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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.

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