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RADIOLOGICAL CLEANUP OF ENEWETAK ATOLL
program,!!4 and establishing long-term monitoring programs.!!5.116,117
These recommendations were adopted by DNA and the AEC.
DEIS criteria for contaminated soil were strongly challenged by the
MLSC, the Natural Resources Defense Council and others. They
suggestedthat criteria for cleanup should notbe set until either the ICRP,
the EPA, or the United Nations Scientific Committee on the Effects of
Atomic Radiation set standards.!!8 Some suggested that the ‘‘hot
particle’? theory must be used in determining contaminated soil criteria.
These suggestions would have delayed the soil cleanup indefinitely. DNA
believed the delay was unnecessary, since the AEC and DOD had set
decontamination standards in 1968 for plutonium-in-soil in the event of a
nuclear accident. These standards directed that plutonium concentration
should be reduced, if possible, when levels are greater than 1000
micrograms per square meter. This value equates to about 265 pCi/g when
averaged over a |5-cm depth of soil whose density is 1.5 gram per cubic
centimeter. The Enewetak Cleanup DEISspecified removal of plutonium-
contaminated soil when the ‘‘proximate’’ surface concentration (top 15
cm) is greater than 40 pCi/g and when the concentration at any depth is
greater than 400 pCi/g. Thus, the DEIS criteria were much more
conservative than existing DOD guides for cleanup of areas anywherein
the world. !19
MLSC comments contended that the criterion of 40 pCi/g averaged
over the top 15 cm ofsoil was too great and recommendedthat the State of
Colorado standard of 0.91 pCi/g averaged over the top | cm should be
adopted for the cleanup.!29 However, DEIS cleanup criteria were based on
adherence to reasonable constraints on living patterns and diet by the
people after they returned to Enewetak. Colorado criteria assumed no
constraints, and they were not based on known or estimated radiation
effects to man but on the arbitrary basis of approximately 25 times the
level of plutonium in Colorado soils as a result of worldwide fallout. !2!
DEISsoil cleanup criteria also were challenged on the basis that they did
not consider the ‘hot particle’? theory which, according to Tamplin,
Cochran, Geesaman, and Martell, indicated that existing plutonium
exposure standards were too low.!22.123 DNA responded that the theory
ate
had not yet been accepted in the national or international standards for
radiological protection and that only the existing guidance could be
considered. !24 Soil cleanup criteria remained a highly controversial matter
cleanup, as is described in subsequent sections.
Disposition of radioactive debris and structures can be accomplished by
standard construction techniques such as cutting, sandblasting, encasing,
or sealing. Removal of plutonium contamination in soil has two solutions:
(1) remove the plutonium from the soi! (extraction); or (2) remove the
Planning and Programming
93
plutonium with the soil (excision). Extraction of plutonium from waste or
soil is theoretically possible, and the technology has been explored by
other countries. It was suggested by the AEC Task Group,!25 but a
practicable technique was not available for field use since national policy
precluded development or use of such technology. Thus, the only
practicable process was excision—the stripping of successive layers ofsoil
using earth-moving equipment until acceptable radiation levels were
reached. !26
Disposal of radioactive waste is one of the most controversial problems
this nation faces. This was especially true as it applied to the Enewetak
Cleanup Project. The Enewetak people’s position was made clear in their
earliest meetings with DNA!27 and was restated in their counsel’s
comments on the DEIS: Disposal on the atoll was rejected, and off-atol!
disposal was the only acceptable solution. Several other solutions had been
suggested during the radiological surveys, including use of a small island as
a disposal dump, !28 packaging and shipping to the Nevada Test Site,!29
burial in place, and dumping in the lagoon.!3° The DEIS considered four
alternatives for disposal:
® Level | - Crater Dumping, by which radioactive materials would be
dumped in Cactus Crater (and in Lacrosse Crater, if required) with
no further action to fix the materials in place. (The craters were
named for the nuclear test shots which had created them.) The
estimated cost for disposal of materials from a Case 3 cleanup using
this method was $320,000.
® Level 2 - Ocean Dumping, by which radioactive materials would be
containerized and dumped in the ocean at a deep-water site. The
estimated cost for disposal of materials from a Case 3 cleanup using
this method was $9,989,000.
@ Level 3 - CONUS Disposal, by which radioactive materials would be
sealed in containers and shipped to the United States for disposal. The
estimated cost for disposal of materials for a Case 3 cleanupusing this
method was $18,910,000.
@ Leve! 4 - Crater Entombment, by which contaminated soil and debris
would be entombed in Lacrosse Crater (and in Cactus Crater, if
required) by sealing the cracks in the crater, mixing the plutoniumcontaminated soil with cement to form a slurry, and pumping the
Slurry into the crater around the contaminated debris, thereby
Tae
be covered by an 18-inch thick concrete cap or lid, to provide an
erosion resistant crypt which would seal off the radioactive material.
The estimated cost for disposal of materials from a Case 3 cleanup
using this method was $6,968,000, !3!