94 RADIOLOGICAL CLEANUP OF ENEWETAK ATOLL The dri-Enewetak and their attorney were on record as being opposed to any disposal of radioactive material on the atoll. AEC-NV strongly supported their position in commenting on the preliminary DEIS. !32 Considering the relatively short radiological half-lives of the fission products and the induced radioactivity found on much of the debris, the AEC Task Group suggested that the debris be disposed ofin shallow burial crypts on the land, in underwater craters, or in the deeper portions of the lagoon. The Task Group recommendedthat plutonium-contaminatedsoil and debris be stockpiled on Runit, pending determination of a final disposal method. Several methods were suggested, including returningit to the United States, casting it into concrete blocks, dumping it into a crater with a concrete cap, or dumpingit in the ocean or lagoon. !33 The EPA objected to the lagoon-dumping or ocean-dumping options contained in the draft AEC Task Group Report, citing Title I, Sec. 101(c) of Public Law 92-532 whichstates: ‘‘No office, employee, agent, department, agency, or instrumentality of the United States shall transport from any location outside the United States any radiological, chemical, or biological warfare agent or any high-level radioactive waste for the purpose of dumping it into ocean waters. ’’ EPA’s response to AECalso pointed out that a United States national policy prohibiting ocean-dumping of radioactive wastes had been in effect since 1970. Any proposal to reverse such a policy would have to involve the Department of State because the United States had already ratified the International Ocean Dumping Treaty. !34 DNA’s overriding consideration on this issue was the identification of an option which could gain eventual approval so that the cleanup project Planning and Programming 95 | the United States for retrievable storage at Savannah River.!49 The 79,000 to 779,000 cubic yards of contamination the radiological cleanup of Enewetak might generate clearly represented a much greater problem. The conferees agreed that CONUSdisposal was uneconomical, would generate considerable political resistance, and would adversely affect the entire project.!41 This option was dropped fromfurther consideration in planning for the disposal of contaminated material. The conferees discussed the remaining options contained in the DEIS: use of the craters on Runit, with or without cement slurry and cap. It was decided that stabilizing the radioactive contaminants in cement would provide retrievable storage. Until a more permanent solution was found, retrievable storage continued to be the only method acceptable to the United States for disposal of such waste. It had been placed in covered trenches in Los Alamos, and in caves in Nevada; but both DNA and EPA believed that cement stabilization would be necessary at Enewetak Atoll to minimize access of the contaminants to the population and environment. !42 The question of crater volume also was considered at the 8 August 1974 EPA-DNA conference. The April [974 preliminary DEIS had indicated that Cactus Crater would be used, then Lacrosse Craterif required. It had been estimated that there were approximately 101,800 cubic yards of material to be placed in the crater (7,300 cubic yards of debris and scrap, 87,800 cubic yards of contaminated soil-cement mixture, and 6,700 cubic yards in the concrete cap). It was estimated that Cactus Crater would hold less than half of that amount (about 52,000 cubic yards). Lacrosse Crater had an estimated volume of 105,225 cubic yards.!43 The conferees agreed regarding disposal options in the DEIS. EPA took the same position it had that Lacrosse Crater should befilled first, even though Cactus Crater was closer to the island. This made covering the cap with soil, as proposed in Law 92-532 was to prohibit ocean-dumping of materials produced for that proposal was abandoned. Entombment in Lacrosse Crater was the radiological testing instead of warfare, their toxicity and effect on the radiologically contaminated soil and debris. The conferees also agreed that uncontaminated scrap and debris should be disposed ofin the deepest part could proceed. EPA and DNA officials conferred on 8 August 1974 taken with AEC on the ocean-dumping option.!35 The intent of Public radiological warfare.!36.137 Even though materials had been used for environment was unchanged. Even if, by some unusual logic, the contaminated materials were considered an unprohibited waste eligible for ocean dumping, the law required extensive research and special actions the preliminary DEIS, less practical (since Lacrosse was on the reef), and method prescribed in the September 1974 DEIS for disposal of of the Enewetak Atoll lagoon.!44 This was omitted from the September 1974 DEIS!45 but was included in the final EIS. !46 before EPA would authorize ocean dumping.!38 The materials would have to be placed in a container that would remain intact until contamination interpreted to be five half-lives.'39 This would have required the plutonium-contaminated soil containers to last for nearly 125,000 years. Ocean dumping appeared to be legally difficult. After the radiological cleanup at Palomares, Spain, 1,310 cubic yards of contaminated soil and vegetation in 55-gallon drums had been returned to OCEAN DUMPING VERSUS CRATER CONTAINMENT: 1974 The AEC remained unconvinced that ocean dumping was not a viable option for disposal of plutonium contamination. In separate letters on 9 and 23 December 1974, they arguedin favor of ocean dumping instead of