94-- RADIOLOGICAL CLEANUP OF ENEWETAK ATOLL The dri-Enewetak andtheir attorney were on recordas being Opposed ; any disposal of radioactive material on the atoll. AEC-NV strong, supportedtheir position in commenting on the preliminary DEIS.1!32 y Considering the relatively short radiological half-lives of the fiss tOn products and the induced radioactivity found on much of the debris, the AECTask Group suggested that the debris be disposed of in Shallow burig crypts on the land, in underwatercraters, or in the deeper portions of the lagoon. The Task Group recommendedthat plutonium-contaminateq Soil and debris be stockpiled on Runit, pending determination of a final disposal method. Several methods were suggested, including returningjt to the United States, casting it into concrete blocks, dumpingit 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, orbiologica warfare agent or any high-level radioactive waste for the purpose of dumpingit 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 Departmentof State becausethe United States had already ratified the International Ocean Dumping Treaty, 134 DNA’s overriding consideration on this issue was the identification of an option which could gain eventual approval so that the cleanupproject could proceed. EPA and DNA officials conferred on 8 August 1974 regarding disposal options in the DEIS. EPA took the samepositionit had taken with AEC on the ocean-dumping option.!35 The intent of Public . Law 92-532 was to prohibit ocean-dumping of materials produced for tadiological warfare.136.!37 Even though materials had been used for radiological testing instead of warfare, their toxicity and effect on the environment was unchanged. Even if, by some unusual logic, the contaminated materials were considered an unprohibited wasteeligible for ocean dumping, the law required extensive research and special actions before EPA would authorize ocean dumping. !38 The materials would have to be placed in a container that would remain intact until contamination radiodecayed to an environmentally innocuous material, which EPA interpreted to be five half-lives.139 This would have required the plutonium-contaminated soil containers to last for nearly 125,000 years. Ocean dumping appeared to belegally 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