application does not pose an unacceptable health risk."
Committee stated:
Elaborating on this conclusion, the
"The reviewers considered the criteria for the relocation of approximately 10 Ci of
plutonium from dispersed locations in the terrestrial environment to a central location
in the Cactus Crater on Runit Island.
"The reviewers concurred with the 40 pCi Pu/g soil value adopted in the Environmental
Impact Statement as a minimal action level and with 400 pCi/g as the mandatory
cleanup level. Using the assumptions in the EIS the reviewers estimated that the lung
dose resulting from lifetime inhalation of air containing an equivalent concentration
(100 pg soil/m®air or 4 fCi Pu/m3%) would be approximately 0.01 rem/year, or 1
mrad/year, assuming a quality factor of 10. This compares with the proposed EPA
federal guidance value of 1 mrad/year to the lung from transuranie elements in the
environment. The reviewers believe that lung doses from inhaled plutonium will be
considerably less than this for persons living and working on the Atoll because of the
small land area which minimizes buildup of plutonium concentrations in the air and
because of the conservative assumptions used in estimating dose; e.g., all contaminated
soil was considered respirable, the concentration of soil in air was maintained constantly
at the 100 pg/m3 level, ete.
"The reviewers recommend that more specific guidance for application of the criteria at
plutonium levels between 40 and 400 pCi/g be developed for the Task Group Commander.
"The Environmental Impact Statement indicates that 20sr and 137Cs in the soil and the
uptake by plants is the major problem which will limit the occupancy and utilization of
certain islands of the Atoll. Certain soil amendments that have been shown to
significantly decrease the uptake of these radionuclides may be useful for hastening the
rehabilitation of the Atoll." (Bair, 8/1977.)
The Bair Committee recognized that the Commander Joint Task Group (CJTG) was in need of more
specifie guidance for application of criteria. At the time of this meeting, the only explicit guidance
appeared in OPLAN 600-77 which said, in essence, excise all areas exceeding 400 pCi/g, whether
surface or subterranean, excise to some lowerlevel of activity any area where the one-half hectare
average exceeds 100 pCi/g, excise to some lower level of activity any area where the one-quarter
heetare average exceeds 40 pCi/g.
Seeking additional guidance consumed many man-hours between August 1977, and January 1978, with
no recorded progress. At the 6 January 1978 meeting, where the transuranics question was resolved,
the question of field application of criteria was also addressed. The conferees agreed that DOE
would develop dose estimates for islands designated for agricultural use. Minutes of the meeting
state: "Of special interest are dose contributions resulting from use of certain islands for
agricultural purposes at or near 100 pCi/g."
The need arose for the Advisory Group to review application of cleanup criteria for transuranic
concentrations in the range 40 to 400 pCi/g when measurements on the northern islands showed many
areas to be in this range. The Task Group Report (issued as guidance) had recommended
case-by-case treatment for areas with TRU concentrations in the 40-400 range, but did not suggest
either a methodology or a case-by-case rationale. Ultimately, the question became one of cost vs.
benefit, that is, to achieve the maximum overall improvement in the TRU situation given the
availability of a finite cleanup resource. ERSP staff, although technically qualified to submit sound
recommendations based on interpretation of Task Group guidance, were too close to the operational
problems of cleanup to make unbiased recommendations that would be acceptable to both DOE/HQ
and DNA.
On 4 April 1978, DOE/HQ again called upon a group of experts not directly engaged in the cleanup
project to review and evaluate operations and advise DOE.
This group was officially titled the
Advisory Group on Cleanup of Enewetak Atoll; however, since Dr. William Bair was designated the
chairman and many of the members were also on the August 1977, Bair Committee, this name was
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