ow rr ~ en ee crater entombment.!47.148 They recommended that the crater entombment option be deleted from the EIS and that the contaminated soil be stored temporarily on Runit while other options for eventual disposal-were studied by AEC.!49 However, they advised that AEC was not committed to provide any additional recommendation on the eventual disposal of contaminated soil and that disposal was a DNA responsibility. !50 The basic argument presented by proponents of ocean dumping was one commonly heard: compared to the amount of fong-lived alpha contamination already dumpedin the ocean, the amount from Enewetak would be insignificant. The AEC estimated there were only a few hundred gramsof actual plutonium inall of the contaminated soil of Enewetak, and that at least a hundred kilograms of plutonium had already been dumped in the ocean from 1947 through 1974.!5! In other words, the additional damage that might be done was negligible compared to the possible damage that had already been done. The counterargument was also familiar: past damage probably cannot be undone, but any additional abuse to the system should be stopped completely. DNA continued planning on crater containment of contaminated soil and debris because this seemed to be the only option that would be acceptable. On 14 February 1975, representatives from the action agencies met with the POD in Honolulu to refine plans for cleanup and rehabilitation. Conferees included: Mr. Peter T. Coleman, Deputy High Commissioner, TTPI. Mr. Oscar DeBrum, District Administrator, Marshall Islands, BG Peel, Division Engineer, POD; Mr. Earl Eagles, HQ DNA: Mr. Tommy McCraw, Energy Research and Development Administration (ERDA,.formerly AEC); Mr. Harry Brown, DOI, COL Esser, Field Command; and Mr. Earl Gilmore, H&N. Much of their discussion concerned development of POD contracts for the cleanup and rehabilitation effort. (These were never written due to subsequent Congressional actions.) More useful discussions were held on the matter of crater entombment. DNA requested that POD develop a design for the crater and cost estimates for that part of the project. Also, POD was asked to provide cost estimates for the complete (Case 5) cleanup which MLSC desired. DOD and DOItasks in the cleanup and rehabilitation efforts were reviewed in detail. The conferees also agreed that DNA and ERDA would develop a much needed Radiological Support Plan. !52 On 24 February conferr i 1975, i DNA, ERDA, and EPA representatives i ically contaminated materials. ERDA wasable to present its case directly to EPA. No allowance had been made in the AEC Task Group’s dose assessment for any radioactivity that might leak from the crater-entombed matrix into the lagoon or nearby ocean. For this and other reasons, ERDA preferred BS WAEAT UES dy EE dt ag EE dy ai ocean dumping. EPA pointed out that the amount of plutonium which had already been deposited in the lagoon and wascirculating in its waters was probably much greater than any that might leak from the crater. !53.!54 In fact, there was a far greater amount of fallout in the lagoon than there was left on the islands to be cleaned up. The lagoon had a far greater area than the islands, and material from the islands tended to be washed into the lagoon. EPA described the measures necessary to obtain a permit in the unlikely event the plutonium contamination could be considered something other than ‘‘material in any form produced for radiological warfare purposes.” The criteria for issuance of a permit were summarized as: (1) establishment of a need to dump; (2) lack of an alternative means of disposal; (3) definition of the potential damage that could result to the marine environment; and (4) the effect of the proposed dumping on other users of the area. Permits could be granted only for an approved dump site. Obtaining approval for a dumping site required selection of a definite site, a survey of the dumping area (including the benthic community) and the ocean currents, and definition of the monitoring process to be used while the dumping is carried out. A minimum of 4 months would be required after receipt of a properly executed application before final action could be expected from a request to EPA. Involved in the process was the requirement for a public notice of 30 days and then a public hearing 30 days after publication of the public notice, followed by allowance of another 30 days for the EPA hearing officer to reach a finding. No assurances could be provided that the finding would not be adverse, particularly if any controversy existed. If the DEIS identified another feasible disposal method, it would virtually eliminate one of the requirements for an ocean-dumping permit, namely the lack of an alternative disposal method. The ERDA representative contended that EPA was overly conservative in applying the United States ocean-dumping law, since the International Ocean-Dumping Agreement would permit other countries to dump quite large amounts of long-lived alpha contamination. EPA countered that the United States law, which predated the international agreement, was based on the philosophy of preventing further pollution rather than facilitating cleanup and disposal of radiological contamination resulting from a past event. Public laws and EPA regulations did not envision a disposal effort of the magnitude of the Enewetak radiological cleanup and provided no Cobb ERDA representatives responded that, while ERDA had several test sites which someday must be decontaminated, ERDA had no intention of adopting ocean dumping for those wastes. However, there was considerable concern that, if crater containment was used, ERDA would