DOE informed DNA by teletype on 2 May 1978 that it was DOE's firm intention to follow the
Advisory Group guidance (stated above) and that final certification decisions would be based on this
guidance. On 3 May, DNA convened a conference of representatives from agencies participating in
the Enewetak Cleanup Project to resolve selected issues so that contaminated soil cleanup
operations could begin.
Detailed review and discussion were held on the critical issues and the
operational impacts that various alternatives would have on the overall success of the cleanup
effort. The Director, DNA, made several key decisions at the end of the conference. (See
conference report in the miecrofiene.) With regard to cleanup criteria and standards, a summary of
the conference states:
"The soil cleanup criteria provided by the Bair Committee report . . . were
tentatively accepted by the Director, DNA, as the criteria to be followed for
cleanup operations. This acceptance is contingent upon the DOE/Bair Committee
developing more precisely the status of islands (e.g., Boken (Irene) or Lujor (Pearl)
which may end up being cleaned to below 400 pCi/gm, but not down to the 160
pCi/gm criteria established by the Bair Committee for food gathering islands."
(Monroe, 1978)
The final criteria for surface soil cleanup, summarized from the Advisory Group report, were:
1.
Condition A. Clean all 0.5 hectare areas on food gathering islands that exceed 160 pei/g.
2.
Condition B. Clean all 0.5 hectare areas on agricultural islands that exceed 80 pCi/g.
3.
Condition C. Clean all 0.25 hectare areas on village islands that exceed 40 pCi/g.
Priority of cleanup actions was the reverse of the above sequence, that is, first priority was assigned
to Condition C, 2nd to Condition B, 3rd to Condition A. Criteria and priorities presented above
remained in effect for the duration of cleanup.
Criteria applicable to subsurface contamination (Condition D) were also specified at this time, but
required additional clarification prior to unambiguous implementation. The original Condition D (see
Appendix E) specified excision of Pu concentrations exceeding 400 pCi/g. The action value was
reduced from 400 to 160 pCi/g as a result of DNA's acceptance of Bair Committee
recommendations; however, additional wordsmithing was still required.
Part of the problem of
interpretation in the field centered on the criteria statement regarding "An assay area", which was
defined (see Appendix E) as the field of view of the in situ detector, and that this area was to be
smeasured” rather than estimated. The in situ detector could not measure subsurface concentrations
of
Pu.
The DOE/ERSP Deputy Manager and the Commander, JTG, sent a coordinated appeal for help in
interpretation to FCDNA and DOE/NV, and suggested some new wording for Condition D. The key
element of the new wording introduced definition of an assay area as a "defined area of interest not
less than 1/16 hectare". There followed an exchange of correspondence between DNA, DOE/NV and
elements on Enewetak, and a request that the Advisory Group resolve the problem. The Advisory
Group was reluctant to do so (Bair, 9/1978 and 10/1978), but found the definition of an assay area
applicable to subsurface contamination to be acceptable.
With no further guidance forthcoming, the final criteria for Condition D, as applied in the field was:
4.
Condition D. TRU activity in any 5 em depth interval below the surface shall not exceed
160 pCi/g when averaged over 1/16 hectare.
Tech Notes 18 and 19 demonstrate field sampling and implementation procedures required to abide
by the final criteria.
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