92 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!