The DNA staff (DNA/HQ and DNA/FC)did not all agree with the priority list suggested in the
February 1977, MFR. Based upon the testimony of General Johnson in March 1976, and supported by
statements in the EIS and OPLAN 600-77 (to which no earlier objections had been raised), but
eounter to the Task Group Report, DNA staff developed the philosophy that plutonium
concentrations greater than 400 pCi/g on Irene, Pearl, and Yvonne (and the Aomon Crypt(s)) were
eategorized as "mandatory" cleanup. The Bair Committee report of the 15-18 August 1977 meeting,
quoted in Section 2.2.4, included the words, "The reviewers concurred ... with 400 pCi/g as the
mandatory cleanup level. . ." FCDNA interpretations equated "mandatory" with "top priority” and
expressed this position in August 1977. (Tate/Ray, 1977.) While signatory to this MFR, the ERSP
Manager expressed concern over the DNA position that cleanup of Yvonne might receive top priority
of the entire atoll (Ray, 1977). FCDNA responded by referencing the Task Group report, the EIS,
the OPLAN and NVO-140 in support of the statement that "... corrective action be taken on all
areas with contamination exceeding 400 pCi/g."
The FCDNA letter went on to state:
". . . definitization of the scope of work involved in meeting the specified
requirements of the EIS, .. is absolutely essential in order for us to know whether
sufficient resources will remain to permit us to consider radiological cleanup on
other, possibly more desirable, islands such as Enjebi." (Tate, 1977.)
An interagency meeting, held 4 and 5 October 1977 to discuss cleanup of Yvonne (Runit), was
attended by the DOE/HQ representative who had chaired the AEC Task Group. The DOE position
was spelled out in the following terms:
"After two or three more instances where DNA staff used the term ‘mandatory
eleanup of 400 pCi/g'. . . I felt compelled to state that this approach to cleanup had
been generated by DNA and was not the intent of the AEC Task Group. I pointed
out that the distinction DNA was making between '>400' as mandatory cleanup and
‘ease-by-case' as budget limited cleanup, was incorrect and that the Task Group had
seen Runit cleanup as requiring a 'case-by-case' determination. In fact, the Task
Group had made a specific recommendation that the approach to Runit cleanup be
devised by a committee such as this one ... . I stated that even though a
case-by-case determination was required for some islands to determine the extent of
cleanup to be performed cleanup of such islands was no less a requirement and no
lower priority than
>400 cleanup on otherislands." (McCraw, 10/1977.)
Positions having been clearly stated, dialogue continued between DNA and DOE with measurable
progress toward resolution of the issue. Citing extensively the available guidance, FCDNA
recommended on 8 November 1977 (Treat, 11/1977) the following:
a.
Highest priority - Islands of size (greater than 50 acres) to be potential residential
islands, specifically Janet, Sally/Tilda, and Pearl. Resources permitting, clean to
Condition C (less than 40).
b.
Second priority - Islands of planned intensive agricultural use. In addition to the
islands of highest priority,
they include
Vera,
Ursula, and
Olive.
Resources
permitting, clean to Condition B (less than 100, later changed to less than 80).
e.
d.
Third priority - Islands of planned food gathering use but whose size (20 to 50 acres)
provides a potential for agricultural use, specifically Alice, Belle, Daisy, Irene and
Lucy. Resources permitting, clean to Condition B.
Lowest priority - Islands whose planned use is food gathering and whose size (less
than 20 acres) does not provide good potential fof residence or agriculture.
Cleanup of contamination levels below 400 pCi/g 39,240py is not warranted. This
priority also applies to Yvonne with regard to areas already below 400 pCi/g.
In all cases, Condition A or D must be applied to concentrations shown to exceed
400 pCi/g (later changed to 160 pCi/g).
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