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