracted,' ends on page 17 with this statement: 

The relevant parameter is tumors per microcurie 

because the basic question is how the risk from hot 

particles compares with the risk from uniformly distributed radiation doses. 

In the previous section of this critique we demonstrated 

that the test of the hot particle hypothesis must be on the basis 

of tumors per particle not tumors per microcurie simply because 

particles can contain more than the minimum activity (and hence, 

be "wastefulII on a per pCi basis). If the AEC had chosen to 

engage in a dialogue with us, this simple but fundamental matter 

could have been resolved and much of the extraneous material 

in this BRW Report could have been eliminated (if not the entire 

report) . 

Page 17. This page contains the following paragraph: 

Two approaches have been used in skin experiments. 

The first was to determine whether isolated small 

areas of irradiated skin gave the same yield of 

tumors per unit as large-area skin irradiations. 

The focal irradiation pattern with low LET radiation, 

electrons (Albert et al., 1967b), was less efficient 

than the large area-exposure in producing tumors. 

'However, with high LET radiation (protons) there was 

no difference (Burns, et al., 1972). If these 

results can be extrapolated to alpha radiation, 

they suggest that the risk from particulate sources 

is no greater than from uniformly distributed sources. 

Apparently the authors of this paragIaph do not understand the purpose and significance of the experiment by Burns, et al., (1972) 
- 24 -

and this is reflected in the last sentence which makes no sense. 

The purpose of the experiment by Burns, et al., was to determine the basis for the lower tumor producing efficiency of electrons 

where the irradiation was performed in a sieve pattern. Since the 

electrons are highly scattered, the focal radiation dose was uncertain. With the relatively non-scattering protons, the sieve 

'pattern produced the same number of tumors per area irradiated. 

2 These experiments demonstrate that if 24 cm of rat skin 

are irradiated to 1000 rem, one tumor will develop per animal. 

2 If you irradiated 12 cm to 1000 rem, one tumor will develop 

2 per two animals; 6 cm should produce one tumor per four animals 

and so on. Moreover, the data strongly suggest that as the 

area irradiated is reduced to that corresponding to a single 

hair follicle, one tumor will develop per 2000 animals. 

The next paragraph discusses the experiments of Albert, 

et al., and ends with the following discussion: 

A plausible explanation for the experimental results 

is that each follicle has a population of stem cells 

at a depth of 0.3 rom that are concerned with the production of sebaceous cells and hair. These stem cells 

apparently constitute the most sensitive potential 

oncogenic cell population to ionizing radiation in 

the rat skin since all the tumors were mainly of hair 

follicle origin (Albert, et al., 1969). Neoplastic 

transformation of a signirTcant number of these target 

cells required large radiation doses which in turn 

killed most of the target cells and thus caused follicle atrophy. 

This is a possible explanation but it does not set aside 

the hot particle hypothesis. The killing of cells and the 

consequent disruption of the tissue may well be sufficient by 

itself for such "neoplastic transformation." The induction of 
- 25 -

tumors with mylar film and millipore filters by Brues, et al.,2l 

would support this as would the precancerous cytological changes 

observed around the lesion excised by Lushbaugh and Langham (1962) 

and' around the microspheres in rat lungs by Richmond, et al., 

(1970). 

Page 18. This page goes on to discuss other skin tumor 

experiments and the first column ends by stating that the evidence does not support the hot particle hypothesis as detailed in 

the Tamplin-Cocbran Report. We offer the above paragraph and 

this entire critique as refutation of that contention. 

The experiments of Richmond, et al., (1970) are discussed. 

This discussion, howev~r, fails to note that Richmond, et al., 

stated that the lesions observed in the rat lungs follO\ving 

exposure' to these hot microspheres were similar to that observed 

by Lushbaugh and Langham (1962) in human palmar tissue. 

Page 19.' The experiment of Passonneau (1952) is mentioned 

here. It was also discussed on page 17. This experiment is 

simply a variation of the experiments of Albert, et al., (1967a, 

1967c, 1969). 

Pages 19-20. These pages discuss the experiments of 

Richmond with Sullivan and Voelz as reported in: 

Richmond, C. R. and G. L. Voelz (eds.) 

LA-4923-PR, pp. 18-34 (April 1972), 

LA-5227-PR, pp. 1-11 (March 1973), 

and Richmond, C. R. and Sullivan, E. M. (eds.) 

LA-5633-PR, pp. 1-9 (May 1974). 

21/ Brues, A., et al., ~ cit. 
- 26 -

These are a series of progress reports on experiments 

wherein microspheres of 239pu02 and 238pu02 incorporated in 

Zr02 particles (10 p diameter) are injected into the jugular vein 

of hamsters. These particles lodge in the capillary network of 

the lung. 

The BRW Report suggests that these experiments are a 

strong argument against the hot particle hypothesis. We shall 

show that while ~~e experiments raise some questions concerning 

the quantitative parameter in the hot particle hypothesis, they 

also support the hypothesis. 

In the initial experiment 2000 particles per animal were 

~njected according to the following dosage schedule (60 animals 

per dosage level). 

Isotope Level ECi/Earticle nCi/animal 

Pu-239 1 0.07 0.14 

2 0.22 0.44 

2A 0.42 0.84 

3 0.91 1.82 

3A 1.60 3.20 

Pu-238 4 4.30 8.60 

5 13.30 26.60 

6 59.40 119.00 

Only two lung tumors developed in the experiments and they 

occurred in the level 2A exposure group. However, the latest progress report (LA-5633-PR) mentions histological changes occurring 

in the lungs of long term animals (15-20 months) in the 4-6 exposure levels. Concerning these changes, Richmond and Sullivan 

(1974, p. 7) stated: 

There has been no increase in frank tumors observed 

wiL~in the past year; however, the epithelial changes 

described above could be considered as precursors of 

peripheral adenomas. 
- 27 -

This suggests an incipient carcinogenic response to the particles 

but the life span of the rats and hamsters is too short for the 

development of a frank tumor. 

Similar histological changes were observed in rats injected with these microspheres by Richmond, et al., (1970) who 

pointed to the similarity of these particle induced lesions in 

the rat lung to that observed by Lushbaugh and Langham (1962) in 

human palmar tissue. 

For reference, in the beagle dog experiment lung tumors 

developed (in all animals that survived 1600 days) some 5 to 11 

years after the initial alveolar deposition of 3 to 50 nCi/gram 

of bloodless lung (Park· and Bair, 1972). The exposures were 

by inhalation, not injection. 

On a nCi/gram basis, the beagle,exposures would correspond 

to exposure levels 3 and above in the Richmond experiments. 

But the medium activity per particle in the beagle experiment 

corresponds to those in exposure levels 1 and 2 in the Richmond 

experiments which suggests that with longer exposure periods, 

lower activity particles (corresponding to levels 1 and 2) 

can produce the histological changes observed in the rat and 

hamster lung and in human palmar tissue. At the same time, 

since the beagle exposures involved a spectrum of particle sizes, 

it must be conceded that the carcinogenic response in the beagles 

couid have been elicited by the larg~r, higher activity particles. 

In either case, the beagle dog data suggest that the 

induction time for the hot particle mechanism of carcinogenesis 

exceeds the life span of the hamster by some three years or more. 
- 28 -

Thus, the absence of a large carcinogenic response in the 

hamsters does not set aside the hot particle hypothesis. 

The Richmond experiments point out one of the uncertainties 

in our quantification of the hot particle hypothesis but they do 

not resolve it. We suggest that a lower limit for a hot particle 

be one that contain sufficient radioactivity to deliver an average dose of 1000 rem/year to the exposed tissue. For an alphaemitting hot particle, this limit corresponds to 0.07 pCi. In 

LA-5633-PR the authors state with respect to this histological 

change (p. 7), "This lesion has been observed almost entirely 

in the higher activity levels (levels 4-6 and in animals given 

relatively small numbers of spheres (2000-6000)." A level 4 

particle contained 4.3 pCi, some 60 times our limiting activity. 

But, at the same time, had these experiments been performed 

with animals that have longer life spans, it is quite possible 

that these histological changes would have developed around 

particles containing our suggested limiting activity. 

Nevertheless, a 60 fold increase in activity requires 

only a 4 fold increase in particle diameter--for Pu-239, a change 

from 0.6 ~ to 2.4~; for Pu-238, a change from 0.09 ~ to 0.36 ~ 

and for high burn-up nuclear fuel, a change from 0.4 ~ to 1.6 ~. 

These particles are still in the range that permits deposition 

in the lower respiratory zone. Thus, these experiments do not 

set aside the hot particle hypothesis. Rather they suggest , 

additional experiments involving longer lived animals to determine 

whether this histological change progresses into frank tumors 

and whether lower activity particles also produce these changes. 
- 29 -

If an experiment comparable to these with hamsters 

were initiated with beagles, it would serve to resolve these 

uncertainties. Such an experiment would take some 15 years to 

complete. In the meantime, we propose that prudent public health 

practice dictates that exposure standards should be established 

on the basis of the hot particle hypothesis. 

The experiments of Little, et al., (1970a, 1970b, 1973) 

are said to add significance to the microsphere experiments. 

As we show subsequently, the experiments of Little, et al., 

involved uniform exposure to Po-2l0 at high dosage (above 8000 

rem). These experiments therefore do not involve hot particles 

and there is no ~ prior~ reason for asslli~ing that t~ey involve 

the same carcinogenic mechanism as hot particles. 

Pages 20-21. The experiments of Shubert, et al., (1971) 

and Brooks, et al., (1974) are discussed here. These experiments 

made a'determination of the frequency of chromosomal aberrations 

in liver cells following uniform and particulate irradiation. 

It is important to note that a causal relationship between 

chromosomal aberrations and subsequent cancer development is 

. only a hypothesis. Moreover, as we have stated previously, 

the actual killing of cells and the subsequent disruption of 

the normal tissue architecture may well be the carcinogenic 

mechanism for hot particles. Thus, these experiments are of 

little value in resolving this issue. . 

Pages 21-22. The experiments of Little, et al., (1970a, 

1970b, 1973) and Grossman, et al., (1971) are discussed here. 

In these experiments hamsters were exposed to Po-210 lung doses 
- 30 -

ranging from 8,000 to 20,000 rem. In some experiments the Po 

was absorbed on hematite particles. However, calculations 

demonstrate that the activity per particle ranged from 10-4 

to 10-3 pCi 22 and, consequently, that these were not hot particles. 

Therefore, the conclusion of Little, et al., (1973) quoted on 

page 22 is not relevant to the hot particle issue. 

We note in passing, however, the nature of the experiments 

was that the entire lung was irradiated to very high dosage 

although there was some aggregation of particles. A large carcinogenic response was initiated in each exposure group. The 

preliminary data reported here indicate that the life span of 

the hamster is longer when the dosages are this high and the 

Po-2l0 is on particles. However, it is not sufficient to demonstrate a'reduction in overall tumor response. Like the beagle 

experiments, the carcinogenic response in these experiments 

appears to be saturated because of the high dosage delivered to 

the whole lung or a major fraction thereof. No conclusions 

can be drawn relative to lower doses nor relative to hot particles. 

With re~pect to lower dosages, the work of Sanders (1973) 

demonstrates a large tumor incidence in rats at a dosage of 320 

rems. 

Pages 22-23. These pages discuss the experiments of 

Cember, et ale The major thrust of the Cember article deals 

with'144Ce particles in the lung. The. l44Ce was introduced 

admixed with stable Ce as either CeF3 or CeC13 in particles of 

about 1 p in diameter (0.5 p3)., l44Ce emits a beta particle 

22/ NRDC Comments on WASH 1535, ~ cit., p. 39. 
- 31 -

of 0.275 MeV and its daughter product l44 pr emits a beta of 

3 MeV. The rate of energy loss for these beta particles in 

tissue is about 0.2 Kev/p compared to some 94 Kev/p for plutonium 

alpha particles. 

This difference in energy loss per micron indicates that 

the activity of the l44Ce.emitters would have to be some 500 times 

that of the 239pu in order to deposit the same energy in the 

tissue irradiated by 239pu alpha particles. Moreover, since the 

OF for alpha particles is 10, the l44Ce particles must have an 

activity (10) x (500) or 5,000 times that of a 239pU02 particle 

to qualify as a hot particle. Since the limiting activity of 

a 239pu02 particle is 0.07 pCi, a hot particle of l44ceC13 

would hav~ to contain more than 350 pCi. After correcting for 

the half-life of l44Ce (288 days) a hot particle would have to 

contain some 500 pCi. 

The geometric mean diameter of the particles in these 

experiments was 1 micron. The highest exposure group received 

50 pCi of l44Ce in 30 pg of CeF • Allowing a density of 3 

6 g/cm3 for the CeF3 , the beta-activity per particle of 1 p 

diameter is only 5 pCi. In other words, these experiments did 

not involve hot particles as defined above. The carcinogenesis 

observed in these Cernber experiments, which was considerable, 

was related to high total and rather uniform organ dosage (1,000-

30,000 rad). 

Page 23. Here the experiments of Sanders (1973) and 

Moskalev (1972) are discussed. Large carcinogenic responses were 

observed in the lungs of rats at doses of 100 to 500 rem 
- 32 -

using "soluble" Pu compounds. One conclusion that is justified 

by the results of these studies is that the exposure standards 

for plutonium may be much too high (at least 100 times too high) 

even when hot particles are not involved. The results of Sanders 

indicate that a uniform dose of 15 rem doubled the natural incidence of lung cancer in the exposed rats. A worker is allowed 

this dose each year and a member of the population could accumulate this dose in 10 years. 

One further point could be made concerning the study of 

Sanders. It is not at all clear from the description given in 

the reference that the exposures did not involve a few hundred 

hot particles. If this were so, these particles could have 

been partly responsible for the observed cancers. 

The preliminary studies by Lafuma (1974) do not appear to 

be published and we have no copy of the seminar given in France. 

Indications are, however, that it is not different from the 

experiments discussed above. 

Again we offer the above and this entire critique as 

refutation of the conclusion reached in the last paragraph of 

this section. 

Pages 25-29. "IV. Human Experience." 

This chapter of the BRW Report discusses the exposure of 

humans to Pu. The major thrust of the. chapter involves workers 

from the Manhattan Project and from the Rocky Flats plutonium 

facility in Colorado. We discuss these in the Tamplin-Cochran 

Report but the authors of the BRW Report overlooked or ignored the 

salient features of our discussion~ 
- 33 -

Pages 25-26. The Manhattan workers are discussed on these 

pages. On pages 38 to 40 of the Tamplin-Cochran Report, based 

upon information from Hempelmann, et al., (1973a, 1973b) we calculated that the exposures of these workers did not involve hot 

particles. The authors of the BRW Report inexplicably ignored 

this discussion and made the unjustifiable assumption that the 

particles here corresponded to those associated with a fire at the 

Rocky Flats plutonium facility. As a consequence, the discussion 

of expected cancers on page 26 is without merit. 

Pages 26-27. The discussion of chromosome aberrations 

has no relevance to the hot particle problem. 

Pages 27-28. The exposure of employees of the Rocky 

Flats plutonium facility in October 1965 is discussed here. In 

the Tamplin-Cochran Report we pointed out that the induction period 

in man for hot particle carcinogenesis is unknown. In the beagle 

dog experiment (Park and Bair, 1972) it was 11 years before the 

dog with the lowest burden developed lung cancer. Thus, although 

no cancers have developed in the Rocky Flats workers at this time 

(9 years post exposure) the possibility exists that a number 

of cancers will appear in the next 10-15 years. 

Page 29. The lesion excised by Lushbaugh and Langham (1962) 

is discussed here. To the extent that a lesion with changes 

similar nto known precancerous epidermal cytologic changes," 

that raise the question of its fate without surgical intervention 

differs from a precancerous lesion, we were remiss in the 

Tamplin-Cochran Report. 
- 34 -

Page 29. As we indicated in the Tamplin-Cochran Report, 

the Pu in fallout did not occur in hot particles and hence, 

fallout Pu is irrelevant to the issue. 

Pages 31-35. "V. Theoretical Consideration." 

At the outset, it is important to note that one hypothesis 

cannot be used to set aside another. Each hypothesis must 

stand alone with respect to supporting experimental data. 

Pages 31-33. "A. Dosimetry." This is general information about which there is little controversy. 

Pages 33-35. "3. Models for Dosimetry and Tumor Probability." We agree with the concluding remarks of this section. 

The models discussed here relate tumor probability to cellular 

radiation dose. Depending upon the assumption, they can give 

a variety of tumor probabilities. 

We would simply add that the lesion excised by Lushbaugh 

and Langham (1962) coupled with the observations of similar 

lesions induced in the lungs of rats and hamsters should be 

sufficient to cause anyone to be skeptical of a tumor induction 

model which indicates a low tumor probability for a hot particle. 

Pages 35-39. "B. Radiation Carcinogenesis Relative to 

Spatial Distribution of Do·se." 

In the first paragraph of this section, the authors state 

that one should use experimental data, "meager as it is," rather 

than models based upon other organ systems. They indicate 

that this is "particularly true" when rat skin data are used 

to infer human lung effects. It is doubtful whether anyone would 

disagree with this. However, in the case of hqt particles, 
- 35 -

the experimental data are not only meager, they are very disquieting. Since this is a public health matter of importance 

and not just an academic exercise, prudence dictates that 

exposure standards should be based upon supportable and conservative hypotheses. 

Pages 35-36. The next few paragraphs discuss the concept 

of "wasted" radiation as it relates to the hypothesis of linear 

dose~effect response. When uniform irradiation is employed 

cancer induction is generally shown to be directly proportional to the dose from low doses up to a few hundred rad. 

The linear hypothesis relates these observations to cellular 

effects that result from single-track ionizing events. But even 

with uniform irradiation as one proceeds to higher dosages 

the response curve changes; for example, the curve steepens 

or the effects plateau and often decline. Obviously this indicates that other phenomena are becoming dominant. The hot particle hypothesis relates to such a different phenomenon (an 

injury-mediated mechanism of carcinogenesis). As such, it is 

not intended to be consistent with the linear hypothesis. 

The mechanism of radiation carcinogenesis is not understood even in the range of the linear hypothesis. This is 

evident in the next several paragraphs of this section of 

the BRW Report. Actually much of the discussion here is supportive of an injury-mediated mechanism wherein the altered 

tissue architecture creates a milieu highly favorable to tumor 

development; for example, the quote of Mayneord (1968). 
- 36 -

Page 36. The discussion of contact inhibition as it 

related to normal or "transformed" cells is again consistent 

with the hot particle hypothesis. It is the disturbed tissue 

architecture that can disrupt the normal contact inhibition. 

As we mentioned earlier in this critique, the induction of 

cancer by myla= film and millipore filters in the experiments 

of Brues, et al., supports such a mechanism. 23 

The paragraph that begins, "Thus, both acute and late •.• " 

is purely speculative and is no more supported by the previous 

discussion than is the hot particle hypothesis. 

Pages 36-38. The following ten paragraphs in this section 

are actually a discussion of an injury-mediated mechanism of 

carcinogenesis. 

Page 38. This is followed by the paragraph, 

At present there is no compelling reason to believe 

that the critical structure or volume required for 

radiation-induced promotion of cancer arising from 

cancer-potential cells of hair follicles is limited 

to the hair follicle. There is also no cogent evidence that the lung has analagous discrete susceptible 

architectural units with critical tissue volume as 

small as the sphere of alpha particle range from 

an isolated "hot particle." 

We would propose that there is also no compelling reason for 

not believing it and that prudent public health practice dictates that such a critical structure should be assumed in 

establishing exposure standards for hot particles. 

Pages 38-39. The next two paragraphs are speculative 

and are followed by the paragraph: 

23/ Brues, A., et al., 2.E...:.. cit. 
- 37 -

Considering the amount of human data available for 

carcinogenic risk estimates, and the variability 

and uncertainty concerning dosimetric factors (e.g., 

relevant doses, differences in spatial and temporal 

dose distribution, etc.), it has thus far been regarded as necessary to select single values of 

quantities that characterize the exposure of an 

organ or that organ in a group of individuals. 

Mean accumulated tissue dose is the only criterion 

that can be used practically at present until 

adequate knmvledge of more relevant criteria 

becomes available. Furthermore, when the energy 

is deposited non-uniformly and its influence in 

the exposed organ or a group of individuals is 

not knmvn, the non-uniformity cannot be dealt 

with until more adequate data are available. The 

linear (proportional) hypothesis is the only one 

that normally permits the use of mean dose as the 

significant dose factor for conditions of nonuniform exposure and exposure rate in an organ 

or among individuals, the purposes of estimating 

risk or setting dose limits in the absence of 

adequate data on distribution of dose and dose 

rates. 

While this paragraph may have been offered as an explanation 

for, or even as an excuse for, the present radiation exposure 

standards, we fail to see how it justifies the standards in 

the future. So far as hot particles are concerned, we have 

submitted a supportable hypothesis to supplant the linear 

hypothesis in establishing hot particle exposure standards. 

The standards are a practical problem of the moment and should 

be established on the basis of conservative and supportable 

hypothesis today. It is irresponsible to leave the health of 

workers and the public in jeopardy while awaiting more definitive 

data. 

The remaining paragraph is a speculative attempt to set 

aside the hot particle hypothesis. In this respect, ~t is 

interesting to note that this section of the report failed to 
- 38 -

recant the observations of Lushbaugh and Langham (1962) wherein 

a 'precancerous' lesion was induced in the palm of a mechanic 

by a single plutonium hot particle. Nor did it discuss the 

observations of Richmond, et al., (1970), Richmond and Voelz 

(1972, 1973) or Richmond and Sullivan (1974) that similar 

lesions were induced in the lungs of rats and hamsters by plutonium hot particles. Th~se are observations, not speculation, 

and they support the hot particle hypothesis. 

Pages 39-40. "C. Assessment of Experimental Animal Data." 

. This section begins with a discussion of a probit transformation of experiment,al data on animals relating lung cancer 

and radiation dosage to which the authors correctly ascribe no 

statistical validity. Nevertheless, so far as the Pu or other 

alpha data are concerned there is little that is related to hot 

particles and that which is, such as the beagle data (Park and 

Bair, 1972), rep~esents a saturated response. The Pu-238 

experiments of Sanders (1972) also demonstrate a saturated 

response at a level of 40 rad or 400 rem. Moreover,. Sanders 

indicates that Pu was soluble in his experiment. 

In the second paragraph they indiyate that these plots 

demonstrate a RBE of about 10 for alpha radiation in accord 

with radiobiological experience. In the third paragraph, they 

make an assumption concerning the non-Qniform distribution of 

the alpha irradiation and transpose the alpha curve in accord 

with this assumption. Considering the nature of the alpha 

experiments (their particle size, solubility, and saturation 

effects) there is no justification for this assumption and 

transformation. For example, Sanders states that his irradiation 

was uniform. 
- 39 -

We see little merit to this entire discussion and the 

conclusions in the 5th and 6th paragraphs that result from it 

are entirely unjustified. 

Page 41. The finalS paragraphs in the BRW Report discuss 

a number of animal experiments that supposedly are contrary 

to the hot particle hypothesis. The first involves the results 

of Laskin, et al., (1963) wherein Ru-l06 pellets were implanted 

in the br0nchi of rats. The results indicated a tumor incidence 

of 7.3% in animals exposed to a few thousand rads with the 

incidence rising to 66% in those exposed to 10 rads. This 

dose was calculated as that delivered to the basal layer of 

the epithelium. One can readily show that this experiment 

·is consistent with the hot particle hypothesis. 

The pellets were some 5000 p in length. They would therefore be expected. to produce lesions larger than the 200 to 

300 p lesions observed around hot particles. The result 

demonstrated a 7% tumor incidence in the 103 rad range with one 

tumor occurring in an animal exposed to 1400 rad. Thus, the 

cancer risk associated with this much 1arger 1esion at a dose 

of some 1000 rad was roughly 1/10 or some 200 times greater 

than that which we assigned to the smaller lesion around a hot 

particle. This is entirely consistent with the hot particle 

hypothesis including the 1000 rem/year activity limit. Moreover, the incidence rose to 66% at higher dosage. The data 

of Richmond and Voelz (1972, 1973) and Richmond and Sullivan 

'(1974) with Pu microspheres demonstrated that these lesions 
- 40 -

develop more rapidly as the particle activity is increased. 

This suggests that if a sufficient induction period were allowed, 

the incidence for the large pellet-produced lesion could be 

unity. Again, this is consistent with the hot particle hypothesis. 

The remaining experiments discussed here involved Co-60 

implants in a variety of animal species (Warren and Gates, 

1968) and-whole body x-irradiation of rats (Koletsky and 

Gustafson, 1955, and Castaneva, et al., 1968). Concerning 

these experiments, the BRW Report authors state: 

Data in figure V-4 for five species of animals 

given 60Co wire implanted in their lungs show lung 

tumor incidences ranging from about 8 to 40%, in 

all but one instance, for total doses of 105-10 6 

rad to either the entire lung or to the esophagus. 

It "is of interest that the entire lung is irradiated, 

including any and all possible "critical architectural 

units," at high dose rates, yet the tumor incidence 

" is not unity. Also of interest is the similar response 

shown for the several species used with the possible 

exception of the rat lung, the highest cancer incidence 

point. The observation of tumor incidences well 

below unity is true also for the whole-body exposu~es 

to X-irradiation in which the 3ntire lungs and body 

of rats received doses near 10 rad. 

All of these experilnents involved whole body exposure at 

fairly high dosage. These exposures elicited a generalized 

carcinogenic response and a significant life shortening effect. 

Since lung cancer was competing with this overall response, it 

is incredible that the authors of the BRW Report expected the 

lung cancer incidence could have reached 100%. 

In the Co-60 experiments, the life shortening effect 

amounted to 80% in all strains and species except for rabbits 
- 41 -

which died earlier. At the same time, 33% of the animals 

developed cancer in one or more of the three tissues studied: 

lung, bone, and esophagus. If all tissues had been studied 

the cancer incidence would have been higher. Nevertheless, 

in the rat, lung cancer had a competitive edge and reached an 

incidence of 75%. In the X-ray study of Koletsky and Gustafson 

(1955) the life shortening approached 50% and the incidence of 

malignant neoplasms was 35% at a whole body dosage of 660 rad. 

In the control group the incidence was 8%. The Castaneva, 

et al., (1968) results showed a malignant tumor incidence of 

100% and a 20% life shortening even at a dosage of 430 rad. 

The control rats in these experiments had a 30% malignant tumor" 

incidence. These experiments are typical of many such experiments and show the overall response to whole body radiation. 

The relationship to the hot particle problem, if any, is 

obscure and remote. There is no ~ priori reason to believe 

that the same carcinogenic mechanism is involved. 

v. Summary and Conclusion 

The Tamplin-Cochran Report presented a hot particle hypothesis based on an injury-mediated mechanism of carcinogenic response. 

In order to assist in setting radiation protection standards we 

proposed quantative values for 1) the minimum activity defining 

a hot particle and 2) the carcinogenic risk per hot particle. 

The ".hot particle hypothesis" is relatively simple. With respect 

to alpha-emitting particles in the lung, it is: 
- 42 -

If a particle deposited in the deep respiratory tissue 

is of such activity as to expose the surrounding 

lung tissue to a dose of at least 1000 rem in 1 year, 

this particle represents a-unique carcinogenic risk. 

The biolog~cal data suggest that such a particle may 

have a cancer risk equal to 1/2000. 

The BRW Report has been offered as a refutation of the 

hot particle hypothesis quantitatively presented in the TamplinCochran Report. The BRW'Report cites numerous experimental 

studies, most of which are not relevant to the hot particle 

issue. Those which are relevant we have shown to be consistant 

with our hot particle hypothesis. Thus, the BRW Report is 

not in any way a refutation of the hot particle hypothesis. 

While it must be recognized that there are uncertainties 

with respect to the quantitative values we have chosen, until those 

uncertainties can be resolved by appropriate experimental data, 

it is incumbant upon the AEC and EPA to adopt radiation protection standards comparable to those in the Tamplin-Cochran 

Report. Furthermore, we submit that these more restrictive 

standards should be quickly promulgated because it is irresponsible to leave the health of the public and workers in jeopardy 

while awaiting more definitive data. 
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47 

GPO t112·01l .. 

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DEPUTY DIRECTOR 

fOANES KANfCHY 

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ALAN B. BURDICK 

February I, 1975 

Warren D. Johnson, Lt.Gen./USAF 

Director, Defense Nuclear Agency 

Washington, D. C. 20305 

Dear Don: 

Enclosed are the Comments of the People of Enewetak upon 

the DEIS for the Clean Up, Rehabilitation, Resettlement 

of Enewetak-Marshall Islands. Thank you very much for 

your forbearance with our various requests for extension 

of the deadline. 

Mitchell 

EnclosureS (as stated - 10) 
Document "Comments of the People of Enewetak 

Concerning the DEIS" not included at this time 

but will be included in final dis tribution. 
Comments 

of the 

People of Enewetak 

Concerning 

The Draft Environmental Impact Statement 

CLEAN UP, REHABILITATION, RESETTLEMENT 

OF 

ENEWETAK ATOLL-MARSHALL ISLA}:~S 

(DATED September 1974, 

issued by the Defense 

Nuclear Agency, Washingt0I1, 

D. C. 20305) 

Prepared by 

Theodore R. Mitchell, 

Counsel for the People 

of Enewetak 

Micronesian Legal Services Corp. 

P. O. Box 826 

Saipan, Mariana Islands 96950 

February 1, ~q75 

1. Introduc~ion 

The impetus for development of this program comes from 

the long-expressed desire of the People of Enewetak to return 

to their homeland. Although resigned to their nearly thirty 

year exile at Ujelang Atoll, they have never given up hope of 

returning to Enewetak, if but only if,.it. is radiologicai1y 

safe for them to do so. They are aware of the substantial 

social and economic problems which necessarily attend the 

relocation and resettlement of their more than 400 persons, 

but the difficulty of assessing the risk from the extensive 

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 

experts in the various radiological scienc6 fields are saying 

about the effects of radioactivity, but that difficulty is 

compounded many times over the differences of opinion found 

among the experts, by the realization that even the experts 

agree that the long term effects of some of the more dangerous 

to 

radionuc1ides 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 

radionuc1ides to be tolerated in the environment and in roan are 

criticized by reputable experts as unreliable and inadequately 

conservative. 

Their ir.dividua1 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 be 

-1-
brought or sold. In their culture the land and marine 

environment of the atoll are fully integrated with the human 

members of the society. It is an economic resource and more. 

Ownership and use of the land refle~ts and is inextricably 

linked to th~ social organization and to the culture as a whole. 

To be sure, their society has undergune and continuously is 

undergoing change as a result of forces both within and without, 

but the extraordinary significance of their being able to 

resettle to the atoll discovered by their ancestors remains 

constant. 

Thus, the people of Enewetak are both the prime beneficiaries 

and the prime risk-takers in this resettlement program. And it 

is in the assessment and, if possible, elimination of the radiobiological health risk that they are the most dependent upon tbe 

united States government. The Defense Nuclear Agency and the 

Atomic Energy Commission have already de·Toted 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 haVe to be done over a long period of time. And throughout, , 

the People of Enewetak will rely upon the responsible agencies 

of the United States government to do everything possible to 

assess and minimiz~ the risk due to the residual radioactivity 

in the Enewetak biosphere. Nothing said in these comments, for 

example, should ever be taken as an assumption of risk by the 

people of Enewetak. When they left the Atoll in 1947 at the 

insistence of the IJnited States government it was radiologically 

safe. That is the state in which it should be for their return. 

-2-
Of course, it cannot ever be restored to that condition, but 

that must be the assumed objective in order that remedial measures 

can more likely fall within the safest possible limits, and sO 

that on-going efforts will be made to continually add to the 

knowledge o~ radiological conditions at Enewetak and refine and 

improve both risk 1'lc:;sessment and rellledial measures as the various 

relevant sciences develop over the year::. 

, 

Not only is the United States trustee for these peop~e, but 

it has an especial humanitarian obligation to them because of 

the uniquely dangerous potential effects due to the use to which 

the trustee put the Atoll. It is an absolute kind of responsibility ~o both return the people to their home and eliminate the 

likelihood of so much as a single radiation induced illness or 

anomaly. 

A full measure of gratitude is due and hereby given, however, 

to the considerable efforts which the United States has made thus 

far. The planning for resettlement, the radiological survey, the 

planning for the clean-up, all represent a very large contribution 

to th~ ultimate success of the program. And we do not wish to 

dampen the enthusiasln and interest of the many persons in and out 

of the government wh~J have given devoted effort thus far. The 

comments made here are offered in the spirit of cooperation, with 

the realiz~tion that they will be received in that same spirit. 

2. Social and Economic Problems Associated with Resettlement 

Further consideration of the social and economic problems 

associated with th8 resettlement must be given. This is perhaps 

-3-
one of the weakest aspects of the DEIS as it now stands. 

Attention is given to both short and long range economic 

planning (Vol. I, § 7, Vol. II, Tab D), but in consultation with 

the people themselves specific objectives and specific economic 

development possibilities must be found so that the shared aim'of 

economic self-sufficiency can be achieved. We realize that with 

all the ether a3pects of this complex project demanding attention 

up to now, this was not intentionally underemphasized. But as 

the program moves into its clean-up phase more attention must be 

given to meeting the future economic needs ot the people. This 

is especlally true because since the writing of the DEIS it has 

become known that adverse radiological conditions in the northern 

part of the Atoll do not permit the rehabitation of Engehi islet 

and severely if not completely restrict the use of the northern 

islets for the foreseeable future. 

The Enewetak Planning Council must continue to be relied upon 

to make the final value judgments upon one proposal or another 

and upon the development of the economy as a whole so that it will 

be consonant with their own capabilities and values, but one or 

more specialists should be engaged by the government and made 

available in an advisory capacity. They must be carefully selected 

both in terms of expertise in the field and suitability tn this 

kind of cross~cultural task and to the max~mum feasible extent 

the Planning Council should participate in the selection. 

Resettlement to Enewetak Atoll from Ujelang will involve an 

unusual amount of stress for individual members of the group and 

for the group as a whole. Physical stress will, if all goes as 

-4-
planned, be a-t a minimum, but we have in mind here the emotional 

stress upon the individual and the stress upon group processes. 

This matter is not addressed at all by the DEIS. 

Ultimately, of course, it is for the people to manage the 

transition well and to adapt with the~r society intact, but 

experience with similar resettlement-schemes is available and 

should be used to increase the likelihood of successful resettlemente The people themselves can benefit from greater awareness 

of the stresses they will experience and those outsiders involved 

in planning and working with them must have the same understanding. 

Dr. Thayer Scudder of the California Institute of Technology, 

a recognize~ authority on the Subject and an experienced consultant, 

should be considered for this assignment and if the Planning 

Council agrees, he should be engaged in this capacity. Dr. Scudder 

has taken a quick look at the DEIS at our request. His comments 

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 en.r:!losed is also useful. 

It is "The Impact of Human Activities on the Physical and Social 

Environments: New Directions in Anthropological Ecolcgy," by E. 

Montgomery, J. W. Bennett and T. Scudder, 2 Annual Review of 

Anthropology 1973.) 

Participation of another anthropologist versed in Marshallese 

culture is also in order, to assi.st both thl!> Enewetak people and 

the outsiders involved in the progrrun. Working in conjunction with 

someone like Dr. Scudder, the total contr.ibution would be invaluable. Dr. Robert Kiste at the University of Minnesota has been 

-5-
consulted by the governmental planners and meets these requirements exceptionally well. 

Short of involving so many advisors and planners that 

decesions and action are unduly impeded, it is essential that 

. those repretienting all the relevant disciplines work together as 

a group with the Enp.wetak Flanning Council and the governmental 

decision-makers. To some extent this is what has been done during 

planning to date, but for the remainder of the program, the 

relevant disciplines should be identified as such, appropriate 

representatives engaged and organized into a more or less formal 

advisory council. 

3. Radiological Considerations 

3.1. The Radiological Survey 

The survey of radiological conditions at Enewetak Atoll in 

1972 under the auspices of the Atomic Energy Commission is, we 

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 

which supervised t~e cond~ct of the survey, the assessment of its 

data and developed final recommendations are open to question. It 

is also apparent that as detailed and elaborate as that survey was, 

follow-up gathering of data and careful assessment of that data is 

absolutely essential, particularly with respect to the risk to 

health from all low-level, long-life radionuclides and especially 

the danger posed by those alpha-emitting radionuclides known as 

hot particles, s~ch as Plutonium-239 and Americium-241. 

We do not wish to detract from the qualifications of the 

-6-
members of the 'l'ask Group, but in a field involving :30 many 

specialties and where equally expert opinions differ markedly, 

it. is imperative that the Task Group for follow-up studie3 be 

enlarged to include scientists known to take the most conservative approach to radiation protectioH, such as Drs. E. A. Martell 

at the National Center for Atmospheric Res(?l'l.Tch , Arthur R. Tdmplin 

at Lawrence Livermore Laboratory, and Donald P. Geesaman at the 

University of Minnesota. Their presence in the Task Group, or 

their participation in some other direct way in designing methods 

to be used for the gathering of information 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 of the Enewetak environment with appropriate emphas.is 

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 ~eb cannot be }~nown without experi-

.: .. mental planting. (DEIS Vol. II, Tab B, p. 29.) These are only 

examples. And as time goes on, scientific kn0wledge of the nature 

and effect of radioactivity is bound to improve and new techniques 

for remedial measures will be found. Thes~ &cientific advancements 

will be lost to the Enewetak people unless the United States 

government assumes a long-range cornmitmeHt of the kind we suggest 

here. And in so doing it is highly probable that important contributions to the development of g):eat:.E:r understanding of radioactivity 

-7-
and its effects will result l to the benefit of the united State3 

und the world at large. 

3.2. The Hot Particle Problem 

It is with the kind assistance of Drs. E. A. Martell, Donald 

P. Geesaman, Arthur R. Tamplin and Thomas B. Cochran that we derive 

our comments here concerning this uillque radiological hazard. 

Drs. Tamplin and Cochran submitted formal- connnents 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 

observations and concerns are entiL'ely consistent with those of -

Martell 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. Martell, "Basic Considerations in 

the Assessment of the Cancer Risks and Standards for Internal 

Alpha Emitters," (Statement presented at the public hearings on 

plutonium standards sponsored by the Uni~ed States Environmental 

Protection Agency, Denver, Colorado, January 10, 1975.) To further 

emphasize OtIr grave concern about this problem, we attach comments 

and materials provided to us by Dr. Donald P. Geesaman as Appendix 

III. We subscribe fully to the views they express and we insist 

that they be dealt with fully in the final impact statement. 

It is beycnd question that the presence of Plutonium-239, 

Americium-24l and perhaps other alpha-emitting radionuclides at 

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 DEIS completely fails to address the recent 

-8-
findings of Martell and others that hot par~icles may very well 

be a causative factor in a number of other disorders. See 

Appendices II and III. The DEIS deals only with inhalation risk, 

yet Americium is known to present a risk for the liver, spleen 

. and bone of man through take-up from ~he gastrointestinal tract. 

(Martell, Personal Communication.) 

Concerning the adequacy of the radiological survey with 

respect to internal alpha emitters, Dr. Martell had this to say: 

It is noted that the survey results for the 

Ellewetak Lagoon sediments show an average of 463 

239+240 241 90 

mCi pu/km2 , 172 mCi Am/km2 and 586 mCi Sr/km2 

(Table 3-11, p 3-75, DEIS Volmne I). In addition, 

241 

the Am concentrations range up to 8.2 pCi/g averaged 

241 239 

over the top 15 cm depth of soils, with Am/ Pu 

ratios varying widely and ranging up to 3.5 (NVO-140 

Vol. 1, p 507). Due to further radioactive decay of 

241 241 

P.u, the run activity concentrations can be expected 

to double over the next 50 years. In addition, densely 

vegetated soils on each island show the highest radioactivity concentrations. 

239+240 

The DEIS limits consideration of Pu to 

inhalation risks. However significant uptake of Pu 

from the gastrointestinal tract has been observed in 

young mammals and similar uptake may occur in young 

children. In addition the uptake of americium in soils 

by vegetation is substantially higher than plutonium 

-9-
uptake. Similarly americium is readily taken up 

from the gastrointestinal tract and accumulated 

in the liver, spleen and bone of mammals, and 

thus undoubtedly in man. 

Based on these considerations 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 th? 

consequent body burdens and heald consequences to 

future atoll inhabitants. (Personal Communication.) 

Dr. Geesaman independently identifies the same inadequacy 

in the DElS and also finds a need for further study of the mechanisms 

by which plutonium contamination in the soil may find its way into 

the body. " 

.: 

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 

public health guidelines. Resuspension is poorly 

understood, it is sensitive to windspeed, soil 

-10-
characteristics, vegetation, hlli~idity, rainfall, 

mechanical distrubance, physical and chemical history 

of plutonium particles in soil. How then does one 

consi~er the' exposure of children throwing dry sand 

on a vl:':'ndy day at the beach? I vlOuld anticipate 

large fluctuations about the irilplicit exposure levels, 

which, even for the limiting soil contamination 

guidelines and predicted air concentrations associated 

with these guidelines, will be approximately a 

maximum perHiissJ.blt:! luny UUL'del'1. {Perl::ional Communication. j 

Each of the questions raised here and in the related appendices 

must b~ addLessed fully and carefully prior to resettlement of the 

people of Enewetak Atoll. 

3.3 Plutonium Soil Standards 

Concerning the standard employed by the DEIS for maximum 

permissible plutonium contamination of soils at Enewetak, Dr. Martell 

points out that "There are no ICRP standards for soil levels of 

Pu and the actinides or for lifetime exposures to internal alpha 

emitters." (Personal Communication.) And he provides the following 

critique of the standards adopted by the AEC Task Group for Enewetak: 

The rec(lmmendation that pluto!1ium contaminated 

239+240 

so;'ls, 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 Colorado Board of Health has adopted 

interim stanJards for Pu contamination limits in soils 

-11-
in land areas for residential use, specifying that 

238 

Pu levels shall not exceed 2 dpm (0.91 pCi) per 

gram of surface soil (i.e., averaged over the top 

1 cm depth 6f soil). It is noteworthy that the 

ABC has not established that th~s standard is unduly 

consGrvative and it is not apparent that the ABC 

has requEsted the ICRP or NCP~ to make specific 

recommendations with respect to standards for Pu in 

soils appljeable to chronic exposure to the general 

public, including children. 

I note that the DEIS recommends no remedial 

action foz. soils containing c 40 pCi or ~ 88 dpm 

Pu/g, averaged over the top 15 cm depth. This is 

much more than 44 times the Colorado interim standard 

(2 dpm per g in the top 1 em) because for most 

Enewetak soils the top cm contains substantially 

higher levels of Pu per gram than the 15 em depth 

average. Thus, for example, at location 101 on 

239 

Pearl, the 

~ 

top 1 cm depth shows 400 pCi Pu/g, 

whereas the average over 15 cm depth is about 60. 

Thus the recommended standard for Enewetak is about 

100 to several hundred times that adopted in Colorado. 

There are recent research developments which 

are expected to lead to reductions in acceptable 

organ burdens of Pu in man by a factor of 100 to 

1000 or more. In my opinion it is likely that a 10 

-12-
pCi lung burden of insoluble alpha emitting particles 

will give rise to significant adverse health effects 

for lifetime exposures. The typical burden of 

insoluble particles of respirable size « 5.0 Urn 

diameter) is about one gram ir. human adults. For 

this reason I wou;t.d recommend that su.rface soils 

239 

should not exceed about 1 pCi ~f Pu02 and other 

insoluble alpha emitting particles per gram of 

insoluble particulates of respirable size in the 

airborne dust resulting [rom Lhe ui::;;i.:.urLd.llc~ and 

resuspension of surface soils. On this basis even 

the Colorado standard may give rise to excessive 

organ burdens. 

Drs. Cochran, Tamplin and Geesaman all raise the same or similar 

objections to the DEIS plutonium standards. 

Further explanation of the plutonium cleanup criteria developed 

by the AEC Task Group is necessary. (DEIS, Vel. II, Tab B, pp. 111-8 

to III-II.) We have already mentioned the questionable wisdom of 

the 40 pCi/g ~tandard. For any concentrations exceeding 400 pCi/g 

the Task Group recommendations require removal of the soil. But 

in the range between 40 and 400 pCi/g, the DEIS standards call for 

"corrective action ••••• on a case-by-case basis. II (Vol. II, Tab B, 

p. 1II-9.) Certain criteria are offered for guidance in the 

exercise of this judgment, but they appear to be entirely too 

unspecific and subjective. Once a deciGion is made to take corrective action, 

-13-
the objective is to achieve a substantial 

reduction in plutonim:1 soil concentratic:ns, 

and further, to reduce concentrations to 

the lowest practicable level, not to reduce 

them to some prescribed numerical value. 

(ILid. Emphasis added.) 

Nor is it entirely clear who will be making these "case-b~

case" decisions. PresuMably it is 'lhe "team of experts" referred 

to in the recommendations of the 'rask G:::-oup (Vol. II, Tab B, p. 27), 

but we are not told who they are or how t~ey will be selected. 

This whole approach must be explained and justified, espe-

~idlly at a time when the EPA is conducting hearings around the 

country on plutonium soil standards for precisely the purpose of 

devel()p~_ng "numerical values" for the maximum concentrations 

permissible. The range between 40 and 400 pCi/g is a wide cne 

indeed and if 40 is too high, then to make decisions on a "caseby-case" basis within that range is to have no standard at all. 

Before any final standards are set for the radiological 

cleanup of Enewetak, the International Commission on Radiological 

Protection should be called upon for plutonium and actinide 

stan~ards applicable to air, water, soils and food concentrations 

for both soluble and insoluble activities, applicable to long-range 

exposure to the general public. Application should also be made 

to the U.S. Envircnrnent~l Protection Agency for special hearings 

for the £w~e purpose. Consideration should also be given to the 

desirability of requesting the United Nations Scientific Committee 

on the Effects of A.toriLic Radiation to conduct hearings and set 

these standards. (We are indebted to Dr. Martell for these 

sugges Lion s • ) 

-14-
At any and all of these hearings, every effort should be made 

to elicit the widest possible range of information and opinion 

bearing upon the question. Once such standards are set, they 

should govern the planning and cleanup activities at Enewetak. 

3.4 Removal and Disposal of Radiocontaminated Materials 

These comments relate to the proposed removal and disposal of 

contaminated scrap metal and soil treated in the DEIS at Vol. I, 

§§S.3.3.3 and 5.5. 

All radiocontaminated scrap metal on the Atoll has been 

identified and will be removed, as of course it must be, but the 

precise method of disposal has not been determined. Four alternative methods are discussed: o~ean dumping of the loose scrap, 

concrete encapsulation in the Cact~s and Lacrosse craters at the 

north end of Runit islet, or removal to the united States mainland 

for storage. We appreciate the practical and political difficulties presented by the various disposal methods which would remove 

the scrap from the Atoll entirely, but the People of Enewetak are 

adamantly opposed to any disposal upon or within the environs of 

the Atoll. Ocean dum~ing, according the DEIS (Vol. I, 8 5.5.2.1), 

was rejected "in view of the difficulty in obtaining a permit and 

certainty of international complications." Disposal to the united 

States mainland was disfavored for similar reasons. (Vol. I, § 5.5. 

2.4.) Disposal on the Atoll must he rejected a~d the other methods 

should be explored, the necessary permits and authority obtained 

and disposal off the Atoll selected as the preferred method. 

Removal and disposal of contaminated soil presents more serious 

cost and practical difficulti~s, bu~ here again the complete r~moval 

-15-
and off-Atoll disposal of all contaminated soil must be the 

stated objective of the program. 

Even using the high plutonium contamination standard set by 

the Task Group (40 pCi/g, etc.), the total amount of Atoll soil 

which would have to be removed and di~posed is 779,000 cubic yards. 

(Vol. I § !:;. 5.2.) If the soil standards are lO''lered as they 

should bE, that volume will increase. 

It is suggested in the DEIS that cost, legal, political and 

technical probleros aside, the removal of contaminated soil and 

its replacement with Cl.ean soii may not "assure radiological 

safety" and may present "serious ecological damage of unknown 

proportions.~" (Vol. I, § 5.3.3.3.) We fully favor this conservative approach to these problems (just as we do when the question 

is one which may reduce the program cost, i.e., high soil contamination standards), but a clear decision must be taken to study and 

fully assess thE relation of soil removal to dose reduction 

(including the risk from airborne hot particles) and the likely 

ecological effects of soil removal and replacement. These studies 

should be commissioned immediately and prosecuted with all deliberate 

.: 

speed. In the meantime, complete soil removal and replacement 

should be adopted as the prime objective. 

In addition, maximum effort must be made to overcome tEchnical, 

legal and political impediments to off-Atoll disposal of c(..r.taminated soil. 

. 3.5 Radiological Monitoring of Cleanup 

The AEC Task Group has wisely recommended the establishment 

of "team of experts" to monitor the execution of the t'adiological 

-16-
cleanup phase of the program. (DEIS, Vol. I, pp. 5-79, 6-5) Even 

if the Task Group is enlarged as we have suggested and specific 

soil standards are developed and implemented, this monitoring group 

will perfor~ a crucial function. Thus, it is important that its 

membership be carefully selected. It is imperative that radioscientists of the most conservative cast be included in the 

monitoring group •. Here again, we suggest that the names of Drs. 

Martell, Geesaman, Tamplin and Cochran. 

And the on-site authority of the monitoring group should be 

clearly defined, with all importan~ or unexpected problems to be 

referred to the enlarged Task Group. 

3.6. Test Plantings, Groundwater and Air Sampling 

We are in full agreement with the AEC Task Group recommendations for test plantings, lens water and air sampling. (Vol. I, 

. pp. 5-80 to 5-81.) But it is not clear whether these recommendations have been implemented. They must be and the studies should 

be commissioned to the best scientists and technicians available, 

under the over-all guidance of the enlarged Task Group. All of 

these studies must deal explicitly with the hot particle problem. 

3.7. Radiobiological Health Followup 

AEC Task Group recommendation 12 (Vol. I, p. 5-81) calls for 

"Baseline surveys of body burdens and urine content of Cs-137 and 

Sr-90 ••• for the Enewetak people prior to return to Enewetak Atoll, 

and periodically thereafter." But here, too, it is not clear 

whether a firm commitment to long-range radiological health 

monitoring of the Enewetak population has been made, and, if so, 

-17-
precisely ho~ it will be implemented. 

A fully adequate radiological health program must be 

designed, funded ~nd implemented. It can and should include the 

people of Bikini, who will one day soon be resettled, the exposure 

victims at Rongelap and utirik Atolls and the Enewetak people. 

The final impact statement should address this question and 

state clearly whether such a program is planned and what it will 

include. It too must deal with the health effects of hot particles 

and all forms of low level radiation, with emphasis on internal 

emitters. 

3.8. Unknown Concerns 

We have tried to identify all the radiological needs of this 

program which require further attention, all with the ultimate 

safety of the People of Enewetak in mind, Dut we cannot be certain 

that we have done a complete job. Hence, we call upon the United 

States government to continue to assu~e the important responsibility of giving the best and most careful attention to these matters 

for the long range future. 

4. Consid~rations Related to Cost 

Fundin~ requests for the initial phase of this program have 

been previously presented to the United States Congress. They did 

not receive very favorable or sympathetic consideration, to put 

it mildly, by the members of the House Armed Services and Appropriations Committees. In general, the objections related tu the 

great cost of the entire program and evidenced a reluctance to 

coroTuit the United States government to ~he first phase of a 
program, the ultimate cost of which would be in the neighborhood 

of $49,000,000. Hence, the request was disapproved. In the 

House and Senate Interior ~ommittees to which the rehabilitation 

and resettlement phases were referred in a legislative package 

separate from the cleanup, sympathetic and fa~rorable action was 

taken and $12,000,000 was authorized. 

Notably absent from the presentations made to the Congress 

and from the inquiries of the Congressmen themselves was realization of the enormous benefit which (in the view of the united 

States) has been derived from the use of Enewetak Atoll for 

nuclear testing and related national security activities. In 

the Armed Services hearings, the total projected cost of this 

prograul was divided by the number of Enewetak people and the 

suggestion made that perhaps the money should simply be given 

to the people. 

We do not have accurate figures for the total cost of the 

atomic energy program, the nuclear weapons testing program, nor 

for the amount of money actually spent for programs at Enewetak. 

But judging by figures we have seen (for example, Congress And 

The Nation, Vol. I, p. 262, Congre~sional Quarterly Service, 

1965) indicate that the cost was on the order of several billions 

of dollars in the ABC budget, and that says nothing about the 

undoubtedly large sums contained in one or more places in the 

Defense budget. We will suggest a figure of, say, $50 billion 

for the sake of discussion. That represents the agreed minimum· 

value to the benzfit to the United States of the same activities, 

the effects of which must now be remedied. Beyond the dollar 

-19-
value, the United States must assign a value to the benefit to 

national security of the testing program, however debatable that 

benefit may be in and of itself. 

The cost of the direct benefits in this program for the 

Enewetak people, such as housing, community development, etc., 

are a very small fraction of the tQtal, about $5,000,000. And 

even that portion of the total funding is directly attributable 

to their forced removal by the United States to make way for the 

testing program. 

And as we have said before, the United States undertook 

trusteeship of the Micronesian Islands of its own free will 

(without consent of the Micronesians) and put Enewetak Atoll, th~ 

property of the trust, to its oWP use for the very nuclear testing 

which deposited the radioactivity. 

This is the only perspective by which to consider and decide 

upon the outside cost limits of this program. The costs of the 

radiological and engineering cleanup of the Atoll are properly to 

be considered ordinary and necessary costs of the testing program. 

Indeed, the cleanup should have been planned from the beginning 

and funded and done at the end of the testing program about 19~8. 

The Enewetak People do not want money in any amount, they 

want and are entitled to their land, in safe and habitable condition. 

In the presentation of future requests to the United States 

Congress, this general approach should be taken and the leadership 

of the people themselves should be called to testify. 

"Case 3", outlined in Section 5.4.3, Vol. I of the DEIS, is 

offered as the preferred plan fOL cleanup 8nc resettlement of the 

-20-
Atoll. Essentially, it represents a compromise of cost, radiological and other factors, which will be far short of the 

theoretically ideal "Case 5". (Vol. I, § 5.4.5). Exclusive of 

contaminated soil and scrap disposal costs, the cleanup cost for 

Case 3 is $35.5 million and for Case 5 it is $81.6 million. 

Comparative soil disposal cost estimates are $7 million for Case 3 

and $92.2 for Case 5. 

We appreciate the political and practical realities of seeking 

sums on the order of $100 million from the United States Congress 

in these times of grave concern about the economy, but given the 

rationable stated above, it is Case 5 for which funding should be 

sought and for which funding should be given. 

Finally, quite apart from any cost-benefit analysis of the 

nuclear testing program, as a result of a recent decision of the 

United States Court of Appeals for the Ninth Circuit (people of 

Saipan, etc. v. U.S. Dept. of the Interior, etc., 502 F.2d 90 

(1974», the obligations imposed by the Trusteeship Agreement under 

which the United States administers the Micronesian Islands has 

become legally binding and enforceable. Under the terms of Article 

6 of the TrusLeeship Agreement, the United States is required to 

"promote tha economic advancement and self-sufficiency" of the 

Enewetak People; to "protect [them] against the loss of tlleir lands 

and resources ll ; to "promote the social advancement II of the Micronesians; and to "Frotect [their] health." These are the express 

Obligations. Beyond that, like any trustee, the United States 

bears implied duties to protect and promote the best interests of 

the beneficiary in every way. 

-21-
Litigatj.on by the beneficiary against the trustee to enforce 

these obligations would unseemly and costly. Every United States 

official involved, including members of the Congress, should 

freely and willingly undertake to fulfill them by planning, 

funding and conductin~ a cleanup, rehabilitation and resettlement program for the Enewetak People which aprroximates the ideal. 

5. Conclusion 

We have made a number of recommendations in the course of 

these comments to which we hope the program sponsors will give 

consideration in the preparation of the final impact stat~ment. 

The recommendations relating to assessment of the radiological 

risk, if accepted, mayor may not result in delay for the project 

as now planned. We hope not, but certainly the further study 

required and the development of soil, air and food contamination 

standards for plutonium may have a direct affect upon the initial 

cleanup phase. We urge the Defense Nuclear Agency to proceed with 

funding requests and planning for the base camp and to seek commitments from the United States Congress for the estimated cost of 

the program as a whole based on the "Case 5" projections. But at 

the same time all of the radiological investigations recommended. 

here should be undertaken and high confidence results obtained RS 

soon as possible so that they can be used to revise and improve 

the radiological cleanup phase before moving forward with it. 

It bears repeating here that we are mindful of the immense 

amount of time, effort and money which has been devoted to development of this program to date by many officialE in the Defense 

Nuclear Agency, the Atomic Ellergy Commission, the Department of 

-22-
the Interior and its Trust Territory a,dministration, to mention 

only the principal agencies. We are deeply grateful the professional and humanitarian commitment of all of these people and 

special appreciation is due Lt. Gen. Warren 'D. Johnson, nirec~or, 

Defense Nuclear Agency for all that he has done and will continue 

to do. 

Respectfully submitted by 

Theodore R. Mitchell, Counsel 

for the People of Enewetak 

Micronesian Legal Services Corp. 

P. O. Box 826 

Saipan, Mariana Islands 96950 

-23-

CALIFORNIA INSTITUTE OF TECHNOLOGY 

""!lADENA. CALlprORNIA 8f108 

DIVISION Or" THE HUMANITII':S 

AND !IOCIAL SCIENC•• October 29. 1974 

Mr. Theodore R. Mitchell 

Executive Director 

Micronesian Legal Services Corporation 

P. O. Box 826 

Saipan. Mariana Islands 96950 

Dear Ted, 

I have now read through the three volumes of the Draft Envircmnental 

Im.pact Statement dealing with the Clean Up. Rehabilitation, 

Resettlement of Enewetak Atoll-Marshall Islands. One thing that you 

have gOIng for you is that the peopleof Enewetak wish to return home. 

and have been pressing for this return for years. Many of the stresses 

associated with the type of compulsory relocation that I have studied 

including the under:mining of local leadership. are simply not present 

although I would suspect a carry-over from the past. 

Another favorable factor has been the willingness of everyone involved 

to date (a) to listen to the local people (at least through their council 

of 12) and (b) to take into consideration their wishes in planning their 

return. On the other hand. any kind of settlement scheme involves 

stress to the settlers and as you note in your letter of October II, 

little attention has been paid to the potential impacts of this stress• 

• Because my predictive theory deals primarily wIth compulsory 

relocation at the time of forced removal, rather than 28 years latp.r!, 

I will have to cast the net wider (which of course is a much more risky 

business) and deal with settlement schemes in general, compulsory 

resettlement being an extreme example of this mC're general category. 

A s I am sure you are well aware. the history of settlement schemes 

throughout the world is a grim one -- with pl'obably over 90% being 

unsuccessful from the point of view of both settlers and settlement 

authorities. It is hard to imagine a more difficult task that crea""'~~':"":''''''''' 

from scratch new communities, which are bcth socially and ~ 

economically viable. Though the situation is more favorabl . >\" 

people are willing participants, in the Encwetak case no se t;,)\~:l~~i't\ ." 7\--: 

selection is possible since everyone who wishes to rf;t1;rn oung:::> ~\J\\ ~': 

and old, conservative and progressive, hare! worring and 1~ , ~lf€>l't ...~~\ 

Aff€kl> I \l :r ~ \t~v- - ....._. 

V 
Mr. The.odore R. Mitchell October 29, 1974 

be accormnodated. In cormnenting on the Impact Statement I wish to 

discuss in sequence (1) Housing (2) Social Services (3) the Economic 

System and (4) Social Factors associated with settlement. Let me 

emphasize right now that (1) and (2) are by far the easiest to handle 

-- and (1) and (2) represent the greatest strengths of the Impact 

Statement. But while it is relatively easy to provide improved housing 

and social services, it is much harder to create viable land and water 

use systems - - indeed it is here that most settlement schemes fall. 

And it is much harder to handle the social factors associated with 

settlement as well as the institutional factors dealing with the interrelationships between settler institutions and those of the agencies 

involved in their future - - all of which must be viewed as part of a 

sinJe (and very complex) social system. 

(1) Housing. Though Holmes and Narver should be complimented on 

the .!xtent to which they have taken into consideration the stated desires 

of the Enewetak people and their system of land tenure in proposing 

house types, as I understand the situation, the people have yet to live 

in houses of the type proposed. If so, we must distinguish between 

what they think they want and what subsequently they decide they want 

after living in the new houses for a complete year. I strongly urge 

that a small number of pilot houses be built for at least some of those 

involved in the initial cleanup operation, so that the people will have 

a chance to assess their strengths and weaknesses -- to work the bugs 

out of them, so to speak, before the main construction program tends 

to rigidify their family structure and social organization in concrete 

for years to come. One thing that planners and architects tend to 

forget when providing housing in permanent materials, is that cl.iecrete 

structures in non-permanent materials provide more flexibility. 

Before pouring concrete one should try to anticipate some of the 

implications which inevitably will arise (and which will have an impact 

on the peoples' hves) and make corrections where desirable. Problems 

of maintenance also need to be anticipated in advance and local people 

trained to maintain their own structures. 

A major problem associated with many settlement schemes relates to 

provision and maintenance of adequate water supplies. Though the 

plans incorporated in the reports look good to me, I just want to 

mention this general difficulty for the record, and to emphasize the 

need to provide the simpliest facilities possible in terms of (1) peoples" 

needs and (2) their hopes -- with the second factor being far less 

important than the first. I have seen too many p!'ojects where people, 

after several years, must fall back on inadequate local water supplies 

simply because government-provided facilities are inadequate to start 
,4 

Mr. Theodore R. Mitchell 3 October 29, 1974 

with, or because costs for their maintenance are not provided, or 

because local people are not trained to properly use and maintain 

them. While I was very favorably impre'ssed by the thinking on water 

supplies within the reports, I wonder if enough thought has gone into 

probleI:?s concerning their long term maintenance. 

(2) Social Services. While impressed. again by the thoroughness with 

which the desires of the local people p.ave been taken into consideration, 

it is hard to comment on social services without knowing more about 

the breakdown of the population itself. None of the reports tell us 

tnuch about the current educational and literacy status of the people, 

and about their goals for self and children -- other than to return to 

Enewetak. Though obviously their expectations for .itnported items 

has gone up during their 28 years of exile, what about their 

occupational desires, and especially the occupational desires of the 

younger people? One thing that bothered me about the reports is that 

~rhile four room schools are proposed for both the driEnewetak and 

driEnjebi, nothing is written about the type of education system 

propose~ for these schools and the type of teachers to be recl'uited. 

Let me generalize this comment to all types of service personnel, 

since I was also concerned about the lack of attention paid, Wltler 

agriculture and fishing, to extension personnel, let alone to the 

relationship of the different types of service personnel to each other. 

I am raising here the fundamental question as to what different 

categories of people will be willing to do, occupationally, once they 

return and how best to facilitate their future economic and social 

independence and development. 

(3) Viable Land and Water Use Systems. The Master Plan was based 

on the assu:rnption that all the islands in the atoll could be used for 

subsistence and cash crop agriculture - - with a total available acreage 

of approximately 1000. As a result, however., of the AEC Task Force 

recomnlendations" this total has been cut to a maximum of 722 us-.ble 

acres for a current population of over 400 people. Bearing in mind 

the poor quality of the soil and the rapid rate of population increase, 

it seems to me absolutely essential that the people retain access to 

Ujelang Atoll. Even then the available land area on a per capita basis 

is considerably less than that utilized by the people prior to their 

first relocation. The situation is worrisome and points up the need 

(a) to obtain thp. best possible seed for coconuts for both subsistence 

and cash crops purposes, with the search bearing in mind the major 

advancee in productivity that have occurred on research stations in 

the Ivory Coast and in the Phi1lipines. (b) to push mariculture hard 

while keeping the means of production strictly in local hands so as to 

spread elnployment. Equipment (outboards for example) should be 
Mr. Theodore R. !vfitchell 4 October 29, 1974 

standarized and kept as simple as possible (seagull type engines va 

Johnstones). A number of interesting case histories come to mind 

here including the lobster cannery which"is the principle employer 

among the several hundred islanders on Tristan da Cunha in midAtlantic who were moved irom their home after a volvanic eruption in 

1961 and returned there later in the 1960s. (c) provide a first rate 

unified extension st::rvice (d) ensure a dependable and sufficient 

water transport service and pier and .port facilities to connect Enewetak 

to neighboring islands (including Ujeland and the relevant market 

centers). (e) actively attempt to diversify the economy, always 

bearing in mind local desires, interests, ne'eds and expectations. 

Especially attractive is the suggestion that the function of the Eniwetok 

Marine Biological Laboratory (which apparently wil.1 continue under 

AEC sponsorship) be expanded to include technical assistance to the 

people. Couple tr,ls •.....ith the possibility of a Community College for 

the Marshalls which would use the facilities already present on Enewetak, 

and one has one way of providing a unified extension service while 

possibly broadening the economic base of the people. Such possibilities 

however need be carefully evaluated concerning the extent to which the 

people will actually be involved and the extent to which they will actually 

profit. This caution applies eVE"n more to the development of a tourist 

industry which even at best is a mixed blessing on small islands. 

It seems to me that the future of the people of Enewetak depends on the 

extent to which the people regain their independence and the extent to 

which their atoll can become economically self-sufficient. It is my 

impression that the authors of the Defense Nuclear Agency report do not 

understand how much reco:rn:rnended Case 3 alters the assumptions on 

which the original Master Plan was based. This alteration also has 

major implications for social factors as I hope to show below. 

(4) Social ImplicatIons of Settlement. Depending on whether they are 

driEnjebi or driEnewetak, the present move honle will represent the 

fifth or sixth time that the people of Enewetak have been moved since 

1944. Since the original move was compulsory, and hence falls within 

the scope of my own research, I suspect that it was accompanied 'by 

a great deal of stress, which, for analytical purposes, can be divided 

into psychological,;physiological and socio-cultural stress. According 

to my own model of how people respond to compu'Sory relocation, 

this stress (or transition) period does not corne to an end until (a) the 

people once again get back on their feet economically or at least rech 

the position that they held before relocation.. and (b) feel at home in 

their new habitat. Since neither of these factors applies to the people 

of Enewetak after nearly 28 years, I would suspect that the older 

people (that is, those who were old enough to remember the trauma 
Mr. Tht.!odore R. Mitchell 5 October 29, 1974 

associated with the original :moves) are still under stress. What this 

:means, however, is hard to access at a distance since :my theory 

applies pri:marily to the :months And years im:mediately preceding and 

following forced re:moval. All I can say is tbat the :mental and physical 

health of the people should be carefully assessed before their shift 

ho:me and before they are involved in :major new ventures - - ventures 

which would require radical changes i~ their activities and life style. 

I say this since the theory predicts that populati.... a.s undergoing forced 

re:moval behave a& if a social syste:m-was a closed syste:m; that is 

they change no :more than they have to in order to continue doing what 

they did in the past and the changes which oc-cur are incre:mental rather 

than- sudden. The insistence of the people through out all these years 

that they be allowed to return "ho:mel! is consistent y.rith the theory 

here. But once the people get ho:me and the euphoria of having "won" 

fades, what then? What can be expected when they begin to settle 

down with three ti:mes the nu:mber of people on an idealized ho:meland 

which can be only partially utiliz'3d. With these questions in :mind, I 

would like now to consider three points. 

(1) It is- very i:mportant to recall that approxi:mately 80% of the popu- .. 

lation is under 30 years of age according to the population figures. 

In other words, the large :majority of the people will either have no 

:me:mory at all or only a vague :me:mory of life on Enewetak. It is this 

age bracket which strikes :me as a :major unknown. To what extent 

do the Council of 12 really speak for the:m? To what extent do they 

wish to return to the life style of their parents and grandparents? I 

can not answer this question at a distance, in large part because the 

Enewetak population within the three volu:me I:mpact State:ment is 

treated as if it was ho:mogeneous. But I doubt very :much that such 

is the case, a. doubt that is reinforced by the odd state:ment in the 

reports -- for exa:mple, "A nu:mber of people have been exposed to 

education a:Vay, fro:m Enewetak and have developed strong tastes for 

i:mported foods and other luxCC;ries" and the people have "achieved a 

good understanding of the behavior and values of A:mericans, and 

several have distinguished the:mselves in govern:ment and :mission 

schools. II In assessing the i:mpacts of. the return on the people I 

su~pect we need. at h~ast differentiate fro:m the very beginning between 

the older 20% and the re:mainder. 

(2) Co:mpulsory resettle:ment projects always run the risk of the 

relocatees developing a dependency relationship with the relocating 

authorities. I would suspect that a strong sense of dependency 

characterizes the older people fro:m Enewetak and that this will continue 

during the next decade. Even if the dependency does not already 

exist, :most of the people are going to be dependent on outsiders for 

years to co:me sirnply because it will take at least seven years to 
Mr. Theodore R. lvfitchell 6 October 29, 1974 

prepare lands for planting, to plant them and then to harvest the 

resulting tree crops. Should the cash cropping of coconuts proceed 

according to schedule only then will the people begin receivil"g what 

Holmes and Narver hope will be an annual cash income of perhaps 

$40,000 or slightly less than $100 per capita in terms of present 

population. In the meantime the people will have to use their trust 

fund (which currently produces $60,000 per annum in income or 

somewhat less than $150 per capita) to' provide for their external 

needs and to depend on the U. S. government and other donors. 

Reliance on both the trust fund and on further external assistance 

continues and increases the risk of a dependency relationship which 

can be expected to make subsequent development more difficult. 

Already the people have acquired a taste for outside staples which 

apparently on occasion can make up as much as 80%" of the diet. 

These include rice, flour, sugar, tea, canned meat, and fish; in other 

words the usual foods that low income people desire after they come 

into ::loser contact with the outside world. So we have the combirJ.ed 

problems of rising expectations and dependency, both of which have to 

be taken into consideration in planning subsequent development for the 

atoll. Neither makes the task easy. Once the euphoria of r~gaining 

the homeland passes, disallusionment may well come, along with new 

demands on the United States (which of course continues to bear the 

responsibility for the original move) to provide for the people. 

Looking to the future, very careful planning and plan execution wil1 

be required if the people are not to continue as wards of the government. 

(3) Another potential problem concerns future relationships between 

driEnjebi and driEnewetak simply because the former cannot occupy 

their former island or indeed their traditional section of the atoll. 

Rather they will find themselves relocated quite close to their neighbors. 

Although I note that distinctions between the two populations have been 

reduced to the .extent that the 12 man council is now elected at large 

from all the people, and that the largE. majority of the population have 

been brought up as members of a "single community, II nonetheless the 

present plan to relocate the driEnjebi on Medren and Japtan puts them 

in the relRtionships of 'relocatees ' to the driEnewetak "hosts" which

raises the possibility of the type of deteriorating relationships which 

all too frequently characterizes hosts and relocatees in other settlement 

schemes, especially where the two conununlties find themselves in 

competition for scarce resources, resources to which the hosts 

traditionally held claims. 

At this point there is little more that I can say without further knowledge. 

In conclusion, however, let me say that there are sufficient social and 

economic problems connected with the entire relocation effort to justify 
Mr. Theodore R. Mitchell 7 October Z9, 1974 

a well-thought out, longterm program for "monitoring" events from 

tl-.J.s day forward - - in hopes of anticipating problems before they 

a.rise and easing those that inevitably do'· arise. If r can be of further 

assistance alone such lines, please let me know. 

With best wishes. 

Yours sincerely, 

~~!2 Thayer Scudder 

Professor of Anthr.opology 

gsh 

enclosure 

P. S. I enclose an article which sUrnnlarizes the impacts of compulsory 

relocation of people moved in connection with big dam projects which ' 

may be of some use to you. No, I .l-...ave not seen Tobin's thesis nor do 

I have easy access to it. If you can get me a (':opy I would much 

appreciate it. 

Basic Considerations in the Assessment- of the Cancer Risks 

and Standards for Internal Alpha Emitters 

Edward A. Martell 

National Center for Atmospheric Resealch 

Box 3000 

Boulder, Colorado 80303 

January 10, 1975 

(Statement presented at the public hearings on plutonium standards 

sponsored by the United States Environmental Protection Agency, Denver, 

Colorado, January 10, -1975.) 
1. Introduction: The adequacy of the biomedical basis of standards 

for occupational and public exposure to plutonium and other internal 

(1' 5) alpha emitters have been widely discussed ~ and seriously questioned (6-8) • 

The serious uncertainties in the cancer risks attributable to 

internal alpha emitters must be resolved ~efore we are irretrievably 

committed to a nuclesr energy program. This is a matter of immediate 

concern in the western suburbs of Denver due to.plutonium and americium 

contamination of surface soils in public areas around the Rocky Flats 

Plutonium Plant(9). Many other localities are similarly affected by 

cranuranium element contamination and its attendant cancer risks. 

Recent controversy regarding the adequacy of plutonium standards 

has centered on several aspects of the problem of the cancer risks 

attributable to inhaled plutonium oxide particles, including such queations 

as which organ and how small a tissue volume constitutes the "critical" 

organ (i.e., that experiencing the highest cancer risk), and whether the 

average alpha radiation dose to the critical organ or the tumor risk 

attributed to a given number of individual hot plutonium oxide particles 

provides the best guidallce for the assessment of risks and standards 

for plutonium. Geesaman(6) has discussed possible mechanisms of cancer 

induction by hot particles and concludes that the tumorigenic risk may 

be as high as 1/2000 per particle for sllbmicron particles of plutonium 

oxide. A recent examination of hot particle risks by Tamplin and Cochran(8) , 

based largely on the Geesaman study, led these authors to recommend that 

the occupational MPLB (maximum permissible lung burden) be reduced by a 

factor of 115,000, to a value of 0.14 pCi. A recent study(lO) was 

carried out by Bair, Richmond and Wachholz at the request of the U.S. 

Atomic E~ergy Commission with the specific objective of providing an 

updated review of the evidence bearing on the problem of uniform vs 
-2-

nonuniform alpha radiation dose distributlou in the lung. The authors 

of this study take exception to the concluRions and recommendations of 

(6 8' Geesaman, Tamplin and Cochran " and conc~ude that 

"the nonuniform dose distribution of plutonium particles in 

the lung is not more hazardous and may be less hazardous than 

if the plutonium were uniformly distributed and that the mean 

dose lung model is 'a radiobiologicall~ sound basis for 

establishment of plutonium standards; t 

(10' Bair et al. ) fail to take into account the full implications of 

some of the recent published results: in particular, the observed higher 

238p (11) tumor risks for u0 than for 239pu0 ' , tha appare~tly limited 2 2 

biological response of mammal lung cells from 23 8pu and 239pu incorporated 

into ceramic microspheres(12,13) and the tobacco smoke radioactivity 

results (14) • The latter results imply that as little as a few picocuries 

of insoluble alpha emitting particles in the lung may give rise to a 

significant risk of lung cancer and other serious health effects in 

the chronic exposure case. 

On the basis of a brief review of the known effects of alpha interactions with cells (below) it will become evident that alpha radiation 

induced cancer in mammals and man must be brought about by subjecting 

a large number of living cells to a limited number of alpha interactions. 

Thus, in principle, the highest risk would be associated with a uniform 

distribution of the alpha dose, in accordance with the conclusion of 

Bair et ale However, in fact, we are almost always concerned with a highly 

irregular tissue dislribution of alpha emitting particles. For hot 

particles, the tumor incidence must be due to the low dose irradiation 

of a large number of cells by a very small fraction of the hot particle 

burden. And for lone term exposures, unecceptably high tumor risks 

app~ar to be associated with picocurie burdens of internal alpha emitters. 

This serious possibility calls for a drastic downward revision of permissible 
-3-

exposure standards for inhaled plutonium. It also i& possible that the 

critical health effects for inhaled alpha emitting particles are the 

incidence of atherosclerosis and other degenerative diseases of the 

cardiovascular system. The published evidence supporting these conclusions 

is briefly' reviewed below. 

2. Tumor Production: The interactions of various types of radiation 

with living cells and their mutagenic effects have been widely investigated, 

with results which have been reviewed and summarized by Lea{15}. Muller{16} 

and others. When alphas interact with the chromosome or its genes in 

the nucleus of a cell, the dense ionization in the track of the alpha particles give rise to closely spaced breaks which bring about a wide variety 

of irreversible chromosome structural changes, or mutations. X~ray and Y-ray 

1nteractio~ give rise to a diffuse distribution of ions, reSUlting in 

widely spaced individual breaks, most of which can undergo repai~ by 

recombining without structural change. Thus permanent structural changes 

for X-rays and Y-rays are proportional to the square of the dose, with 

greatly reduced incidence at low dose rates. By contrast, structural 

changes resulting from alpha interactions are directly proportional to 

the number of interactions and are independent of alpha interaction rates. 

Thus, with reg.,rd to the production of irreversible structural changes in 

cells the relative biological effectiveness of alpha radiation, compared 

to X-rays and Y-rays, increases markedly at lower dose rates and over 

longer periods of exposure. 

For alpha interactions with cell nuclei, most of the structural 

changes are lethal and lead to the mitotic death of the cell at the next 

{17 l8} (15) or subsequent cell division ' • However, as Lea and others have 

pointed out, some cell nuclei experience only minor structural changes 
-4-

(chromosome inversions, duplications, trans10cations. deletions, etc.) 

and remain viable. However, although only a very small fraction of alpha 

interactions give rise to viable mutated cells, these survive to 

proliferate, whereas cells which suffer lethal changes are eliminated 

from the cell population. Thus in the cas~ of long-term exposure of 

tissue to int~rna1 alpha emitters at low dose rates there is a cumulative 

increase in the population of cells which have survived one or more 

chromosome structural changes. However it is equally obvious that a 

cell whose nucleus is subjected to repeeted alpha inter~ctions within 

the mean life of the cell has only a negligible chance of survival. 

It is likely that the production of a radiation-induced tumor begins 

with the formation of ~ single malignant cell characterized by a combina~ 

tion of tw~or more chromosome changes andlor gene mutations. The alpha 

radiation-induced bone tumor incidence in dogs is observed to be p~oportiona1 to the square of the alpha dose(19) implying that a sequence of 

two or more low probability events mustbe involved. This is consistent 

(20 21) with the two-mutation and mu1tip1e-2utation theories of cancer ' based 

on the age distribution of cancer in man. On the basis of these considerations the production of a malignant cell involves a sequence of events, 

as follows: (1) 

~ 

~roduction of a viable mutated cell; (2) clone growth 

from the mutated cell; (3) production of a second viable mutation in 

one or more of the clone; . (4) growth of a clone of doubly-mutated cells; 

etc. Thus, for a two-mutation sequence, the tumor risk would be proportional 

to the R2t 2 (t/T ), where R is the alpha dose rate, t is the time of 

c 

exposure, and T is the mean life of the normal cell and singly mutated 

c 

cell. The term (tIT ) represents the influence of the growth of the clone 

c 

of the singly-mutated cellon the long-term risk. 

This tumor risk relationship makes it abundantly clear that a linear 
-5-

extrapolation to low dose rates is not only not conservative for alpha 

radiation induced tumors, but rather that there is a marked inverse dose~ 

rate vs risk relationship. There is an increasing bOGy of published 

experimental evidence that reflects this trend. 

Speiss and Mays(22) observed. that for .22_Ra alpha radiacion indu~ed bone 

sarcoma in man, the tumor incidence per rad approximately doubled for a fourfold increase in the spacing of 22~Ra injections and that the observed incidence 

of bone t~rs per rad in children was nearly twice that for adults. Upton 

et ale (23) show a significantly higher incidence of tumors in mice for a 

given neutron dose at more protracted periods of exposure. Moskalev gnd 

Buldakov(24) showed that fractionation of the administered 239pu dose over 

larger periods of time increased bone tumor induction. The higher tumor 

- rad f incidence per or the smaller lung burdens of crushed 2··Y~Pu02 microspheres observed by Sanders(ll) seems best explained by the limited al~ha 

irradiation of large numbers of cells by numerous very small, mobile 

particles of low activity per particle (see below). Hamsters subjected to 

low alpha doses from 210pO distributed quite homogeneously in the bronchiolaralveolar region show a marked increase in the lung tumor incidence yer rad 

at very low doses and dose rates (25) • And the incidence of bronchial cancer 

in uranium mine~s reflects a higher tumor risk per rad at the lower doses(26) 

for this low dose rate exposure group. The tobacco radioactivity results(14) 

indicate a ~ignificant tumor risk for the cumulative alpha radiation dose 

from 210po in insoluble particles in the bronchi of smokers, involving much 

lower dose rates. 

Based on the above considerations it is evident that the tumor risk is 

optimized when a very large number of cells and their descendants are 

subjected to only a few widely spaced alpha interactions with the small 
-6-

target afforded by the cell chromosomes. This follows necessarily from 

the fact that most alpha interactions with cell chromosomes lead to the 

~- h (17,18) subsequent m1toti c death 0 f t he ce11 • as Ba~endsen &_s s own • The 

production of a malignant cell calls for a sequence of two or more low 

probability events and thus cannot be speeqed up by the application of 

massive alpha doses, but rather only by subjecting Q much larger number 

of celIe to a limited number of interactions. Additionally, assuming that 

the tumor risk to the tissue suhjected to alpha irradiation is proportional 

2 2 to R t (tIT ), explained above, it is apparent that the-alpha activity c 

concentration or the activity per particle which is equated to a given 

tumor risk decreases with increasing time of exposure and also that a given 

risk can be attributed to smaller cumulative doses when the time of exposure 

t is appre~iably longer than the mean life of the cell, T. Brues(27) and 

c 

Burch~'28) . both pointed out that the two-mutation theories of carcinogenesis(20,2l) would imply an exceptionally high effectiveness of widely 

spaced radiation for tumor production. It is proposed that just such a 

dose rate relationship serves to reconcile the observed significant tumor 

risk in cigarette smokers with the presence of a persistent lung burden of 

insoluble smoke particles involving a total of only a few picocuries of 

2.l0 (14) po • 

3. "Hot" PuO Particle Risks: If the above tentative conclusions are --~--~2.~~~~~~~~ 

correct, then the same considerations must apply in the assessment of 

tumor risks for hot particl~s. In this connection a preliminary consideration of the influence of specific alpha activity and particle size of the 

hot alpha emitting particles is in order. 

(29) 238 Raabe et al. . report an apparent rate of dissolution of Pu02 

in l~mg fluid which is two orders of magn1.tude higher than that observed 

for 239puO particles. Such a draJr.atic di.ffet·ence in the chemical behavior 2 
-7-

of two isotopes of plutonium is seriously inconsistent with the negligible 

influence of isotope effects on the chemical kinetics of heavy elements. 

Thus it seems necessary to explain this apparent solubility difference on 

physical grounds. The sp~cif1c activity of the 2!8Pu0 particles (-80% 2 

238puO and -20% 239puO ) was about 220 ti.mes that of 239Puo2. In addition 2 2. 

the 238 puo2 particles exhibited a very significantly lower density than the 

239 puo2 particles(30), indicating a highly fault~d structure and weakened 

intermolecular bonding for the 23 8Pu02 particles. Fleischer(~l) proposes 

that the apparently higher dissolution rate for 238Pu02 may be explained 

by the alpl,a re~ull llu~l~us ablation of the surface layers of the particles, 

with a fragmentation rate proportional to the specific alpha disintegration 

rate and with variable ;1zes of f~agments ranging up to _104 atoms. The 

poorer structural integrity of the 238Pu02 particles may give rise to an 

increase in the size range of the ejected fragments. Such small fragments, 

ranging ~p to tens of angstroms in diameter or more, would pass readily 

through the 0.1 ~m diameter pores of the membrane filters used in the 

dissolution experiments (29) • Also, such small ablation fragments may exhibit 

a much higher mobility in tissue than tha.t of 0.1 to 1.0 ~U!. diameter, the 

size range o·f pArticles used in li1ust animal inhalation experiments. This 

greater mobility for very small ablation fragments in tissue may explain 

the observed more rapin rate of translv~ation for 238puO than for 23·puO 2 2 

from the lung to the liver and bone(32,33). 

Another explanation for the apparently higher solubility of 239 puO2 

than 238Pu02 is the possibility that the intense alpha radiolysis of the 

lung fluid at the surface of the particles leads to the prodUction of 

chemically active free radicals which in turn react with Pu0 molecules 2 

on the particle surface. This process also would proceed at a rate 

proportional to specific activity and to particle surface area. In this 
-8-

case the dissolved p14tonium would diffuse away from the hot particles. 

However this dissolved plutonium undoubtedly would be slowly redistributed 

in the lung in the same fashion as ~hat reported by Moskalev(34) for 

inhaled soluble compound~ of plutonium, resulting in a"highly non-uniform 

distributioa, with hot spots located predominantly in the sub-pleural region 

of the lungs. This gradual cOllversion ~f. the aoluble plutonium compounds 

to small colloidal size particles at focal points of activity may be the 

result of the self-chelating properties of tetravalent plutonium in solution. 

In recent studies of rat inhalation of 238pu02, Sanders(ll) has 

demonstrat~d a substantially increased risk per rad fer small lw,g burd~n6 

of aged, Hcrushed" 238pu02 microspher.es. In this case the inhaled particles 

involve smaller particles and a correspondingly larger surface area. The 

observed more rapid rate of translocation to other organs can be attr.ibuted 

variously to the higher mobility of the smaller particles, or to the higher 

rate of surface ablation (or dissolution) for the increased surface area, 

or both. The higher tumor incidence can be attributed to the fact that 

the greater mobility and wider redistribution of the 238pu02 microspheres 

and their breakdown products subject a much larger number of cells to a 

limitp.d number "of alpha interactions. 

The correctness of the above interpretation is reinforced by the 

results (If the Los Alamos ceramic sphere experiments reported by Richmond 

(12 13) (10) et al. t and further discussed by Bair et al. • In these experiments 2000 Zirconium oxide microspheres of 10 ~m diameter, each set containing a specified amount of plutonium, were injected into the lungs of 

groups of experimental animals. The total plutonium per microsphere 

ranged from 0.07 to 1.6 pCi of 239pu and from 4.3 to 59.4 pCi of 23Bpu , 

with identical activi:y for each of the 2000 microspheres in each of eight 

animal exposure groups of 70 animals per group. The local dose rate, 
-9-

averaged over the small tissue volume within 40 ~m from the surface of 

the ceramic microspheres is ~17,OOO rads per year for the 0.07 pCi microspheres, or ~200,COO alpha disintegrations per year within each microgram 

of irr.adiated tissue. ~e dose rate is correspondingly higher around the 

microspheres of greater activity. Less than one milligram of tissue, only 

one millionth of thE: lung, is subjected to these massive radiation doses. 

The limited biological response obtained in these experiments is 

consistent with expectations based on Barendsen 1 s results C17 ,lS}j the small 

population of cells within the alpha range around the microspheres experience so many alpha interactions that they all receive chromosome structural changes that result in their mitotic death. The 10 ~m diameter 

.. micro~phere~ are immobile in tissue. Also their specific alpha activity 

is so low compared to pure Pu0 that their surface recoil ablation and 2 

dissolution rates are negligibly low. Thus in these experiments there 

is no large population of cells which are subjected to a limited number 

of alpha interactions, as is the case for Sanders crushed 238pu0 micro­ 2 

sphere experlments Cll}. Richmond and voelz(12} observed only two lung 

tumors (at 9.S months and 12 months in animals exposed to 2000 ceramic 

microspheres of 0.42 pCi 239pu per microsphere) for a total of _106 hot 

particles. It is proposed that these two tumors may be attributed to 

secondary protons ejected by alpha inte~actions with hydrogen atoms. The 

4 expected yield is one proton per 10 alpha interactions. Such protons 

have energies of about 100 KeV and a range about 4 times that of the alpha 

particle. Thus theG~ secondary protons irradiate 63 times as many lung 

cells at correspondingly much lower doses. It is unlikely that the two 

tumors observed in these experiments can be attributed to X-rays or 

Y-raya flom plutonium for reasous discussed by Warren and Gates(33,36). 
-10-

4. Critical Health Effects: It is widely recognized that inhaled ineQluble 

alpha emitting particles deposited in the lung are, in part, translocated 

via the phagocytic action of macrophages to the lymph nodes and to other 

sites in ~~e reticuloendothelial system, and also via blood leucocytes to 

the liver, spleen and bone marrow. Recent experiments with inhaled 

plutonium make it ev~dent that the pattern and rate of translocation of 

plutonium from the lung to other sites is highly dependent on particle size 

and specific activity, with more rapid transport of the smaller and more 

active particles. Thus, it is far from obvious whether the lung, lymph 

nodes, liver, bone or other organ, or fraction thereof, should be taken 

as the critical organ or critical tissue site. 

It ha~ long been known that those tissues in which there is more 

active cell division suffer the earliest and most severe radiation damage 

effects, and that this includes the blood forming cells in lymphatic glands 

(16 3~' and in bone marrow ,. ~ Such effects include the destruction of rapidly 

multiplying cells that produce the blood platelets which assist in the 

control of blood clotting. Similarly the population of leucocytes is 

reduced with a corresponding reduction in resistance to disease. These 

effects plus t~e accompanying chromosome structural changes can give rise 

to the earlier incidence not ouly of cancers, but the whole pattern of 

diseases of the cardiovascular and ren~l systems(37,38). 

Let us review the mounting evidence which suggests that inhaled 

insoluble alpha emitting particles may be the agent of atherosclerosis 

and thus give rise to an increased risk of death by early coronaries and 

strokes. ~therosclerosis is reported to be present in every instance of 

partial or comp~ete arterial occlusion and every case of coronary thrombosis (39) • 
-11-

Recently Benditt has shown(40) that the human atherosclerotic plaque is 

a monoclonal proliferation of a mutated cell of the artery wall, and thus 

an arterial tumor. Elkeles(4l-43) has obs~rved anomalously high concentrations of alpha activity at the calci.fied plaque sites. In addition 

atherosclerosis plaques normally occur i~ the main and abdominal aortas­

(42-44) and the coronary arteries, but rarely in the pulmonary arteries • 

This distribution suggests a respiratory origin for the mutagenic agent. 

Attempts to reproduce arterial lesions in animals by chemical, mechanical 

and nutritional means have not produced plaques similar- to those of 

atheroscler.osis in man (40) • However atherosclerotic plaques have been 

directly induced in human arteries by intensive irradiation with X-rays 

and radium(45). There ~s a high incidence of early coronaries among 

cigarette smokers, with a mortality rate for males who smoke two packs or 

more daily that is 2 to 2.5 times that of non-smokers but at a mean age 

. (46' of death some 10 to 16 years earlier. ~orall these reasons it is proposed 

that inhaled insoluble alpha emitting smoke particles are very likely to be 

the mutagenic agent which gives rise to atherosclerosis in cigarette smokers. 

If this i6 the case, similar increased risk of early coronaries are to be 

expected for other groups of individuals who are occupationally or environ­

•

mentally exposed to the inhalation of insoluble alpha emitting particles 

of respi~able size. Attention should be addressed to industrial and combustion 

product aerosols which contain uranium oxide, thorium oxide and lead-210, 

as well as to plutonium oxide from nuclear industry, nuclear accidents 

and fallout from atmospheric nuclear Lests. 

The first and most obvious pl&c~ to look for such effects is among 

past and present plutonium workers. Very significant increases in the 

incidence of early coronaries as wall as lung cancers and cancers at other 

sites is observed among cigarette smokers(46) with insoluble alpha emitting 
-12-

particle burdens of only a few picocuries of ?lOpo in the lung(14) and 

similar total alpha activity per 100 grams of arterial wall tissue(4l-43). 

By comparison, plutonium workers exhibit plutonium organ burdens ranging 

from a few picocuries to a few manocuries or more(47,48). And although 

there has been no ~pidemiological study of the age-incidence of heart 

disease and cancer among plutonium workers, the limited published information 

bearing on this question is more disturbing than reassuring. Most oft~n 

(49,50) ci ~e d i s t he medica1 experi ence 0 f 26 p1utoni um workers at Los Alamos , 

usually accompanied by a statement to the effect that none of the medical 

findings fur this gruup can b~ attrlbuled definitely to in~ernally deposited 

plutoni.lm. With equal justification one may state that most of the serious 

medical findings in thi~ group can be attributed to plutonium. ~e member of 

the original group died in the early 1950's. Cause of death is not reported. 

Another died of a coronary at age 38. A third suffered a coronary occlusion 

but recovered and was well compensated. A fourth developed a hamartoma of 

the lung and his right lower lobe was surgically removed in May 1971. A 

fifth had a melanoma of the chest wall. A sixth had a partial gastrectomy 

for a bleeding ulcer. One subject suffer~d loss of teeth, apparently due 

to damage to the lamina dura of the jaws which show the earliest effects 

\ 

in beagles given toxic doses of plutonium. Another subject has gout. The 

full medical history of this group, now mostly in their fifties, haa not yet 

completely unfolded. Only 12 of these 26 plutonium workers were exposed 

to plutonium inhalation. Which of the observed effects were experienced 

by the inhalation exposure group? Regardless of the distribution, the 

medical experience of this small group thus far provides no basis for 

complacency about the health consequences of plutonium exposure. 

Hanford employees and others whose autopsy tissue samples exhibited 

plutonium levels in excess of 5 fCilg died mainly of coronary heart 
-13-

disease an~ other cardiovascular effects and to a lesser extent of cancer 

and pulmonary emphysema (47) • Based on evidence reviewed above it appears 

that atherosclerosis is a cancer of the artery wall and thus that coronary 

heart disease and other diseases of the cardiovascular and renal systp.m 

are expecteo effects of inhaled plutonium. and of other insoluble alpba 

emitting particles. An adequate assessment of the magnitude of these risks 

can only be obtained by a comprehensive medical. follow-up of all past and 

present plutonium workers. Until the age distribution of these effects 

among plutonium vorkers is fully assessed, any claim by the proponents 

of nuclear energy that there is little risk associated with the MPLB 

(maximum permissible lung burden), 16 nCi of plutonium, or fractions 

thereo~is"totally unjustified. The growing evidence suggests that as 

little as a few picocuries of alpha activity in the lung, in ar~erial tissue, 

and in other organs gives rise to a significant cancer risk. 

5. Discussion: The published evidence, reviewed above, clearly indicates 

that a linear extrapolation to lower doses and dose rates is not conservative for internal alpha emitters. The initial effe~ts of alpha interactions with cell chromosomes are irrev~rsible and thus will vary lineerly 

with alpha dose !ate. However the cumulative effecLs of internal alpha 

emitters gives rise to an increase in the populations of mutated cells 

(cells with viable structural changes in their chromosomes) and in the 

health consequences of such changes. Therefore the tumor incidence per 

alpha disintegration must increase with decreasing dose rate. For this 

reason a given cancer risk is equated with smaller cumulative alpha 

doses and with much smaller internal alpha emitter burdens as the period 

of exposure increases. 
-14-

By contrast, the cellular effects of ~-rays and y-rays are largely 

repairable at low dose rates. This stems from the fact that the diffuse 

distribution of ion pai~s produced by such radiation results in widel~" 

spaced single chromosome breaks which repair themselves readily. For 

these reasons the relative biological effectiveness of alpha particles, 

compared to X-rays and y-rays increases continuously with decreasing dose 

rate. Thus alpha radiation acquires a greatly increased biological si&-

nificance relative to soft radiation in the production of tnmnr~ and other 

health consequences of chromosomal structural changes. 

There are several.other lines of evidence which reinforce the 

possibility that alpha interactions with cells play a unique role in human 

cancer production. The distribution of cancer sites in the bronchi, in 

the lymphatic system, in arterial tissue, in the liver and bone, all 

involve sites at which insoluble alpha emitters are known to accumulate. 

Anomalously high concentrations of alpha activity have been observed at 

the bronchial cancer sites(5l), at cancer sites adjoining lymph glcs.na::; 

(52 53) (41-43) in other organs ' in atherosclerosis plaques , at liver cancer 

. ~, (54)

sites in thorotuast patients , at bone tumor sites in the radium dial 

workers (55) , etc. The difficulties of producing lung cancer by exter~al 

radiation h~s been pointed out by Warren and Gates(35,36). The absen~e 

of cancers in muscular tissue, except at sites of thorotrast injection or 

plutonium injection, also is relevant to this issue. All of the~e observations reinforce the possibility that one or more of the chromosomal 

structural changes which characterize a malignant cell must be brought 

about by alpha interactions and not by low intensity X-rays or y-r.ays. 

In this conuecti.ofl, the determination of the nature of the structural 
-15-

differences between the healthy and t~e walignant cells of each organ could 

shed some light on this important question. 

It alRo is observed that the relative .significance of chemical agents, 

viruses and radiation in the incidence of humaa cancer is not known. 

Details ot the mechanisms of cancer induction by chemical agents and viruses 

also are poorly understood. And the proposed chem: al carcinogens in 

cigarette smoke and in polluted urban environments have not been demonstrated 

to be carcinogenic at the low concentrations involved. For all of these 

reasons it is deemed likely that radiation, and alpha ~adiation in particular, 

msy be the principcd agent of human cancer. In view of such a possibility, 

it is very disturbing to note that the U.S. National Cancer Institute, now 

spending about one-half billion dollars per year on cancer research, has 

completely'neglected the field of radiation induced cancer research. 

. (39-45) Published evidence indicates that atherosclerosis is a tumor 

of the artery wall and that the alpha activity at the calcified plaque 

site is likely to be the mutagenic agent. If so the major causes of death 

in the general population - coronary disease, other cancers, and strokes -

may in large part be attributable to internal alpha emitters from natural 

and pollutant sources. If so, fallout plutonium and alpha emitting 

contamix-ants mus't already be contributing to increased health risks and life 

shortening to the general public. Cigarette smoking causes increased risks 

of early coronaries, lung cancer, cancers at other sites, and other health 

effects(46) , with aLout 15 years reduction in l~fe expectancy for those who 

regularly smoke 2 packs of cigarettes per day or more (attributable to 

lung burdens of only about five picocuries of 210 po in excess of that of 

nonsmokers). Fallout levels from past atmospheric nuclear tests have given 

rise to plutoni~~ organ burdens of -0.5 pCi/kg of lung tissue and -0.7 pei/kg 

of live~ tissue in the general public(56). Although these levels are only 
-16-

about 10 percent of the 210 pO organ burdens of heavy smokers, the effp.cts 

may be correspondingly greater because the total population is exposed. and 

the inhalation exposures begin at birth. 

If the health risks attributable to fallout plutonium exceed 10 percent 

of the risks of heavy smoking, then inhal~tion exposure at ~20 times 

fallout (the surface soil concentration of plutonium Wllich corresponds 

to the interim soil standard adopted by the ColQrado Board of Health in 

1973) would give rise to organ burdens more than twice that of heavy smokers. 

Exposing children to such levels would be tantamount to their smoking four 

packs of cigarettes per day, beginning at birth. This estimate assumes, as 

I believe to be the case, that the inhaled, insoluble radioactive smoke 

particles give rise to the serious health effects of smoking. 

For the estimation of organ burdens which may result from the inhalation 

of soil contaminants, it is common practice to attempt to determine the 

average surface soil concentrations, the applicable resuspension factors, 

inhalation exposure patterns, particle size distributions, lung retention, 

clearance and translocation patterns and rates, etc. The large cumulative 

errors and uncertainties in the prediction of the ultimate organ burdens 

from long-term exposure to contaminated surface soils and urban dusts by 

such a long sequence of complex processes serve to make this procedure an 

almost useless exerciEe. There is a more direct approach which sould give 

more reliable estimates. Lewis et al(S7) show ~hat the adult lung burden of 

nitric acid-insol~ble particles increases almost linearly with age, with 

about 1.5 grams per kilogram of lung tissue at ag~ 60. It seems reasonable 

to assume that individuals chronically exposed to soil dust and urban rlusts 

will acquire just such burdens of the insolubJe constituents in the respirable 

size fraction of dust particles (i.e., particles less than ~5 ~m diameter). 

It should be noted that Pu0 particles are highly insoluble and friable. 2 
-17-

Experi~ents in the Rocky Flats area also have shown that about one-third 

of the airborne plutonium which has been resuspended from soil surfaces 

by ~~nd action falls within the respirable particle size range. However 

only a yery small -fraction of the bulk surface soil is made up of insoluble 

particles of respirable size. For this reason, surface soils with one 

picocurle of plutonium per gram (the Colorado interim soil standard) 

should contain an estimated 10 to 100 pCi of pl~tonium per gram of insoluble 

Boll particles of respirable size. Such a soil level should lead to 

plutonium lung burdens of 5 to 50 picocuries by age 20; or 15 to 150 picocurlee by age with correl:lpundingly higher concencracions in the lymph 

nodes, liver, and bone. Thus the Colorado interim soil standard is hardly 

a safe or acceptable standard unless it can be shown that such levels of 

plutonium have no serious long term health effects. 

There are. of course, a number of considerations which make it insppropriate to equate the effects of a given burden of low specific activity 

alpha emitting {",igarette smoke particles with the same amount of alpha 

(12 13) activity in hot particles. The Los Alamos experiments • make it 

evident that most of the alpha dose from "hot" particles of Pu0 is 2 

wasted in the excessive irradiation of cells within the alpha L~,ge of 

the hot particle surface. Thus the high tumor risk for the hot 238pu02 

particles(11) call be variously cttributed to (a) thE:' mobility of the 

smaller particles (b) the recoil ablation and/or dissolution rateR which 

increase with specific activity and with surfacE:' area of hot particles 

and (c) the irradiation of larger numbers of cells with scattered protons 

(an effect that may be significant for very hot particles). 
...;18-

For these reasons, the insoluble alpha emitting smoke particle, 

uranium oxide, thorium oxide and other alpha emitting particles of 

moderate to low specific activity may be expected to give rise to a higher 

tumor risk per alpha disintegration or for a given cumulative dose. 

Similarly plutonium-239 in mixed fallout particles may be expected to 

produce more tumors per disintegration than is th~ case for pure 138pu02 

and 239puo2 • However although larger burdens o~ hot particles will be 

required for a given tumor risk, such risks can be expected to increase with 

both alpha specific activity and with particle surface area, and the effect~ 

should occur earlier for a given burden of smaller particles of higher 

specific activity. 

The above considerations make it obvious that the present practice of 

averaging the alpha dose over the whole lung or some arbitrary fraction 

(10-13) thereof is & highly questionable and grossly misleading procedure 

at best. 

It also should be noted that americium-24l is present in association 

with plutonium contamination in the Ro~ky Flats area and in nuclear test 

areas. III addition, clOrium isotopes as well as am.t;!!'icium"-24l will be 

present in hig~ concentration in Lhe nuclear foel mixture from fission and 

breeder reactors which use plutonium fuel. The chemical behavior of 

americium and curium in the environment will give rise to their substantial 

uptake in the biosphere and the foon chain. ThuG the ingestion of americium 

and curium, their uptake from the ga~t~ointestiual tract, and their 

accumulation in the liver and skeletal tissue of mammals and man will give 

rise to additional serious health rl~ks. These con~aminants will be relatively 

more serious than plutonium inhalat:f.or:. in some environments, particularly 

in vegetated areas of moderate to hig~ rainfall, where soil resuspension 

processes are not effective. 
-19-

6. Reco~endations: It is urged that the U.S. Environmental Protection 

Agency consider and act upon each of the following recommendations which 

are c&lled for (a) in order to provide an i~proved basis for the assessment 

of health risks and standards for plutonium and other actinides and (b) 

to provide a higher degree of protection from the effects of internal alpha 

emitters ft:'r occupational groups and the. general public by adopting more 

conservative interim standards for plutonium exposure. 

(1) Initiate a comprehensive interagency research program to assess 

the health risks of inhaled alpha emitting particles, with special attention 

tn both "hot" particles and insoluble pa=ticlee ef lew act:i'v~it:y per particle 

(Some rertinent studies have been proposed to the EPA(S8).) 

(2) Conduct a comprehensive epidemiological health study of all past 

and present plutonium workers, and of all other groups which have been 

exposed to the inhalation of plutonium at levels &ignificantly above fallout 

plutonium. 

(3) Call upon the National Cancer Institute and the National Heart 

and Lung Institute to apply an appropriate fraction of their resources to 

assess the role of inhaled alpha emitting particles on the incidence of 

human cancer and heart disease. 

(4) Adopt more conservative occupational standards for plutonium. 

A reduction of present air concentration and lung burden standards by a 

factor between 100 and 1000 appears to be in order. Better protection 

should be provided for younger employees and groups exposed to possible 

inhalation of finely divided and higher specific activity plutonium. 

(S) Maiiltain public exposure levels of plutonium. and other alpha 

emitters to the practical minimum. In my view this would limit public 

exposure to airborne dusts not exceeding O.S picocur±es of alpha activity 

(Mbout one alpha disintegration per minute) per gram of nitric acid insoluble 
-20-

particulates of respirable size. This level would result iu the accUMulation of adult organ burdens about equal to that from fallout p1utonitrm(56) • 

On this basis the Colorado interim standard'may be at least 10 times too 

high. 

(6) Call for a full disclosure of al~ past plutonium spills and accidental 

releases and conduct appropriate surveys- and c1cs~up operations. 

(7) Develop standards for americium and curium. with particular attention 

to their distribution in the food chain and their uptake from the gastrointestinal tract. 

(8) Give 1mmed1ate attention to current plans of the U.S. Department 

of Defense and the U.S. Atomic Energy Commission to resettle Euewetak 

Atoll. The high levels of plutonium and americium on these islands and 

in the lagoon sediments are likely to give rise to tragic health effects 

on this small native population group. 

-21-

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-22-

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-23-

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41. Elkeles, A., "Radioactivity in calcified atherosclerosis," British 

Journal of Radiology 34, 602-605, 1961. 

42. Elkeles, A., IIAtherosclerosis and Radioactivity," Journal of the 

American Geriatrics Society 14(9), 895-901, 1966. 

43. Elkeles, A., "Alpha-ray activity in coronary artery disease," 

J. Amer. Geriatrics Soc. 16(5), 576-583, 1968. 
-24-

44. Mitchell and Schwartz, Arterial Disease, Blackwell Sci. Publ., 

Oxford,!965. 

45. Sheehan, J. F., "Foam cell plaques in the intima of irradiated small 

arteries," Arch. Path. 379 (5),297-308,.1944. 

46. The Health Consequences of Smoking, January 1973, seventh of a E~ries 

of r~ports of the Public Health Service, U.S. Department of Health, 

Education and Welfare, (U.S. Government Printing Office, WashingtJn, 

D.C. 20402, $1.85). 

47. Nelson, I. C., Heid, K. R., Fuqua, P. A., and Mahony, T. D., "Plutonium 

in Autopsy Tissue Samples," Health Physics 22:925, 1972. 

48. Lagerquist, C. R., S. E. Hammond, D. L. Bokowski and D. B. Hylton, 

"Distribution of plutonium and americium in occupationally exposed 

humans as found from autopsy samples," Health Physics 25,581-584, 1973. 

49. Hempelmann~ L. H.: Richmond: C. R., .Rnn Voplz. (:0 Lo» irA ~lenty-Se'...en 

Year Study of Selected Los Alamos Plutonium Wt)rkp.rs," Los Alamos 

S~ientific Laboratory report LA-5l48-MS, 1973. 

50. Hempelmann, L. H., Langham, W. H~ Richmond; C. R., and Voelz, G. L., 

"Manhattan Project Plutonium Workers: A Twenty-Seven Year Follow-up 

Study of Selected Cases," Health Physics 25:461, 1973. 

51. Little, J. B., E. P. Radford, H. L. McCombs and V. R. Hunt, "Distribution of polonium in pulmonary tissues of ciga~atte smokers," New 

Eng!. J. Hed. 273, 1343-1351, 1965. 

52. Watson, S., "Only vertebrates with a lymphatic system are subject to 

malignant disease (Ullman)," Medical Journal of Australia 2.~ 993-994, 

1965. 

53. R. Oliver and S. Watson, "The lymphatic system--a storehouse of longstay deposits of inhaled radioactive particles," Health Physics 12, 

720, 1,966. 

54. Proceedings, Conference on Distribution, Retention and Late Effects 

of Tnorium Oxide, Ann. N. Y. Acad. Sci. 145, 523-858, 1967. 

55. Gofman., J. W. and A. R. Tamplin, "The question of safe radiation 

threshold£ for alpha emitting bone seekers in man,lt Health Physics 

21, 47-51, 1971. 

56. Moss, W. D. and E. E. Campbell, "Plutonium concentrations in tissues 

of a general population," Health Physics 22, 933, 1972; Los Alamos 

Sci. Lab. report, LA-4875, 1972. 

57. Lewis, G. P. and L. Coughlin, "Lung 'soot' accumulation in man," 

Atmospheric Enviornment I, 1249-1155, 1973. 
-25-

58. M'1rt~11, E. A., "Evaluation of the cancer risks from insoluble particles 

of low apecific alpha activity in man," proposal submitted to U. s. 

Environmental Protection Agency, October 1974. 

APPENDIX III 

COMr1ENTS ON THE 

DRAFT ENVI RONNENTJ'l.L HtlPACT STATEf1ENT 

LIQUID HETAL FAST BREEDER REACTOR PROGRAr·, (~lASH-1535 ) 

Donald P. Geesaman 

School of Public Affairs 

Univ!'rsi ty of r·:i nn::sota 

r·li liii0ClPO 1is, Hi nnesota 5545::; 

Dated: April 24. 1974 

PREFACE 

Four cowments are attached. 

Comment #1, ACCIDENTS 

l/comment #2,

, 

ESTINATION OF THE HEALTH EFFECTS OF 

PLUTONIUN AND OTHER ALPHA-ENITTING 

TRANSURANICS 

Comment #3, DIVERSION MID SAFEGUARDS OF 

FISSIONABLE NATERIALS 

COmr.ient #4, GENERAL AND IN SUNNARY 

Witn the possible exception of #2, these comments are genEric 

in nature. For a draft statement of this physical extent, detailed 

- . 

comment \'(ould be nearly prohi bi ted by personal 1imi tati ons of time 

and resources. This dilemma is not encountered here since generic 

comment seems indicated. Treatment of acne cen be sensibly defer:'cd 

\A/hen the patient shows systemic failure. 
;. 

COir'u"ent #2, ESTHU\TIm: OF THE HEALTH EFFECTS OF PLUTONIUj·1 MID OTIIER 

ALPHA-HIITTI t:G TRN1SURMi ICS 

The estimate of lung Cdncer incide~ce associated with the inhalation 

of plutonium (or oth2r transuranics) in particulate form is a critical 

factor, along \'/ith source terms and resuspension, in defining the proba~le 

impact of the l~lFBR's plutonium based fuel':"cycle. -. ,is subject is discussed , 

in Sectien 4.G.5 IIParticle lung Dose Effects l1 of L~ASH-1535. I quote the 

first sentence from that section: 

"The estimates of lung cancer incidence associated with 

the inhalation of transuranics used in this report are 

based upon a cilculation of the averaQe radiation dose 

delivered to the lung and application- of tumor incidence 

estimates for the uniformly irradiated lung as estimated 

in the BEIR report."l . 

This cited basis, and hence the derived estimates, are indefensible. 

Section 4.G.5 acknowledges "that 'insoluble ' particles of 

ra9ioisotopes, when deposited in tissue, provide focal spots of high 

radiation dose rates tlose th2 the particle," so there is no presumption 

that the exposure by particulates of plutonium is uniform. The deep 

respiratory tissue of the lung is made up of 108 alveoli. Each aveolus 

is a complex1y organized unit of tissue. If an insoluble alpha-emitting 

particulate is- dept1sitcd in this tissue some 10 to 100 alveoli \'lill be 

exposed. A crude ,nea;:,ure of the nonr.miforr:.ity of this exposure is that 

at most about one-millionth of the lung's alveoli are affected by a single 

particulate. 

The si9nific;;n~ce of the preceding is that in the actual lung 

eX[10SU1~e by an alpha-c::1itting particulate. the energy of the ionizing 

rctdL.=tt-ioll is d2posi'i:C:l: in a very lir.lited 'JolUiile of tiSSl!2, and hence that 

th2 {·':tll~l l'ddiation 0030 to lUli£1 tissue scal:::d roughly a million tii:1:::S 

-6-
-7-

larger than the dose associated with an averaging of the equivalent 

radiation energy over the entire lung. 

A multiplicative difference of a million in a significant 

physical quantity generally suggests a qUllitative difference. Suppose, . , 

for example, that the problem \"/ere to estimate the effects of small 

projectiles on human organisms. Suppose that the projectiles \-/eigh 1/2 

ounce and have a velocity of 1000 ft/sec. Note that the effect of the 

projectile depends on the energy, and note that a 6 ton vehicle moving at 

1 mile per hour has similp,r energy. There is experience '-Jith humans stopping 

slo\'l mov; ng vehi cl es by e:~erti ng strenuous counterforces. Usi ng thi s 

experience the effect of the projectil~s on humans is inferred to be 

oxidation of-the biological fuel necessary to do the \'Jork of stopping the 

vehicle. But this reasoning is manifest nonsense. Even though the energies 

inv,olved are similar, a fast moving dfle bullet is quite different from 

a truck weighing a miilion times more and moving at a one-thousandth the 

velocity. The former dissipates it~ energy in the local disruption of 

tissue, the latter leads to the orderen and non injurious oxidation of 

biological fuel. The end results become very different as the physical 

characteristics' " of the situation change, and a new biological phenomenon 

intercedes, Obviously the \-/ay to estimate the effects of rifle bt.illets is 

either from past experience that is explicitly applicable, or alternatL'ely, 

to calculate the effects considering the physical characteristics of the 

rifle bullet and knm-/ledge of the biolc~ical and physical charactedsUcs 

of the human organism. 

This nonsense :.:xalliple has iiluch the same l09ical structure as the 

method of est'in:Gting hat p::!l~ticles E:ffec:ts set forth in Sect-jon t,..G.5 of 
-8-

l·:AS!I-1535. There, by introducing a fictitiously large m~$S of exposE:d 

tissue, the calculated dose becomes cexmensurately small. In passing from 

the real situation in which a hot particle i~radiates 10 to 100 alveoli, 

to the fictional situation in which the ionizing radiation from the hot 

particle is averaged over 108 aiveoli, the dose scale has decreased by 

roughly a factor of a million. 

Living tissue shows extensive intra-cellular and inter-cellular 

organization. Several regimes of biological response would be expected 

as physical characteristics of exposure are varied. Carcinogenic response 

to 1!!hole organ exposurE by non Ctcute doses of radiation Hill fall in one 

of these regimes, and this will be a regime in which there is human 

experience. From the physical characteristics of plutonium aerosols) from 

the lung deposition experience with aerosols, and from the lung clearance 

experience \·rith plutonium particulates, it can be inferred that at least 

one class of particle,s exist \'/!1ich subject lung tissue to an exposure 

associated with a different carcinogenic response regime. This is because 

other biological pheno~enon has intervened. 

For hot particle exposure that phenomenon lS mitotic death of 

cells, i.e., loss of the cellis ability to divide. There is an extensive 

literature on the subject. Radiologically induced mitotic death is, in 

fact, the basis for treating malignant tissue with ionizing radiation, and 

is the calise of most acute syn~ptoms consequent to radiation exposure. 

Even though the intercession of extensive mitotic death of cells must 

inevitably place certain particulate exposur2S in a different response 

regim~ fro:/I \·:ilole lung, non acute exposures, a compelling aj~gllment might 
-9-

less than the carcinogenic response in the latter. This argument would 

appear to have merit since mitotic death of cells, of well as reducing the 

general viability of the tissup., \'!Ould also 'reduce the number of irradiated 

cells with ~arcinogenic potential. Usually implicit in this argument is a 

conceptualization of all radiation carcinogenesis as' a single-cell, directinjury process. 

To confirm this argument, there is a ~espectable literature in 

which carcinogenesis is described as occurring Cofter doses of radiation . that are sufficiently local as to not be organism lethal, and that are . sufficiently high for the fraction of mitotically competent cells to be 

greatly reduced, i.e., to 1% or less. Unfortunately, in at least some of 

these experi~ents, carcinogenesis is inversely related to the fraction of 

mitotically competent cells, i.e., cancer induction in the regime \';here 

mitotic competence is greater than 1% is small compared \'/ith the cancer 

induction 'in the regi.me \·/here mitotic competence is much less than 11~. 

There are several points to be made here. Loss of mitotic 

competence and carcinogenesis are t\'/O indices of radiation effect in tissue. 

They cannot be im.lelJendent, and their relationship can tell us something 

about some ridi~tion carcinogenesis. . " 

Mitotic competence is not generally related in a linear \'lay to 

carcinogenic ~esponse. Moreover, it is a Inajar anomaly that an increased 

carcinogenic response is observed in dose regimes associated with greatly 

reduced mitotic competence. It is difficult to reconcile this result with' 

any s'iuglc-cell, direct-effect origin for radiation induced c(:ncer. 

Mitotic cc~r~tencc of a cell population decreases exponentially 

\':ith incrcu:iing a.1i'Jha-rudiatieJ/] dos!:: ~:nd is a fairly ~cnet'al ind~x of 

rlldiat'ion effect in tissue. If rl1c1iaUon cUl'ciIl0gelK~:;is lir:';vcrsiilly 
1 • 

-10.. 

.. 

decreased with mitotic competence, then estimates of carcinogenesis based 

on a fictitious averaging of a local inhomogeneous dose over a much larger 

volume would be necessarily conservative. S~ncc radiation carcinogensis 

can, and in, fact, does increase to ano~alously large values while the mitotic 

competence becomes vanishlingly small, the, fictitious averaging of dose , 

over larger volumes is not necessarily 'Conservative, instead it \'1ould 

appear that an intense local dose of ionizing radiation can be a more 

efficient carcinogerl than a diffuse tissue exposure \'lith the same type of 

ionizing radiation and the same total energy. The above then implies that 

averaging of dose over la~ger volumes may be far from conservative. 

It is obvious that as a local exposure becomes more intense, a 

stage must finally be reached \'/nere the carcinogenic efficiency of the 

exposure (on a per unit energy basis) is reduced. This is not pertinent 

tc? previ ous m'guffil?nts. It \'/ou1d, hm'/ever, be important to knm'l the 

charactet'istics of the most carcinogenicly efficient exposures, 

The folloY-/ing excerpt taken from the BEIR report (po 95) sU!l:mar'izes 

the state of knowledge concerning the causation of cancer (emphasis added): 

"Althouqh the mechanisD5 of carcinoqenesis~ or of 

radtc ti on carei nogenesi S lJlLar'ticultlr'} are not Ft'..!Jx 

kno\'ln, cvailable information implies that most, if not 

all, types of cancer develop as a result of the ccmbined 

effects of multiple factors. These causative factors 

may include: prezygotic (inherited) mutations of 

chromosomal bberrations, which can spread during development to many kinds of ce11s; somatic cell mutations or 

chromosomal aberrations~ \'Ihich can be acquirec at any time after conception; changes resulting from the action 

of viruses; and changes in sY$tcmic grovth factors (e.g., de:.H~cssDc.l i!,::.:une comp2tGnCe, hormnntt1 ~il~ba1ance) and 

in lecal tissue j'equlC!tion (diso'''~Janiz(1tion, da:,:~qc), sucTics--r.·1-(l y-re:'silfFrrcm 'cn s'e:a-s6s-(;ili'c;-- -th~,i caricer-or 

1-"0'" " ~I. (,i "'(·V····:",· I U)I,- .. 't C] 

... ~ C~J"", ',n'" (1) • 

IlAlthcligh p~dnt rnut,J.t·inns, c!U-Oi;]OSO'lj,11 i.tbt\-=ii.1t·jon5, 

and ethor Ch(HI~eS at the cc:lllll~n· Clnd l::c"!cculcn~ level 

Til<:ly require oolly slii?:I'1 U(}s:;::;, tis~~~~is~:!.~·Fln!~~_tio~.C3.r:...d_ 
-llgross disturbances in physiology al~e unlikelJ \'1ithout 

jarger doses (2). -

1I0f the m~n.L!Y...2..es of changes \·thich radiation _call 

cause in cells or tissues, none is. considered to be 

unique for radiation. r'luni, if not a! I, such changes 

can preslimably resul t fro!!1 a vari ety of other agents. 1I 

This surrunary vie\'/ on carcinogenesis is cl'mpatible \'/ith the ideas leading 

to the conclusion reached earlier, that fictitious dose averaging to 

larger tissue masses need not be conservative. The possibility of various 

modes of carcinogenesis is acknowledged, and in particular, mention is 

made of a pathv/ay mediated by tissue disruption . . 

Disease profiles are highly sp=c1e~ specific. Cancer is no 

exception. Gross characteristics are obviously highly species s~ecific 

also. A ra~ and a mouse are distirct and yet incredibly similar. The 

gross tissue differences are articulated out through subtly different 

informational resonances amongst cell populations, - the collective behavior 

being phased ultimat~ly, though perhaps remotely, by the genetic controls 

of the cells. Not to belabor this point unnecessarily, - cancer profiles 

are species specifi~; gross characteristics and, of cours~, genetic material 

are also species ~pecific. Collective detuning of tissue, by tissue 

disruption seer:, as acceptable an origin for the tissue instabilities of .' 

cancer as does an isolated single cell event. 

Return now to the problem ot risk estimates associated \·lith 

radioactive particulates in human 1ungs. r'1ost of wh:=tt has been said earlier 

in this connent has been general, and has been aimed at showing that there 

was no inherent conservatism in the ~~thod of es~iffiating canczr risks set 

forth in th2 first s2nt0nce Df 4.G.5, an~ that ~~reovcr the Method cDuld 

112 fnr from cOTisen'<1tive. The conclu~:ion cOi.!ld as \'Jell be applied t.o 
-12-

Having this backgr'ound notice that human lung tissue has a \.;ell 

known carcinogenic potential under a number of situations, including 

exposure to ionizing radiaticns; and that in the Hanford dog study induction 

of lung cancer was observed after exposure to plutonium aerosols. Tt,ese 

are a sufficient basis to establish plutonium induced lung cancer as d • 

legitimate concern for humans. 

The follm'Jing is a revie\'1 of the offic;ial guidance for estir.1ating 

the carcinogenic effects from exposure to radioactive particulates • . I. "(210) The NCRP has arbitrarily used 10% of the 

volume of the organ as the significant volume for 

irradiation of the gonads. There are some cases in 

which choice of a significant volume or area is 

virtually meaningless. For example, if a single particle of radioactive material fixed in either lll!!.9.. 

pr. lym~h node may be carcinogenic, thE: avera9ing of 

dose either over the lunq, or one cubic centimeter 

Pl.E1 have 1i tt1e to do \.!i tTlfhe case. Use of s i gnfFi ctint 

volumes or areas must be looked on as one of the round 

off devices \'lhich in special cases must gi'.'e \'!ay to 

detai 1ed study." 

NCRP Repot't #39 

Basic Radiation Protection Criteria 

Jdnuary 15, 1971. 

(emphasis added) 
-13-

I.' O· 1 ' .. ,":" n::: 1'; \.~Oi1C:i;nIC( her.;; with the rd:tti....·.· II. 40, 'I'lIt: 1'1'..)111:-1':.15 ofhi3:1ll:C~l Co!:c';r';~:·.'i'-'It "I.I,~ Orr"l·t;CI·!~t . '1"'- .-~.' I " 1 • " .. .1!'\:.J' .I. .......l_,,'. (; ......h"t;.;..I"tt.. I :U..tla.V "~""·r.H""t··:T of do:,c: an; at theil' lBO:.t 1'(;\":.:r-: \'li~h n:di'-J:lcth',::: .. \ .. .. ..... _.. ...t 1'i:._ 

·,lmt With l';)mc sor, :-:-r;>.')' I;;ITtI.;;;;ol\'J (t-"'rJ~'l''''l ;" Jl;".rti:.:ulntc m:~krii~l in the ti~;lH':. <:;p·;(;i"l~r with '"" . ..\..\. ,..~ 

lung .?.nd in lr.i.Hj)h n()\:!cs-, :.~ncl :~ni" 4ln:·J·... ·~.; h:t·-cr1 <Y.:crn'iu'::'5, Ht'r~ th..: Joc;)l dme Cil!l n:,~ch vcrr , • .... ' .., ~", ...t 

nn (.iO:;t: (!:::tt:rmmattO;l encounter... p~...,!(n:r:d h1Sh v ...lu(::;. CVe!! thOll!fh the lneC'n ti)i"~ GO-t· 

" difficu!.ic:I, Co;:sidGr!n~-, or:lf thl! ~p:·ni)hoid t:.%ll!:~ Ina), be: wry low_ C~rt.~i~ Iy it c.\tm~t b~ ~'~~~Il~;(i th.:rc: is firs~ th\.! p;·(.Ib!t:rn or l,~c}: of b:(.wkd·,-,: of th'lt lin:::uity ofd03.e and. t;i1cct "'itl ho!d <'.~ th~~~: ' , . I'" d .., tlIe 5t:n.;tllnty to r::l.C !:~ttOn-11! m:cd m...ri;;n~nt hiZh dOles and do':>c r~tcs, On tIte o~!:l"r _ }--'·'<.l tc:.,.) ('.',' 1 ,. 1 ella\l3e o. 1m: .fe.lCll urn C;.:II:1o pri:3~~nt. 1<.W:. po.>,;- the!"c may ue a great deal ofcdl death, <'.~d par­ ibl)r :lIst) of lrmpho~rt(::> th~.m'::h·s" Al~o '~\Iy ti.cuhtrly wi~h a-emission, with its short &loud •....cUc...lcubt~o:\ of (!c:;<tge di:it:ib"tti.;:;n Lo the V~:-iOli:i clefim::d range. th;: number ofaffeCted hl~t \"jabh~ , 

cleUlents of the lrmplloid tlS:ltle -,vould t'c:quh';! ce1t~ ma), b~ small cOfl'1pared with the num:,er of l 

information. C!t prcs~nt lm;l\·4).H<!.t.l,.~. 01\ s~\ch kLUer! cells. However. this r:ttio witt deo,:.1d on. ! 

subjects ;0":; t!1e (kgr:~c or:~g~~rr.:~at~o:l oft!:c p:lrtr­ tIll:: size and 2.ctivity of the p...:"tick~, th~ extent I 

culat~ m;;:.t;;:rial wi::hin the liTnf.lh nOtk~. it. tl') which they ag~cgatt:. and thcir ffit)';ement : 

ch;.mgc wi;.h time and the :n~O'lem.t:n:: of t:,~ within the tis:>u.e, and the movement of th:: cell; ! 

past them. . ' p .. .rtidcs within, the i)';nph nod('$. In tl\:klition 

11. On the ua:;i~ ofgenerat comider~t!on:; zmd lh.:::rc is verr little .report~d wo:'!,: 0:. the di::;tric..f some c;.:peric:1tnt!ll data and cHnit;:;o.\ c~:pcr!­ lmtion of the malt:riat wtthin the nodes, y.'hidl 

CIlce tht.: '1'r:..')k Grollp 'yerc of the Opill!')n th?t. could lY.: (lbtnin~(t by :'.utor;":.dioz.r;lp'I;{~ "tl.'(l~'> 

,1\.,,,,, "r,~ l""::ll "l.""" ... .... cc::-"c....... .t.t(; l~" ...t -.(1C' s,;tme r?(.i('!.,,:un 1- ~. cnci"'!:!Y· ab- . or oil the denree of flbro:,t; atld other h;~to10~:cal D , 

clmnges yt"oduc;ed. Dt::Ht::r data. "I'':: :.'~h·:> required sorption might well be It:5S effective when d!std- l 

on the residence time:>. oftht: p,.rtkllhh: l1l:ttt.:ri~l b'.1ted as a series of «hot spots" them when uni- ; 

fOlm1r distriuuted. ThtlJ. with p<~rti(;tl!atc f.:1.dio- ; in the J)"ll\i-lh Hodes amI th~ ;.;olubiIit), of th~ . \ ' pMticubtc matc!"ial ove! lnaUr Y(.::tr:;. i uotl~er active SOlt.rC~ within a ti:;:;ue, a m.ean tis~tlC c.lo:;e ! 

would ~probably factor to h:::: t~·.1~cn intu r.:.m.,'ider....~it1n. CO~"l;nl)n to introduce a factor of ~~f,::ty. \ 

How::ver. dl p:l.rticubte tkpo3ition and (;!-p,~ci.aUr to th05:: a sever".:: pr<l.ctical pl·oh!<:"m.h<~s HOW i 

invl'h'i,1" (I-emil t(!rs, i:; t1".<l.t the alllnht:r of cells been recl.")zoized in connection with the iahnht­ i;) • •

irr~di"'tt:<l i5. [N' the sn\ll~ menu ti';:>11= eto:;e, VeiY non ofp!utonimn particu1<l.tes. f1.ml is now b:::'ing dq)encknt en the particle :,iz~. I'inaHy. Ip:tpho­ considered in detail by a 'Task Group of Committee ~)'lC: rnig~<lfion.ls <'. f."'\ctor that l'hotlld be takea 1 of IeRI>. 

42. )!rom. dog c~perir.1ent') being carl"~,~d out ' mto com!uerat!On, 

45. In so f::1.t' as mean dQ';.':: (:~\lcltlatioa:; (;an 1.;e in the United St.:~tes <mel from limitt:c1 stut.Ees in 

made the Task Group COM:Jr!rt~d thnt th~y human sulJ;ec:ts it ha.s be-come ch:ar that inh:l.b.­

S IOU1.d. 101' (" con:n:>tcnc}, , \\'h -·1 lin, . • ttlC 1 .'C-CO!I'.lncnc,a- tion of plutonim:::l. p,rr,ticulat'!:s can lead to lliZh 1 

tio;l.';, refer to the wholt! lrmph ti5!.~le <tad not concentrations of th;:: pZ!rticulate makr!~l in the 

onl)' to the respir.?lor), Ij'mph nodes. H()w{,~ycr. pulmonary lymph nc)des. ?nd that the mean 

until more information lx:comc.'i ;\vL'..ibLk on radiation d03(: to the pu!monary lymph nodc:s 

some of the subject::> r:lcnt!or..cd <tUo\rc:. Ii ttlc and indeed to lymphoid tis'iu~ 2,5 a ,·;hole is wei~ht e;.m be put on do,::..:: (:~,lcI\1;>.liom. D,~tn on likely to be greatly in cxces') ofihat to the lun'T 

1· h' . ¢' tl1ltlour l'll"oducl:on from ;mitn<1t c:\:pcdments nre W llC IS a! present rt:gardcd a:; tho! c.ritical o!'l.!<tn 

of more signific:!Ilct'!. <'.nu th<! l·\."Sl.llt" (If pt·e.~ent for inh::1.1cc.l particuhtc matte\-. \'Iork with d()~~.:;. Ilarticubrly tho:'c with l.:'·,';er 43. The actual cl03e ratio.> are ~ot yet l:::'!o",vn , ' d .,. .. with amount:; ofp!tttOlllum. a ....e ;Wi''.ltf:" '.':Ito lateTC~,. ~I.l\y precision but the '1'<'.$1;: Croll.? l.mc.:::rMood In the Jt'lean'i.me~ the Tm1~ Croup .~re of tht: that the me....l.l do;e to lrmphoid ti>mc M 

opinion that &lony imm{:diat~ chanse ;3 the dme a wlioIt: might c:<c~ctl th3.t to the lung by a Hmh for ph~tollium on the b~5is of risk to 1)''-:\­ f"ctor of 10 or m'lrc. and, if the l·e.$pirr:.tory 

phoid tissue is. not wan·at\tcd. lymph node~ "jere alone td~t:n into cO:1.;ic.~ri\­

tion, tllC fnctm' cO!ltd Lc 100 01' pcrk~r)3 ..md} 

greater, '1'h:~ prob1c:n is w~\i:th·~r Ipl1ph~)H ~!;~L1C 

?') n whoh: 0:' n:'ijlir.a~O:T lymp~1 pt:,~l;; ti;m:.: i:1 ICRP Publication 14 

p:!l'tkubr !>hi.1dd h:: ta~,:;.:n ,t3 till: edt!"::'.1 .Radiation Sens i ti'.'i ty and 

org.m. ?,nd, if so, wh·;th;;;· the d(J3l: Emit Spatial Distribution of Dose 

(r,li'C) hr J\ht"'l:il~r.:. k p1.,ticu;:,·,,; f".'1'.l (Publication 14 epp2~rs :s a :.;l~?n!J b;: :;'l!lHt~ltt~i;~!! y' a·dtl~·(;d \;::b's ttl:: ('I ;;-­ .'e!,ort of tViO Task Groups, 

l:cnt ,'(!lu:;. and not as tile c-:~icial 

reco:;!r1er:daticns of the ICRP,) 
-14-

(2a) Wi:hin the range of the j\,lil.ximum 

Pccmis;i~)le Dose;; (:.cc p:\l",\gr3ph :>7) specified. 

for occupationd C:-:pO:iUre, \·...hen it is assumed. 

that there is no thrc,ho!d aad that cficct:; arc: 

l~ll.earl)' reb·.ted to do:>c, it .is jtl>t!JiaL!c to con., I 

stder the a ..~er.12~ d05C to the wlIol,; or~an or { 

tissue;·l:'.lthouzh it h reco~l!ized th:'Lt when morel 

inform::.tion is available, it will be more I 

_(20~ !n the C<1S? of nCH1-J:()rno0,=n.~.w5 d;;;-; app:-op;-:;<~tc to me the mean do.;~ for cells of any; III. 

t.r.I:;'lltlO:l. of gb;:rH'oed .(It,,'s. Ia the !ll!Jlr· <';!1: given trpe, as is alrcadr .dQne when the bron- . 

•pttlna!t: nf the 1J,"I.;(~ ):';Jltl\',:k£1t te. trl~' ,,:bhf~ citi.tt n;uco:;a i:; irrwlat.::d hy d,tughtcr products; 

lum". dct~rmir.~d l'1r;rdy hy tfH: l'!',yll;~-:t or of" r",lo-' "'I,d tllo"on The use of the lrtCan. d03C • .. ,1.. • _ ~ " t. c;.., .. ~ "' .. t. .... • 

QF a,d tk: mi.":,Tl ~b;rlrh{'d d':hCcHl::lV k~ rr:-~.clv has practical ad\'.anU!~~3 in that the. significant i 

i;\ __c;:r~o., but our ftlll I!Ilrl:,,·~.t='.:~d;:!~ c,! th::; voiume can be taken as that of th~ orgau or 

Jlrob!cm rnlr;~· aWAit fnrtll';r C'\.!J:;(tr:!(:·I'.t1: ti5SU" \.nckr co'\sic1'·r;l.tina 1n. fact. this pr:n- :' • n, ,-- • ... ..... • '.. J j -.. .. ..... •• , • I

(;.\;"kn;:-c. 11;....1111': ll!(':'.l~tlr~i: J..!~::"f: n l1'! c".":,'!;,: ciple h::>-s necessarily been used alrct\u)' m: 

CY'idcncc t'.) ::hr,\.,.- wh~therl wit!l :'. !':\.~!. :'!W"ll: C~lcllh';'I'r lnaX;mlll1l Fcrr.li.,iihle lJUrdclIs of! __ 1 • ~ • .. .~.s I • _"...",...... ~ '- ... u " . .. .... 

a.k3~J;}:!:d dIJ;tt';, tl;::' f\:~~(:plC~.',( f!~~' P.:;;:()(:i:..tl.:d.'.':10~ radil')tl~~clldei in ti:;sl1(O$.. Jj?~.],,~t;r)';:::l~,~p(;=:=.':.r(~:n~Y.· 

R J1ol1-hOmo'''::il~OIl''; d.;tnLll1twr. I:: rp:il.l.::r 0:' inl-r"1F.-e"n;t, or (l~}:>t; 'rot' e"~::l!1nl!: -,ntn.. "' .. ! .................' ..... ":"". . ..... ..".!..:';: ~",,"'~~.-cI ~\.;.;:.~.....,.....~~~_...c'«'''''''_l~ 

lc:,s tlH!U tht~ rL;!~ lc"ntttilr: tc(J~1! a lntJr~...· dd'li::~ n"'rt~"·H'·l·t' rt'"li,)"'~c~i\.·i..! nl~'Jr:i*J:·.1 ot h.i'fh ~~:t~\G fItA·" t'" ... J ... '......... ~"'I l~...........\-\rl 1';';;_ ......... ,...\ .... ...-..:....... ~ """"- .~--.. 

S!1"fn1... ;t~10~! (It t ,:U (,O;!: l!l t::c !I<";. Jl~:~ ?~ti':i:\'\"!ldl<q>rlJc,~dt:;-CHl:'.V hCI'l,~.p'):"-'P:!'tl.(' .• .. uP .. lit C .. 4.' I.. ct,.. • ... ~ . ~ . .. _. . .____ I II .. 

irradi.ltion rc:.ult$ from the illlml,dioil of thoron :.ibi: i;. it 'matter UpO:l whi.ch further work,ls 

(lr n~doll aud dau:;htt:r PW(Ilicts, t!if; rdc\':'.nt needed. A1;.o, fa:' cxtcm2!.1 c~p\);'I!rC of the !>klll, 

Dose F.rIUl\·?!cnt is that ill the L:-()n~:hi;!.l· cst')ec:i"n" wilen the di5t:!11Cc:! to the source is 

mllCO,:):l. . W !-.·h- •. tC, ]s t I' It: ttssue CO.n~!('l~fCC 'I 1 b to .:; i vcry J S!l::>:·t J or whea the expos::.. I'arca 1:; vc.r)' 

most heavilr irradiatt:d. Here t!1C U5~: of the! small. i: would Hot be appropri.'ttc to ::Iscr~ge 

wl101e lung would be an ir.adcq,u<1tc s:!b:;tituk : the (h.l5~ over the cntire skill. Jmtcad, it is 

for that of th.e irradiated tis~lIe IJ'ccommendcll that the cl03C b~ ~wcraged ova 

~ln an::l of a l''lllil.rc c(:ntimctrc in the n:giclil 

rccci\'ing tht:" highest dose; howc\,t':r. with \'c,'r 

'nan-ow beams of cxtreme1r hiZh iu~(;nsity. such

X ,. l • 1 ....c-J 1 r as those usce Jot" -ray al\at)'::ilS, t.!C ,aluc v 

• I t' 1 such :!.n ~\'crage do-;c may b::! mls.cac:nng. PoHC 

protection measure.> have to be ba.!;cd on 

qualita:.i;·c comidcrationS. 

ICRP Publication 9 

Recommendations of the 

International Committee 

on Radiological Protection 

(adopted September 17, 1965). 
-15-

The reconunendations of the Uationa1 Council on Radiation Protection 

and Neasurement set forth in I, and the recommendations of the Inte)~national 

Comnission on Radiological Protection set forth in III, are explicit in 

offering no guidance. 

iI is a discussion of the hot pa)~ticle problem taken from tne 

repm~t of an ICR!J Task Group. It is npt. intended to give dispositive 

official guidance. The discussion is useful co~roentary, but inconclusive. 

The very conditional statement made in the first and second sentence of II 

(41) is not generally convincing . . llith regard to th~ IH·t!viousiy cited method of risk estimation 

describtd in the first sentence of 4.G.5, that section continues with the 

following supportive references: 

IIThis approach has been used by the Environmental 

Protection Agency in recent reports on the potential health consequences of the nuclear fuel cyr.le. 2- 5 

The approach leads to estimates comparable to those 

of Gavankai:6 follm'/ing Thorilpson et ~7 based on 

linear non-threshold extrapolation of observations 

on beagle dogs administered 239Pu02 aerosols." 

As to the first, consensus in error may provide amiable agreement amongst 

federal agencies, but seems hardly a desirable basis for decisions involving 

the public heal":h and safety. The observations on bE'~gle dogs are discussed 

.: 

further on 4.G-117 and deserves separate consideration. 

It requires pathological optim-isrn to find reassurance in the 

resul ts of the nm'1 completed Hanford beagl e experiment. Dogs \'/ere giVen 

initial aerosol burdens of approximately 1-10 microcuries of Pu2390~. By tnine years post-exposure the lung cancer response \'!as virtually satura.ted 

and multicentric origins were noted in some dogs. Those receiving larger ~ 

lung blu-dens ~weater than 10 mi crocuri es di ed of pulmonary i nsuffi ci CIlCY 

\'Iithill ~--1/2 years. T\'!enty-or,e dogs sUI~vivcd for more than ".-1/2 ye\!~'s) 
-16-

and only one of these did not exhibit lung cancer at death. A relationship 

observed beh:een initial lung burd~n and time to death 'l'lith cancer has 

been often used to infer a threshold burden ,below which no life shortening 

of dogs would be E:)~pected. This is sho'tln in Figure 4.G.10 on 4-G 118. 

Note that the fibrotic deaths there have no bearing on cancer incidenc~ 

and inclusicn of those points in the constructing extrapolated curves is a , , 

senseless exercise. Note also that the results are exhibited on a log-log' 

graph which virtually obscures all differential detail. Most important, 

recognize the nature of the experiment J i.e., the lung hurdens \'I.ere large, 

the results were saturated, and the number of animals \'1as small. The 

crude rplationship observed between initial lung burden and time to death 

"lith lung cancer does not necessarily imply that a threshold burden exists 

for beagles. ~ Quite to the contrary, the range of exposures above the 

inferred threshold burden may be interpreted as a region of saturated 

carcinogenic response, that is a burden regime in which lung cancer induction 

in a beagle population approaches 100% during a normal life span. The point· 

is that the observed time to death is more likely related to the burden, 

through a population depletion effect, l'dther than through a burden 

dependent latent period. In the former interpretation appreciable cancer .. • I , 

\'lOuld be anticipated at 1m-fer burdens. This is again consistent ''lith 

extensive observations of radioisotope-induced bone tumors in mice, which 

'support the interpretation that Illatent period is constant and that the 

apparent relationship beb'leen increasing dose end decreasing time to 

death "lith tumor is due to the effects of dose-level on survival and on 

tumor expectancy. II (See Toxicity of Ra-226 in r~ice,1I r·,. Finkel et al, in 

Radiation-Induced Cancer, IAEA, Vienna, 1969.) 

The domain of this comment is broadened here in order to surl1marize 
-1/-

a specific concern with plutonium, and. to a lesser extent, other transuranics. 

Ur.der a number of circumstances plutonium forms aerosols. The physical 

character of these aerosols is such that on inhalation by humans they are 

preferentially deposited in respiratory tiss·ue. Because of Slo\-1 c1earaf,ce 

and because. of their insoluble character, particles may experience lor.g 

residence times in tissue. An appreciable. mass fraction of the aerosol is '\ 

usually associated 1r/ith particles suffici'ent1y large that small but 

physiologically si.gnificant volumes of tissue \-,i-11 be exposed to intense 

(i.e., organism lethal or greater) radiation doses within a meaningful 

physiological tim~. Studies of the effects of intense local radiation to 

skin and kidney tissue indicate that despite the near mitotic sterilization 

of the involved tissue, an enhanced carcinogenic response may occur, in the 

sense that energy dissipated in a limited volume may be far more carcinogenic 

than if the same type of radiation 1rlere to dissipate its energy over a , 

much larger tissue mass. The question is then: do particulates of plutonium 

lead to exposures that have enhanced carcinogenic potential? If they do, 

then present standards can be in error by orders of magnitude . 

. Notice that the emphasis here is on the anomalous hazard 

associated with a single particl~; ,and that if any threshold is relevant, 

it is not a dose ~, threshold since local exposures are large, but rather a 

possible volumetric threshold that must be exceeded by the physical extent 

of the exposure. Plutonium, as an insoluble aerosol-forming, long-lived 

alpha-emitter, const'jtutes a very special case of the 10\'1 exposure problem. 

In conclusion, it is indefensible to base estimates of cancer 

risk on the method of dose'averaging over fictitiously large vCJlumas. 

Similarly, estimates based on non conservdtive interpretations of the 

Ha,nford beagl e' resul ts are highly suspect. 

PLUTONIUM AND PUBLIC HEALTH 

by Donald P. Geesaman 

A talk given at the University of Colorado on April 19, 1970. 

Printed with references added in Underground Uses of Nuclear 

Energy, Part 2. Hearings before the Subcommittee on Air and 

Water Pollution of the Committee of Public Works, United States 

Senate, August 5, 1970. 

Printed with Author's Note added in Electric Power Consumption 

and Human Welfare, AAAS Committee on Environmental Alterations, 

August 11, 1974. 

It will be published as Perspectives on Energy: Issues. Ideas, 

and Environmental Dilemmas, edited by Lon C. Ruedisili and 

Morris Firebaugh, Oxford University Press, * 1975; and in 

Energy and Human Welfare, eds. Commoner, et al Macmillan 

Publis hing Company, 1975. 

*Published with the permission of Oxford University Press. 

COpy 

PLUTONIUM AND PUBLIC HEALTH 

Donald P. Geesaman, 1972 

AUTHOR'S NOTE- -JUNE 1972 

On May 11, 1969, a m.ajor fire occurred at the large Rocky Flats 

plutonium facility located northwest of Denver, Colorado, and operated 

for the Atom.ic Energy Com.m.ission by the Dow Chem.ical Company. 

Consequent to this fire E. A. Martell and S. E. Poet conducted a pilot 

study on the plutonium. contam.ination of surface soils in the Rocky Flats 

environs. Their results suggested an off-site contam.ination orders of 

m.agnitude larger than that which would have been expected from. the 

measured plutonium releases in the air effluent of the facility.· 

In a letter of January 13, 1973, to Glenn Seaborg, then chairm.an of the 

Atom.ic Energy Com.m.ission, and in a press release of February 24, 1970, 

by the Colorado Com.m.ittee on Environm.ental Inform.ation, Martell and 

co-workers called attention to this anom.alous contam.ination and expressed 

concern over its uncertain origin and over its significance to public 

health. In response the Atomic Energy Corn.rn.ission fixed the probable 

origin of the off-site contamination as wind dispersal of plutonium leaking 

from. rusted barrels of contarn.inated cutting oil, and denied that cause 

existed for concern over hazards to public health. 

It was my conviction that the Atom.ic Energy Com.m.is sion response provided 

a distorted and inadequate representation of the possible hazards associated 

with the observed off site contam.ination, and that the im.m.inent large-scale 

comm.ercial introduction of plutonium. gave this situation a precedential 

significance m.uch greater than the already considerable significance of the 

situation itself. 

Dr. Donald P. Geesam.an is an associate professor in the School of Public 

Affairs of the University of Minnesota, Minneapolis, Minnesota. His 

professional interest is in the relationship between technology and political 

institutions. He spent thirteen years in the Theoretical Physics Division 

and the Biom.edical Division of the Lawrence Radiation Laboratory, 

University of California, where m.uch of his research was concerned with 

nuclear technologies and their im.plications concerning society. 

From. Underground Uses of Nuclear Energy, Part 2, Hearings before the 

Subcom.m.ittee on Public Works, United States Senate, August 5. 1970, and 

subsequently subm.itted as a working paper to the AAAS/CEA Electric 

Power Study Group (1972), Reprinted by perm.ission of the author. 
In April 1970 a representative of the Division of Biology and Medicine of 

the Atomic Energy Commission and I were invited to present our views at 

the University of Colorado. 
Attachment #1 to COll1ment #2 

" 

"Plutonium and Public Health,1I in 

Electric Pm'/er Consumption and 

Human Helfar-e, AAAS Committee 

on Environmental Aiterations, 

Augu$t 11, 1972 (non-copyrighted). 
I-IJ2 

PLUTONIUM AND PUBLIC HEALTH 

Donald P. Gecsam.an 

Author's Note--June 1972. 

On May 11~ 1969 a major.fire occurred at the large TIocky Flats 

plutonium facility located north~vest of Denver, Color~do, . and, ~perated 'for 

the AEC by the Dow Chemical C oropany. For description of this fire see 

AEC press releases M-121, May 20, 1969, and M-257, Novem~er 18, 1959. . . C~msequent to this fire E.A. Martell and S. E. Poet conducted a 

pilot study on the plutonium contamination of surface soils in the ?ocky 

Flats environs.. rrheir results suggesced an off site contamination that was 

orders of magnitude larger than that which wonld have been expected from . . . 

. the measured plutonium releases in the air effluent of the facility. 

In a letter of January 13, 1970 to Glenn Seaborg, then chairman . . 

of the 4EC, and in a press release ofFebr1.l~.ry 24, 1970 by the Colorado 

Committee on Environmental Information: IVIarteU el al. called attention . . '. 

. , . 

to this anomalous contamination and expressed concern ove;:' its u!1certain 

origin and over its signi~icance to public heahh. In respunse the A EC fixed 

the probable origin Qf the off site contamination as wind diGpersal of plutoIlium leaking from rusted barrels of contaminated cutting oil, and denied 

that cnU3~ existed for coneern over hu~rt!'t1s to public health (St~{' 1\ EC 

It was my conviction th.:lt the AEC 1'~;5pOnse pro,..idcd a (Ii~to;·tec1 
and inudequa"le representatio:: of the posbibh: hazards associated \·:ith the 

observed off site contamination, and that the ~mmhlent lu"rge-scale: COinmc~'

cial introduction of plutonium gave this situation a prcccdcntial significance 

much greater than the already considerable significance of the situation 

itself. 

In April 1970 a repres~ntative of the AEC's Division of Biology ?.:ld 

Medicine and myself were invited to presE;nt our views at the Univer~ity of " " . 

Colorado." "Plutonium and Public Health" derhres from the preceding his-" 

tory and should be so interpre.ted. The presentation was. to a lay audience " 

and was made with that expectation. Adequate rcfe~encing was added to 

the written text prior to its inclusion in Underground UsPs of Nuclear Energy, 

Part 2. Hearings before the SubcommIttee on Air and 'Vater Pollution of the 

Committee on Public \Vorks Uliited States Senate, August 5, 1970. 

As it staltds the p~"per still represents a legitimate critique, and 

. the recent emphasis on plutonium as a major energy source increas es the " " 

relevance "of the discussion. An upda"ting would "involve only increlnenta1 

changes, and "would generally 

-

supplement"rather than" disturb the substantive

,~ " " 

arguments of t~e ol'i"ginal"paper. Hence while such an upd()ting is desirable, 

it is also of suffic~:;:nt marginal value that It can he properly d~fcrred at 

my discretion. 

For those who ~"re intere.sted in l'e~tding.the t~i:lditional AEC posit.ion on Hw ::lllbject I would ~jllggest "i\ppelitlb: 2'1 - Safety CtHISld<"I'al iOll6 in 

the OpCl·~"tions of th~ Ho('ky F'l~\ts Plutonium Pr'ocessing PlanI.", from 
Times have changed since 1\:1ny WG8. T!lt..m plutonium \':a5 rcgal"d(~d 

ns =t milit8.ry substance and \'las accordingly gh'cn,.little pllblic attention. 

NoW it is much puhlicized as the energy sou!"ce of thc not too distant future. 

April 1970 was a. tilne of transition, and I felt the: slrong 'presence of the 

, ea~lier tradition~ and the de~i5ion to speak \'Jas' not an easy one for me. 

I have had no regrets'. , 

D. P. G. 

Plutonium nncI Public IIe8.1tll 

For the sake of completeness let me give,you some background on 

plutonium, Ii: is an elelncnt that is virtually non-existent in the earth's 

natural crust. In the early 1940·5 it was first produced and isolated by 

Dr. Seaborg and colleagues; --Dr. Seaborg is presently Chairman of the 

Atomic Energy Commission~ Plutonium has several isotopes, the most 

important being piutonium-23S. which, because of its fissionable properties

-. 

and its ease of production, is potentially the best of the three fission fuels . 

•

That is why it is of hiteresl. Asipc from its fissionable properties, plu-, 

tonium-239 is a radioactive isotope of relatively long half-life (24,000 

years). hence its radioacti vi~y ifi undiminished within human time scales. 

\Vlten it decays, it emits n helium nucleus of substantial energy. n(:'caus(~ 

Ihf~ nlall~rial along it:; Flth; :~nd :"Hi a {!on~j(:qut:nCe (Ii:.'po:;its ii,s l'IlPI'gy in 
I-lS5 

1/10 of tho.L A cell Vlhose nudeus iB itltcr'ccp~(;d by the path of such a p<.t.rtide suffers bufficient injury tlu:·,t its cc~radty for cell div~sion is um.:ally 

lost (Bnr1(end'3on, A. \V q 19G 2 and Bloom, \V., 1959). 

The cancer inducing pot(~ntia.l of plutonium.j.s well known. One 

millionth of a gram i!ljected intradermally in rf.ice has caused cancer 

(lisco, H., et al. ~ 191,7); a similar amount inject~d into the blood system 

of dogs has induced a substantial incidence of i:)one cancer {Mays, C. \V., 

et aL ~ 1947L becau.se of plutonium's tendency to seek bone tissue. Fortunately.the body maintains a relatively effective barrier against the entry 

of plutonium i,nto the blood system. Also.. bec~nH;e o,f the short r~.nge of 

the emitted helium nuclei, the radiation from plutonium deposited on the 

surface of human skin do?s n'ot usually rcat:h any relevant tissue. Unfortunately the lung is more ~ulnerable. 

Before,I d,esr;ribe 'yhy ~his is, I'd like to say something abo~t the 

characteristics of. an aerosol'. .An aerosol is physically like cigarette 

smoke, or fog, or cement dust. Because uf their small size. the particles 

'-. 

comprising an aerol'lol remain suspended in air for long period::; of tinle. 

If an aerosol is inhaled" then.. d'=!pending on its physical characteristics, it: 

" 

may be deppsited at different sites in the respiratory tree (Health PhY.5ics, 

19(6). Larger aerosol sizes are usually removed by turbulence in the nose, , . 

particles deposited in the bronchial tree are cleared upward in 1:o1.1rs by the 

cilifttcd.mucus blanket that c,?vers the structu.ce. This clearance system 

r!ll~~; not pendrate into the deep respiratory structur(:s, th0 ;),l\':!o1i, .where 

111,-' b~1.r;ic oxygen-carbon dioxide cxchnngc of tho;!' lun~ takes plHcc. Smaller 
1-1;)(; 

pl.1rticks tend to be deposited here by gl'avita.tion:ll settling. nnd if they arc 

iru;oluble they may reside in the alveoli for <l considerable time. The problew is thal, under a number of conditions CAnclerfon. B. V•• et all"' 1967; 

li'r.1sC'r, D. C •• 1967; Kirchner. R. A •• 1966; 1\1ann, J. R •• el a1., 19G7; 

Stewart. K., 1963; "Vilson, R. H. et a1., 1967) plutonium tends to form 

aerosols of a size that are preferentially deposited in d.eep ... ung tissue. . , 

Plutonium dioxi¢le, 'which is a principal offender. is insoluble and may be 

immobilized in the lung for hundreds of days before being cleared to the 

throat or to the lymph node~ around the lungs (Hoalth Physics. 1966). 

An aerosol is comprised of particles of many different sizes, and 

their radioactivity may differ by factors of thousands or even more. I will 

. simplify' the argument and say that there is a class of these pa rticles. the 

largest ones deposited in the deep lung tissue, Umt ~an be expected to have 

a different potentia1 of ~ance.r induction than lhe particles of the smaller 

class. This is hecause they are sufficiently radioactive to disrupt cell 

popalations in the volume of cell tissuew.hich they expose (Ge(~saman. 

D. P., 1968a). An example might be a particle that emits 5000 helium 

nu'clci per day. It wOldd subj::('t between 1 and 20 alveoli to intense radiation, .sufficient to inflict suht;tantia] cell death and tissue disruption. 

For reference, the alveoli "':.l"C the basic structural units of the deep lung. 

Tiley arc ::;haped and bunclH:d roughly like ho]]o'.\{ g['ClIWf) O.:~ millimd(',' 

ill dia illf!ft-" Tlleil' . ,wall:; aJ'(' tllin.•1 r(:w fh~H:~Cllld!hs of :1 rnillilll(·!{'r·• . 
1,-10" 

p:~}'t.iclc proh1em. The question is: dOCG ElH.:h cl particle have an cnhanct:d 

potential for cancer? No one knows. One c~tn argue that cancer cannot 

cvvlve from dead cells, hence a depleted ccll population must be less 

carcinogenic. This is believeable, and must be true on occasion. The 

facts are. though,' that intense, local doses of radiation are' extremely 

effective carcinogens, much more so than if the energy \Vel e averaged , , 

,over a larger tissue- mass' (Geesaman. D.P•• 1968b). Fur:therrriore. this 

cantake place at high doses of radiation where only one cell in ten thousand 

has retained its cap~city to divide. The cancer susceptibility of lung tissue to radiation has been demonstrated in many species; one can say in 

general that the lu~g is more susceptible to inhomogeneous exposures from 

particles and Implants than it is to diffuse uniform radiation. Some very 

careful skin expe~iI!lents of'Dr. Albert have indicated that tissue disrupHon is a very likely pathwaY'of radioactive induction of cancer after intense 

exposure (Albert, R. E., et al.. 1967a, ID67b. 195rlc~ 1969). The experimC:i1ts, show that the most severe tissue..!.njury is not necessary. nor even 

opt,imal. for the induction of cancer. When the?e notions are applied'to a 

. t _ 

hot particle in the lung. U;e po!:!sibility of one cancer from. 10, 000 disruptive particles is 'reaUstic. This is disturbing hecause an appreciah>le 

po:::-tion of the total radioacti vity in a plutonium aerosol ~s usually in the 

large particle component. 

Let me demonstrnh' what I mean. S\lPPOSC a man rN'cived a 

n.;~:drnlllll p~.\r·mis~dhh\ lung hunfpll for' plu!oniulll, and ~ui)poSC rough})' 
of pnrticlcs clCpo3it~d (tl10,t is. those emitting sc:veral tho:.l~?ntld hditlln Ilucl~i 

p'~L' clay), This is reasonable. There would be sowcthing like a lhou:=.and nf 

these particles and each would chroni<:;alIy expose ~ to 20 alveoli to intensc 

radiation. If the risk of cancer is like 1 in 10, 000 for one disruptive particle. then the total risk in this situation is one it; ten, i. c., one man in ten 

would develop lung cCl;ncer. 

Put another way,. about 1 cubic centimeter of the lung is receiving 

high doses of radiation. It would not be surprising if intense exposure of 

such a localized volume led to a cancer one timp in ten. 'I'he question i~: 

if the indivic!ual volumes are separated from each other, is substantia.! 

protection afford:d? No one knows. It is :.:nuch easier to find two cancers 

using 50 exposures of 1 cubic centimeter e~v:h. than it is to find a couple 

of cancers in 50, 000 single, particle exp'osures. Certainly the length scales 

of injury arc long enongh that a disruptive carcinogenic pathway cannot be 

disregarded for isolated hot particles (Geesaman, D: P .• 1968b). 

One can look to the relevant exp~rience for re<.'l.ssurar:ce. In an 

experiment, done at Hanford by pro Bair and his coneagu~s. beaele dogs 

\- .-. 

were given Pu23902 lung b~rdens of c:.t few hundred thousandths of a gram 

(Bail', W. J .• ct al., 1966; Ross, D. M., 1967). At 9 years post exposure, 

or after roughly half of an adult beagle life sp2.n. 22 of 24 deaths i.nvolved 

lung cancer, usually of multiple origin. Fi'J'e dogs rClnain alive. For 

cornp~·.rison, these exposurc's ar'(: about 100 timet, h\!'[~~l' th..·m the pres('nt 
I-15!1 

b,'(,:U.If;C all of the dogs are developing canc;er, it i.~ impo;;siblc to infer "'hat 

would happen at lower exposures: simple pt-op?rUorw.l~ty does, however, 

Cl.lo"rrest that present human standards are too lax by__ at least a factor of .. , lit .!:* .. 

ten. Second. because the radiation dose is large. with tissue injury almost .. 

killing the dogs; and becauGe large numbers of particles are involved. _often 

, 

acting in conjunction; -it is improbable that the risk from disruptive particJ.es 

can be inferred. And after all, this is what we need to know. since almost 

all human exposures will involve hoLparticles acting independel~tly. and if 

there is a risk from these particles, it will be additive throughout the p6pulation; --there will be no question of a threshold burden; and there will be 

a possibility that a ~an with an undetectable burden of a iew particles \T::~l 

develop a cancer as a consequence. Fo~ the exposures of concern, 1000 

people with 100 disruptive particles each \1.i11 suffer as many total cancers 

as la, 000 people with 10 'particles each, or as 100 people with-1000 particles each. 

Human experience does not glve"us the answer eith0r. Plutonium 

-has been around for 25 ,rears, and people have been exposed. In 1964 . .... '-. 

through }966 contractors indicated an average total of 21 people per year 

with over 25% of a maximum permissible burden of plutonium (Ross, D. M., 

19(8). Three out of four of these exposures cleri V(~cJ from inhalation. To 

h~ rea~on:1.bly useful. the ducnnwntntion of exposure n"iust go back more 

Ih;~.:J Hi yt\~lrS, lweau~e of tt1l.' latent period fut, radiation indnc('d cancer. 

fa !'I:c:~nt ::c-at·;:; doclI!!1cntatioa has imp!'o:v'f.:d Ln:"[ltly, hut from early day::; >. 
I -HiO 

.Since I have mentioned maxin1tUn pcrmissii.,le lung burdens. you 

nrc aware that there is official guic1::mcc. I would lik.::! to conuncnt on it. 

The maximl1m permissible lung burden is establi·shed by equilibrating the; 

exposure from the deposited radioactive aerosol with that of an acceptable 

unifonn dose of x-rays. The International Commission or. Radiological 

, , ' 

Protection indicates thi,s may be greatly in error, and specifically state;::; 

in its ,publication 9, "In the meantime there is no cle~r evidence to show 

whether, with a ,given mean absorbed dose, the biological risk associated 

with a non-horrlogeneou::; nistribution is greater ur less than the risk'resuIting from a more diffuse distribution of that dose in the lung. II (ICRP, 

1966). They are e~fectively saying that there is no guidance as to the risk 

for non-homogeneous exposure in the lung, hence the maximum permissible 

lung burden is meaningless for plutonium particles~ as are the maximum 

permissible air concentrau'ons which derhre from it. 

So there is a hot particle problem with plutonium in the lung, and 

the hot particle problem is not understood, and there is no guidance as to 

'the risk. I don't think, there is any c~ntroversy about that. Let me quote 

.l 

to you from Dr. K. Z Morgan's testimony in January of this year before 

the Joint Committee on Atomic En~rgYI U.S~ Congress (Nlorgan, K.Z•• 

, , 

19GO). Dr. K. Z. Morgan is one of the United States' two members to the 

main Committee of the International Commission on HadiologicaJ. J?rotecHen: he hus been a member (If the commitlce longer than anyone: Hnd he 

is director of Health Physics Division at O::lk Hidge Nationcll L~d.Joratory. 

1 'luo!(:: "There arc many thing::,; about radiation exposure \'/(; uo not 
, I-IGI 

unc1cn;t~lIld, and there will continue to be unccrtaintie's until hCC:llLh physics 

can provide a coherent theory of radiation dcmo.ge" This is why some of 

the basic t"esearch studies of the USAT~C are so important. D~P. Gccsaman 

and Tam,plin have pointed out recently the prc!.llems of plutonium-239 partic1es and the unc'ertainty of the risk to a man who carries , 

such ' a particle 

of high specific aC'tivity in his lungs. II At the same hearing, .. in response , . . . : ~ 

.. to the c~mmittt:~els: inquiry abou.t priorities in basic research ~n the bi'ologlca!. effects of ,radiation, Dr. M. Eisenbud, then Director of the New York 

City ,Environmental Protection Administration, in part replied, "F'or some 

reason or other the , , particle problem has not come upon' us in quite a little 

while" b,ut it probably win one of these days. \Ve are not much furt,her 

along on the basic question of whether a given amount" of energy delivered 

to a progressively smatler and smaller volume of tissue iR beUcr or 'v~rs£: 

for the recipient. This is another way of asking the question of how you 

calculate the dose when you inha~e a single particle. If (Eisenbud,' I'lL, 1970). 

He was correct; the problem has come..up again. 

In the context of his comment ~t is interesting to refer to the 

t 

Nat.ional Academy of Sci~nces, National Rcsearch Council r~port .of 1961 

on the Effects of ~nhaled Radioactive Particles (U. S~ NAS. NRC .1961). 

The first sentence reads, "The potential hazard due to airborne radioacth'e 

particulates, is probably the ieast understood of the hazards associated. 

with atomic weapons t{~Rts, produc:lion of rncioeJomcnts. nnr} the ('xp:-tl1ding 

H:-;f~ (If nuch~n)' energy ror r()\V(~r production." /\ deccde later t1I:l~ statc-

"WI1~ i:; ~ti.n valid. Fin::\lIy let me qnot!.: Drs. fiander:-l, Thomp:;o:.1. and 
t· T-1(i2

-" 

Hair from a pnper given by them last Octave r (S-wders, C. L .• W7D). Dr. 

Hair and hls collc."gucs have done the most ri:lcv8,nt plutonium oxide inha-

]~ltion experiments. "Nonuniform irradiation of the lung from depus ited 

radioactive 'particulates is clearly more carcinogenic than uniform exposure (on a total-lung dose basis), and alpha-irradiation is nlore carcinogenic than betfl-irradiation. The doses required for a substan tial tumor ' 

incidence, are v~ry high, ho'wever, if Ineasured in proximity to the particle; anal ~Lgain, there 'are no data to establish the low-incidence end of 

a dose-effect curve. And there is no general theory, Or data on which to 

bRse a theory. which would permit extrapolation of the high illc1dence portion of the curve into the low incidcnce region. II I agree and I suggest 

~ . that in such a circumstance it is Hppropriate to view the standards with 

extreme caution. 

There is another hazardous aspect of the particulate problem in 

which substantial uncertainty exists. In case of an aerosol depositing on 

a surface. the material may be resuspEmded in the air. This process is 

crudely described by a quantity cnl1ed a reEustJension factor which is reIT18.rkable in that it seems generally known only to \vithin a factor of hi!-

lions (Kaibr·en. R. L. ,1968). Undoubtedly it can be pinpointf'd somc\vhat 

IH,tter than this for plutonium oxide, but the handiest way to dispatch the 

problem is to say there is some eddence lhat plutonium particles become 

.i:t:wh.:::cl to larger particles ::md arc therefore no longer potential aecofiob. 
· t· 1-' 1(; 3 

-" 

heing rcdepoEitcd tend to knock small particles free. In relation to this, 

I'd like to give yoq a little subjective feeling for the hazard. Tbe,-£! is no 

official guiclance on surface contamination by pll-1tonium. Two years ago, in 

an effort to determine some indication of the opinions of kno'~'lcdgeaule 

persons with respect to environmental contamination by plutonium, a brief 

questionaire was administered'to 38 selected !--RiJ employees (K~thren, 

11.L., private communication). All were pE::rsons who were well acquainted 

with the hazards of plutonium. The group consisted of 16 Hazards Control 

personnel, primarily health ph~sicists and senior radiation monitors. The 

remainder were professional pprsonnel from Biomedical Division, Chemistry, and Military Applications.. who had extensive experience with plutonium. 

I had nothing to do VJith the survey, nor- ,vas lone of the members who was 

queried. ' The conjectured situation was that their neighborhood had been 

contaminated by plutonium Q:}dde to levels of 0.4 microcuries 'per squarE> 

meter. For reference,' this value is roughly ten times the highest concen1.ration Dr.. Martell found east of the Rocky Flast Dow Chemical facility 

(Martell. E. A., 1970), --and bear in mind that a f::ictor of ten is a small -.. 

t 

difference relative to the large uncertainties associated with the hazards 

from plutonium contamination. Several quesf.ions were asked. One was, 

would you allow your C'hildren. to play in it? 86% said No. Should these 

levels he decontaminated? H9% sairl Yes. I'\nd to what l(~vd should 1111: 
I-I GII 

hhu:ie about the levels of contcnninatioll encountered east vf Hoc!cy Flats. 

Finally I would like to describe lhe: problem in a larger context. 

By the year 2000, plutonium-239 has been conjcct.ur~d to be a lnajar energy 

. . source. Commercial p'rC'duction is projected at 30 tons per year by 1980, 

in excess of 100 tons per year by 2000. Plutonium contamination i:;; not an 

academic question. Unless fusion reactor feas.ibility is demonstrated in 

the near future, the commitment will be made to liquid nletal fast breeder 

reactor!:i fueled byplutonium. Since fusion reactors are presently speculative, . the decision for liquid m~tal fast breeders should be anticipated and 

plutonium should be considered as a major pollutant of remarkable toxicity 

and persistence. Considering the enormous economic inertia imrolved In 

the commitment it 

, 

is imperative that public health aspects be carefullv and ". 

honestly defined prior to active promotion of the industry. 'fo live sanely 

with plutonium .~me must appreciate the potential magnitude of the risk, and 

be able to monitor against all significant hazards. 

. A n indeterminate amount of plutonium hus gone off site at a majo:::-

facility 10 miles upwind from a metropolitan area. The loss was unnctked. 

t -

'rhe origin is somewhat sl)eculati"ve as is the ultimate deposition. 

The health and sa~ety of public and workers are pl"otected by a 

set of standards for plutonium ncknowledged to he meaningless. 

Su(:h things make Qtrave;sty of public hc.ulth, 'and raise seriolls 

que:;lions ilhout a hurried U(~ccplane(.~ of nudc.ar cncq:;'y. 
1-165 

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Albert, n.~-;., F.J. Burm'l anrlH.D.lIcimLach. 19G7. Thccffectofpcnctration depth of electron radiation ell sk:n tum~r fcrmcltion in the rnt. 

~ation Res. 30: 515-524. 19B'la. 

Skin damage and tumor formation from grid and sieve patterns 

~f-elect;on and beta radiation in the rat. Radiation Rc~_ 30: 525-540, 

J967b. 

____ .....,. The association between chr.onic radiation damage of the hair 

follicles and tumor formation in the rat. Radiation Ras. 30: 590-599. 

1967c. 

_____, 1969. .An evaluation by alpha-particle Bragg peak "radiation of 

the critical depth in the rat skin f<?r tumor induction. Radiation Il~~. 39: 

332--344, 1969. 

Anderson. B. V., and I.C. Nelson. 1967. .Plutonium air concentrations 

and particle size relationship in Hanford facilities. BNWL-495. 

December 1967. 

Ba~r. \V.J. i J.F. Park. andVif.J. Clarke. 1966. Long-tern"lstudyofinhaled plutonium in dogs. Battelle Memorial Institute Technical Report. 

AF'VL-TR-65 -214. . . Barendson.. G. \V •• 1962. Dose-survival curves of human cells in tissue 

culture irradiated with a1pha-, beta-. 20-kV x- and 200-kV x-radiation. 

Nature 193: 1153-1155, 1962. 

Bloom. \V .• 1959. Cellular responses. Rev. Modern Phys. 31: 21-29, 1959 . 

. F!iseohud, M .. Panel. discussion." ,,1970. In ·Environmental Effects of Produs.ing 

Electrical Power, Phase' 2. Testimony presented at Hearings before the 

Joint Committee on Atomic E!nergy; 91st Cong.• 1970. \Vashington, 

D.C •• U.S. Gov't. Print. Off. {To he· published). 

Fraser. D. C., 1967. Health physics problems as~ocinte~ with the production of experimental reactor fuels containing Pu02. Health Phys. 13: 1133-

1143. 1961. . . 

(; cesamall, D. P. ,19B Sa. l\n am.llysis of the carcinogenic risk from CUl 

j tlf>oluble nlpha -crnittinI! aerosol df~po;:;ited in <ll:~p respiratory lisfju~. 

lJ!livel'sit.Y of Califol'nla Ih:diation ),ahorato!'y. Livcrmore, tICRL-503S7. 
I-luG 

... , 1968b .. An analysi:. of the cC!.rcinogl'nic risk from an iusoluhlr: 

;:lp!~'.-e~itU.n~ aerosol deposiTed in dr.:cp rC.3piratol'Y ti:=:suc; j\ddcndum, 

UnivCl'sity of California TIadiaHon Lahoratory, Liverrnore. UCR L-!:l03U7, 

Addendum. 

Health P~.F., 1966. Task Group--Chairm::m, PatH E. Morrow, Dcro~it'ic)n and retention models for internal dosimetry of the human respiratory 

tract, 12: 173-207. 

ICRP. 1966. ~ccommendati()~s of the Inter01.ttonal Commission on Radiological Protection (Adopted Sentember 17, 19(5), ICRP :publicR.tion 9. 

Oxford, Pergamon Press. ICRP-PUBL-9.. I966. 

Kathren. R. L., 1968. Towards interim acceptable surface contam!nationlevels for env~ronmental Pu02.BNWL-SA -1510. 

_____. Battelle Northwest (private communication). t 

Kirchner. R.A .• 1966. 'A plutunium particle size study in production areas 

at Rocky Flats. Am. Ind. Hygiene Assoc. ,1. B: 396-401, 1966 . .. 

Lisco, H .• M.P. F~nkel. and A. M. Brues, 1947. Carcinogenic properties 

of radioac:tive!fission products and of plutonium. Radiology 49: 36l-S63. 

1 

Mann, ~T. R., and R. A. Kirchner. Evaluation of lung burden following 

acute inhalatiqn expcsu:rc to highly insoluble Pu02' Health Phys. )3: 

877-882, 196 7 ~ 

Martell, E.A.\, P.D. Goldan, J.J. Kraushaar~ n.w. Shea, and,R.H. 

William.s, 197~. Repor,t on the DO\-" Rocky Flats fire: Implications of -

plutonium releases to the publk health.~nd safety. Colorado Committee 

for Environmental Information, Subcommittee on Rocky Flats, Boulder, 

Colorado, January 13. 1970. (Personal communication to Dr. Glenn T. ~ Seaborg, Chait:'man. Aiomic Energy Commission). , .! ! 

1 

IVIays, C . \V. ~ ft aL. 1969. Radiation-induced bone cancer in beagles. _ 

In Mays. et al,j ~ (eds.). Dela;red Effects of Bune-Seeking TIadionuclides. 

Salt Lake City! University of Utah Press. 

Morgan~ K. Z ••.Radiation standards for reactor' siting. ,In Environmenhl 

J:;ff~cts of Proch.lcinLElE;ctricHl p()w_~.l-Phase 2. Tcsthnony presented at 

11c.~~I.rlnef; before the Joint Committee on A tom~c Energy, gIst Cong., 1970. 

Wr:!shinglon, D. C., U. S. Gov't. Print. Off.. (To be published). 

l ' , ? ':)) - <:'('1:, .1. Ji'., 'et 21. I uno. Clu'onic effects of inhaled ....,: l'u()2 in b:::3.g1cs. 

T~!";T/ L-lO;lO, Part 1: 3.3-3.5. 
. ,.. 

! -l G', 

1

,.,.-" J) r...t 1968. A stalL-tical summary of United Stcl.t~s Atomic l!::ncrrl\.· \ ...h'l, • • uJ 

Co:nmi!:wion contractors' internal exposure: experience, ID57-UJ6G. In 

h'ol'nhcr[;, n. A •• and \V. D. Nor'wood (cds:), DictQ;nof.i~ and TrC'::t~m~lL9i._ 

Deposited nadi~~1iJc~ Proceedings of a Symposium held at Richland, 

'VftshingtoB, 15-17 lvlay Hl67. N. Y. I Exccrpt8. IVrcdica Foundation, 19G8. 

pp. 427-434. (CONF-670521). 

S.1.l1dcrs, C.L., R.C. Thompson, and \V.J. Bair, 1970. Lung cancer: 

Dose response studies with radionuclidi!s.' In,1nhalation Carcinogensis. 

Proceedings of a Biology Division, Oak Ridge l'htional Laboratory.. 

conference held in Gatlinburg~ Tennessee. October 8-11, 1969. M. G. 

Hanna, Jr., P. Nettesheim. and J.R. Gilbert', (eds.) U.S. Atomic Energy 

Commission Symposium Series 18, 1970. pp. 285-303, (CONF-691001). 

Shnvart, K., 1963. The particulate material formed by the oxidaticn of 

,plutonium. In Technology" Engineering and SafcEJ C. Nichols, (eel.) 

NeVI York, The Macmillan Company 5: 535-579, 1963. . 

U. S. NAS-NRC -SUDCOIVIM. Hl61. Effects of Inhaled Radioactive Particles. 

Report of the Subcommittee on Inhalation H8.z2,rds. COlnmittee on Path::­

logic Effects of Atomic Radiation. National Academy of Sciences-National 

Research Council, ,\Vashington.. D.C.,' Publication 848. NAS-NRC/PUB848. 1961. 

,\Vilson, R.H .• and J.L. Terry. 1967. ·Biological stuuies associated with 

a field release of plutonium,. In Inhaled Particles and Vaponrs II, C. 

Davies. (ed.) Oxforc1~ Per-gamon Press, 273=-2DO, 1967. 

Advisory Council 

On Historic Preservation 

1 j LL K. -:,treet .'\J. W. ,")UllL' 4.> 0 

Washington D.C. 20005 

Lt. General Warren D. Johnson, USAF 

Defense Nuclear Agency 

Department of Defense 

Washington, D. C. 20305 

Dear General Johnson: 

This is in response to your request of September 3, 1974 for comments 

on the rlraft environmental statement for Clean Up, Rehabilitation, 

Resettlement of Enewetak Atoll, Marshall Islands. Pursuant to its 

responsibilities under Section 102(2) (C) of the National Environmental 

Policy Act of 1969, the Advisory Council on Historic Preservation has 

determined that while you have discussed the historical, architectural 

and archeological aspects related to the undertaking, the Advisory 

Council needs additional information to adequately evaluate the effects 

on these cultural resources. Please furnish additional data indicating: 

I. Compliance with Section 106 of the National Historic 

Preservation Act of 1966 (16 U.S.C. 470[f]). The Council 

must have evidence that the most recent listing of the 

National Register of Historic Places has been consulted 

(see Federal Register, February 19, 1974 and monthly 

supplements each first Tuesday thereafter) and that ~ither 

of the following conditions is satisfied: 

A. If no National Register property is affected by the 

project, a section detailing this determination must 

appear in the environmental statement. 

B. If a National Register property is affected by the 

project, the environmental statement must contain an 

account of steps taken in compliance with Section 106 

and a comprehensive discussion of the contemplated 

effects on the National Register property. (Procedures 

for compliance with Section 106 are detailed in the 

Federal Register of January 25, 1974.) 

II. Compliance with Executive Order 11593, "Protection and Enhancement of the Cultural Environment" of May 13, 1971. 

A. Under Section 2(a) of the Executive Order, Federal 

agencies are required to locate, inventory, and 

nominate eligible historic, architectural and 

archeological properties under their control or 

jurisdiction to the National Register of Historic 

Places. The results of this survey should be included 

,!, ,,': J' 'I'. t IIltlt Ilf d,' I \,'CII'n (' Ill'" 1/. " of tbl' [lda,,1 GOl tTl/moJ! ,lltI,.~,,1 b) {hI' Act 0/ 

(!,' ,.r : ". ,1,11 ,\f' II Pr ,Jdn.I,1fdC(IfJ.'rn,illth'·fi"'''ofllilf()lil'Prt5l'rI'i.//ioll. 
in the environmental statement as evidence of 

compliance with Section 2{a). 

B. Until the inventory required by Section 2{a) is 

complete, Federal agencies are required by Section 

2{b) of the Order to submit proposals for the 

transfer, sale, demolition, or substantial alteration 

of federally owned properties eligible for inclusion 

in the National Register to the Council for review 

and comment. Federal agencies must continue to 

comply with Section 2{b) review requirements even 

after the initial inventory is complete, when they 

obtain jurisdiction or control over additional 

properties which are eligible for inclusion in the 

National Register or when properties under their 

jurisdiction or control are found to be eligible for 

inclusion in the National Register subsequent to the 

initial inventory. 

The environmental statement should contain a determination as to whether or not the proposed undertaking 

will result in the transfer, sale, demolition or 

substantial alteration of eligible National Register 

properties under Federal jurisdiction. If such is 

the case, the nature of the effect should be clearly 

indicated as well as an account of the steps taken 

in compliance with Section 2{b). (Procedures for 

compliance with the Executive Order are detailed in 

the Federal Register of January 25, 1974, "Procedures 

for the Protection of Historic and Cultural Properties," 

pp. 3366-3370.) 

C. Under Section 1(3), Federal agencies are required to 

establish procedures regarding the preservation and 

enhancement of non-federally owned historic, architectural, and archeological properties in the execution 

of th~ir plans and programs. 

The environmental statement should contain a determination 

as to whether or not the proposed undertaking will contribute to the preservation and enhancement of non-federally 

owned districts, sites, buildings, structures and objects 

of historical, architectural or a~cheological significance. 

III. The procedures for compliance with Section 106 of the National 

Historic Preservation Act of 1966 and the Executive Order 

11593 require the Federal agency to consult with the appropriate 

2 
State Historic Preservation Officer. The State Historic 

Preservation Officer for the Trust Territory is Mr. Neil 

Chase, Chief, Land Resources, Department of Resources and 

Development, Trust Territory of the Pacific Islands, Saipan, 

Marianas Islands 96950. 

Should you have any questions or require additional assistance, please 

contact Brit Allan Storey of the Advisory Council staff at P.O. Box 25085, 

Denver, Colorado 80225, telephone number (303) 234-4946. 

Sincerely yours, 

;./;; /" ·';;L#~~ JAohn D. McDermott 

V Director, Office of Review 

and Compliance 

3 

Section 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

TAB 10 - SUMMARY OF COMMENTS ON DEIS 

Environmental Protection Board, 

Department of Health Services, TTPI 

Office of Environmental Affairs, HEW 

Office of Marine Environment and 

Systems, USCG 

Division of Biomedical and Environmental 

Research and Safety Programs, USAEC 

Director Categorical Programs, Assistant 

Secretary of Defense (Health and Environment) 

Region IX, USEPA 

Natural Resources Defense Council, Inc. 

Micronesian Legal Services Corp. 

Office of Review and Compliance, Advisory 

Council on Historic Preservation 

Page 

10-1 

10-3 

10-6 

10-7 

10-12 

10-13 

10-16 

10-17 

10-21 

SUMMARY OF COMMENTS ON DEIS 

1. ENVIRONMENTAL PROTECTION BOARD, DEPARTMENT OF HEALTH SERVICES, TRUST TERRITORY OF 

THE PACIFIC ISLANDS (TTPI) (KUMANGAI, OCTOBER-IS, 1974) 

Comlnent 

Pg 1, Par. 2 

a. The DEIS satisfactorily addresses most of the 

various environmental, social, and cultural 

aspects of the problem. 

b. The DEIS represents the most practical and 

realistic approach to the problem. 

Pg 1, Sect. 1 

c. An environmental/health education program is 

required. 

(1) The Enewetak people require a thorough education 

and understanding of the concept of radiation 

poisoning and the consequences of long-term 

exposure to excessi ve radiation levels. 

(2) The adequacy of the translation of the summary to 

explain potential hazards is questionable. 

(3) A comprehensive training program for Enewetak 

people, their legal counsel, and TTPI governmental officials is required to ensure cooperation with 

the program. 

d. Ashes resulting from burning of combustible nonradioactive debris recommended for use as soil 

conditione r. 

Pg 3, ~ect. 2; Ib 

e. Nonradioactive, noncombustible debris recommended to form artificial reefs in lagoon for 

development of a new reef environment for 

associated flora and fauna. 

a. None required. 

b. None required. 

c. See below. 

(1) The ERDA has informally agreed to prepare educational documents for the Enewetak people pointing 

out the radiation hazards. These will include graphic 

illustrations of the types of radiological exposures 

that may be encountered and the possible effects that 

could result. Graphics are based on those presented 

to Enewetak people in September 1974. 

(2) The summary was written in terms which the 

Enewetak people can comprehend. Criticism of the 

content was provided by English speaking Marshallese people. The documents mentioned in (1) above 

will be a supplement to the summary. The level of 

residual radiation on Enewetak Atoll should not be 

thought of as excessive when other situations are 

considered, but can be classified as low level longterm ionizing radiation. The summary was not 

intended to provide a comprehensive discussion of 

potential hazards but rather an overview. 

(3) Such a program is being planned by DOL and should be 

included in the school curriculum for the Enewetak 

people. Indoctrination of the counsel for the people 

and the TTPI officials should be a continuing program 

of employee development by the organizations concerned. See Sect. 7.4. 

Sect. 5.4. 3. I, Pg 5- 33, EIS 

d. Ashes will be stockpiled for agricultural use in 

accordance with Case 3. 

Sect. 5.4.3. I, Pg 5-33, EIS 

e. Location of reefs to be determined. Information 

would be collected during cleanup operation. 

10-1 
I. EPB TTPI (Continued) 

f. Discusses disposal alternatives. 

(I) Shipment to CONUS would not result in a delay not 

in the best interests of the people. 

(2) Deep ocean dumping could result in unpredictable 

ecological consequences. 

(3) Disposal by burial in the craters on Runit requires 

additional supportive data in the form. of a feasibility study. 

Reply to Comment 

f. See below. 

(1) Considered impractical. See discussion Sect. 5.4.3, 

Vol. 1. 

(2) Deep ocean dumping rejected. See discussion Sect. 

5.4.3, Vol. 1. 

(3) Investigations by the U. S. Army Corps of Engineers 

show that the geological and physical conditions of the 

craters are compatible with this method of disposal 

and that this concept is feasible. (Tab H, Vol. II). 

The EPA position on crater burial is favorable and is 

shown in the EPA comments found later in this 

summary. 

10-2 
2. OFFICE OF ENVIRONMENTAL AFFAIRS, DEPARTMENT OF HEALTH, EDUCATION AND WELFARE (HEW) 

(CUSTARD, NOVEMBER 15, 1974) 

a. Sect. 5.3.3.1 Control of Food Sources. The 

comment summarizes the radiological findings 

and recommendations conce rning radiological 

dose levels, the problems of external and 

internal dose levels particularly the problems of 

internal exposures from food grown in radioactive soil and the problems associated with 

corrective action. 

b. Sect. 5.6.1 Dose Estimates. Clarification 

required on inclusion of ground water in dose 

estimates. 

c. 5.6.1 Dese Estimates. Clarification required 

regarding mortality rates of Table 5-14 (pg 5- 60) 

as the rate may be effected by the dose to bone 

marrow. 

d. Sect. 6. 1 Selection of Case 3. Statement required 

on control and/or quarantine measures to be 

implemented and enforced over a specified number 

of years. 

e. Sect. 7.2.4 Community Center Development. 

Since there are significant shortages of health 

services manpower, additional information is 

required on the long-term health services to be 

provided to the people at remote locations. 

f. Sect. 7.2.4 Community Center Development. A 

recommended generalized method of providing 

health care is described. 

g. Sect. 7.2.4 Community Center Development. 

Recommends physical examinations, immunization 

and preparation of individual health records prior 

to relocation. 

a. None required. 

b. Dose estimates do not include the contribution from 

ground wate r. Table 5-12 indicates this omission. 

This omission is recognized in Sections 5.4.1. 3, 

5.4.3. 1. 2 and 8.23.6. Studies of the ground water 

system, particularly the fresh water lens have been 

undertaken as a part of the long range follow-up 

program by ERDA. 

c. As mentioned in the response to the AEC comments, 

the bone marrow dose is traditionally accepted to 

be one-third the bone dose for 90Sr bone deposition. 

The exposure standards for these two target organs 

are also different by a factor of three. Consequently 

when 90Sr is the principal source of bone and bone 

marrow exposure, as is the case at Enewetak, it 

essentially does not make any difference relative 

to the normally accepted exposure standards which 

organ is used for the hazards analysis. (Table 

5-12). The contributions due to sources othe r than 

90s r are not sufficient to significantly affect the 

. analysis of any of the cases presented, as shown 

by the AEC data. (Sect. 5.6.1) 

d. Necessary quarantine measures will be enforced by 

the people and the TTPI as a matter of their law 

enforcement agency. (Sect. 7.1.3 and 7.4, Vol. I). 

An educational program by the TTPI will be used to 

indoctrinate the people to the dangers of radiation. 

The long-term follow on health program should 

detect undue exposure and the effectiveness of the 

quarantine measures. 

e. The TTPI intends to man a dispensary with a health 

aid or nurse as is the case with other outer islands. 

A medical officer and dentist generally will accompanya field trip vessel which will call approximately 

once a month. ERDA will provide periodic monitoring of the health status of the resettled people to 

insure that the dose rates do not exceed FRC radiation protection guides. Follow on studies of the 

radio decay processes and the potential food chain 

to man will be conducted. See Sect. 7.2.4. 

f. The method described is that generally intended by 

the TTPI. See Sect. 7.2.4. 

g. TTPI medical authorities will institute such measures 

in conjunction with the follow on program to be 

conducted by ERDA. See Sect. 7. 1. 1. 3 and 7.4. 

10-3 
2. HEW (Continued) 

Comment 

h. Sect. 7.2 . ..j, Community Center Development. Are 

the hospitals at Majuro and Kwajalein equipped to 

handle cases of radiation sickness? 

i. Sect. 7.2.4 Community Center Development. 

Clarification on location of dispensaries should be 

given. 

j. Sect. 7.2.5 Utilities. What means of augmenting 

the potable water supply other than the existing 

ground water lens can be used? Can the 43,000 

gpd distillation plant be used? The feasibility of 

other techniques for augmenting the water supply 

should be investigated. 

k. Sect. 7.2.5 Utilities. Effluents from septic tank 

drain fields may contaminate the fresh water lens. 

1. Sect. 7.2.5 Utilities. Suggests definitive sanitation program be implemented for continual 

monitoring of usable water supplies. 

m. Sect. 7.2.5 Utilities. Recently developed small 

scale aerobic digestion unit should be considered 

as an alte rnative to septic tanks. 

n. Sect. 8.6 Base Camp Sewage Dis posal. Existing 

sewage outfall lines should be relocated to flow int 

ocean rather than the lagoon. 

o. Sect. 8.11 Impact of Pesticides A concern is 

expressed for toxic effects to workers applying 

pesticides for insect and rodent control and to 

people working in general areas. 

h. Hospitals at Ebye and Majuro do not have that 

capability. Kwajalein has the personnel but not the 

equipment. Radiation sickness cases would have to 

be evacuated for treatment at TripIer in Honolulu 

or specialist centers on the mainland. (Sect. 7.2.4, 

Vol. I) 

i. These locations are clearly indicated in Master Plan 

(Tab D, Vol. 2 EIS, Plates 33 & 34, Pgs 4-31 & 4-32). 

j. While a powe r plant exista on Enewe tak Atoll only 

2 small KVA generators will be available for use at 

selected locations. The TTPI does not have the 

resources. the capability or the expertise to maintain 

and operate sufficient power sources on Enewetak 

Atoll to provide electric power for a supplemental 

water supply at this point in time. The study of this 

problem and the application of other techniques are 

factors which must be considered by responsible 

staff elements of the TTPI in the long range development of the atoll. Emergency water supplies can 

always be provided by ship in the event of a severe 

water famine. (Sect. 7.2.5, Vol. Il. 

k. This is a ve ry real conce rn in that the fre sh wate r 

lens has a stay time of a considerable period and 

once it becomes contaminated, decontamination will 

be difficult. The migration of water appears at this 

time to be from the ocean toward the lagoon. However, it should be noted that ground water is very 

. sparse and may not be of sufficient quantity to 

provide any reliable potable supply except in eme rgencies. Drain fields will be located carefully along 

the lagoon shore to take advantage of the hydraulic 

gradient of the ground water and other natural 

features to obtain the most acceptable solution. 

(Tab G, Vol. II). 

1. Wells and cisterns will be monitored by the health 

aid at frequently scheduled intervals. See Sect. 

7. 1. 3, Vol. 1. 

m. Limited resources for the generation of power do 

not permit the use of such equipment. Consideration 

of this method of sewage disposal will be included in 

future development studies. See Sect. 7.2.5, Vol. 1. 

n. A brief study of the base camp sewage disposal problem is attached at Tab G, Vol. II. Large populations have used the existing system for 25 years 

with little or no re ported adve rse effects. 

o. Pest control operations will comply with OSHA 

Standards, Part 1910, Sub Part G, Sect. 1910.63, 

Table G- 1 and Sect. 1926. 55. (Sect. 8. 11. 1, Vol. II. 

10-4 
2. HEW (Continued) 

Comment 

p. Sect. 8.16 Impact of Blasting. Recommends 

extensive sampling for fission and activation 

materials before harvesting shellfish. 

q. Sect. 8.22 Impact of Toxic Materials. Safeguards 

for workers conducting cleanup of toxic materials 

(beryllium) not mentioned. 

r. Sect. 9.26 Impact of Noise. No mention made of 

the impact of noise levels which may affect 

workers and people residing on the atoll. 

Reply to Comment 

p. This comment seems to have confused nuclear 

explosions with minor high explosive blasting which 

may be required to provide shallow channels from 

the lagoon to the shore of a few of the northern 

islands to provide access. This blasting is not 

expected to cause significant disturbances of bottom 

sediments. The controls recommended could be 

implemented and integrated into the long-term follow 

up studies by ERDA. 

q. The residual levels of beryllium have been reported 

to be very small. A cleanup operation by the USAF 

has already been conducted and natural processes 

have been working to further reduce the problem. 

Protective clothing and breathing equipment will be 

required to protect workers in accordance with 

OSHA Standards, Part 1910, Sub Part G, Table G-2. 

r. OSHA Standards for noise control and protection of 

personnel will be observed, Sub Part D, Sect. 

1926.52. 

10-5 
3. DEPARTMENT OF TRANSPORTATION, U.S. COAST GUARD (CALDWELL, DECEMBER 13, 1974) 

a. Concern over termination of DNA Contractor 

support services for LORAN Station to December 

31, 1977. 

12/13/74. Par. 4 

b. LORAN Station on Enewetak Island should be 

mentioned on text and in summary. 

c. Should review basis for calling atoll and island 

"Enewetak" versus "Eniwetok". 

d. In Vol. 3, "Phase 3 - Resettlement" use of "that 

the living patterns of the people conform to the 

limitations recommended" could be offensive if 

taken out of context. 

lZ/13/74, Pg Z, Par. Z 

e. The elements of sewage disposal and ocean-lagoon 

water quality should be commented on by EPA. 

lZ/13/74, Pg Z, Par. 3 

f. Should mention that trans port of radioactive 

material by vessel will be done in compliance with 

cu rrent regulations. 

Reply to Comment 

a. DNA will operate Enewetak as Host-Manager until 

cleanup is completed and approved. Support for the 

LORAN Station will be available until the cleanup 

operation is completed, now estimated to be about 

mid-1979. (Sect, 3.3,4,1, Vol. I). 

b. See Par. 3.3,4. I, VoL I, EIS, Mention of USCG 

LORAN Station in Summary is not considered 

necessary, 

c. It was a DNA decision to use Marshallese names 

the Enewetak people would unde rs tand them. 

so 

d, Have prefaced sentence with "For the safety of the 

people concerned ... ", (Pg 3, Vol. Ill). 

e, EPA was given opportunity to comment on entire DEIS. 

See No, 6 following. 

f. Normal trans port of radiological material expected to 

be within the confines of Enewetak lagoon. In the 

event that radioactive material would require transport to the U. S. by ves sel, 46CFR 146. 19 will be used. 

Sects. 5.4.3. Z. 1, 5.4.3. Z. 4, 8. Z3. 4, Vol. I). 

10-6 
4. U,S. ATOMIC ENERGY COMMISSION BIOMEDICAL AND ENVIRONMENTAL RESEARCH AND SAFETY PROGRAM 

(UVERMAN, DECEMBER 9, 1974) 

Comment 

Pg 1, Par. 1, Comments 

a. DEIS presents a careful and thorough study of 

problem. Agree that Case 3 is reasonable, 

feasible and assures the health and safety of the 

people insofar as is practical. 

Pg I, Par. 2, Comments 

b. Presentation of AEC radiation exposure criteria 

is satisfactory, but the word "standards t! should 

be replaced by "guidelines". Those criteria are 

based on current, recognized national and international standards. 

Pg 2, Par, 1, Comments 

c. Estimates for maximum annual exposures for 

individuals considering the most sensitive 

members of the population presented in the Task 

Group Report should be used rather than material 

fron NVO-140. 

Pg 2, Par. 

d. Tables 5-11, 5-12 and 5-13 shOUld be deleted. 

Pg Z, Par, 

e. Sects, 5,6.1. 1, 5.6.1. 2 and 5.6.1. 3 and Tables 

5- 8, 5-9 and 5-10 should be revised using information from Appendix 4, Task Group Report 

(Tab B, Vol. II, EIS). 

Pg 2, Par. 1 

£. Doses for bone marrow, not bone, should be used 

in all tables presenting maximum annual marrow 

criteria, 

Reply to Comment 

a. None required. 

b. The term "standards" has been replaced by the term 

"guidelines" in EIS. (Sects. 5 and 6, Vol. I). 

c. The AEC Task Group Report (Tab B. Vol. 2 of the 

EIS) shows that calculations based on the most 

sensitive individual do not result in dose estimates 

significantly different than those for adults, 

especially when reporting doses to one significant 

number only. (Sect. 5.6.1) 

d. Table 5-11 is a simplification of Table 240 in 

Appendix II of the Task Group Report. As noted on 

page II-I of the AEC Task Group Report. Tab B, all 

_three methods of measuring external gamma doses. 

including the method referenced in Table 5-12. agree 

within 10%. Also, Table 5-12 is retained as it 

provides a basis for estimating relative amounts of 

land areas involved in various cleanup actions. 

(Table 5 11 now 5-9, 5-12 now 5-10) 

Table 5-13 provides full disclosure of the methods 

used to develop maximum annual doses from 30-year 

integrated doses. These methods are consistent 

with 30-year and annual dose relations in the AEC 

Task Group Report and are completely satisfactory 

when considering doses to one significant number. 

(Table 5-13 now 5 11) 

e. Sects. 5.6.1. 1. 5.6.1.2 and 5.6.1. 3 and Tables 

5- 8 and 5- 9 we re developed from the AEC Task 

Group Report using adaptations of Task Group Report 

results which are appropriate to habitation plans and 

cleanup actions in the EIS. Use of Appendix 4 of the 

Task Group Report to obtain bone marrow dose would 

not change conclusions with regard to acceptability of 

any plan of action since guideline to-dose estimate 

ratios for bone and bone marrow are the same on 

Enewetak. New Tables 5-6, 5-7, 5-8. Vol. I. EIS. 

(See Sect. 5.6. 1 also) 

f. See Item e, 

10-7 
-±. AEC (Continued) 

Comment 

g. AEC estimates of 30 years and maximum annual 

doses for Belie, the island with the highest predicted doses, be used for Case 1 wherever appearing instead of exposure estimates for an average 

individual for the entire atoll. Estimates of 

averaged exposures over the entire atoll are 

meaningles 5 and should be deleted. 

Pg 2, Par. I, Lines 3-5 

h. Recommend revising Table 5-14 to present 

estimated risks as upper limits and add footnote 

to show that at low dose rates, risk may be zero. 

Pg 2, Par. 2, Lines 6, 7 

1. Risk estimates should be recalculated to account 

for revisions needed for estimates presented in 

Table 5-8 in calculation of 30-year dose. 

Pg 2, Par. 2, Lines 8-10 

j. Based on suggested revisions to 30-year and 

maximum annual dose estimates, revise Table 

5-16 to reflect these changes. 

Pg 2, Par. 3 

k. Further discussions of the reasons for rejecting 

ocean dumping means of disposal is necessary. 

Pg 3, Par. I, Lines 1-8 

1. Ocean dumping option is believed to be the leas t 

costly method of disposal, the safest, and hence 

this option should be left open. 

Pg 3, Par. I, Lines 8-9 

m. Return of Pu contaminated soil to CONUS for 

burial would be unacceptable. 

n. Burial of material on an island would required 

pe riodic follow up. 

Par 2 

o. Clarify the requirement for blasting operations 

inSect. 8.16. 

Reply to Comment 

g. The Belle Island case is considered an extremely 

remote possibility in view of historic living patterns 

and stated preferences of Enewetak people for return 

atoll. Furthermore, the doses as calculated for 

Case 1 are already so high that this case is unacce ptable. Thus, use of Belle Island would only make an 

already unacceptable situation even more unacceptable. 

h. These comments have been incorporated by revlswg 

table and text to reflect range of risk. (Table 5-12, 

Sect. 5.6.2, Vol. I). 

i. No recalculation is required since as noted in Item g 

unacceptable cases become more unacceptable. 

Furthermore, acceptable cases would remain 

acceptable. 

j. No change required. See Item i. 

k. Sect. 5.4.3.2. I, Vol. 

discussions. 

1, E1S, includes these 

1. Ocean dumping and the reasons for its rejection are 

discussed in detail in Sect. 5.4.3.2. I, Vol. I, EIS. 

Federal law requires a complete study of the ocean 

community around the proposed dump site, and that 

does not guarantee approval after that requirement 

has been satisfied. Costs and delay incurred would 

probably lead to abandonment of the entire program. 

m. This is recognized as discussed in Sect. 

Vol. I, E1S. 

5.4.3.2.4, 

n. This is recognized in Sect. 5.4.3.2.3, Vol. I, EIS. 

o. Blasting operations are required to clear channels 

of coral heads so that marine craft can land equipment and personnel to conduct cleanup operations on 

some northern islands. Channels are for approach 

from the lagoon side only and will not be cut through 

the reef to the ocean in any instance. Sect. 8.16, 

Vol. I, EIS. revised to clarify this. 

10-8 
4. AEC (Continued) 

Con"lment 

Pg 3, Par. 3 

p. Delineation of responsibilities for future studies 

is not ge rmane and should be deleted. 

Pg 3, Par. 4 

q. Confusion over temporary storage of contaminated 

material on Runit as an intermediate stop pending 

additional study by AEC. Disposal is DNA 

responsibility. AEC not committed to provide 

additional recommendations except possibility of 

reduction in volume of plutonium contaminated 

material. 

r. A discussion of the views of AEC and others 

concerning the early return to Japtan Island should 

be included. 

Letter 12./2.3/74, Pg 1 

s. The disposal of alpha activity into the oceans under 

the management of the European Nuclear Energy 

Agency has totalled 3633 Ci during the period 

1967-1974. It is evident that the disposal of a 

few hundred grams of Pu from Enewetak Atoll 

would not materially add to the existing burden. 

Staff, Pgs 2 & 3, 5-11. 12, 13. 5-54. 57, 59, Par. 

t. The use of isopleths as defined by the EG&G 

aerial survey as an approach to radiological cleanup alternatives is deficient in that it does not treat 

the more significant exposures from internal 

emitte rs in the food chain. 

Staff, Pg 3, Sect. 2 , Par. 1 

u. No mention of environmental impacts of alternate 

methods for contaminated debris and soil disposal. 

It is not clear which disposal method is recC'mmended for specific wastes. 

Reply to Comment 

p. Statement has been deleted. However, responsibilities for various aspects of the operations have been 

rewritten. DNA has always considered that ERDA, 

as the certifying agency, must monitor such actions 

to insure that acceptable procedures were followed 

and that guidelines have reasonably been achieved. 

The ERDA has accepted full re$ponsibility, including 

funding. for future periodic follow up radiological 

surveys as npcessary; and the maintenance of periodic monitoring of the health status of the resettled 

people and of the radioactivity in the environment 

Rubsequent to rehabilitation. (Sect. 1. 4, Vol. I; 

Tab KI, Vol. II.) 

q. This alternative was shown to comply with the requirements of the CEQ gUidelines. The intent was to provide temporary storage during the period of time 

required for ERDA/AEC to perform the necessary 

research on processing the contaminated soil in 

order to separate and/or recover the plutonium to 

reduce the volume of contaminated material. This 

alternative has been deleted as crater entombment is 

considered to provide retrievability of the material. 

r. A more complete discussion of early return is given 

in Sect. 7. 1. 1. 1, Vol. I, EIS. (Tabs E and J, 

Vol. II also. ) 

s. This is recognized. However. U. S. law demands 

compliance with more stringent requirements than 

those of the international body. See Sect. 5.4.3.2.. I, 

Vol. I, ErS. 

t. The use of isopleths was only intended as an engineering means of determining the cost effectiveness 

of the various cleanup alternatives for the external 

radiation exposure pathway. (Table 5-4, Vol. I). 

u. Impacts of disposal of contaminated mate rial by crate r 

entombment are discussed in Sect. 8.19 as a part-of 

of the proposed cleanup plan. Impacts of alternate 

methods are not included since they are not pertinent 

to the program. Discussions of various disposal 

methods are in Sect. 5.4.3.2. Nonradioactive debri~ 

disposal is discussed in Sect. 5.2.2, Vol. I, EIS. 

10-9 
-1, AEC (Continued) 

Staff, Pg 3, Sect. 2, Par, 2 

v. There are two radioactive waste disposal areas 

near Richland, WA. Should differentiate between 

them as one is privately owned. 

Staff, Pg 3, Sect. 2, Par. 3, Lines 1,2,3,4,5 & 6 

w. Conflict between rejection of ocean dumping in 

Sect. 5.5.2.1 and Sect. 11. 

Staff, Pg 3, Sect, 2, Par. 3, Lines 6,7,8,9,10 & 11 

x, Radioactive sea dumping not discussed in Environmental Impact Section (8) while disposal of noncontaminated debris at seas was included (8. 18). 

Staff, Pg 3, Sect. I, Par. 4 

y. What agency will be responsible for long-term 

surveillance and maintenance of the craters 

containing radioactive material? 

Staff, Pg 3, Sect. 2, Par. 5 

z. Proposed method of disposal of Pu contaminated 

material assumes that Lacrosse Crater can be 

pumped out. DNA should establish whether craters 

require pumping for this ope ra tion and if SO 

whethe r it can be done. 

Staff, Pg 4, Sect. 2, Par. 1 

aa. Suggest removal and disposal of all Pu bearing 

soil in excess of 400 pCi I g at all locations and 

40 pCilg on islands where housing may someday 

be located. 

Staff, Pg 4, Sect. 2, Par. 2, 3, & 4 

bb. Recommend deletion of crater entombment and 

substitution of storage for eventual disposal in its 

place as regards treatment of radioactive debris 

and Pu bearing soil. 

Staff, Pg 4, Sect. 3, Par. 6, 3- 49 

cc. Change "patrilineal" to "matrilineal" in reference 

to succes 8ion to Iroij. (chief). 

Staff, Pg 5, Sect. 3, Par. 3, 3-63 

dd. DEIS minimized danger from ingestion of Pu. 

Reply to Comment 

v. AEC letter of December 23, 1974, clarified disposal 

sites. See Sect. 5.4.3.2.4, Vol. I, EIS. 

w. Ocean dumping has been rejected. Statement in 

Sect. llwasinerror. (Sect. 5.2.2.3, Vol. I, EIS). 

x. Radioactive waste disposal by dumping at Bea was not 

adopted as part of plan. Therefore it had no impact 

as part of the plan. Disposal of nonradioactive debris 

at sea had been the planned method for that type of 

waste. (Sects. 5.2.2.3 and 8. 18. 1) 

y. ERDA as part of follow up responsibilities. See 

Sect. 1. 4, Vol. I, E18. 

z. Crater feasibility study (Tab H, VoL II, EIS) shows 

it feasible to conduct operation without pumping. 

(Also see Sect. 5.4.3.2.3, Vol. I, EIS.) 

aa. Cleanup and disposal of Pu bearing soil will be in 

accordance with AEC guidelines. Housing planned 

only for Enewetak, Medren and Japtan islands. Any 

additional cleanup of Pu contamination would be on a 

speculative basis for future housing and could increase 

costs to a point where the program would be econom. 

ically unfeasible. (Sect. 5,7 Vol. I; also Tab D, Vol. II) 

bb. Crater entombment is method selected by DNA for 

disposal of those materials. See Sect. 5.4.3.2.3, 

Vol. I, EIS, also Tab H, Vol. II, EIS. 

cc. See "Resettlement of Enewetak People: A Study of a 

Displaced Community in the Marshall Islands", 

pgs 125-126, Tobin, 1967. (Sect. 3.5. I, Vol. I). 

dd. Sect. 3.8. 1. 1. 3, Vol. I, EIS, revised. 

10-10 
... AEC (Continued) 

Comment 

Staff, Pg 5, Sect. 3, Par ..., 3-63 

ee. DEIS doe s not conside r airborne concentrations of 

Pu as a result of resident activities. 

Staff, Pg 5, Sect. 3, Par. 5, 3-84 

ff. Locations of beryllium contaminated areas not 

clear. 

Staff, Pg. 5, Sect. 3, Par. 7, 5-13 

gg. Text and Table 5-6 inconsistent as to food growing 

restrictions on Enjebi. 

Staff, Pg 5, Sect. 3, Par. 9 8. 10, 5-25 &: 5-32 

hh. Figures 5-2 and 5-3 inconsistent with text on 

limits of southern islands. 

Reply to Comment 

ee. Sect. 3.8.1. 2, Vol. I, EIS, revised. 

ff. Sect. 3.8.2, Vol. I, EIS, revised to specifically 

show the location of beryllium contamination. 

gg. Table 5-6 deleted. Data now contained in Table 5-5, 

Vol. I, EIS. 

hh. Figures 5-2 and 5-3, Vol. r, ErS, revised. 

10-11 
5. ASSISTANT SECRETARY OF DEFENSE FOR HEALTH & ENVIRONMENT CATEGORICAL PROGRAMS 

(MEADE, NOVEMBER 13, 1974) 

11/13/74, Pg 1, Par. 2, 1/1 

a. Estimated time frame of phases of operation 

should be specified; especially completion of 

Phases 3 and 4, 

b. Relative hazard level to personnel relocated to 

islands should be tabulated instead of gene ralized. 

c. Enforcement of Runit quarantine must be enlarged 

upon. Educational program required to insure 

unde rstanding of risks to Enewetak people. 

11/13/74, Pg 1, Par. 5, #4 

d. Long-term continuous monitoring program 

required until hazard is removed. 

11/13/74. Pg 1. Par. 6, #5 

e. Consideration should be given to the possibility 

of more adequate disposal techniques becoming 

available in the future. 

Reply to Comment 

a. While inclusion of the specific times for the phases 

would be desirable. it must be remembered that 

this is a continuing program and appropriations 

authorized and appropriated by Congress will govern 

the specific time phasing of the operation. 

b. Terms used in describing risks from radiation are 

not translatable into Marshallese language in understandable form. A primer is being prepared by ERDA 

to provide a better understanding of the health hazards. 

(Sect. 7.4. Vol. I). 

c. See Sect. 7.4, Vol. I, EIS. Long-term monitoring 

program to be conducted by ERDA will assist in 

determining effectiveness of quarantine enforcement. 

Data produced by this program would show degree of 

exposure to radioactivity for individuals. 

d. ERDA is responsible for conduct of monitoring program for inhabitants 1 health status and atoll environment (See Sect. 1.4, Vol. I, ElS). 

e. Some means is required to remove plutonium from 

being immediately available to the biosphere. 1£ the 

plutonium we re stockpiled and left in the open policing 

would be difficult and costly and the hazard would 

remain. Crater burial renders the plutonium 

inaccessible but retrievable in accordance with the 

concept considered viable by EPA. Minute amounts 

of Pu are expected to be released through the geological formation. These, however, will be small 

and insignificant compa red to the amounts already 

in the lagoon. The concrete matrix, surrounding 

coral and the concrete cap will provide a shield from 

external exposure. Monitoring can be accomplished. 

If more adequate disposal techniques become available in the future and further action is determined 

necessary, the material could be retrieved and the 

techniques applied. (Sect. 5.4.3.2.3, Vol. I, EIS.) 

10-12 
6. u. S. ENVIRONMENTAL PROTECTION AGENCY, 

(FALCO, DECEMBER 12, 1974) 

Comment 

Pg I, Sect. 1, Par. a 

a. Radiological, bacteriological and chemical 

quality tests should be conducted for a 

minimum of 12 months to determine water 

quality of brackish water lens. 

Pg I, Sect. 1, Par. b 

b. There is a need for a 12-month, mmlmwn, 

air sampling program on all islands to 

be inhabited, on heavily contaminated islands 

after cleanup and before lifting of quarantine. 

Actual conditions should be dete:rrni.ned, not 

calculated. 

c. Were air samples taken during AEC survey 

analyzed for uranium? 

Pg 1, Sect. 2, Par. 1 

d. Follow on monitoring of air, water, food 

and body burdens of Enewetak people is needed. 

This requires some agency to be responsible 

for implementation and funding. 

Pg 2, Sect. 3, Par. I 

e. Application of Pu cleanup criteria too 

uncertain. Criteria given should be considered 

upper limits and cleanup levels and population 

doses should be maintained as low as 

practicable. 

Pg 2, Sect. 3, Par. 2, Lines 1, 2, & 3 

f. Crater entombment should be recognized as a 

semi-permanent solution. 

Pg 2, Sect. 3, Par. 2, Item I 

g. Discussion of ocean disposal should contain 

technical advantages and disadvantages and 

not be rejected on only legal and international 

problem basis. 

Pg 2, Sect. 3, Par. 2, Item 2 

h. If volwne of two craters is insufficient to 

contain all contaminated soil, what remedial 

action will be taken? 

REGION IX, SAN FRANCISCO, CALIFORNIA 

Reply to Comment 

(See ERDA letter of February 6, 1975, Tab Kl. Vol. II. 

for amplification). 

a. A ground water sampling program has been initiated under ERDA which includes 15 drilled 

wells on 7 major islands in the atoll. Program 

objecti ves are the determination of radionuclides 

and stable element concentrations, cycling 

mechanisms, recharge rates, etc. (See Sect. 

5.5.3.3, Vol I, ErS). 

b. Item #11, Sects. 5.5.3.3 and 5.7. Vol. I, EIS, 

comment on air sampling program. It should be 

performed by those providing health physics 

support for cleanup and be under direction of 

agency responsible for cleanup (pgs 27 and 31, 

Tab B, Vol II, EIS). Results of air sampling 

would be documented in final report of cleanup 

agency and samples could be analyzed for all 

radionuclides including uraniwn. 

c. Apparently samples were not analyzed for 

uraniutn. 

d. ERDA will be responsible for implementation 

and funding (Sect. 1. 4, Vol I, EIS). 

e. We believe that recommendation Nos. 6, 7, & 8, 

pages 27-29, Tab B, Vol. II, EIS and associated 

material in Appendix 3, Tab B, Vol II, EIS are 

specific enough to guide the actions and decisions 

of a qualified group who are tasked with carrying 

out cleanup actions at Enewetak Atoll. 

f. It is, as solidified material is retrievable (Sect. 

5.4.3.2.3, Vol. I, EIS). However, we believe 

that crater entombment will be a permanent 

solution. 

g. See Sect. 5.4.3.2. I, Vol. I, EIS. 

h. Calculations indicate more than sufficient volume 

in both craters to contain all contaminated Boil 

collected in Case 3. (Sect. 5.4.3.2.3, Vol. I; 

Tab G, Vol. II. ErS.) 

10-13 
6, EPA (Continued 1 

Conunent 

Pg 2, Sect. 3, Par. 2, Item 3 

i. What action will be taken if people of 

Enewetak reject entombment option? 

Pg 2, Sect. 4, Par. 2 

j. The decision to permit subsistence coconut 

production in northeastern islands not 

justified in DEIS. Virtually all predicted 

dose received by the Enewetak people under 

this proposed plan is due to this decision. 

Use of "as low as practicable" dose concept 

should be deferred unle s s it can be shown 

there is no practicable alternative for an 

adequate diet or that radionuclide contaminaation is much lower than predicted. 

Ps, Sect. 4, Par. I 

k. Marketing of copra should be on "as low as 

practicable" basis to determine if the economic 

benefits to Enewetak people outweigh radiological cost of population dose to off-island 

people. 

Pg 3, Sect. 4, Par. 2 

1. No discussion in DE1S of short and long 

range implications of radionuclides in lagoon 

sediments. No indication in DE1S of feasibility 

of minimizing future radiation dose from 

seafood pathway. 

Pg 3, Sect. 4, Par. 3 

m. No discus sion of decision to permit 

unrestricted fishing in lagoon. 

Reply to Conunent 

1. Crater disposal is considered permanent. However, if other more suitable disposal methods 

were found and the need for redisposal was 

determined, the contaminated soil and debris 

could be recovered from the crater. This is not 

anti cipated. 

j. Justification for reconunended actions is in 

Tab B, Vol. II, E1S. Use of northeast islands 

was reconunended for growing coconuts as a 

cash crop (copra) not as food source. Coconuts 

grown in southern islands will provide ample 

food source. It is recognized that wherever 

coconuts are grown, regardless of purpose, 

some will be eaten. Also northeast islands' 

use increases agricultural land areas by about 

500/0 (Table 3-1, Vol. I, E1S), a large factor 

where usable land is at a premium. Review of 

predicted doses does not support EPA comment 

that virtually all of predicted dose received by 

Enewetak people is due to this decision. Comparisons of 30-year doses can be made using 

Living patterns A&B, Table 1-4, Tab B, Vol. II, 

EIS. Maximum annual dose comparisons are 

made using Tables 3, 4, 5, 8, 9, & 10, 

Appendix IV, Tab B, Vol. II, EIS. Predicted 

doses assumed all coconuts for food came from 

northeast islands, Mijikaidrek-Billae (Kate- Wilma), 

while it is expected that coconuts eaten by southern 

island inhabitants will be a mixture with the 

majority coming from southern village islands. 

Expected doses will fall between Living Patterns 

A&B, and Patterns I & 2. (See Tab KI, Vol. II, E1S) 

k. This concept would not guarantee acceptability of 

product outside atoll. AEC Task Group could not 

determine unquestionably acceptable level of 

radioactivity. Detectable levels of radionuclides 

from nuclear testing will be found in copra from 

other atolls too. (See Section 8.36, Vol. I, also 

Tab K, Vol. II, E1S) 

1. Dose estimates in EIS include contributions of 

239pu and 90S r coming through seafood pathway 

and thus are directly related to radioacti vity in 

lagoon sediments. Evaluation efforts were 

directed to reasonable number of options for 

exposure reduction and control against primary 

pathways for radiological doses to humans. (See 

Sect. 5.3. I, Vol. I, EI5). 

m. Seafood at Enewetak is among lowest of all 

contributors to radiation dose to inhabitants. 

Both annual and up to 70-year doses are 

presented in EIS. (See reply above. ) 

10-14 
6. EPA (Continued) 

ComITlent 

Pg 3, Sect. 4, Par. 4 

n. Can restrictions on coconut crabs on northern 

islands be enforced? Also, no saITlples froITl 

northern islands taken to back up decision 

on restriction. 

Pg 3, Sect. 5, Par. 1 

o. Constant health physics support required to 

ITlonitor pos sible inhalation exposure to 

workers and transport of radioactive ITlaterial 

froITl greater to lesser contaITlinated areas. 

Pg 4, Sewage Disposal during Cleanup 

p. RecoITlITlends that some forITl of sewage treatITlent be provided for waste waters generated 

by cleanup personnel and subsequent visitors. 

Pg 4, Garbage and Trash Disposal during Cleanup 

q. Garbage and trash residue should not be 

dUITlped into the lagoon. Burial or SOITle other 

disposal ITlethod should be used. 

Pg 4, Water Supply and Waste Disposal 

r. A careful evaluation of plans to use septic tanks, 

leach fields and burial of garbage as they ITlay 

affect the possible contamination of the suppleITlental water supply for the cOITlITlunity. 

Pg 4, Water Supply and Waste Disposal 

s. A discussion of the potential problem should be 

presented with evidence that the suppleITlental 

water supply will not be degraded. 

Pg 4, Water Supply and Waste Disposal 

t. The TTPI DepartITlent of Environmental 

Health should have a fundaITlental role in the 

decision process on the selection of water 

supply and waste disposal system. 

Reply to COITlITlent 

n. An effort was made to sample crabs throughout 

the atoll. Samples only found on Ananij (Bruce), 

lkuren (Glenn), Ribewon (James), Kidrenen 

(Keith), and Biken (Leroy). Environment on 

Northern islands does not now support this forITl 

of terrestrial fauna. (Enewetak Radiological 

Survey, Vol. r, NVO-l40; also Tab K. Vol. II, ErS.) 

o. See Sect. 5.7, Item 7a; also Sect. 6.2.4, Vol. r. 

EIS. 

p. Historically there has been no treatITlent of 

sanitary waste at Enewetak, even during nuclear 

testing when the atoll population was in the 

thousands. There is no recorded evidence of ill 

effects froITl discharging raw sewage into the 

lagoon during that period, or since. For the short 

period of caITlp operation and relati vely srrlall 

population in residence, DNA will utilize the 

existing systerrl. (Sect. 6.2.2, Vol. r; Tab G, Vol. II.) 

q. Edible garbage will be dUrrlped froITl the garbage 

pier on Enewetak for the benefit of the fish. COITlbustible trash will be burned in the island burn pit 

(near the garbage pier) and the ashes stockpiled for 

soil conditioner, noncorrlbustible trash will be 

COrrlpacted and buried in the vicinity of the garbage 

pier. It should be noted that the available land for 

this type of disposal is liITlited. (Sect. 8.5. l, 

Vol. I). 

r. Ground water lens is suppleITlental water supply for 

eITlergency use only. Quality and quantity of lens 

water restricts use to this category only. Waste 

water study (Tab G, Vol. II, EIS) indicates that 

locating the septic tanks, leach fields and garbage 

pits along the lagoon shore will take advantage 

of the ocean-to-lagoon ITligration of ground water 

flow and the natural hydraulic gradient. Also this 

location would reITlove the potential source of 

contaITlination iroITl proxirrlity to the center of 

any wate r lens. 

s. This is discussed in Sect. 8.29.6, 8.30.1 and 

8.30.6, Vol. I, ErS. 

t. The Master Plan for Enewetak Atoll (Tab D, 

Vol. II, ErS) was cOITlITlissioned by the TTP! 

Government and approved by the TTPI 

GovernITlent. 

10-15 
7. NATURAL RESOURCES DEFENSE COUNCIL, INC. (NRDC) (THOMAS B. COCHRAN, SEPTEMBER 24, 1974) 

Comment 

a. DEIS fails to address hot particle theory as 

proposed in "Radiation Standards for Hot 

Particles", A. R. Tamplin, T. B. Cochran, 

February 14, 1974. 

Reply to Comrn.ent 

a. Until this theory is substantiated and accepted by 

national authorities we have no recourse but to 

comply with the radiation standards promUlgated by 

the Federal Radiation Council. Discussion of the 

problem is included in Sect. 5.8, Vol. I, EIS. A 

letter from the Energy Research and Development 

Administration, dated January 29, 1975, with 

attachments, WASH-1320, and LA 5810-MS, are 

included in Tab I, Vol. II, EIS. Further information is contained in the "The Toxicity of Plutonium", 

The Medical Research Council, published by Her 

Majesty's Stationery Office, London, 1975. Acceptance of the standards proposed by Tamplin and 

Cochran would result in either the prevention of 

the Enewetak people from returning to their atoll, 

or make the cost of the project 80 prohibitive that 

it could not be accomplished. 

10-16 
8. ).UCROXESIAN LEGAL SERVICES CORPORATION (MLSC) (THEODORE R. MITCHELL, 

FEBRL'ARY 1, 1975) 

COInInent 

a. General. The people left the atoll in a radiological safe state, it should be returned to them 

in the same state. The U. S., as trustee, has a 

humanitarian obligation due to the dangerous 

materials left from the nuclear weapons testing 

on the atoll. Such responsibility exists both to 

return the people to their home and to eliminate 

the likelihood of so much as a single radiation 

induced illness or anomaly without respect to 

cost or consequences. 

b. Social and Economic Problems 

(1) More attention is needed for adequate plans to 

meet the future needs of the people so economic 

self sufficiency can be achieved. 

(2) The Enewetak Planning Council must be relied 

upon to make plans with more assistance from 

government provided specialists. 

Reply to COInInent 

a. General. From a technical point of view, the 

concept that is presented is not considered to be 

a feasible solution within the lifetime of the people, 

their grandchildren or their grandchildren's 

grandchildren. If this proposed program is to be done 

now, the monetary and other costs for the solution 

proposed by the counsel for the Enewetak people 

are estimated to be prohibitively high. The commitment of such large quantities of the national 

economic resources to the solution of this one 

problem may be considered unreasonable by 

prudent men when due account is taken of other 

national priorities. The accomplishment of the 

goal stated by the counsel for the people when 

compared to the gi ven goal for the proposed project 

is idealistic to the extreme and could be considered 

technically, ecologically, and economically 

infeasible. For example, background radiation 

alone on Enewetak and in most other parts of the 

world contributes to risks of induced cancerS which 

are indistinguishable from those occurring naturally. 

If the counsel for the Enewetak people persists in 

the most ideal solution, the DNA position will be to 

recoInInend that the proposed project be abandoned 

or postponed. 

b. See below. 

(1) While the EIS outlines several proposed methods 

of economic development for Enewetak Atoll, it 

will be the responsibility of the TTPI and the 

Enewetak people themselves to see that one or 

more of these is implemented. Sufficient technical specialists are available in the TTPI staff Or 

could be obtained on a consulting basis to provide 

the degree of technical advice required. It is 

acknowledged that some copra producing land 

had been lost due to residual radiation, but this 

does not restrict the people in initiating some of 

the other means of strengthening their economy, 

such as drying fish, shark fins and promoting 

handicrafts for sale elsewhere in the Marshalls. 

See Sects. 7.2 and 7.3, Vol. I, EIS. 

(2) The TTPI government has worked and will continue to work with the Enewetak Planning Council. 

It is recognized that the council would have the 

last word in selecting the method best suited to 

the people for enhancing the economy of the atoll. 

Specialists in these fields selected by the council 

could be provided by the TTPI. See Tab D, 

Vol. II, EIS. 

10-17 
8. MLSC (Continued) 

Comment 

(3) The physical and emotional stresses 

caused by the relocation and resettlement 

of the people which affect the individual and 

group processes are not addressed in the 

DEIS. The objective of such a study would 

be to make the people aware of these 

stresses and how to adjust to them and 

survive with their society intact. Drs. 

Scudder and Kiste should participate in this 

study. 

(4) The Planning Council, its advisors and 

government decision makers should work 

together in a more formal manner. 

c. Radiological Considerations 

(1) More survey work is required to provide 

follow-up data and assessment of the data 

for all long life radionuchdes, especially 

the alpha emitting radionuclides known as 

hot particles. Experimental plantings and 

other long range research on the marine 

and terrestrial pathways to man should be 

conducted to ensure scientific advancements 

and new remedial measures are applied on 

Enewetak. The governmental task group 

which directs such follow-up studies should 

be enlarged to include scientific personnel 

known to take the most conservative 

approach to radiation protection. Messrs. 

Martell, Tamplin. and Geesaman are 

recommended. 

(2) A basic inadequacy exists in that the DEIS 

does not address the hot particle theory 

and other associated risks of uptake of 

alpha emitting radionuclides through the 

foodchain into organs other than the lungs. 

All the questions raised by Tamplin, 

Cochran. Geesaman. and Martell should be 

answered. 

Reply to Comment 

(3) It is expected that the entire Ujelang population will have lived for a period of time on 

Japtan Island starting with the early return 

program and the anticipated periodic rotation 

of families. This will give the people an 

opportunity to gradually acclimate themselves to Enewetak, as well as an opportunity 

to advance their economic status by working 

on the Japtan temporary camp and through 

the other occupations contained in the Early 

Return Operational Plan (Tab E. Vol. II. 

EIS). The U. S. Department of Interior has 

ample resources and will adequately handle 

any problems arising from the UjelangEnewetak transition. See Sect. 8.35. I, 

Vol. 1, EIS. 

(4) If the TTPl considers it to be a requirement in 

the intere st of obtaining the proper planning 

decisions. the technical advisors would be 

organized into an advisory council. However, 

the procedures required to accomplish a 

formalized council should be worked out 

between the Distad and the council. 

c. 

(1) The AEC Radiological Survey is the most 

extensive compilation of data known to exist 

on the radiological conditions of the atoll. 

An additional program is now in progress 

to provide added information on the chemical. 

bacteriological and other natural processes 

which quicken the reduction of radioactivity. 

the proces ses by which plants assimilate 

radionuclides and other related processes. 

Practical and cost effective scientific 

methods which appear in the future will be 

applied to the solution of acute problems of 

radioacti ve contamination on Enewetak. The 

Ad Hoc Task Group for establishment of 

gUidelines has been disbanded and the necessary 

research programs to accomplish the objectives of the Task Group recommendations 

will be pursued by the established ERDA 

staff organization. See Sects. 1. 4, 5.5.3.3 

and 7.4, Vol. I; Tab K2, Vol. II, E1S. 

(2) It is recognized that the DEIS did not address 

the hot particle theory espoused by Tamplin, 

Cochran and others. This problem is a relatively 

controversial subject at present. Adequate 

material explaining the pros and cons of the 

theory is now included and referenced in the 

EIS. Since this theory has not yet been 

accepted in the national or international 

standards for radiation protection, only 

existing guidance from the FRC, NRPe, and 

lCRP were considered. National authorities 

and scientific bodies are now considering 

the proposals made by Tamplin, Cochran, 

and others. A resolution of the controversy 

cannot be expected for several years. It is 

interesting to note that this proposed standard 

is so restrictive that the effects of worldwide 

fallout would be found unacceptable over 

extensive areas. See Sect. 5.8, Vol. 1; Tab K2. 

Vol. II. Also WASH-1535. 

10-18 
8. MLSC (Continued) 

Cornrnent 

(3) The AEC guidelines for 239 pu and their 

application to the specific Enewetak 

problem are questionable in light of the 

hot particle theory and standards set 

by the State of Colorado. Before final 

guideline for Enewetak are adopted, 

international and national bodies should 

review, hold public hearings and 

establish numerical standards for allowable 

concentrations of 239 +24°Pu and other 

transuranic wastes in soil, air, water and 

food. Once such standards are set they 

should govern the planning and cleanup 

activities on Enewetak. 

(4) The objective of the program, regardless 

of other consequences, requires the 

complete removal and off-island disposal 

of all contaminated soil. 

(5) Studies must be made of the relationships 

between soil removal and dose reduction 

(inch.ding risk from airborne hot 

particles) and the ecological effects of soil 

removal and replacement. 

(6) A team of experts must be formed to 

monitor the cleanup and disposal of all 

radioacti ve materials and soil. This 

team should include scientific per sonne1 

known to have the most conservative 

approach to radiological problems (see 

para. (1) above). 

(7) Studies of test plantings, lens water and 

air sampling should be undertaken 

irnrnediately and should include the best 

scientists and technicians available. The 

work would be under the overall guidance 

of the enlarged task group. 

(8) A full radiological health follow-up prograrr. 

must be instituted. It should include the 

Bikini people, the Enewetak people and 

the Rangelap and Utirik peoples as well. 

(9) Since all of the problems cannot be 

anticipated, the U. S. Government should be 

prepared to give its best and careful 

attention to all situations which may occur 

in the future. 

Reply to Comment 

(3) The current status of consideration of the 

hot particle theory is given in ERDA letters 

of January 29, 1975 (Tab I, Vol. II, EIS, 

The research on other aspects of this 

problem particularly the food pathways to 

man and the potential problem concerning 

other organs will require many years of 

research. Accordingly, if one subscribes 

to the theory, the people of Enewetak should 

not be permitted to return to any part of 

the atoll until the results of the research 

are known and necessary cleanup activities 

accomplished. (Also Tab K2, Vol. II.) 

(4) To disregard all consequences and make a 

clean sweep type of operation, subsequently 

disposing of contaminated soil in an offatoll location would be irresponsible. This 

would result in many delays and long-term 

damage to the land and completely defeat 

the purpose of returning the Enewetak people 

to their atoll where they could benefit from 

the present resources (Tab K2, Vol. II). 

(5) The ERDA plans to conduct these studies as 

a part of their follow on program. See 

Sects. 1. 4, 5.5.3.3, and 7.4, Vol. I, EIS. 

(6) The cleanup operation will be conducted in 

accordance with the established ERDA 

guidelines. When required. a team of experts 

will be selected; however it is too early 

to determine the staffing. Consideration 

will be given to the recommended persons 

at that time. 

(7) Studies of test plantings and lens water are 

currently in progress on Enewetak Atoll 

under the sponsorship of the ERDA. (Sect. 

5.5.3.3, Vol. I). Air sampling studies 

are planned by ERDA when the cleanup 

operation commences, as the conditions at 

that time would be more representative of 

an inhabited atoll. To pursue an air 

sampling program at present would produce 

results comparable to an uninhabited atoll. 

(8) The ERDA accepts the responsibility for 

the conduct of a follow on radiobiological 

health program for the Enewetak people 

(see Sect. 1. 4, Vol. I, EIS). Whether 

this is done in conjunction with the people 

from other atolls will be determined by the 

ERDA. This latter problem is not a 

subject of this EIS. (See Tab KI, Vol. II, EIS.) 

(9) The intent of this cornrnent appears to be a 

catch-all or "hold harmless" clause bound 

in many contracts. It is intended that this 

project be accomplished to provide a 

reasonable degree of safety from both 

radiological and physical hazards and to 

resettle the people in adequate horne s and to 

provide stimulation for the future 

10-19 
8. MLSC (Continued) 

Conu:nent 

d. Considerations Relating to Cost 

(1) Since the nuclear testing program resulted 

in significant benefits to the U. S. defense 

posture, the cost of this program represents a small fraction of the estimated 

te sting co st. 

(2) The U. S. has an obligation under the UN 

trusteeship to protect the people, their 

health, and promote the economic and 

social advancement of the Enewetak 

people. In determining what must be done, 

the cost of the program should not be a 

conside ration. 

Reply to Conu:nent 

development of the islands. Should acute situations 

as a result of use of the atoll by the United States 

be found to exist after the completion of cleanup, 

such conditions will most certainly be dealt with 

when the situation is fully known and a reasonable 

cost effective solution is available. 

d. See below. 

(1) DNA plans to use this approach in the hearings 

before the congressional conu:nittees. 

(2) It is agreed that the U. S. has an obligation 

toward the people of Enewetak under the terms 

of the U. S. trusteeship. However, when the 

judgment of prudent officials indicates that 

actions proposed would be uncertain of achieving 

the stated goals or that such actions would 

result in more harm than good, the trustee 

would be derelict in permitting those actions to 

be accomplished. In the situation under 

consideration, the idealistic solution proposed 

is not only uncertain of success but if accomplished could most certainly devastate the 

meager land resources available to the people. 

10-20 
9. ADVISORY COUNCIL ON HISTORIC PRESERVATION (MC DERMOTT, 19 NOVEMBER 1974) 

Comment 

a. Show evidence that the most recent listing of the 

National Register of Historic Places has been 

consulted and that either of the following conditions 

are satisfied. 

(ll No National Register property is affected. 

(2) If National Register property is affected show 

compliance with Sect. 106 of National Historic 

Preservation Act of 1966. 

b. Executive Order 11593 Protection and Enhancemen 

of The Cultural Environment requires: 

(I) Conduct survey of atoll and report results in EIS. 

(2) Review of properties is continuous procedure to 

propose properties for inclusion in the National 

Register. EIS should contain a determination 

whether the proposed action will result in the 

transfe r sale, demolition or alte ration of 

properties. 

(3) EIS should contain a determination whether or not 

the project will contribute to the preservation and 

enhancement of nonfederally owned facilities of 

significance. 

c. Consultation with the appropriate State historic 

preservation officer is required. 

Reply to Comment 

(Sect. 3.6, Vo. I, EIS) 

a. The latest edition of the National Register of Historic 

Places published in the Federal Register of Tuesday, 

4 February 1975 (Vol. 40, No. 24, Part II) has been 

consulted. No properties Or other facilities are 

shown on Enewetak Atoll, Ma rshall Islands. 

(1) The above review indicates that no National Register 

property is affected by the proposed property. 

(2) None required in view of (1) above. 

b. The DNA Enginee ring Survey while not done specifically 

in compliance with Executive Order 11593 shows the 

major features of the atoll. 

(1) The survey shows no features which fall within the 

criteria established for the National Register. 

(2) No significant property meeting the criteria exists. 

(3) Not applicable. 

c. The TTPI Historic Preservation Officer was contacted 

for assistance. 

10-21 
UNCLASSIFIED 

UNCLASSIFIED