92
RADIOLOGICAL CLEANUP OF ENEWETAK ATOLL
program, !!4 and establishing long-term monitoring programs.!!5.!16,1,,
These recommendations were adopted by DNAand the AEC.
DEIScriteria for contaminated soil were strongly challenged by i,
MLSC, the Natural Resources Defense Council and others. The
suggestedthatcriteria for cleanup should not be set until either the ICRP.
the EPA, or the United Nations Scientific Committee on the Effects of
Atomic Radiation set standards.!18 Some suggested that the ‘ho
particle’ theory must be used in determining contaminatedsoil Criteria,
These suggestions would have delayed the soil cleanup indefinitely. DN4
believed the delay was unnecessary, since the AEC and DOD had sq
decontamination standards in 1968 for plutonium-in-soil in the eventof,
nuclear accident. These standards directed that plutonium concentration
should be reduced, if possible, when levels are greater than 1009
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 DEIS specified 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 depthig
greater than 400 pCi/g. Thus, the DEIS criteria were much more
conservative than existing DOD guides for cleanup of areas anywherein
the world, 119
MLSC comments contended that the criterion of 40 pCi/g averageg
overthe top 15 cm of soil was too great and recommendedthatthe Stateof
Colorado standard of 0.91 pCi/g averaged over the top 1 cm should be
adopted for the cleanup.!20 However, DEIS cleanupcriteria 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 orestimated radiation
effects to man but on the arbitrary basis of approximately 25 times the
level of plutonium in Colorado soils as a result of worldwidefallout. !2!
DEIS soil cleanupcriteria also were challenged on the basis thattheydid
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 respondedthat the theory
had not yet been accepted in the national or international standardsfor
radiological protection and that only the existing guidance could be
considered. !24 Soil cleanupcriteria remained a highly controversial matter
throughout the planning phases of the project, and even into the actual
cleanup, as is described in subsequentsections.
Disposition of radioactive debris and structures can be accomplishedby
standard construction techniques such as cutting, sandblasting, encasing,
or sealing. Removal of plutonium contaminationin soil has two solutions:
(t) remove the plutonium from the soil (extraction); or (2) remove the