t, “4 Col. Charles J. Treat b) 2 "Situations with soil levels in the 40 to 400 pCi/g range may receive corrective action ...." (underlining added). c) “Islands with soil levels in the above range may be divided into two categories, those of sufficient size for construction of permanent houses, and those that are not .... Removal of 239Pu contaminated soil is better justified within the range above for the larger islands such as JANET or SALLY where permanent housing may some day be located and for near surface locations on the larger islands .... The smaller islands may be considered of less concern ...." Note: This is the only place in the guidance where an indication of relative priorities for cleanup of contaminated soil is given. The highest priority is given to larger islands and near surface locations on Jarger islands. | I made two statements in the meeting that were derived from the material just quoted: 1. Cleanup of areas above 400 pCi/g should not be considered to be any more mandatory than cleanup in the 40 to 400 pCi/g range once a judgement (case-by-case) has been made that such cleanup is..justified. 2. Cleanup of levels above 40 pCi/g on Enjebi should be as high a priority as cleanup above 400 pCi/g on some small island like Boken. oo I strongly urge that in the implementation and interpretation of the Task Group recommendations, the impression not be given that cleanup actions that are to be taken on the basis of case-by-case determinations in the field are of Tess importance and lower priority than what may be described as prejudgement actions. We must be equally prepared, if not more so, to defend case-by-case decisions to perform or not perform cleanup along with prejudgement decision and actions. Viewed in this context, statements that cleanup of islands with soil concentration above 400 pCi/g is the only mandatory action are in error. If the requirements for cleanup are to be stated in absotute terms, - jt must be stated instead that performing case-by-case determinations for 40 to 400 pCi/g areas is also a firm requirement and, therefore, mandatory and any associated field determination that an action is