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 vere dumped into the ocean,
St vould represent only about 75 Ci for this one time action. This is
far below the vpper disposal limit of 1910 Ci/year for alpha wastes

(based on Pu2?9) 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 followup that for practical purposes would last
forever. Specific comments related to ocean dumping and encryptment

aval

ba see ea

bea

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 vould 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 nore information on the expected impact of new openings in the
reef on the ecology of the Atoll.
As a matter of policy beyond the scope of this Statement, we recommend that
the last sentence (lines 18-20) on page 5-35 of the fourth recommended
study be deleted, since it is not germane for any environmental statement

to address detailed responsibilities of other agencies which have not
been formally agreed upon.

There appears to be some misunderstanding regarding Storage on Runit
(Sections 5.5.2.5, page 5-48).
As presented in the DEIS, it is indicated

that as an intermediate step, contaminated soil will be stored on Runit
pending a study and recommendation by AEC as to its ultimate disposal.

AEC is not committed to provide any additional recommendation on the
ultimate disposal of the contaminated soil. The disposal of debris is

a DNA responsibility.
The only open question is whether or not it may
be feasible to reduce to some degree the amount of contaminated material

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