In a coverletter to which the above notes were attached the AEC representative further stated,
"The differences between the Task Group approach and the DNA approach
involve issues that are so fundamental that to try to change the approach and
adopt their position would bring us into conflict with both the spirit and letter
of regulations that govern Federal agency radiation protection activities. It
is not possible to conform to their wishes by merely putting forth a wider
spectrum of cleanup alternatives." (McCraw, 1974.)
Viewpoints of the various concerned agencies were exchanged during the next several months. The
Task Group continued to work on its recommendations, incorporating many suggestions submitted by
reviewers, and responding to critical comments with detailed rationale for positions taken. The final
report on recommendations was issued on 9 July 1974 (see Section 2.1.5). The Director, DNA,
informed the Chairman, AEC, by letter dated 7 August 1974, that DNA had accepted the AEC staff
position on the radiological criteria and the advisory controls necessary for return of the people to
Enewetak. Planning began immediately for a meeting to be held at Enewetak to present the DEIS
and the results of the radiological survey to the people of Enewetak (as discussed in Section 2.1.6).
Reviewer comments on the DEIS were received by DNA and in one instance ERDA prepared a
response. Commenting on the comments supplied by the Micronesian Legai Services Corporation
(MLSC), ERDA staff noted:
"Numerical values of radiation exposure and concentrations of plutonium in soil were
recommended by the Task Group as guides for use in evaluating radiological conditions
at Enewetak Atoll only. Such guides are not to be considered as standards. These
guides were used as limits in evaluating remedial action options in order to recommend
actions and restrictions that will insure that exposures of people when they return will
not exceed the basic FRC, ICRP, and NCRP standards. These considerations are the
basis for actions and restrictions recommended in the DEIS. While there is no National
or International standard for plutonium expressed as a concentration in soil, the guides
recommended, 40 and 400 pCi/g, were derived using the best current information
relating such soil concentrations to possible exposures to man. The guidance for cleanup
of contaminated soil was selected such that exposures of people are expected to be well
within the basic standard. This guidance has been approved by EPA for use at
Enewetak." (Biles, 1975.)
Guidanee provided by the Task Group was quite clear with respect to soil with Pu concentration
below 40 pCi/g or above 400 pCi/g, but the case-by-case treatment of concentrations between 40
and 400 pCi/g became an obstacle in cleanup planning.
There were numerous meetings and
exchanges of correspondence during the next two years on this subject with no real progress toward a
solution; planners could not identify beforehand specific actions appropriate for treatment of Pu
concentrations in soil between 40 and 400 pCi/g.
In the memorandum prepared following the ERDA - Marshall Islands Workshop on 27-29 June 1977, it
was noted that:
"The rationale for removing plutonium-contaminated soil is based on assumptions
regarding resuspension of Pu that are not validated by empirical data. Additionally, we
question whether the guidelines which have been established for soil removal are
supportable.
"The present total inventory of plutonium in the terrestrial environment at Enewetak
available for resuspension and resultant dose commitment cannot be significantly altered
by the proposed course of action." (Gates, 1977.)
The Bair Committee reviewed criteria for removal of contaminated soil at the meeting of 15-18
August 1977 and concluded: "There was unanimous agreement that the criteria for cleanup of the
islands contaminated with plutonium are reasonable in light of present knowledge and their
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