Soil Cleanup Planning
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questions on the compatibility of this guidance with that in the EIS. The
association of criteria levels with island use was a surprising development
to Field Command planners whohadfollowed development of the criteria
ys a sampling technique to be used with thein situ system. The association
between {00 pCi/g and agricultural use appeared to have no technical basis
since the AEC Task Group Reporttreated islands to be used for food-
gathering and agriculture the same with respect to plutonium.
~ Dr, Bruce Wachhoiz, ERDA Headquarters, briefed the panel on
unofficial EPA views related to the conformance of the soil cleanup criteria
10 its forthcoming guidance, then under development, on dose limits for
rransuranic elements in the general environment. EPA’s verbal
assessment was that the “‘less than 40 pCi/g”’ level would not be a problem
and the 40-400 pCi/g”’ range most likely would not be a problem. During
the guidance development, a very preliminary EPA document, ‘*Draft
Proposal, Federal Guidance for Plutonium in Soils, [9 August 1976,”
autracted particular DNA interest 23.24.25 as it indicated a cleanup action
level about a factor of three lower than the 40 pCi/g level recommended by
the AEC as a very conservative guideline for the Enewetak Cleanup. 26
Guidance ofthis nature, if followed, would significantly affect quantities of
soil for removal; however, informal opinions from EPA and DNA
indicated that no guidance for the United States should apply to Enewetak
Atoll. MG Shedd stated DNA’s view that the cleanup should proceed as
planned. Mobilization was too far advanced to allow the project to be
delayed for more studies, reviews, and EIS actions to consider undefined
allernatives of uncertain value.
The Bair Committee generally rejected the unsigned position paper’s
objections and endorsed the OPLAN 600-77 soil cleanup criteria, removal,
and disposal methods. There was unanimous agreement that the criteria
for contaminated soil cleanup were reasonable and that the planned
emplacement of plutonium-contaminated soil and debris in concrete in
Cactus Crater did not impose unacceptable environmental and health
risks. The panel recommended that morespecific guidance for application
of the criteria to plutonium levels between 40 and 400 pCi/g be developed
for the Commander Joint Task Group (CJTG).2? Although the unsigned
position paper had been thoroughly addressed and answered, its resolution
set in motion events which consumed a significant amount of the project’s
most critical resource—time—and substantially delayed soil cleanup
operations. These events are described in subsequent sections.