APLENDIX II

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APPENDIX II

transuranium elements in soil, noe juse Pu-239, 240, and using a
conservative applicacion of Federal standards. The consideracion
of all of these long-lived alpha emitters was not stressed in the
AEC Task Group's*report and the reporr used the term “pluconiun”
rather than "transuranium elements." This point was cleared up in
discussions with DNA staff.
The radiological criteria recommended for planning purposes for

evaluation of land use options were based on a conservacive app!.-

cation of Federal standards. ‘These have not changed. Algo, criteria recommended by AEC for soil cleanup were noe changed by EPA's ©
issuance of proposed guidelines for transuranium elements in soil.
It is expected that cleanup of soil according to AEC criteria will
meet the EPA guidelines.
Further incerprecation of the applicacion of the 40 to 400 pCci/g

criteria (i.e., within this range), which had been left by che

Task Group for a later determinatior, was done when requested Sy

DNA.

However, there was no change in the basic criteria.

The

only change has been DOE's recommendation that certain islands in

the northease of che Atoll chat were to be planced with coconut,

not be planced.
This recommendation was basea upon very recent
experience ac Bikini Acoll.

Nealth cousiderations, and the associated assessments of tadiolog-

ical conditions of islands, the application of recommended criseria,
and the developrent of recommendations, must take precedence over

the people's preferences in decisions on land use.
‘while DOE supporcs
the full participation of the Enewetak people and their advisors in
decisionmaking, i¢ would be a mistake to give the impression that,

they will decide where they will live and where their food wii! be

grown.
If instead of a good level of ccoperation, we must assume
lictile or no adherence to restriceions, the planning assumpetons

inherenc in the EIS and the agreement thact the people may be returned safely are voided. The Enewecak Atoll master plan contains
che people's preferences regarding land use, but the actual use

will depend on che degree of soil cleanup actually achieved on varfous islands and on a statement of permissible land usage issued

by DOE in the final certifacacion process. This certificacien will
be based on an assessment of radiological condisions ac che end of
cleanup.

We Seiteve chaz GAC consider revising the report to delete stacements concerning enforsemens of restrictions and iascead stress

the positive aspects cf this profect where many parties are <:s03-

erating in a long and difftculs task that pushes the iiniss of

technology and where there is no appiicadie precedence. We Seiieve
the statements chat OCE has changed che cleanup ¢riteria and nade

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