268
RADIOLOGICAL CLEANUP OF ENEWETAK ATOLL
~ individual member of the public. The Task Group recommended ,
hat
whether or not cleanup should strive for the added factor of ten sq fety
margin be determined on a case-by-case basis.
The AEC Task Group guidelines had seemed clear enough when they
were adopted in DNA’s EIS in 1975 and in Field Command, DNa’,
Concept Plan (CONPLAN) I-76 in 1976, ie.:
a. Plutonium concentrations below 40 pCi/g required no action.
b. Plutonium concentrations over 400 pCi/g would be excised.
c. Plutonium concentrations between 40 and 400 pCi/g would be
treated on a case-by-case basis considering potential use and othe,
factors.
d. Once cleanup action was initiated, the plutonium concentrations
would be reduced to the lowest practicable level, not to some
prescribed numerical level.
{n implementing the last guideline, DNA had stated in its EIS that,
whereinitiated, soil cleanup would be to well below 40 pCi/g. Thiscriteria
had been modified by ERDA-NV’s input to the OPLAN which permitted
cleanup to levels below 400 pCi/g (Condition A) and to levels below 100
pCi/g (Condition B) depending on potential use by the people and other
factors. This change was challenged by the DNA planners who had
developed the EIS on the basis that the change violated the EIS
requirement to clean to well below 40 pCi/g. ERDA-NV representatives
argued that cleanup to below 40 pCi/g would require removal of
unnecessarily large amounts ofsoil, causing irreparable damage to some
islands. They maintained that DNA had misinterpreted the AEC
guidelines in developing the EIS. They were aware that the original
guidelines were vague and had attempted to provide better criteria in the
OPLAN.
Mr. Roger Ray, ERDA-NV, explained that the soil cleanup criteria
developed for the OPLAN were intended to associate a plutonium level
with an island use. In Mr. Ray’s explanation, ‘‘Condition A’ was
specifically related to ‘‘food-gathering’’ use: an island could be used for
food gathering if the surface plutonium concentration at any location
(assay area) did not exceed 400 pCi/g, ‘‘Condition B’’ related to
‘agricultural use,”’ i.e., an island could be used for agriculture if the
surface plutonium concentration in any half-hectare did not exceed 100
pCi/g; ‘‘Condition C’’ related to residential use, i.e., an island could be
used for residence if the surface plutonium concentration in any quarterhectare did not exceed 40 pCi/g,; and ‘‘Condition D,’’ an additional
restraint, related to all three uses, i.e., an island could be used for food
gathering, agriculture, or residence provided it met the appropriate surface
criterion and provided the subsurface plutonium concentration at any
location did not exceed 400 pCi/g. These changes raised fundamental
“WM