-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 pre- pared 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/fgm 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; (2) 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 1s sound and the Statement quite properly does not promise an early end to restrictions on use of the Northern Islands. that have However, there are several aspects of the plan 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.