Donald C.

Gestiehr

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development of the soil cleanup criteria, i.e., the
4O and’ 400 pCi/g, was based upon consideration of all
transuranium elements in soil, not just Pu-239, 240,
and using a conservative application of Federal

Standards.

Unfortunately, the consideration of all

of these long-lived alpha emitters was not stressed
in the AEC Task Group's report and the report usec the
term "plutonium" 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 conservative apnilication of Federal standards.
These have not changed.
Also, criteria recormended
by AEC for soil cleanup were not changed by EPA's
issuance of proposed guidelines for transuranium elements
in soil.
It is exmected that cleanup of soil according
to AEC criteria will meet the EPA guidelines.
Further interpretation of the application of the 49 to

4OO pCi/g criteria (i.e., within this range), which had

been left by the Task Groun for a later determination,
was done when requested by DNA.
However, there was no
change in the basic criteria.

The only change has been

DOE's recommendation that certain islands in the north-

east of the Atoll that were to be planted with coconut,

not be planted.
This recommendation was based upon very
recent experience at Bikini Atoll.

Health considerations, and the associated assessments of

radiological conditions of islands, the applicaticn of
recommended criteria, and the development of recommendations, must take precedence over the people's vreferences
in decisions on land use.
While we support the full par-

ticipation of the Snewetak people and their advisors in

decisionmaking, it would be a mistake to give the inpression that they will decide where they will live and
where their food will be zrown.
If instead of a food level
of cooperation, we must assume little or no adnerence to
restrictions, the planning assumptions inherent in the
EIS and the agreement that the people may be returned
safely are voided.
The Enewetak Atoll master plan contains the people's preferences rerarding land use, but
the actual use will depend on the degree of soil cleanup
actually achieved on various islands and on a statement
of permissible land usage issued by DCE in the final
certification process.
This certification will be based

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