question, and with so much soil requiring disposal that the only option
would have been ocean disposal, an action EPA advised was not acceptable.

The removal of soil from much larger land areas,an action that would have

been required by the EPA limits, would have accomplished only a small
increment of additional dose and risk reduction.

How the EPA screening

level would have been interpreted in planning Enewetak cleanup is a matter
for guesswork, It may have been a liability because of the potential for

misuse and misinterpretation.

I do recall several matters that may be relevant.

The task group had little

faith in use of air sampling data to determine that significant levels of
TRU contamination were not present in the soil. Also, they considered but

did not recommend plowing to dilute TRU concentrations below the levels to
be considered for soil removal. In retrospect, use of EPA dose limits to
plan soil cleanup at Enewetak appears incompatible with the need to prepare
a complete spectrum of cleanup alternatives that would give OMB and Congress
some choice as to the magnitude of the Enewetak cleanup effort.
The task group recommended a conservative application of existing standards
for use at Enewetak. In recommending use of dose limits based upon an
extremely conservative risk value, EPA ignores these standards.

Viewed from

the prospective of the Enewetak experience, EPA's development of yet another
set of numerical dose values significantly lower than Federal standards and
described as limits, restricts rather than promotes flexibility in cleanup

For Enewetak there where significant areas of land contaminated with TRU

elements and fission products, high visibility and public interest and
concern, the involvement of land owners and their legal advisors, and
concern for the cost of cleanup.

Under such circumstances, AEC acting on

its own judgment may have found it impossible to justify conduct of soil
cleanup not meeting Federal dose limits even with advice from EPA that these
limits are not to be interpreted as absolute values to be met in every
instance. If available in 1973, dose limits that need not always be applied
as absolute values, would have been a new and confusing concept in radiation
prediction and I suggest this is true today as well.
Though permitted by the EPA criteria, development of cleanup recommendations
that present a justification for exceeding a dose limit that is some

fraction of the FRC standards for use at Enewetak, would have created a
problem for those planning cleanup. Almost any advice that was not
supported by existing standards would have resulted in disagreement on
technical and legal issues. This could have made cleanup a more
controversal political issue than it was.

A justification for exceeding EPA's dose limits would have focussed

attention away from the fact that basic radiation standards could be (and

were) met at Enewetak through a combination of cleanup actions and land

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